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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
`
`: OCTOBER 22, 2020
`
`AMENDED COMPLAINT
`
`FIRST COUNT: (Jolly John’s Truck and Equipment2 LLC v. Richard Cheney
`
`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.
`
`2. The defendant is an individual with an address of 42 Oak Drive in Mansfield
`
`Center, Connecticut.
`
`3.
`
`In January, 2018 through July, 2018, the defendant rented a 1973 John Deere pay
`
`loader from the plaintiff.
`
`4. The amount due for the rental of said equipment is Six Thousand Dollars & 00/100
`
`($6,000.00) plus tax of Three Hundred Eighty—One Dollars & 00/100 ($6,381.00)
`
`A copy of the invoice is attached hereto as Exhibit “A”.
`
`5. Despite demand, the defendant has failed, neglected, or refused to pay the same.
`
`

`

`SECOND COUNT: (Jolly John’s Truck and Eguipment v. Mattern Construction, Inc.)
`
`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 is Connecticut corporation with a place of business at 26M
`
`Bushnell Hollow Road, Baltic, Connecticut, 06330.
`
`U)
`
`In January, 2018, through July, 2018, Richard Cheney, as agent for and acting on
`
`behalf of the defendant, Mattern Construction, Inc, rented a 1973 John Deere pay
`
`loader from the plaintiff.
`
`The amount due for the rental of said equipment is Six Thousand Dollars & 00/100
`
`($6,000.00) plus tax of Three Hundred Eighty-One Dolloars & 00/ 100 ($6,381.00)
`
`A copy of the invoice is attached hereto as Exhibit “A”.
`
`The defendant has failed, neglected, or refused to pay the same.
`
`

`

`WHEREFORE, the plaintiff claims:
`
`1.
`
`2.
`
`Monetary damages;
`
`Interest;
`
`Attomey’s fees;
`
`Court costs; and
`
`Any other legal or equitable relief to which the plaintiff may be entitled.
`
`This matter is within the jurisdiction of this Court.
`
`Dated at Woodstock, Connecticut this CD?» day of October, 2020.
`
`THE PLAINTIFF
`
` y:
`
`M R. Brouillard
`
`
`
`
`
`
`nge & Brouillard
`St.
`Its Attorneys
`
`

`

`CERTIFICATION
`
`I hereby certify that on this <g22_~day of October, 2020 a copy of the foregoing was
`
`sent Via electronic mail, to the following self—represented party:
`
`Mr. Richard Cheney (pro se)
`42 Oak Drive
`
`Mansfield, CT 06250
`
`
`
`Commis ioner 0f the Superior Court
`
`

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