View Complaint and Exhibits

Transcription

www.ratemyhorsepro.com
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General Civil Case Filing Information Form (Non-Domestic)
Coun ty CHEROKEE
Court
IB' Superior
D State
Date
Filed~J1d1 1~
MM-DD-YYYY
Plaintiff(s)
Defendant(s)
Batchelder, Carol
Iron Gait Perc heron's Inc . dba Iron Gait Rescue
Ftrst
Middle I. Suffix Prefix
Maiden
Last
Last
F~rst
Mtddle I.
uffi x Prefix
Maiden
Last
F~rst
Beach James
Ftrst
Middle I Suflix Prefcx
Eric
Mtddlc I.
s
Polydor Denise
FirSI
Middlc I. Su fTix Prefix
Matden
Last
First
Middle l. Suffix Prefix
Maid~n
Last
No. of Plaintiffs I
0 Pro Se
:\Iiddle I. Suffix Prefix
Middle!. Suffix Prefix
Mat den
Maiden
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First
Middle I
Suffix
se
John
B ar # 24 1125
or
Check Primary Type (Check only ONE)
D Contract/ Account
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D Wills/Es tate
Real Property
0
Dispossessory/Di stress
0
Personal Property
0
Equi ty
0
I !abeas Corpus
0
Appeals, ReYicws
0
Post Judgment Garnishment, Attachment, or
Other Relief
0
Non-Domestic Contempt
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First
Maiden
No. of Defendants 3
Plaintiff/Petition er's Attorn ey
Edwards
F~rst
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Last
Last
unix Prefix
Maiden
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Last
Last
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Docket #
[i( Tort (If tort, fill in right co lumn)
D Other General Civil Specify _ _ _ _ _ _ __
If Tort is Case Type:
(Check no more than TWO)
D Auto Accident
0
Premises Liability
D Medical Malpractice
0
Other Professional Negligence
D Product Liability
D Other Specify
Are Punitive Damages Pleaded? !1!" Yes D No
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Plaintiff,
v.
IRON GAIT PERCHERONS INC.,
d/b/a IRON GAIT RESCUE
JAMES ERIC BEACH and
DENISE S. POLYDOR,
Defendants.
CIVIL ACTION
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FILE NO.
/4C~Q LJq3"Jli
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CAROL BATCHELDER,
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IN THE SUPERIOR COURT OF CHEROKEE COUNTY
STATE OF GEORGIA
SUMMONS
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TO THE ABOVE NAMED DEFENDANT:
You are hereby summoned and required to file with the clerk of said court and
serve upon the Plaintiffs attorney whose name and address is:
H
or
The Law Offices of Edwards and Johnson LLC
John C. Edwards, Esq.
270 East Main Street Suite C.
Canton, Georgia 30144
pe.p . CLERK OF SUPERIOR COURT,
~ ._, ~OKEE
COUN
GEORGIA
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Answer to this complaint for damages and other relief which is herewith served
upon you, within 30 days after service of this summons upon you, exclusive of the day of
service. If you fail to do so, judgment by default will be taken against you for the relief
demanded in the complaint.
To Defendant upon whom this complaint is served:
This copy of Complaint and Summons was served upon you, _ _ __
_
_
_ _ , 2014.
IN THE S UPERIOR COURT OF C HE ROKE E C O UN T Y
ST AT E OF G EORG IA
CAROL BATC HE LD ER,
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Defendants.
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VE RI FI ED C O M PLAINT FOR DAMAG ES AND OT HER R ELI EF
OW, Carol Batchelder, named as Plaintiff herein, and brings this, her Verified
or
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COMES
Complaint For Damages And Other Relief, and shows this Honorable Court as follows , to wit:
I.
Plaintiff brings this Complaint as one seeking equitable and injunctive relief, thus this
2.
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Court properly has subject-matter jurisdiction over the basis of this Complaint.
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Defendant Iron Gait Percherons, lnc.(hereinafter "IGP") is a Georgia non-profit
corporation maintaining its principle place of business as 114 Hancock Mountain Trail, Waleska,
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Cherokee County, Georgia 30183 , where service may be perfected upon its registered agent,
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James E. Beach, thus venue is proper before this Court.
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YCVfY.d K?>JH
IRO N GAIT PERC H ERO NS, INC.,
d/b/a IRON GA IT R ESCUE,
JAMES ERIC BEAC H and
DEN ISE S. POL YDOR,
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Plaintiff,
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3.
Defendant Iron Gait Rescue is an unincorporated entity which holds the stable license
issued by the Georgia Department of Agricu lture for the stable located at 114 Hancock Mountain
Trail, Waleska, Cherokee County, Georgia 30183, thus venue is proper before this Comt.
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4.
Defendant Denise S. Polydor resides and may be served with a copy of the Summons and
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Complaint in this matter at 114 Hancock Mountain Trail, Waleska, Cherokee County. Georgia
30 I 83, thus venue is proper before this Court. Said Defendant is Chief Executive Officer of
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Defendant IGP.
5.
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Defendant James Eric Beach resides and may be served with a copy of the Summons and
Complaint in this matter at I 14 Hancock Mountain Trail, Waleska, Cherokee County, Georgia
30 I 83 , thus venue is proper before this Court. Said Defendant is Chief Financial Officer and
Secretary of Defendant IGP.
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6.
Plaintiff is a resident of Gorham,
ew Hampshire. Plaintiff submits herself to the
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jurisdiction of this Court for all matters arising from the facts giving rise to this Verified
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Complaint.
Facts Giving Rise To All Counts
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herein.
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Plaintiff hereby incorporates paragraphs I through 6 by reference as if set forth wholly
8.
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On or about November 22, 2012, Plaintiff purchased two Belgian draft horses from a kill
pen in New Holland, Pennsylvania after seeing them posted on Facebook. These two horses had
been together for some time and had gained a close bond as a result of having been together for a
Batchelder v. Iron Gait Percherons, Inc., et. a!
