1. State of Minnesota In District Court
County of Pope Eighth Judicial District
Wettstein Construction, Inc., Court File Number:
Plaintiff, Case Type: CNT
vs.
Complaint
Mark L. Ogden,
Defendant.
The Plaintiff, for its cause of action against the Defendant herein, states and alleges:
I.
That at all times hereinafter mentioned, Plaintiff was, and still is, a domestic corporation
duly organized and existing under the laws of the State of Minnesota.
II.
Upon information and belief, that at all times hereinafter mentioned, Defendant had an
office for the transaction of business within the County of Pope, and the cause of action arose
therein.
III.
That heretofore and on or about the 8th day of January, 2006,Plaintiff and Defendant
entered into a contract in writing wherein and whereby Plaintiff, among other things, agreedto
provide all the work, labor, and services, and to supervise the furnishing and decorating for a
certain house under construction at the time of said contract, which said house is located on Eide
Circle, in the City of Villard, County of Pope, State of Minnesota.
2. IV.
The Defendant failed to carry out his contractual responsibilities, delaying the occupancy
of the dwelling, because of the necessity to sublet portions of the work to another contractor at a
higher cost.
V.
That as a result of the forgoing, Plaintiff has suffered damages in the amount of Twenty
Thousand Dollars ($20,000).
WHEREFORE, Plaintiff demands judgment against the Defendant in the sum of Twenty
Thousand Dollars ($20,000), plus interest, costs, and disbursements herein.
Dated this 9th day of February, 2013.
STEPHENS, BOWEN & JANSEN
____________________________________
Mavis M. Pattee
Attorneys for Plaintiff
1601 Jefferson Street
Alexandria, MN 56308
Tele: (320) 762-4516
Atty. Reg. No. 63-74777
STATE OF MINNESOTA )
) ss.
COUNTY OF DOUGLAS )
Mavis M. Pattee, being first duly sworn upon oath, deposes and says that she is the
attorney for the Plaintiff in the within action, that she has read and knows the contents of the
foregoing Complaint; and that the same is true of her own knowledge, except as to the matters
therein stated to be alleged on information and belief, and as those matter she believes it to be
true.
____________________________________
Mavis M. Pattee, Attorney for Plaintiff
2
D:ConFacconversion16637296productiontest-complaint-130219221451-phpapp01.docx
3. Subscribed and sworn to before me this 9th day of February, 2013.
____________________________________
Notary Public
The party(ies) upon whose behalf this pleading is submitted, by and through the
undersigned, hereby acknowledge(s) that sanctions may be imposed for a violation of Minn. Stat.
Section 549.211.
____________________________________
Mavis M. Pattee, Attorney for Plaintiff
3
D:ConFacconversion16637296productiontest-complaint-130219221451-phpapp01.docx