Just got this email from Perfect Paralegal -

Good afternoon,

After discussing the mustang sale issue, we have concurred within the office that we should take a stab at filing an emergency motion for an ex parte order to halt the sale/transfer/disposal of the mustang, and a corresponding motion for hearing on the regular docket for entry of a lien against the mustang correlating to the child support lien and requesting the mustang be sold via receiver or auction to take the control out of her hands.

What we need from you is the following:

Any documentation substantiating the arrearage from the FOC (I think you might have provided us this before--please let me know if you did. However, if you can access / print something with a current date, that would be awesome).

(b) Anything you have substantiating the transfer of title to Lurch.

(c) An affidavit from your friend attesting to the conversation you informed us of.

(d) A copy of DH's JOD showing the award of the mustang to DH and any other documentation that may be helpful like if you had an old copy of the title or something similar.

Let us know if you approve of the plan and want to proceed and can get us that information.

Thanks, Perfect

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