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DOCKET NO. WWM-CV-19-6016996—S : SUPERIOR COURT
`
`JOLLY JOHN’S TRUCK AND
`
`: JUDICIAL DISTRICT OF WINDHAM
`
`EQUIPMENT, LLC
`
`VS.
`
`: AT PUTNAM
`
`RICHARD CHENEY
`
` 3 ' MARCH 22, 2709402021.
`
`AMENDED COMPLAINT
`
`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
`
`company with a principal place of business at 380 North Main Street in Moosup,
`
`Connecticut.
`
`The defendant; Richard Cheney; is an individual with an address of 42 Oak Drive
`
`in Mansfield Center, Connecticut.
`
`
`
`leadeehem—theplamhll~
`
`
`In, JanuarV. 201.8. the defendant. Richard Cheney. reg uested of the plaintiff that he
`
`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
`
`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
`
`purchase thepay loader, then he would be charged the reasonable rental value of
`
`

`

`
`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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`
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`4:5.
`
`
`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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`
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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”.
`
`
`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,
`
`Connecticut.
`
`

`

`
`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
`
`
`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.
`
`

`

`WHEREFORE, the plaintiff claims:
`
`1.
`
`2.
`
`3.
`
`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.
`
`THE PLAINTIFF
`
`

`

`By:
`
`Mark R. Brouillard
`
`St. Onge & Brouillard
`Its Attorneys
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`CERTIFICATION
`
`I hereby certify that on this
`
`
`
`
`22”d day of QetelwrMarch, 2020 a copy of the
`
`
`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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`
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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
`
`Mansfield, CT 06250
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`(Email: richel859@gn_1ail.con_t)
`
`

`

`Mark R. Brouillard
`
`Commissioner ofthe Superior Court
`
`

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