Attorney for Plaintiff
Clarence B. Darrow, IV, Esq.
410 555 1313
cdarrow@darrow.com
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
___________________________________
Renee D. McKinney, |
Plaintiff |
v. | Civil Action No.
Peter W. Poulos,
Russ E. Eisenstein, |
Defendants |
___________________________________ |
COMPLAINT
Jurisdiction
1. Plaintiff
is a citizen of
2. Defendants
are citizens of
Count 1 – Breach of
Contract
3. In the Fall of 2003, Defendant Poulos promised to pay Plaintiff McKinney $5,000 if a particular horse won the Kentucky Derby.
4. In return, Plaintiff McKinney promised to pay Defendant Poulos $5,000 if the horse referred to in Paragraph 3 did not win the Kentucky Derby.
5. The horse referred to in Paragraph 3 won the Kentucky Derby.
6. Despite repeated requests by Plaintiff McKinney, Defendant Poulos has refused to pay Plaintiff.
7. Defendant Poulos is liable to Plaintiff for breach of contract.
Count 2 – Fraudulent
Misrepresentation
8. Defendant Poulos committed the tort of fraudulent misrepresentation when he make the contract.
Count 3 – Intentional
Interference with Contractual Relations
9. Defendant Eisenstein has intentionally interfered with Plaintiff’s contractual relations with Defendant Poulos.
Relief
10. Plaintiff seeks damages from Defendant Poulos in an amount exceeding $75,000.
11. Plaintiff seeks damages from Defendant Eisenstein in an amount exceeding $75,000
_______________________________
Clarence B. Darrow, IV
Attorney for Plaintiff