Verified Complaint for Damages
Case o.: TBD
Page 2
considerable length of time. The horses were named "Big Ben" (now "Solly") and "Mable"
(now "Ness") (collectively referred to as "the two horses" or "Solly and
ess").See Exhibit "A"
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(receipt) attached hereto and incorporated by reference as if set forth wholly herein.
9.
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Plaintiff went to con iderable time, effort and expense to rehabilitate Solly and Ness with
rehabilitation ofthe two horses.
10.
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veterinary care,-dental care, farrier care, quarantine and other expenses related to the
Plaintifffirst approached Debra Wehmueller of Millington, Maryland for assistance with
taking care of the short-tenns needs of Solly and
ess, inc! uding the required 30-day quarantine.
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With the help of Ms. Wehmueller, transportation was arranged from
ew Holland to Fellowship
Fann in Millington, Maryland. Plaintiff paid the $300.00 for the transport of the two horses.See
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Exhibit "B" (receipt) attached hereto and incorporated by reference as if set forth wholly herein.
On
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11.
ovember 26, 2012 , the two horses were delivered to the Quarantine Facility for their
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rehabilitation and daily care. At that time, the two horses were placed in a 200' by 400' paddock
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with sufficient shelter and light grazing was available. At this time, the two horses were
"barefooted" and their hooves were severely overgrown and quarter cracks had developed in
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their hooves.
On
12.
ovember 30,2012, Solly and Ness were wormed and were examined by Brook
Bowman, D.V.M. on December 5, 2012. Dr. Bowman made recommendations for the treatment
Batchelder v. lron Gait Percherons, Inc., et. a!
Case o.: TBD
Page 3
of the two horses, and prescribed penicillin for one of the horses that had developed a nasal
discharge (Ness). As prescribed, Ness was given 25cc of penicillin twice a day for ten days by
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Debra Wehmueller.See Exhibit "C" (Chesapeake Vet Perfonned Listing) attached hereto and
incorporated by reference as if set fo1ih wholly herein . On the same day, Dr. Bowman diagnosed
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Solly as having lameness issues in the left front leg.
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On December 8, 2012 , the two horses were treated by a farrier. The fan·ier, Chris
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Bender, trimmed the two horses' hooves and recommend that the quarter cracks be treated with
betadine, and Solly and Ness were treated with betadine for the remainder of their stay in
Maryland . They would be treated by the fa1Tier again on January 30, 20 13.See Exhibit "D"
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(receipt) attached hereto and incorporated by reference as if set forth wholly herein.
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14.
On December 9, 2012 , the two horses were examined by Judith Flynn Cockey, an equine
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dentist. The older of the two horses ("Solly") was detennined to be 19 years old and the younger
ofthe two horses ("Ness") was determined to be under 15 years of age. Both ofthe horses' teeth
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were floated , and it was determined that Ness would need fmiher dental work under sedation for
an overgrown tooth.
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15.
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During the first month of their stay in Maryland, the two horses started progressing well
and gaining weight at a healthy pace. At this point, they were taken daily for hand grazing in a
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richer pasture for approximately one and one-half hours per day.
Batchelder v. Iron Gait Percherons, Inc., et. al
Case No.: TBD
Page 4
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During the month of December 2012, Plaintiff visited the two horses in Maryland. She
found them to be fit and well, as evidenced by the picture attached hereto as Exhibit "E" and
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hereby incorporated by reference as if set fmih wholly herein.
17.
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At the end of their initial thiiiy-day stay, they were moved to another stable, Sugarland
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Stables, operated by Summerwinds Stables Horse Rescue. They remained there until being
transported to Georgia.See Exhibit "F" (receipt) attached hereto and incorporated by reference as
if set forth wholly herein.
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18.
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After having provided for the needs of the two horses, Plaintiffbegan searching for a
suitable horse rescue at which these two horses could live out the remainder of their natural lives
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as sanctuary horses. While several homes were found for the two horses, Plaintiff deemed them
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unacceptable and the search continued.
19.
In horse rescue circles, the tem1 "sanctuary horse" means a horse that is brought to a
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ce1iain location, there to live out the remainder of its natural life is not placed with other persons
20.
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for adoption.
Case No.: TBD
Page 5
In February of2013, Plaintiff contacted Defendant IGP regarding pe1manent sanctuary
and to inquire whether room was available for the purpose of providing the two horses with
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sanctuary.
21.
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Defendant Denise Polydor, CEO of IGP , advised that she would sanctuary the horses and
continue with the recommended courses of veterinary treatment and faJTier treatment.
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22.
"ambassadors" ofiGP.
23.
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Defendant Polydor further represented that the two Belgium draft horses would be
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Defendant Polydor further represented that she would keep Plaintiff infom1ed about the
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two Belgian horses, their condition, their activities and their treatment.See Exhibit "G" (print of a
Facebook page) attached hereto and incorporated by reference as if set forth wholly herein.
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24.
After a telephone conversation, Plaintiff reached an agreement with Denise S. Pol ydor,
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IGP and Iron Gait Rescue to ship the two Belgian draft horses to Georgia, where they would
reside for the remainder of their natural lives as sanctuary horses at the stable operated by IGP
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and licensed to Iron Gait Rescue. As of the date of filing, Solly and Ness continue to be listed as
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Sanctuary Horses on the IGP page at pinterest.com . See Exhibit " H" (print from IGP Pinterest
page) attached hereto and incorporated by reference as if set forth wholly herein.
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25.
Case No.: TBD
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On or about February 20,2013, Plaintiff notified Ms. Wehmeuller that she had made the
decision to send the horses to Defendants, where they could live out the remainder of their lives
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as sanctuary horses, be cared for, be used once a week for light trail rides and as part of their
children's program and grooming lessons.
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26.
