Estate of Theodore C. Chemodurow, Deceased, Gail C. Williams, Executor - Page 7




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          for Jury Trial in Cause No. DV 96-60 (second amended complaint)             
          is dated February 12, 1997).  Ms. Williams answered and made a              
          counterclaim (the answer and counterclaim).  The second action is           
          styled “GAIL SUZANN CHEMODUREAU WILLIAMS, Plaintiff, vs. GEORGIA            
          DARIA HOHENSEE, CYNTHIA JAKUBEK, PAUL JAKUBEK, the heirs et al.,            
          Defendants”, Cause No. DV 96-109 (Cause No. DV 96-109).  Cause              
          No. 96-109 was initiated by complaint filed April 1, 1996 (the              
          complaint).  A cross-complaint (the cross-complaint) was brought            
          in Cause No. DV 96-109, styled “GEORGIA DARIA HOHENSEE,                     
          Plaintiff, vs. GAIL SUZANN CHEMODUREAU, et al., Defendants.”                
               Cause No. DV 96-60 involves several causes of action based             
          upon agreements plaintiffs claim they entered into with decedent,           
          including an agreement entitled “LIVESTOCK AGREEMENT” (the                  
          livestock agreement).  Among the averments made by plaintiffs in            
          support of their causes of action are that (1) by the livestock             
          agreement, decedent had (A) leased the Abagail ranch to them and            
          (B) agreed to provide and maintain necessary equipment (i.e., the           
          ranch equipment) for ranch operations, and (2) Ms. Williams,                
          individually and as a personal representative of decedent’s                 
          estate, had breached those agreements.  Among the counts in                 
          Ms. Williams’ counterclaim are counts alleging that plaintiffs              
          are unlawfully in possession of, and have refused to return to              
          Ms. Williams, the ranch equipment.                                          
               In Cause No. DV 96-109, Ms. Williams averred that she was              
          the sole owner of the Abagail ranch and sought to quiet her title           




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