- 7 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011