On February 21, 2013, Dr. Bowman examined the horses, provided necessary
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vaccinations and Health Certificates were issued.
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27.
On March I , 2013 , the two horses were boarded onto a transfer truck for the ride to
Georgia. They atTived at the IGP property on March 2, 20 13.See Exhibit"!" (receipt) attached
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hereto and incorporated by reference as if set forth wholly herein.
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28.
Despite numerous promises to provide Plaintiff with infonnation regarding the horses,
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Defendant has completely and totally failed and refused to offer appropriate infom1ation, only
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occasionally responding to requests for infonnation regarding their condition and progress.
29.
Requests for photographs of the horses have gone refused and/or unanswered for the
30.
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purpose of concealing and secreting the deterioration and condition of the horses.
One ofthe conditions P1aintiffp1aced upon the horses coming to live as sanctuary horses
at Defendant IGP's facilities and under the care of Defendant Polydor and Defendant Beach was
that the two horses be true sanctuary horses, and not be adopted out.
Case No.: TBD
Page 7
31.
However, upon receiving pictures of Solly and Ness showing them in a depreciated
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condition, Plaintiff asked Defendant Polydor about their condition. At this time, Defendant
Polydor claimed that the two horses had been adopted out and had come back in their current
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underweight condition.
32.
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Plaintiff sent two (2) payments of $100.00 each via PayPal to help with the care of Solly
set f01th wholly herein .
33.
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and Ness.See Exhibits "J" and "K" (receipt) attached hereto and incorporated by reference as if
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Since arriving in the care of Defendants, Solly and Ness have been forced to live in
mud. Solly and
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squalor, often being penned in a paddock with a small amount of hay covering their feces and
ess have been neglected since their arrival, having arrived as "full-weight"
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horses and now having deteriorated to skin and bones.See Exhibits "L", "M", "N", "0", "P",
herein.
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"Q", "R" and "S" (pictures) attached hereto and incorporated by reference as if set f01th wholly
34.
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Defendants adve1tise Iron Gait Percherons, Inc. and Iron Gait Rescue as a 50l(c)(3)
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organization and solicit donations both on their webpage and on their Facebook page. Persons
who adopt horses through TOP are given a charitable donation receipt for their tax records.See
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Exhibit "T" (print of JGP Facebook page) and Exhibit "U" (print of donation page at
Case No.: TBD
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http://www.igprescue.org) attached hereto and incorporated by reference as if set forth wholly
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First Cause of Action: Repudiation of Contract
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herein.
35.
wholly herein.
36.
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Plaintiff hereby incorporates paragraphs I through 34 above by reference as if set f011h
There was clearly a contract between the parties that called for Solly and Ness to live out
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the remainder of their natural lives as sanctuary horses in exchange for Defendants ' promise to
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not adopt them out.
37.
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Defendants, in adopting out Solly and Ness, breached the contract. However, Plaintiff
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hereby repudiates the contract and chooses to sue at fraud.
38.
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The contract, a verbal contract, included an offer, consideration and a bargained for
39.
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exchange.
The offer was to care for the horses as sanctuary horses for the remainder of their natural
lives.
Case No.: TBD
Page 9
40.
The consideration was Solly and
ess, the two Belgian draft horses.
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41.
The bargained for exchange was the knowledge that Solly and Ness would never be
ess would live out the remainder of their natural lives, that
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moved again, that Solly and
Plaintiff would send money as she could to help with their care, that Solly and Ness would be
ess would never be adopted out.
42.
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"ambassadors" of IGP, and that Solly and
As stated hereinabove, Plaintiffhereby repudiates the contract and chooses to sue at tort.
Second Cause of Action: Fraud
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43.
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Plaintiffhereby incorporates paragraphs I through 42 above by reference as if set forth
wholly herein.
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44.
Defendants had no intention of keeping Solly and Ness at the IGP horse stables or
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making Solly and Ness "ambassadors" of IGP.
45.
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Fraud requires the presence of five (5) elements.
Defendants Polydor and IGP made false representations including, inter alia, that Solly
and Ness would live out the remainder of their natural lives as sanctuary horses, that Solly and
Case o.: TBD
Page I 0
Ness would not be adopted out to anyone and that Solly and Ness would be "ambassadors" of
Defendant IGP.
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47.
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Defendants Polydor and IGP knew that the statements were false (scienter).
48.
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Defendants Polydor and IGP intended to induce reliance on the pati of Plaintiff, vis-a-vis,
49.
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her sending the two horses to IGP.
Plaintitf did send the horses to Defendants in justifiable reliance upon their promises.
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50.
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Plaintiff has suffered harm as a result of the actions of the Defendants in terms of her
constant wotTy about the horses and their suffering and the neglect which they are experiencing
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at the hands of the Defendants. Further, Plaintiff has lost a considerable amount of sleep
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worrying about the horses.
51.
Plaintiff has further suffered banns in terms of the monies which she spent on purchasing
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the two horses, having the two horses seen by a veterinarian, the costs associated with any dental
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veterinary work, the costs associated with the fan·ier and shoeing of the horses.
52.
Plaintiff contends that the Defendants never intended to properly care for the horses,
despite their promises to the contrary.
Batchelder v. Iron Gait Percherons, Inc. , et. al
Case No.: TBD
Page II
53.
Plaintiff contends that the Defendants never intended to allow Solly and Ness to remain
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on the IGP fann as sanctuary horses despite their promises to do so as evidenced by their quick
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action in allowing the adoption of Solly and Ness.
54.
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Plaintiff contends that the promises of allowing Solly and Ness to serve as ambassadors
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of IGP were for the sole purpose of inducing her to send the horses to IGP. Defendants never
intended to employ a Belgian draft horse as an ambassador for an entity called Iron Gait
Percherons
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55.
Plaintiff has been defrauded by Defendants and is entitled to a judgment on the basis of
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fraud.
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Third Cause of Action : Replevin
56.
