Richard Orin Berge - Page 8

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               Plaintiff, Donna Wold, alleges that on or about 1995 through           
               1998 an oral agreement was made between Donna Wold and                 
               Richard O. Berge.                                                      
               Plaintiff, Donna Wold, lent money to defendant, Richard O.             
               Berge, and paid his expenses and debts on defendant’s                  
               promise that he would repay said money lent and paid on                
               behalf of and for the benefit of defendant.  Defendant was             
               to repay said money lent and paid upon his graduation from             
               law school.  Plaintiff is informed and believes and thereon            
               alleges that defendant has graduated from law school and               
               despite plaintiff’s demand therefore, has failed and refused           
               to repay the said money lent and paid by plaintiff on behalf           
               of and for the benefit of defendant.                                   
               On or about February 2, 1999, the defendant breached the               
               agreement by the following acts:  Defendant has failed and             
               refused to repay the money lent to him and has failed and              
               refused to repay the money paid by plaintiff on behalf of              
               and for the benefit of defendant.                                      
                         *    *    *    *    *    *    *                              
               Plaintiff suffered damages legally (proximately) caused by             
               defendant’s breach of the agreement * * * as follows:  The             
               sum of $50,978 lent to defendant and paid on behalf of and             
               for the benefit of defendant.                                          
                       Second Cause of Action - Common Counts                         
               Plaintiff, Donna Wold, alleges that defendant, Richard O.              
               Berge, became indebted to plaintiff within the last four               
               years for goods, wares, and merchandise sold and delivered             
               to defendant and for which defendant promised to pay                   
               plaintiff the sum of the total of all payments according to            
               proof on auto, for money lent by plaintiff to defendant at             
               defendant’s request, and for money paid, laid out, and                 
               expended to or for defendant at defendant’s special instance           
               and request.  [The amount of] $50,978 plus all payments                
               owing on auto, which is the reasonable value, is due and               
               unpaid despite plaintiff’s demand, plus prejudgment interest           
               according to proof.                                                    
                            Third Cause of Action - Fraud                             
               Plaintiff, Donna Wold, alleges that defendant, Richard O.              
               Berge, on or about 1995 through 1998 defrauded plaintiff as            
               follows:                                                               





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