WALKER & PESKIND, PLLC 

Attorneys and Counselors

16100 North 71st Street, Suite 140

Scottsdale, AZ 85254

Telephone: (480) 483-6336

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Richard K. Walker, SBN 004159

WALKER & PESKIND, PLLC

16100 N. 71st Street, Suite 140

Scottsdale, Arizona 85254-2236

rkw@azlawpartner.com

Phone: (480) 483-6336

Facsimile: (480) 483-6337

Counsel for Defendant/Counterclaimant/Cross-Claimant/Third Party Plaintiff WYO 

TECH Investment Group, LLC

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Wells Fargo Bank, N.A.,

Plaintiff,

vs.

WYO TECH Investment Group, LLC; 

CWT Canada II Limited Partnership;

Resources Recovery Corporation; and 

Jean Noelting,

Defendants.

CASE NO.: 2:17-CV-04140-JJT

DEFENDANT/COUNTERCLAIMANT/

CROSS-CLAIMANT/THIRD PARTY 

PLAINTIFF WYO TECH 

INVESTMENT GROUP, LLC’S 

NOTICE OF RECENT FILING OF

APPLICATION FOR RELIEF FROM 

AUTOMATIC STAY WITH THE U.S. 

BANKRUPTCY COURT FOR THE 

DISTRICT OF WYOMING

[Assigned to the Honorable John J. Tuchi]

WYO TECH Investment Group, LLC,

Counterclaimant,

vs.

Wells Fargo Bank, N.A.,

Counterdefendant.

Case 2:17-cv-04140-DWL Document 41 Filed 02/08/18 Page 1 of 4
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WALKER

& PESKIND, PLLC

Attorneys and Counselors

16100 North 71st Street, Suite 140

Scottsdale, AZ 85254

Telephone: (480) 483-6336

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WYO TECH Investment Group, LLC,

Cross-Claimant,

vs.

CWT Canada II Limited Partnership, 

Resources Recovery Corporation, and 

Jean Noelting,

Cross-Claim Defendants.

WYO TECH Investment Group, LLC,

Third Party Plaintiff,

vs.

Schlam Stone & Dolan, LLP, a New York 

Limited Liability Partnership; and Jeffrey 

M. Eilender,

Third Party Defendants.

NOTICE IS HEREBY GIVEN that Defendant/Counterclaimant/Cross-Claimant 

and Third-Party Plaintiff WYO TECH INVESTMENT GROUP, LLC (“WYO TECH”) 

filed, on February 7, 2018, in the United States Bankruptcy Court for the District of 

Wyoming, an Application for Relief From The Automatic Stay with Notice of Time to 

Object, a copy of which is attached hereto as Exhibit “A.” WYO TECH provides this 

Notice to establish on the record in this proceeding the facts that: (a) Dennis M. Danzik

(“Danzik”), a Judgment Debtor under a certain New York judgment, has filed a 

bankruptcy petition in the United States Bankruptcy Court for the District of Wyoming

(“Danzik Bankruptcy”); (b) Defendants/Cross-Claim Defendants CWT Canada II 

Case 2:17-cv-04140-DWL Document 41 Filed 02/08/18 Page 2 of 4
3

WALKER

& PESKIND, PLLC

Attorneys and Counselors

16100 North 71st Street, Suite 140

Scottsdale, AZ 85254

Telephone: (480) 483-6336

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Limited Partnership, Resources Recovery Corporation, and Jean Noelting, the Judgment 

Claimants under the aforementioned New York judgment, have asserted that the funds 

sought to be interpleaded in this action by Plaintiff/Counterdefendant Wells Fargo, N.A., 

are subject to a beneficial or ownership interest of Danzik (which WYO TECH denies); 

(c) a question has been raised as to whether, in light of Judgment Claimants’ assertion, 

this action might be subject to the automatic stay in the Danzik Bankruptcy; and (d) in an 

abundance of caution, WYO TECH has sought a ruling in the Danzik Bankruptcy to 

ensure that this action can proceed unimpeded, notwithstanding the aforementioned 

automatic stay. Inasmuch as the issues addressed in Exhibit “A” are currently before the 

Wyoming Bankruptcy Court for resolution, the parties to this action will be filing with 

this Court contemporaneously herewith a stipulation for continuance of deadlines in this 

proceeding pending a ruling in the Danzik Bankruptcy on the applicability of the 

automatic stay to this action. 

RESPECTFULLY SUBMITTED this 8

th day of February, 2018.

WALKER & PESKIND, PLLC

By:/s/ Richard K. Walker

 Richard K. Walker

 Walker & Peskind, PLLC

 16100 N. 71st Street, Suite 140

 Scottsdale, Arizona 85254-2236

 Attorney for Defendant/Counterclaimant/

Cross-Claimant/Third Party Plaintiff 

WYO TECH Investment Group, LLC

Case 2:17-cv-04140-DWL Document 41 Filed 02/08/18 Page 3 of 4
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WALKER

& PESKIND, PLLC

Attorneys and Counselors

16100 North 71st Street, Suite 140

Scottsdale, AZ 85254

Telephone: (480) 483-6336

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NOTICE OF ELECTRONIC FILING AND CERTIFICATE OF SERVICE

I hereby certify that on February 8, 2018, I electronically filed the foregoing 

Defendant/Counterclaimant/Cross-Claimant/Third Party Plaintiff WYO TECH Investment 

Group, LLC’s, Notice of Recent Filing of Application for Relief from the Automatic Stay 

Filed with the U.S. Bankruptcy Court for the District of Wyoming, with the Clerk of the 

Court for filing and uploading to the CM/ECF system, which will send notification of such 

filing to all parties of record.

/s/ Michelle Giordano_

Case 2:17-cv-04140-DWL Document 41 Filed 02/08/18 Page 4 of 4