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Plaintiff hereby incorporates paragraphs I through 55 above by reference as if set forth
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wholly herein.
57.
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Plaintiff seeks the equitable remedy of replevin.
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58.
A Percheron is a breed of draft horses.
Case No.: TBD
Page 12
Plaintiff gave the two horses, Solly and Ness, to Defendants on the conditions that the
two horses remained at the IGP stable as sanctuary horses, that they were well-fed, that they
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were cared for. that she received regular updates on their conditions and pictures of them on a
regular basis.
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59.
Defendants have possession, custody and control over the two horses, which are legally
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property of the Plaintiff.
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60.
The two horses are not earnings of the Defendants and the Defendants do not derive
earnings from Solly and
ess.
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61.
Plaintiff does not seek a writ of replevin for the purpose of delaying, hindering or
defrauding a creditor of the Debtors.
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62.
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the case.
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Plaintiff shows that there is a substantial likelihood that she will prevail on the merits of
63.
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Plaintiff shows that she fears that Defendants may dispose of the two horse prior to
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rulings by this Court on the merits of the case, in an attempt to rendering this action completely
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moot as to these Defendants.
Batchelder v. Iron Gait Percherons. Inc., et. al
Case o.: TBD
Page 13
64.
that they are well and healthy.
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Fourth Cause of Action: Fraud (second count)
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Plaintiff has legal ownership of Solly and Ness and has a very special interest in ensuring
64.
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65.
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wholly herein.
Defendants promised that they would give regular updates on Solly and
ess and send
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pictures of Solly and Ness to Plaintiff on a regular basis.
66.
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Defendants never intended to provide Plaintiff with regular repot1s on the conditions of
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Solly and Ness.
67.
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Defendants never intended to provide Plaintiff with pictures of Solly and Ness.
68 .
Defendants knew that they did not intend to provide Plaintiff with regular repot1s on the
ess or with regular pictures of the two horses.
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conditions of Solly and
69 .
Defendants knowingly made these promises as part of their plan to coerce Plaintiff into
placing the horses in their care.
Case No.: TBD
Page 14
70.
The facts are evidenced by the lack of communications between the patiies initiated by
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any of the Defendants and the complete and total lack of pictures having been sent by the
Defendants to the Plaintiff.
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71.
Plaintiff did rely on the representations of Defendants to send her regular updates on the
conditions of the two horses and regular pictures of the two horses in sending the horses to live at
72.
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the IGP stables.
Plaintiff has suffered as a result of her justifiable reliance on the false representations
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knowingly made by the Defendants both in sending the two horses to live at the IGP stables and
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in sending money via PayPal to assist in providing for their care.
73.
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Plaintiff is entitled to a judgment on the second count offraud.
Fifth Cause of Action: Neglect
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Plaintiff hereby incorporates paragraphs I through 73 above by reference as if set fo tih
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wholly herein.
75.
Upon their an-ivai at IGP in early March of 2013, Solly and Ness were healthy horses,
had appropriate medical care, and were a healthy weight.
Case o.: TBD
Page 15
76.
Since their aiTival at the IGP facilities, Solly and
ess have lost a significant amount of
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weight due to a lack ofreadily available food and due to the use offood that is not of good
quality.
77.
Solly and
ess have. since their an·ival at the IGP facilities, not been properly housed and
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have not been given ready access to grass.
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78.
Moreover, Solly and Ness have been forced to live in squalid conditions including living
in a small paddock providing minimal shelter that is not regularly cleaned, forcing them to stand
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around in their own feces and mud, which has been covered by a light dusting of hay.
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79.
Additionally. Solly and Ness have open sores around their hooves, their legs and on their
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faces and ears near their halters which have not been treated.
80.
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On infonnation and belief, Solly and Ness have not been seen by a veterinarian since
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their anival in Georgia, despite Defendants' representations that the recommended courses of
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treatment would be followed to the letter of the law. Defendants have not continued the
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veterinary care, the dental care or the fan·ier care to resolve Solly's lameness.
81.
On futiher intonnation and belief, Solly has not continued the recommended course of
farrier treatment and Ness has not had her teeth floated as recommended.
Case No.: TBD
Page 16
Sixth Cause of Action: Animal Abuse
82.
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wholly herein.
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83.
Plaintiff shows this Court that Defendants have not properly fed Solly and Ness, causing
clearly visible through their skin and fur.
84.
Moreover, Solly and
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them to become severely underfed to the point that their hip bones, ribs and backbones are
ess are housed in a small paddock and are forced to stand in a
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filthy mixture of mud and feces, which constitutes an unhealthy situation for the two horses.
Finally, Solly and
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85.
ess have open flesh sores (referred to as a condition called
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"dennatitis" in the horse community) about their hooves, legs and face which have not been
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treated and which are both painful and dangerous to the health of the two horses.
86.
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The failure to properly feed, provide clean living conditions and care for the medical
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needs of the horses constitutes animal abuse and can only result in deterioration, possibly
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itTeversib1e, of the two horses.
87.
On information and belief, Solly has not continued the recommended course of fatTier
treatment and Ness has not had her teeth floated as recommended .
Batchelder v. Iron Gait Percherons, Inc., et. a1
Case No.: TBD
Page 17
88
Solly and
ess.
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Seventh Cause of Action: Charitable Organization Fraud
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No amount of remedial measures can reverse the itTeparable ham1 being suffered by
89 .
wholly herein.
90.
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Plaintiff hereby incorporates paragraphs 1 through 88 above by reference as if set forth
Defendants, both on their website (www.igprescue.org) and on their Facebook page
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advertise that they are a charitable organization, which is true, and seek donations from across
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the United States and across the world.
91.
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Plaintiff is a resident ofthe State of ew Hampshire. She found Defendants through
their Facebook page. Defendants have sought donations and ongoing donations from Plaintiff
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and other persons throughout the United States and the world. Plaintiff sent money to the
92.
