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SC-100, ITEM 3, Attachment

1. On October 9, 2013, Plaintiff and the defendant entered into a written loan contract. The terms of the written loan contract provided that Defendant would put up his 2004 Range Rover up as collateral for a cash loan form Plaintiff of $3000.00. The contract provided that the Defendant would repay the full amount of the loan by November 3, 2013. The contract also provided for a daily interest of $50.00 a day until the loan was fully repaid. 2. Plaintiff hereby realleges and incorporates by reference the allegations in paragraph 1 as though fully set forth in this action. 3. Plaintiff has performed all duties, promises, and obligations required of plaintiff and all conditions precedent that plaintiff agreed to perform in the agreement described in Paragraph 1. 4. Under the terms of the agreement described in Paragraph 1, defendant was obligated to repay the $3000.00 loan or transfer his ownership of the 2004 Range Rover to Plaintiff as described in Paragraph 1. 5. Defendant has failed and refused, and continues to fail and refuse, to repay the $3000.00 loan or transfer his ownership of the 2004 Range Rover to Plaintiff as described in Paragraph 1. 6. Defendants failure and refusal to repay the $3000.00 loan or transfer his ownership of the 2004 Range Rover to Plaintiff as described in Paragraph 4 constitutes a breach of the agreement described in Paragraph 1. 7. Because of defendants breach of the agreement described in Paragraph 1, plaintiff has suffered general and consequential damages; Plaintiff is therefore entitled to damages of $7,500 or the transfer of ownership of the 2004 Range Rover. 8. Defendant is liable for all attorneys fees paid by the Plaintiff to enforce the agreement described in Paragraph 7, pursuant to provision 22 of said agreement. 9. Plaintiff hereby realleges and incorporates by reference the allegations in paragraphs 1 through 8 as though fully set forth in this action. 10. At the time plaintiff and defendant entered into the agreement referred to in Paragraph 1, the consideration plaintiff was to pay under the agreement was adequate and the agreement is just and reasonable as to defendant, as the signed contract reflected. 11. Within the time prescribed by the agreement, Defendant has never offered to pay the full consideration called for in the agreement and continues to fail to repay the $3000.00 loan to plaintiff. 12. Plaintiff has demanded that defendant convey the property described in Paragraph 1, under the terms of the agreement described in Paragraph 1.

13. Defendant has refused and continues to refuse to convey to plaintiff the property described in Paragraph 1, as required by the terms of the Agreement described in Paragraph 1. 14. Plaintiff has no adequate remedy at law to enforce the provisions of the agreement described in Paragraph 1 other than specific enforcement of the agreement. 15. Plaintiff is entitled to specific performance of the terms, conditions, and provisions of the agreement described in Paragraph 1, by court decree, among other things, ordering defendant to complete conveyance of the property described in Paragraph 1. 16. Plaintiff is entitled to compensation incidental to a decree of specific performance by virtue of the delay of defendant in conveying of the property described in Paragraph 1 in that Plaintiff was deprived of receiving any benefits under the terms of the agreement.

Dated: _____________

_______________________________ Plaintiff in Pro Per