- 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