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Defendants as a result of these solicitations.
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Defendants have not registered IGP as a charitable organization in the State of ew
Hampshire, as required by
ew Hampshire law.
Veritied Complaint for Damages
Case No.: TBD
Page 18
93.
Moreover, Defendants have not registered IGP with any states outside of Georgia. Many
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states require such registration (approximately 39).
94.
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Defendants are soliciting donations from around the United States and from around the
world.
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Accordingly, their actions are in violation of various state laws requiring some fonn of
registration, which constitutes charitable organization fraud.
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Eighth Cause of Action: Breach of Fiduciary Duty
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96.
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wholly herein.
97.
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This count is against Defendant Polyclor only.
98.
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As the CEO of a charitable organization, Defendant Polydor has a fiduciary duty to act in
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the best interests of the charitable organization.
99.
In neglecting the horses entrusted to the charitable organization of which she is the CEO,
Defendant Polydor breached and violated her tiduciary duty to the charitable entity.
Case No.: TBD
Page 19
100.
In abusing the horses entrusted to the charitable organization of which she is the CEO,
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Defendant Polydor breached and violated her fiduciary duty to the charitable entity.
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and as such is entitled to recover her property and donations .
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Plaintiff has uffered ham1s as a result of Defendant Polydor's breach of fiduciary duty
Ninth Cause of Action : Breach of Fiduciary Duty
102.
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wholly herein.
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103.
This count is against Defendant James Eric Beach and against Defendant Iron Gait
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Percherons, Inc.
104.
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Defendants Beach and IGP have a fiduciary duty to the charitable organization and its
donors to ensure that the CEO of the charitable organization fulfilled her fiduciary duty to the
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charitable organization.
105.
In standing mute wh ile Defendant Polyclor neglected and abused horses entrusted to the
care of Defendant IGP, Defendants Beach and IGP breached their fiduciary duty to the donors of
the charitable organization.
Veritied Complaint for Damages
Case o.: TBD
Page 20
106.
Plaintiff has suffered harms as a result of the breach of fiduciary duty by Defendants
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Tenth Cause of Action : Breach of Public Duty
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Beach and IGP and as such the Plaintiff is entitled to recover her property and donations.
107.
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Plaintiff hereb y incorporates paragraphs I through 95 above by reference as if set forth
108.
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wholly herein.
As a charitable organization, the officers and directors of the charitable organization
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seeking donations from the general public, the Defendants had a public duty to the general public
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as well as to the Plaintiff to act in the best interests ofthe horses entrusted to their care.
109.
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In allowing horses to become emaciated and underweight to the points their backbones,
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ribs and hipbones were clearly visible through their skin, Defendants breached their public duty.
110.
In failing to ensure that the horses entrusted to them were properly vetted, Defendants
111.
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breached their public duty.
In failing to follow veterinarian and farrier treatment plans for Solly and Ness,
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Defendants breached their public duty.
Batchelder v. Iron Gait Percherons, Inc. , et. a!
Case No.: TBD
Page 21
112.
Defendants.
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Eleventh Cause of Action: Commingling of Funds
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Plaintiff has uffered ham1s as a result of the breach of public duty on the part ofthe
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Plaintiff hereby incorporates paragraphs I through 112 above by reference as if set fot1h
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wholly herein.
On infom1ation and belief, Defendant Denise Polydor does not have any source of regular
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On infom1ation and belief, James Eric Beach does not have a source of regular
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116.
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Defendants Beach and Polydor are believed to be taking monies from Defendant IGP to
pay their personal expenses and living off the donations made to Defendant IGP.
117.
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Plaintiff has been harmed by this commingling of funds.
Batchelder v. Iron Gait Percherons, Inc .. et. a!
Case o.: TB D
Page 22
Twelfth Cause of Action: Intentional Infliction of Emotion al Distress
118 .
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wholly herein.
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119.
and the distress she feels over the conditions of the horses.
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120.
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Plaintiff has suffered severe emotional distress as a result ofthe actions ofthe Defendants
Plaintiff has spent considerable time won·ying about the neglect and improper care being
received by the horses she placed in Defendants' care based on the Defendants' representations.
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121.
Solly and
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Plaintiff has spent many sleepless nights worrying about the deteriorating condition of
ess perpetrated by the Defendants and which her decision to place Solly and Ness
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with the Defendants resulted in.
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Thirteenth Cause of Action : Punitive Damages
122.
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wholly herein.
123.
Defendants have acted cavalierly in a manner that is wilful, wanton, and malicious and
showing a complete abandon for the consequences thereof.
Case No.: TBD
Page 23
124.
Pl aintiff has suffered harm to both herself and her horses as a result of the wilful , wanton
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and malicious acts of the Defendants coupled with their complete lack of concern for the
consequences thereof.
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125.
Defendants should be punished for their actions in an amount deemed sufficient to deter
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these Defendants from so acting in the future and to deter other, similarly situated defendants
from so acti ng in the future.
Fourteenth Cause of Action: Attorney's Fees and Costs
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126.
wholly herein.
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127.
Plaintiff has incutTed and wi ll continue to incur significant attorney's fees and costs
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because of the actions of the Defendants.
128.
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Plaintiff seeks a complete recovery ofthese attorney's fees and costs.
Case 1 o.: TBD
Page 24
WHEREFORE, Plaintiff prays for relief in the following manner:
a.
That this Complaint be filed and considered;
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b. That process issue and this Complaint be served upon all Defendants together with a
copy of the Summons issued in this matter;
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c. That Plaintiff have a trial by jury;
d. That this Co uti hold that Plaintiff has properly repudiated the contract between
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Plaintiff and Defendants;
e. That Plaintiff have a judgment against Defendants, jointly and severally, for fraud;
f.
