Incentive Capital v. Camelot Entertainment Group et al

Filing 125

WRIT of Execution issued. Signed by Judge Waddoups on 11/28/11. (jmr)

Joseph G. Pia (9945)
Nathan S. Dorius (8977)
PIA ANDERSON DORIUS REYNARD & MOSS
222 South Main Street, Suite 1800
Salt Lake City, Utah 84101
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
[e-mail]
Attorneys for Plaintiffs
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF UTAH, CENTRAL DIVISION

INCENTIVE CAPITAL, LLC, a Utah Limited
Liability Company,
WRIT OF EXECUTION
Plaintiff,
Civil No. 2:11-cv-00288
v.
Judge Clark Waddoups
CAMELOT ENTERTAINMENT GROUP,
INC., a Delaware Corporation; CAMELOT
FILM GROUP, INC., a Nevada Corporation;
CAMELOT DISTRIBUTION GROUP, INC.,
a Nevada Corporation, ROBERT P. ATWELL,
an individual; JAMIE R. THOMPSON, an
individual; STEVEN ISTOCK, an individual;
TED BAER, an individual; PETER
JAROWEY, an individual,
Defendants.

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THE UNITED STATES OF AMERICA to the Constable, Sheriff, or other enforcement
person, agency, or entity:
1. An application for Writ of Execution has been entered jointly by the parties Incentive
Capital, LLC (“Plaintiff” or “Incentive”) and Defendants Camelot Entertainment Group, Inc.,
Camelot Film Group, Inc., Camelot Distribution Group Inc. (collectively, the “Camelot
Defendants”).
2. The Liberation Film Library, which refers solely to those titles listed on Exhibit 2 of
the Settlement Agreement, is the property of Incentive pursuant to the Settlement Agreement
entered into by Camelot and Incentive; whereby, Camelot transferred all ownership in the
Liberation Film Library and all elements related thereto to Incentive.
3. You are directed to enter into the Camelot Defendants’ premises and/or any premise
utilized by the Camelot Defendants for the storage of business records and tangible materials
solely related to the Liberation Film Library and/or any physical item associated with the
Liberation Film Library and to take immediate possession of such materials (“Materials”) for and
on behalf of Incentive.
4. The “Materials” include without limitation any materials relative to the Liberation
Film Library comprising approximately 888 film, television, and other media titles and all
tangible elements thereof, such as:
a. Camelot’s data bank stored on its computers and servers and elsewhere,
including but not limited to copyright information, creditor lists, websites,
copyrights, trademarks, registration marks, patents, advertising and marketing
graphics and materials, logos, deals and contracts by library titles and
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distribution agreements, DVD inventory reports (including where available
the location of any physical materials);
b. Film elements and materials in storage, software related in any way to the
Liberation Film Library that Camelot has access to or is in the possession of;
c. The website relating to the Liberation Film Library, website scripts, database
and efiles, current keyword rankings, CSS script functions, master artwork
files in any format, title descriptions, digital audio/visual files, and any online
materials solely related in any way to the Liberation Film Library;
d. Any and all contracts, contract rights, deals, and correspondence related to the
Liberation Film Library;
e. Any and all money, bank accounts, and safety deposit boxes relative to
proceeds held in the name of or for the benefit of Incentive or Camelot
relative solely to the Liberation Film Library.
5. You are to return this Writ within 10 days after receiving it, with a signed account of
your actions in executing this Writ.
6. The Writ of Execution is intended to survive the dismissal of this case with prejudice
because it arises out of the parties Settlement Agreement.
28th November
11
Dated this __ day of ________, 20___
UTAH FEDERAL DISTRICT COURT

_________________________
Hon. Judge Waddoups, designee, or Clerk of the Court
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