NO. DM-2004-2138

By on October 21, 2011

STATE OF NEW MEXICO

COUNTY OF BERNALILLO

SECOND JUDICIAL DISTRICT COURT

NO. DM-2004-2138

MARY RUTH KRUMM,

Petitioner,

v.

LOUIS J. KRUMM,

Respondent.

MOTION FOR ORDER TO DIRECT THIRD PARTY CHARLES SCHWAB TO SELL STOCKS TO SATISFY JUDGMENT

COMES NOW, Petitioner, Mary Ruth Krumm, by  and through her attorney of record, Amanda D. Navarro (Standridge Law Firm, PC), and requests this Court to order Charles Schwab to sell ANN INC. stocks, and in support of this motion states as follows:

1. This court has jurisdiction over the parties and subject matter herein.

2. On June 2, 2011, ther court entered the Order Granting Relief Pursuant to Rule 007.1 for Non-Response and Order Directing Third Parties to Release Funds to Petitioner.

3. Respondent owes Petitioner a total of $55,249.00 in unpaid child support and alimony.

4. The Order Granting Relief Pursuant to Rule 007.1 ordered Charles Schwab to release funds to Petitioner to satisfy the $55,249.00 judgment.

5. To date. Respondent has not satisfied the judgment and has failed to make his monthly child support and alimony payments.

6. Because the funds held in account ending 8199 by Louis J. Krumm are held in stock, Charles Schwab should be directed to sell the stocks in ANN INC. under the symbol “ANN” of 12,843.000 units purchased, a current market price of 28.1500, and a market value of 361,530.45 to satisfy the $55,249.00 arrearages.

7. Charles Schwab should be ordered to satisfy the $55,249.00 in a lump sum or in the alternative, to make payments in the amount of $2,000.00 per month.

8. Concurrence in this motion was sought at the time of filing but was/was  not obtained.

WHEREFORE, Petitioner requests this court for an order directing third party Charles Schwab to sell the ANN INC. stocks to satisfy the judgment owed to Mary Ruth Krumm, and for such other relief this court deems just and proper.

Respectfully submitted,

/s/ Amanda D. Navarro

Amanda D. Navarro

Attorney for Petitioner

1516 San Pedro Dr. NE

Albuquerque,New Mexico87110

(505) 880-8737

HCS Pub. October 21, 28, November 4, 2011

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