That Plaintiff be awarded damages for fraud in an amount deemed to be sufficient by
the enlightened conscience of the jury in this case;
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g. That this Court order that the horses be tumed over to Plaintiff instanter to be
or
transferred to a rescue facility in Texas that represents it can and will provide proper
sanctuary for Solly and Ness;
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h. That this Couti grant judgment on the second count of fraud;
That Plaintiffbe awarded damages for the second count of fraud in an amount
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deemed to be sufficient by the enlightened conscience of the jury in this case;
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That this Couti find the horses to have been neglected while in the care of
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Defendants;
k. That this Couti find that Defendants have engaged in a course of abuse with respect
to Solly and Ness;
I.
That this Court find that Defendants have violated the charitable organization statutes
of several states by soliciting donations from all 50 states;
Case No .: TBD
Page 25
m. That this Court grant Plaintiff a judgment for intentional infliction of emotional
distress;
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n. That this Court award Plaintiff damages for intentional infliction of emotional distress
in an amount to be detem1ined by the enlightened conscience ofthejury;
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o. That this Court enter judgment in favor of Plaintiff on punitive damages;
detennined by the enlightened conscience of the jury;
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p. That this Court award Plaintiff damages for punitive damages in an amount to be
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q. That this CoUlt enter judgment in favor of Plaintiff on both breaches of fiduciary
duty;
That this Court enter judgment in favor of Plaintiff for breach of public duty;
s.
That this Court enter judgment in favor of Plaintiff for commingling of funds;
t.
That this Cou1t award Plaintiff attomey's fees and costs as proven at trial; and
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u. That this CoUlt grant Plaintiff such other and further relief as the CoUlt deems just,
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equitable and proper.
day of March, 2014.
bmitted,
FICES OF EDWARDS & JOHNSON, LLC
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This
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270 E. Main Street, Suite C
Canton, GA 30114
770-345-8200 Fax 770-345-8260
Case o.: TBD
Page 26
*
PLAfNTIFF,
VS .
DENISE S. POL YDOR, JAMES ERIC BEACH, AND
*
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CIVIL AcTION FILE No:
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DEFENDANTS.
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IRON GAIT PERCHERONS, INC.,
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CAROL BATCHELDER,
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THE SUPERIOR COURT OF CHEROKEE COUNTY
STATE OF GEORGIA
VERIFICATION
Personally appeared before the undersigned attesting officer, CAROL BATCHELDER, who,
are true and correct.
day of February, 2014.
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This the/lJ
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COMPLA INT
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after first being duly sworn, deposes and says that the facts contained in the within and foregoing
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CA OL BATCHELDER
PLAINTIFF
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Sworn to !Jfl~subscribed to before me
This the~ day of2z.tu, 2014
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Notary Public
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IN THE SUPERIOR COURT OF CHEROKEE COUNTY
STATE OF GEORGIA
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AFFIDAVIT OF SHANIA MEHAL
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STATE OF GEORGIA
CHEROKEE COUNTY
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COMES NOW, Shania Mehal, who, having first been properly sworn and deposed, states
as follows under oath:
1.
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My name is Shania Mehal. I am an adult over the age of eighteen, having recently
attained my eighteenth birthday.
2.
[ took several pictures of Belgian draft horses known as Solly and Ness using the camera
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in my cell phone. I used my cell phone camera because I did not want anyone to see me taking
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The pictures were taken in January of2014. I was seventeen at the time they were taken.
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Defendants.
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IRON GAIT PERCHERONS, INC.,
IRON GAIT RESC UE, JAMES
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DENISE S. POL YDOR,
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CAROL BATCHELDER,
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I was, at the time, a student at Cherokee County High School enrolled in an after-school
program associated with Iron Gait Percherons, Inc. from November 20 I 3 through January 2014.
During this time, I boarded my horse at Iron Gait Percherons stable in exchange for mucking
stalls.
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5.
living in such ditiy and unsanitary conditions.
6.
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I took the pictures out of concem for the horses because they were so underweight and
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To the best of my knowledge, Solly and Ness were never adopted out. They were kept
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on a back pasture with several other horses, who were also incredibly emaciated and
underweight .
7.
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There was a lady who was a volunteer that told me that she was going to adopt Solly and
Ness when she could afford them, and that Denise was holding the horses for her. She told me
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that Denise wanted $1 ,000.00 for the horses.
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I never knew Denise Polydor, Eric Beach or any volunteer with Iron Gait Percherons,
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Inc. to feed horses Triple Crown or other high-quality products. In fact, 1 had to start keeping
my horse feed in my car because Denise Polydor would take and use the feed I bought for my
horse without my pennission. They were also using m y tack without my pennission.
9.
I certify that the pictures accurately depict the underweight conditions of Solly and
ess
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as well as the conditions they lived in and the untreated open sores that cover their hooves, legs
and facial areas. Additionally, the gelding "Solly" had a discharge from his eye.
10.
I give this aftldavit, consisting of three (3) typed pages freely and voluntarily for use with
knowledge, infonnation and belief.
II.
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filings in court regarding Solly and Ness and swear that it is true and cotTect to the best of my
expressed herein are mine.
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Further, Affiant sai th not.
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While the wording may be that of a lawyer representing Carol Batchelder, the ideas
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Sworn an ubscribed before me
Clay fMarch 2014.
Solly& Ness PayPal
L/11/2014
~oily
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From:
Date
02-06-2014 07:26PM
Date Description Currency
PayPal Transaction -Oct 15,2012 through Jun 15.2013
Status Gross Fee Net
Pagc4
11 /22/2012 Payment Sent: SunDew Stables and Equine USD -741.00 0.00-741.00
Rescue
ID: 85Y74823ST7 16791G
Completed
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11 /22/2012 Charge From Credit Card :Credit Card USD 741.00 0.00 741.00
ID: 4LX715184M728983T
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3/11/2014
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PP Receipt for Solly & Ness's bail out of the kill truck ..... Solly was already on the
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Carol
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Date Type Status Details Amount
Nov 22 , 2012 Payment To LmTaine Smith Completed .. . -$741.00 USD
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Nov 22 , 2012 Charge From Credit Card CompletedYour transfer from your credit card to your Pay Pal account is
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PP Receipt for Solly& Ness's bad out of the I<JII truck ... Solly'Mls already on the truck KellySmth got him off....
