Melford Olson Honey, Inc.

Minnesota State to the above-mentioned Defendant:

The plaintiff has filed a case against you at the above-mentioned court. The plaintiff’s claims are contained in the complaint issued with this summons. You are hereby called and obliged to serve the summons on the attorney of Melford Olson Honey, Inc., whose address is 5th street, Cannon Falls, MN, within 20 days of the summons’ service.Failure to this, a default judgement may be taken against you for the relief demanded in the complaint.

You are required to appear in court on the dates stated below, unless all the plaintiff’s order demands are met:

16th Jan 2018 8:30 a.m. No appearance required if full payment made.

17th Jan 2018 8:30 a.m. No appearance required if full payment made.

18th Jan 2018 8:30 a.m. No appearance required if full payment made.

19th Jan 2018 8:30 a.m. No appearance required if full payment made.

Full payment represents the plaintiff’s order requirements set forth in a June 2002 contract.

By your signature, you acknowledge receipt of a copy of this Summons to Appear for Review, and you agree to appear at the above dates unless full payment is made.

__________________________________ Date __________________________________

Name / Signature

__________________________________ Date __________________________________

Street Address Social Security Number

State Complaint

STATE OF MINNESOTA State Court

COUNTY OF GOODHUE Minnesota Judicial State

Melford Olson Honey, Inc. )

) Case No. 141217-017

(Plaintiff) )

) COMPLAINT

)

Vs. )

Richard Adee )

(Defendant) )

The following information contains allegations made by Melford Olsson Inc. against Adee Honey Farms. The case is filed in breach of the contract that was entered between you and the plaintiff and the negligence in the execution of the contract. The complaint will explain the defendant failed to do, the harm that occurred as a result, and the damages that the plaintiff is praying.

Melford Olsson Inc. raises the following allegations of the breach of the contract as below.

That the Plaintiff is a registered entity operating in South Dakota, Nebraska and Minnesota

The defendant, is registered as a Company with operations in South Dakota

That on or about March 2002, the defendant was contracted to supply honey to the defendant through an oral agreement

That the Defendant was allowed to deliver honey in quantities other than the contracted

That the honey was delivered by the Defendant

That the defendant failed to honour the contract thus in breach of the contract

That as a result of the breach, the plaintiff incurred monetary loss

That the damages the plaintiff is praying are quantifiable in monetary.

Count 1- Negligence

The defendant failed to honour the contract that was entered into by both parties when the defendant failed to submit the funds as per the Statutes Minn. Stat. § 336.2-201(1)

Count 2- Damages

Because of the negligence, the plaintiff incurred losses as to the delayed payments for the supplied honey to the defendant of which, thereof, the plaintiff is praying together with the lawsuit costs.

Dated this 20th day of December, 2017

Name and Signature

Federal Summon

UNITED STATES DISTRICT COURT

For the

STATE OF MINNESOTA

United States of America )

vs. )

Richard Adee )

(Defendant) )

)

SUMMONS IN A CASE

YOU ARE SUMMONED to appear before the district court of the United States on the place, date and time set forth to answer to allegations made by Melford Olsson Inc. about a breach of commercial contract.

PLACE: Minnesota District Court

COURTROOM NO.: 015

DATE AND TIME: 16th Jan 2018 8:30 a.m.

The offence is briefly described as follows:

The plaintiff (Melford Olsen Honey, Inc.) entered into a commercial contract with the defendant on March 2002. The contract was an oral agreement, where the defendant was required sell an agreed amount of honey and make deliveries over a period of time. According to the Plaintiff, the Defendant breached the commercial contract by failing to meet the terms of the contract.

Date: Issuing officer’s signature

Printed name and title

Federal Complaint

UNITED STATES DISTRICT COURT

For the

STATE OF MINNESOTA

United States of America )

Vs. )

Richard Adee ) Case No. 141217-017

(Defendant) )

)

)

COMPLAINT

I, the complainant in this case, acknowledge that the following is true to the best of my knowledge. On or about the dates of March 2002 in the state of South Dakota, the defendant’s central place of business, the defendant violated:

CODE SECTION:

OFFENSE DESCRIPTION: The defendant failed to meet the requirements of the contract set forth on March 2002.

THE CRIMINAL COMPLAINT IS BASED ON THESE FACTS:

Complainant’s Signature

Printed Name and Title

Sworn to before me and signed in my presence.

Date: Judge’s Signature

City and State Printed Name and Title

IN THE DISTRICT COURT OF MINNESOTA STATE

Melford Olson Honey, Inc, ) Case No. 141217-017

)

)

vs ) Document No. 48791

)

Richard Adee )

MEMORANDUM

The memorandum is filed by the clerk of the honourable court by the plaintiffs’ Attorney in pursuit of the enforceable breaches y parties recognized in the contract. The facts and features as contained in the agreement between the plaintiff and the defendant are enforceable by the honourable court. It is noteworthy that the defendant, through the purchase order for the supply and delivery of thirty loads affirmed the prior oral agreement. The variation in the quantity was communicated as stipulated in the Minn. Stat. § 336.2-201(1).

The damages being sought for are the initial agreement of $1.10 per pound and not the $1.55, as the defendant did not consent to the increase from $ 1.10 to $ 1.55 per pound. The loss that was because of an act of God such as drought or flood, as was the case in South Dakota at the time. The honourable court should thus allow the orders being sought by the plaintiff and offer restorative justice by granting the said damages including the cost of the suit and the Attorneys’ fees. This will enable the plaintiff to recoup the losses and the delays in payments necessitated y the defendant in the case.

Bibliography

Calvert Chipchase, Federal District Court Law Clerk Handbook 103-06 (American Bar Association 2007)