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
___________________________________
Sandra R. Stipp, |
Plaintiff |
v. | Civil Action No.
Blake W. Jackson,
James T. Cagle, |
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 Jackson promised to pay Plaintiff Stipp $5,000 if a particular horse won the Kentucky Derby.
4. In return, Plaintiff Stipp promised to pay Defendant Jackson $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 Stipp, Defendant Jackson has refused to pay Plaintiff.
7. Defendant Jackson is liable to Plaintiff for breach of contract.
Count 2 – Fraudulent
Misrepresentation
8. Defendant Jackson committed the tort of fraudulent misrepresentation when he make the contract.
Count 3 – Intentional
Interference with Contractual Relations
9. Defendant Cagle has intentionally interfered with Plaintiff’s contractual relations with Defendant Jackson.
Relief
10. Plaintiff seeks damages from Defendant Jackson in an amount exceeding $75,000.
11. Plaintiff seeks damages from Defendant Cagle in an amount exceeding $75,000
_______________________________
Clarence B. Darrow, IV
Attorney for Plaintiff