3/1112014
Customer Service U RL: http://www .sundcwstablcsandcgui.ncrcscuc
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Amount sent:
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Date:
Nov22,2012
Time:
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Status:
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Subject:
You have sent $741.00 USD to Lorraine Smith with Pay Pal
Note:
Belgian bonded pair.
Funding Type:
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Funding Source:
S741.00 USD- Visa Credit Card
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This transaction will appear on your bill as "PA YPAL *SUNDEWSTABL''.
a.. About Us
b .. Contact Us
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Copyright © 1999-2014 PayPal. All rights reserved .
213
3/11 /2014
PP Receipt for Solly& Ness' s bail out of the kill truck ... .Sollywas already on the truck Kelly Smith got him off....
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Solly& Ness
2/1112014
Solly & Ness
Carol
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300.00 Mike lsajew icz Transport from New Ho lland PA
MD
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PP Receipt for QT with Fellowship farm in MD Melanie was barn manager
Carol
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Transaction Details
Payment Sent (Unique Transaction 10 # I AC67020L25721221)
Nov 23 , 2012 Payment To melan ic ferrio Completed ... -$300 .00 USD
Re lated Transact ion
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PP Recetpt for QT v.~th Fellowship farm in MD Melanie was barn manager
3/1112014'
Nov 23, 2012 Charge From Credit Card ComplctedYour transfer from your credit card to your Pay Pal account is
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Time:
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Status:
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You have sent $300.00 USD to melanie ferrio with Pay Pal
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Run Date: 2/712014
Time: 10:36:49 A
Procedures Performed Listing
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Dale Range: 1111 f20121hru 212112013
Trainer/Farm: Chesapeal<e Vet
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Horse: Ness
Amount Invoice
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Results
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Exam: [email protected], HR@43, RR@12,
discharge @ l nostril, possible tooth roo1
abcess or inf in nasal pasSCJge. OWner
declined bloodworl<. Disp Pen: 25oc, IM,
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Run Date: 21712014
Time: 10:36:20 A
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12/512012 Sully
Invoice
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12/20/2012 Charge From Credit Card: Credit Card USD 575.00 0.00 575.00
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Solly& Ness PP
2/11/2014
Solly & Ness PP
Carol
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02-06-2014 07:42 PM
I / 18/2013 Payment Sent :Sugar! and Stables USD -5 75.00 0.00 -575.00
ID: 12M429761V200571B
Completed
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1/ 18/2013 Charge From Credit Card: Credit Card USD 575.00 0.00 575.00
ID : OCS28204FH114930D
Completed
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Board at Summcrwinds for Solly & Ness
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Solly& Ness PP
2/11/2014
Solly & Ness PP
Ca rol
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2/ 18/2013 Charge From Credit Card :Credit Card USD 575.00 0.00 575.00
10: 8VE443968M 31 0670J
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Board at Summcrwinds for Solly & Ness
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2/ 18/2013 Payment Sent : Sugar land Stables USD -575.00 0.00 -575 .00
10 : 6X6824277A522925K
Completed
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PP Receipt Boarding
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PP Receipt Boarding
Carol
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Payment Sent (Unique Transaction ID # 6X6824277A522925K)
Feb 18,2013 Payment To Sugarland Stables Completed ... -$575.00 USD
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Feb 18, 2013 Charge From Credit Card CompletedYour transfer from your credit card to your Pay Pal account is
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Sugarland Stables (The recipient of this payment is Verified)
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-$575.00 USD
Fcc amount:
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Net amount:
-$575.00 USD
or
Amount sent:
Date:
Feb 18,2013
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Time:
22:26:32 PST
Status:
Comp leted
Subject:
You have sent $575.00 USD to Sugarland Stables with Pay Pal
ote:
Solly & Ness
Funding Type:
Credit Card
Funding Source:
$575.00 USD- MasterCard Credit Card XXXX-XXXX-XXXX-0205
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Payment Sent (Unique Transaction lD # 8AS602413B068292V)
Dec 20. 2012 Payment To Sugrrland Stab les Comp leted ... -$575.00 USD
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Amount sent:
-5575.00 USD
Fee amount:
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Net amount:
-5575.00 USD
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Date:
Dec 20.2012
Time:
08:0 I :42 PST
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Status:
Completed
Subject:
You have sent $575.00 USD to Sugarland Stables with Pay Pal
Note:
Solly & Ness
Funding Type:
Credit Card
Funding Source:
S575.00 USD- Visa Credit Card XXXX-XXXX-XXXX-0 I 05
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Sanctuary Horses
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Ol••et tovaole Q1rlsMavf3 been
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eat sl&ep at~<l do everyth1ng
together 1 LJna dOes. nave COPO
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Hanovenan mare- , 5 yrs old ana
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aoaut '- hanos Owner
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na~
1equestu;J that MJr.ah stay t'l'fre at
trOt"' Ga1t a~ d pan ot our
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people due tc pnor aouse mat
napponed ~ years ago wt~ oe
work1ng N·t'· ~er :3ai!Y to t~y to
hanos- lllly ~~ il very qu1et ana
·cvtng tr are •ovos to be orusneo
ana na,,..::Hoo ano r,er "at~ t'l":Jse
Sne 1s sun gotng ltlrouqh fa mer
treatment fer t1er feet Oue to her on
ano oM
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aga1n Jameres.s
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at Iron ':Ja,t
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approx 1 7 hanos She nas arthnhs
tn her nockS t)Vt tt ts controtled as
long as she 1s Qlven Cortanex H.to
oa1l)' She nas also 1n the past
(prev1ous ownen nao rorc surgery
ana nern1a surgery Ooo to
rnedteal 1ssues sne Will rerru:un here
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at Iron
Perdleron mare
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yrs Old ana approx 18 + nands
~ue to orev1ous owner nav•ng
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11m1<1 sne was 11c
f1nancw1 oroblems dues to rned1cal
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she w•ll rernadl hera as. Iron Ga1t as
a pan. of our Commun,ty so thai
owner r..an
VlSit
Blue anyttrne
currently work1ng
personality & ve"
people & thtngs a
patience & gentle
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p ""'
0rH81l'ltlr · Fn~Stan mar& I 0 vrs
cld aflfJ aop10-.:
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was savea from an auct•on wt1ere
5f'.e was
.rl
a 1(11t pen heaomg tor
Severe quartet r.rack or
Jront toot marks on rorehead !hal
':laked
hk~
2>4 bedhng
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rema~r1 11ere at 1ron Ga1!
