Kapoustin V Lciad Statement Of Claim
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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS Civil Action No.
MICHAEL KAPOUSTIN,
Plaintiff, v. LIFECHOICE INTERNATIONAL A.D.
Defendant
STATEMENT OF CLAIM
Jurisdiction And Venue
1.
This Court has original jurisdiction in person am according to 28 USC Section 1330 (a) and pursuant to 28 USC Section 1367(a), in that are so related to claims within the original jurisdiction of the district court that they form part of the same case or controversy under Article III of the United States Constitution.
2.
Venue is proper in this district pursuant to the provisions of 28 USC Section 1391(f) (1) (3), and pursuant to 28 USC Section 1391(d) and 28 USC Section 1391(a).
3.
The Defendant LifeChoice International A.D. is a private Bulgaria commercial company incorporated in the City of Sofia, Bulgaria on July 17th 1993 and having commercial interests and activities in the United States.
4.
The Plaintiff Michael Kapoustin, having been a resident of the United States and citizen of Canada has a derivative proprietary interest in commercial activities of the Defendant in the United States and elsewhere. The Plaintiff Kapoustin having suffered damages as a direct result of the Defendant’s failure to meet its obligation to the Plaintiff.
5.
Plaintiff’s rights are evidenced in all instances by a bank document issued by the International Bank for Investments and Development of Sofia, Bulgaria or Balkan Bank, Plovdiv, Bulgaria or by contract executed by a legal representative of the Defendant
19305852.doc
Page 1 of 2
Facts 6.
The Defendant, as of July 31st 1995 owes the Plaintiff SEVEN MILLION FIVE HUNDRED AND FIVE THOUSAND ONE HUNDRED EIGHTY NINE DOLLARS AND THIRTEEN CENTS or in numbers $7, 505, 189.13, for money had and received from the Plaintiff by the Defendant;
7.
The Defendant, as of August 11th, 1995 FURTHER OWES the Plaintiff ONE MILLION SEVEN HUNDRED NINETY EIGHT THOUSAND NINE HUNDRED FOURTEEN AND FIFTY SEVEN GERMAN MARKS or in numbers 1, 798, 914.57 DM. to the Plaintiff for money had and received from the Plaintiffs by the Defendant.
8.
The Defendant agreed to pay the Plaintiff on June 16th 1997 the full amount owed the Plaintiffs in cash or by converting the Defendant’s debt into common shares of the Defendant Corporation.
9.
On June 17th 1997, the Defendant was legally obstructed from settling in cash or shares the Defendant’s debt to the Plaintiff and was allowed additional time by the Plaintiff.
10. As of August 18th 2002, the Defendant is no longer legally obstructed from settling in cash or shares the Defendant’s debt to the Plaintiff yet has failed to do so and is now in default of the agreement of June 17th 1997. WHEREFORE PLAINTIFF DEMANDS JUDGMENT AGAINST THE DEFENDANT for the sum of SEVEN MILLION FIVE HUNDRED AND FIVE THOUSAND ONE HUNDRED EIGHTY NINE DOLLARS AND THIRTEEN CENTS; AND ONE MILLION SEVEN HUNDRED NINETY EIGHT THOUSAND NINE HUNDRED FOURTEEN AND FIFTY SEVEN GERMAN MARKS, plus pre-judgment interest, post-judgment interest, costs, attorneys' fees and such other relief as this Court deems just and proper. Plaintiff Consents to United States Magistrate Judge under Title 28, U.S.C. Section 636 (c). Place of trial: Chicago, Illinois Dated at the City of Chicago, in the State of Illinois on ……….. January 2003.
Robert Kap On behalf of and as Agent for the Plaintiff Michael Kapoustin Address for service: Chicago, Illinois 19305852.doc
Page 2 of 2
MICHAEL KAPOUSTIN,
Plaintiff, v. LIFECHOICE INTERNATIONAL A.D.
Defendant
STATEMENT OF CLAIM
Jurisdiction And Venue
1.
This Court has original jurisdiction in person am according to 28 USC Section 1330 (a) and pursuant to 28 USC Section 1367(a), in that are so related to claims within the original jurisdiction of the district court that they form part of the same case or controversy under Article III of the United States Constitution.
2.
Venue is proper in this district pursuant to the provisions of 28 USC Section 1391(f) (1) (3), and pursuant to 28 USC Section 1391(d) and 28 USC Section 1391(a).
3.
The Defendant LifeChoice International A.D. is a private Bulgaria commercial company incorporated in the City of Sofia, Bulgaria on July 17th 1993 and having commercial interests and activities in the United States.
4.
The Plaintiff Michael Kapoustin, having been a resident of the United States and citizen of Canada has a derivative proprietary interest in commercial activities of the Defendant in the United States and elsewhere. The Plaintiff Kapoustin having suffered damages as a direct result of the Defendant’s failure to meet its obligation to the Plaintiff.
5.
Plaintiff’s rights are evidenced in all instances by a bank document issued by the International Bank for Investments and Development of Sofia, Bulgaria or Balkan Bank, Plovdiv, Bulgaria or by contract executed by a legal representative of the Defendant
19305852.doc
Page 1 of 2
Facts 6.
The Defendant, as of July 31st 1995 owes the Plaintiff SEVEN MILLION FIVE HUNDRED AND FIVE THOUSAND ONE HUNDRED EIGHTY NINE DOLLARS AND THIRTEEN CENTS or in numbers $7, 505, 189.13, for money had and received from the Plaintiff by the Defendant;
7.
The Defendant, as of August 11th, 1995 FURTHER OWES the Plaintiff ONE MILLION SEVEN HUNDRED NINETY EIGHT THOUSAND NINE HUNDRED FOURTEEN AND FIFTY SEVEN GERMAN MARKS or in numbers 1, 798, 914.57 DM. to the Plaintiff for money had and received from the Plaintiffs by the Defendant.
8.
The Defendant agreed to pay the Plaintiff on June 16th 1997 the full amount owed the Plaintiffs in cash or by converting the Defendant’s debt into common shares of the Defendant Corporation.
9.
On June 17th 1997, the Defendant was legally obstructed from settling in cash or shares the Defendant’s debt to the Plaintiff and was allowed additional time by the Plaintiff.
10. As of August 18th 2002, the Defendant is no longer legally obstructed from settling in cash or shares the Defendant’s debt to the Plaintiff yet has failed to do so and is now in default of the agreement of June 17th 1997. WHEREFORE PLAINTIFF DEMANDS JUDGMENT AGAINST THE DEFENDANT for the sum of SEVEN MILLION FIVE HUNDRED AND FIVE THOUSAND ONE HUNDRED EIGHTY NINE DOLLARS AND THIRTEEN CENTS; AND ONE MILLION SEVEN HUNDRED NINETY EIGHT THOUSAND NINE HUNDRED FOURTEEN AND FIFTY SEVEN GERMAN MARKS, plus pre-judgment interest, post-judgment interest, costs, attorneys' fees and such other relief as this Court deems just and proper. Plaintiff Consents to United States Magistrate Judge under Title 28, U.S.C. Section 636 (c). Place of trial: Chicago, Illinois Dated at the City of Chicago, in the State of Illinois on ……….. January 2003.
Robert Kap On behalf of and as Agent for the Plaintiff Michael Kapoustin Address for service: Chicago, Illinois 19305852.doc
Page 2 of 2
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