With no explanation, chose the best option from "A", "B", "C" or "D". added.) It is undisputed that Hoy gave notice of his claim for compensation to the attorney for Alpha Corporation, and that the Alpha Corporation attorney understood this claim to extend not only to judgments, but also to all “money due,” including settlement proceeds. Consequently, Hoy satisfied the statutory notice requirements for establishing an attorney’s lien. Second, although at least one jurisdiction requires counsel to bring a separate action against his client to enforce an attorney’s lien, Neilson v. Neilson, 780 P.2d 1264 (Utah Ct.App.1989), we align ourselves with the majority of jurisdictions which hold that an attorney’s lien may be enforced either through a separate action or incident to the underlying litigation. See Gee v. Crabtree, 192 Colo. 550, 560 P.2d 835 (1977) (<HOLDING>); Plaza Shoe Store, Inc. v. Hermel, Inc., 636

A: holding that a lawyers claim for impression of his statutory charging lien upon the recovery secured in an action may be prosecuted as an ancillary proceeding to the main litigation
B: holding state courts authority under iowa code section 59821 not the lien created there under prevented debtor from claiming the iowa homestead exemption and therefore the debtor could not avoid the lien because the lien did not impair an exemption to which the debtor would have been entitled but for the lien
C: holding that no lien may be imposed without direct and specific notice to the fund of an opposing party or its carriers that a lien is asserted before the proceeds are disbursed
D: holding that the attorneys charging lien may be asserted and enforced in the civil action which gave rise to the lien claim or in an independent action
D.