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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.
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
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

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Production test complaint

  • 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