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Lawsuit filed by Jason Roe against Paige Kreegel

Lawsuit filed by Jason Roe against Paige Kreegel

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Published by Peter Schorsch
"While Paige is exploiting Congressman Radel's recent problems as a platform to hold himself up as a paragon of virtue, he is quite the opposite. Our firm's experience with Paige revealed behavior that we believe disqualifies him from office."
"While Paige is exploiting Congressman Radel's recent problems as a platform to hold himself up as a paragon of virtue, he is quite the opposite. Our firm's experience with Paige revealed behavior that we believe disqualifies him from office."

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Published by: Peter Schorsch on Jan 23, 2014
Copyright:Attribution Non-commercial

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03/22/2014

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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUITIN AND FOR CHARLOTTE COUNTY, FLORIDA
REVOLVIS CONSULTING INC.;
Plaintiff,
vs.
Case No. 12-3795-CA
PAIGE V. KREEGEL, M.D. d/b/aKREEGEL FOR CONGRESS;
Defendant,
/SECOND AMENDED COMPLAINT
Plaintiff, REVOLVIS CONSULTING, INC. (the Plaintiff'), sues Defendant PAIGE V.
KREEGEL, M.D. d/b/a KREEGEL FOR CONGRESS (the Defendant ) and as causes of
action alleges:
GENERAL ALLEGATIONS
1. At all times material to the matters alleged herein, Plaintiff, was and is a foreign
corporation conducting business in this state and was conducting business in Charlotte County,
Florida.
2. The Defendant PAIGE V. KREEGEL M.D. is a natural person sui juris and based
upon information and belief, is a resident of Charlotte County, Florida, doing business as
KREEGEL FOR CONGRESS, an unincorporated entity.
3. The Plaintiff and the Defendant entered into a written agreement (the Agreement )
wherein the Plaintiff would provide campaign consulting services (the Services ) to the
Defendant in exchange for the Defendant's payment for said services; a true and correct copy ofthe unexecuted contract is attached hereto as Exhibit I and incorporated herein by reference.
Page 1 of5
 
4. The Plaintiff fully performed its obligations under the Agreement.
5. The Defendant failed to remit payment in full pursuant to the Agreement.
6. Venue is appropriate in Charlotte County, Florida.
7. All conditions precedent to the filing of this action have been satisfied or otherwise
waived.
8. Plaintiff has retained the law firm of Fowler White Boggs P.A to represent it in this
action and has agreed to pay a reasonable fee for their services. Plaintiff is entitled to recover
these fees from the Defendant pursuant to the terms of the Agreement.COUNT I: BREACH OF CONTRACT
9. This is an action for damages that exceed $15,000.00 exclusive of interest and costs.
10. The Plaintiff realleges and incorporates by reference the allegations of Paragraphs 1
through 8 as if set forth fully herein.
11. The Plaintiff and the Defendant entered into the Agreement whereby the Plaintiff
provided the Services to the Defendant and the Defendant agreed to pay for the Services.
12. The Defendant breached the Agreement by failing to remit payment in full for the
Services as evidenced by the invoices (the Invoices ) that are attached hereto as Exhibit 2
and incorporated herein by reference.
13. The Plaintiff has been damaged by the Defendant's breach of the Agreement.
14. The Defendant owes the Plaintiff the sum of 52,262.63 that is the unpaid balance due
under the Agreement for the Services.
15. The Plaintiff has performed all conditions precedent to be performed by the Plaintiff, and
any conditions not performed were waived by agreement of the parties or prior breach by the
Defendant.
Page 2 of5
 
WHEREFORE, Plaintiff, REVOL vis CONSULTING, INC. respectfully requests thisCourt enter Judgment against Defendant, PAIGE V. KREEGEL, M.D. d/b/a KREEGEL FOR
CONGRESS, for:
i) Damages plus interest thereon;
ii) Costs and reasonable attorneys' fees for this action; and
iii) Such further relief as the Court may deem just and proper.
COUNT II: ACCOUNT STATED
16. This is an alternative action for damages that exceed $15,000.00, exclusive of interest and
costs.
17. The Plaintiff realleges and incorporates by reference the allegations of Paragraphs 1, 2,
and 4 through 7 as if set forth fully herein.
18. Before the institution of this action, the Plaintiff and the Defendant had business
transactions that include, but are not limited to, the months of July 2012 through August, 2012.
19. The Plaintiff rendered letters (the Notice Letters ) regarding the outstanding account
statementlinvoices to the Defendant; a true and correct copy of the letters are attached hereto asExhibit 3 and incorporated herein by reference.
20. Defendant did not object to the amount stated in the Notice Letters.
21. Defendant owes Plaintiffthe agreed upon sum of 52,262.63.
WHEREFORE, Plaintiff, REVOLVIS CONSULTING, INC. respectfully requests thisCourt enter Judgment against Defendant, PAIGE V. KREEGEL, M.D. d/b/a KREEGEL FOR
CONGRESS, for:
i) Damages; and
ii) Such further relief as the Court may deem just and proper.
Page 3 of5

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