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`JOLLY JOHN’S TRUCK AND
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`: JUDICIAL DISTRICT OF WINDHAM
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`EQUIPMENT, LLC
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`VS.
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`: AT PUTNAM
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`RICHARD CHENEY
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` 3 ' MARCH 22, 2709402021.
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`AMENDED COMPLAINT
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`FIRST COUNT: (Jolly John’s Truck and Eguipment3 LLC v. Richard Cheney)
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`1. The plaintiff, Jolly John’s Truck & Equipment is a Connecticut limited liability
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`company with a principal place of business at 380 North Main Street in Moosup,
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`Connecticut.
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`The defendant; Richard Cheney; is an individual with an address of 42 Oak Drive
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`in Mansfield Center, Connecticut.
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`leadeehem—theplamhll~
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`In, JanuarV. 201.8. the defendant. Richard Cheney. reg uested of the plaintiff that he
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`be allowed the use of a ceitain 1973 John Deere av loader in order to evaluate
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`whether he wished to purchase the same. Igwas agreed bV the mintift‘ and the
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`defendant. Richard Cheney. that if he in fact purchased. the pay_loader. that he
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`would not be chargedanv rental fee. it was further agreed that if he did not
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`purchase thepay loader, then he would be charged the reasonable rental value of
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`4.
`In. January ZtllSJLhrough July 2018. the defendant. Richard Cheney. had the use of
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`the 1973 John Deere pay leader. The ame’c'mt—due—defendant. Richard Cheney did
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`not purchase the pay loader and. the plaintiff requested. that the pay loader be
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`isreturn of the a r loader.
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`4:5.
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`In. accordance with the agreement reached by the Jgrties. wherein the
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`defendant would be responsible to pay for the reasonable rental value of the 1.973
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`John Deere payloader in the event that it was not purchased. the sum. of Six
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`Thousand Dollars &and 00/100 ($6,000.00) plus tax of Three Hundred Eighty—One
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`Dollars & 00/100_(j5381.00)~f0r a total. due of Six Thousand 'l'hree l-lundred liiiight-
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`One Dollars & 00/ 100 ($6,381.00) A copy of the invoice is attached hereto as
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`Exhibit “A”.
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`31.6.
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`Despite demand, the defendant has failed, neglected, or refused to pay the
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`same.
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`SECOND COUNT:
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`Joll John’s Truck and E ui ment v. Mattern Construction Inc.
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`1. The plaintiff, Jolly John’s Truck & Equipment is a Connecticut limited liability
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`company with a principal place of business at 380 North Main Street in Moosup,
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`Connecticut.
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`2. The defendant. Mattern Construction, Inc. is Connecticut corporation with a place
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`of business at 26M Bushnell Hollow Road, Baltic, Connecticut, 06330.
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`3.
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`In January, 2018, through July, 2018, Richard Cheney, as agent for and acting on
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`behalf of the defendant, Mattern Construction, Inc., mateda Ireed to urchase
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`and/or to rent a 1973 John Deere pay loader from the plaintiff.
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`4. The amedntdaepay loader was not purchased. and the defendant is liable for the
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`reasonable rental value of derideqdi-pmeiattsthe 1973 John Deere pay loader in the
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`inal-e>iee—is-attaehed—herete~as—Exh-ibit—‘3Ai.)_.
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`5. The defendant has failed, neglected, or refused to pay the same.
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`WHEREFORE, the plaintiff claims:
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`1.
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`2.
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`3.
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`4.
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`5.
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`Monetary damages;
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`Interest;
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`Attorney’s fees;
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`Court costs; and
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`Any other legal or equitable relief to which the plaintiff may be entitled.
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`This matter is within the jurisdiction of this Court.
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`THE PLAINTIFF
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`By:
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`Mark R. Brouillard
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`St. Onge & Brouillard
`Its Attorneys
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`CERTIFICATION
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`I hereby certify that on this
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`22”d day of QetelwrMarch, 2020 a copy of the
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`foregoing was sent Via electromec—mail and/or facsimile and regular mail, to the following
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`counsel of record. and self-represented party:
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`Chini o .lgeone & Maruzo LLP
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`1.41 Broadwav
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`PO Box 510
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`Norwich. CT 06360
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`Facsmilc: 860—887—1 744
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`Mr. Richard Cheney (pro se)
`42 Oak Drive
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`Mansfield, CT 06250
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`(Email: richel859@gn_1ail.con_t)
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`Mark R. Brouillard
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`Commissioner ofthe Superior Court
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