IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

NAMED PLAINTIFF, )
)
) Civil Action
) No. [ ]
)
)
vs. )
)
NAMED DEFENDANT, )
______________________________________________________)

NOTICE OF FILING ATTORNEY’S CLAIM OF

LIEN AND DEMAND FOR PAYMENT

COMES NOW, [ Claimant Attorney ] & [ Claimant Attorney ], PC and [ Claimant

Attorney ], Esq., (hereinafter “[ Claimant Attorney ]”) and hereby claim(s) a lien in the amount

of $339,000.00, together with all additional accrued and unpaid interest, upon the following real

property and intangible property pursuant to OCGA § 15-19-14: All causes of actions asserted in

the above-styled action by 2016-CV-404123, 2016-CV-422123, Fulton County Superior Court

Civil Action File No. 2014-CV-204748 (and all proceeds recovered there from); and any and all

proceeds that may arise in the below listed cases that are directly related to the settlement in

this/these cases and payable to any American Corporation Entity (as defined in 2016-CV-

404123): United States Bankruptcy Court for the Northern District of Georgia, Atlanta Division;

[ Case Citation ], LLC, et. al.; Adversary No.: 12-05568.

2. Additionally, [ Claimant Attorney ] claims a lien in all settlement agreements (and

all proceeds to be paid to any American Corporation Entity, including 2016-CV-404123, and 2016-

CV-422123 there under made and entered to by any plaintiff and any defendant in the above-styled

action;

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 3. Additionally, [ Claimant Attorney ] claims a lien in all settlement agreements, all

final judgments and/or awards in favor of any American Corporation Entity, including 2016-CV-

404123 and 2016-CV-422123 (and all proceeds to be paid to any plaintiff) there under (in the

above-styled action); and,

4. Additionally, [ Claimant Attorney ] claims a lien in all settlement agreements and all

money or other personal property of any kind to which any American Corporation Entity 2016-CV-

404123 and 2016-CV-422123 is entitled to as a result of the above-styled case.

5. Pursuant to OCGA § 15-19-14(b), [ Claimant Attorney ] & [ Claimant Attorney ],

PC and [ Claimant Attorney ], Esq.’s lien is binding upon all persons, including all American

Corporation, plaintiffs, and defendants including 2016-CV-404123, 2016-CV-422123, Real

Property listed at Fulton County DB 1983 P 654, DB 1983 P 656, DB 1983 P 643, DB 1983 P

641, LB 2109 P 1726 and LB 1159 P 1692 and all plaintiffs and defendants in the above-styled

actions, and no person is at liberty to satisfy any settlement agreement, judgment, or award, and/or

the sale of the real property that was the subject of this action, until this lien of [ Claimant Attorney ]

& [ Claimant Attorney ], PC and [ Claimant Attorney ], Esq., has been fully satisfied. Payment

should be made to [ Claimant Attorney ] & [ Claimant Attorney ], PC at the address below:

[ Claimant Attorney ], Esq.

[ Claimant Attorney ] & [ Claimant Attorney ], PC
1000 Straight Street, Suite 1000
Atlanta, Georgia 40404

[ Claimant Attorney ] & [ Claimant Attorney ], PC and [ Claimant Attorney ], Esq., hereby demand

payment directly from the American Corporation, plaintiffs, defendants and/or 2016-CV-404123

and/or 2016-CV-422123. This lien is superior to all liens, except tax liens.

This the _____ day of [ ______________ ], 2019.

2
___________________________
[ Claimant Attorney ], Esq.

Georgia Bar No. ________________

[ Claimant Attorney ] & [ Claimant Attorney ], PC
1000 Straight Street, Suite 1000
Atlanta, Georgia 40404

Email: [ Claimant Email ]

Phone: (404) 444-4444
Fax: (404) 444-4444

3
STATE OF __________________

COUNTY OF ________________

VERIFICATION OF FACTS OF NOTICE OF FILING

ATTORNEY’S CLAIM OF
LIEN AND DEMAND FOR PAYMENT

COMES NOW, [ Claimant Attorney ], Esq., who after being duly sworn deposes and
states as follows:

1.

My name is [ Claimant Attorney ]. I am an attorney licensed to practice law in the State

of Georgia.

2.

I represented the American Corporation (as defined in the body of the pleading and
testimony in the case) and I am the procuring cause of the settlement originally announced on
October 18, 2018 and finalized, by contested hearing and entry of final judgments in January of
2019.

3.

I and my firm have not been paid (in the amount stated above) for the work performed for
American Corporation in the above styled case.

4.

I certify that the facts stated in this: NOTICE OF FILING ATTORNEY’S CLAIM OF
LIEN AND DEMAND FOR PAYMENT are true and correct to the best of my knowledge and
belief.

This the _____ day of [ ______________ ], 2019.

___________________________
[ Claimant Attorney ], Esq.

Georgia Bar No. ________________

[ Claimant Attorney ] & [ Claimant Attorney ], PC

4
1000 Straight Street, Suite 1000
Atlanta, Georgia 40404

Email: Donaldstewart5354@yahoo.com
Phone: (404) 444-4444
Fax: (404) 444-4444

5
 IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

NAMED PLAINTIFF, )
)
) Civil Action
) No. [ ]
)
)
vs. )
)
NAMED DEFENDANT, )
______________________________________________________)

CERTIFICATE OF SERCVICE

I hereby certify that I have this day served the following pleadings and documents:

NOTICE OF FILING ATTORNEY’S CLAIM OF

LIEN AND DEMAND FOR PAYMENT

according the methods of electronic filing authorized by the Superior Court of Fulton County,
Georgia and by First Class Mail, postage prepaid, addressed as follows:

American Corporation
2900 Central Road
Atlanta, Georgia 31548

This the _____ day of [ ______________ ], 2019.

___________________________
[ Claimant Attorney ], Esq.

Georgia Bar No. ________________

[ Claimant Attorney ] & [ Claimant Attorney ], PC
1000 Straight Street, Suite 1000
Atlanta, Georgia 40404