ShvAnne- Mustang mare 11 yrs
.')fd ana approx 13 nai"Os Upon
rateo under a 1 Of'l
Body Scare She Wl!l rema1n nere
as our SPQkPS Mare Shy wa-;
rescueo from a e-.:tremeJy neglectful
nome She "las a VER'l' sweet
personal ty k1nd & loveat>le ltttie gtn
wno loves all tne artenltan sne can
get Old c;how horse Oroke to nde
out nas been qune somet~me sJnca
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aga~n
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2/19/2014
Pinterest
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Solly & Ness Tnese two w111 be
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http://www.pinterest.com/search/pins/?q=Sol ly%20and%20ness
2/ 19/201 4
Solly& Ness PP
2/11/2014
Solly & Ness PP
Carol
From:
Priority:
Normal
Date
02-06-2014 07:50 PM
om
To:
2/21 /2013 Payment Sent :James Parlier USD -500.00 -14.80 -514.80
ID: 7W7928006K564951 L
2/21 /2013 Charb'C From Credit Card : Credit Card USD 514.80 0.00 514.80
ID: 6HM4800868037373P
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Completed
Transport from MD toGA Iron Gait for Solly & Ness
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Completed
PLAINTIFF'S
EXHIBIT
-,:
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1/1
Solly& Ness PP
2/1112014
Solly & Ness PP
Carol
From :
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Transport from MD to Tron Gait GA
PR
3/2/2013 Charge From Credit Card : Credit Card USD 514 .80 0.00 514.80
!D: 1U5813960V3812216
Completed
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3/2/2013 Payment Sent :James Parlier USD -500.00 -14.80 -514.80
!D: 7U002321SJII4352S
Completed
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1/1
PP Receipt Transrnt
3/11 /2014
PP Receipt Transport
Carol
From :
Priority:
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Date
03-09-2014 12:24 PM
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To:
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a .. LogOut b .. Help c .. Security and Protectiona .. M y Account
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a .. Overview
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a .. Basic Search
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a .. -a .. -a .. -a .. --
Update
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Transact ion Details
Payment Sent (Unique Transaction lD # 7W7928006K564951 L)
Feb 21 , 2013 Payment For James Parlier Completed ... -$500.00 USD
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Feb 21, 2013 Chrn·ge From Credit Crn·d Comp letcdYour transfer from your credit card to your Pay Pal account is
complete. Your transfer from your credit card to your Pay Pal account is complete. Details ~514.80 USD
.c
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Sent to:
James Prn·lier (The recipient of this payment is Verified)
Email:
Amount sent:
-5500.00 USD
Fee amount:
-514.80 USD
Net amount:
PR
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-5514.80 USD
or
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Date:
Fcb21 , 2013
Time:
06:36:17 PST
Status:
H
Completed
with Pay Pal
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Subject:
You have sent 5500.00 USD to
M
Note:
For Solly & Ness, two Belgians going from MD toGA Thank you .
Funding Type:
Credit Card
Funding Source:
at
e
$514.80 USD- MasterCard Credit Card XXXX-XXXX-XXXX-0205
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3/11/2014
313
3/11/2014
From :
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03 -09-2014 12:20 PM
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To:
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Transaction Details
... -$500.00 USD
or
Mar 2, 20 I 3 Payment For
se
Payment Sent (Unique Transaction lD # 7U002321 SJ I I 4352S)
Related T ransaet ion
Mar 2, 20 I 3 Charge From Credit Card Completed Your transfer from your credit card to your Pay Pal account is
M
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comp !etc. Your transfer from your credit card to your Pay Pal account is complete. Details $514.80 USD
Sent to:
James Parlier (The recipient of this payment is Verified)
e
Email:
R
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Amount sent:
-$500 .00 USD
Fee amount:
-$14.80 USD
Net amount:
-$514.80 USD
1/2
311112014
Date:
Mar2.20l3
Time:
07 : 11:34 PST
Status:
Subject:
You have sent S500.00 USD to
ote:
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Completed
So sorry for the mis-understanding. Thank you so much! 2 Belgians ...
Funding Type:
PR
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Credit Card
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with Pay Pal
Funding Source:
S514 .80 USD- MasterCard Credit Card XXXX-XXXX-XXXX-0205
se
This transaction will appear on your bill as "PA YPAL *JTMMYPARL!E" .
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212
Solly& Ness PP
211.1 /2014
Solly & Ness PP
Carol
From :
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Date
02-06-2014 07:53PM
311 1/2013 Payment Sent: Iron Gait Percherons USD -100.00 0.00-100.00
ID: 34356142U56965733
Completed
PR
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S ize : 570 bytes
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Money to help Iron Gait care for Solly & Ness
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PLAINTIFF'S
~XJPIT
https·flerral 1and1 corni0J611FOTZ1sCj/newlnfoltemHidden.hlrrl#guld= OX.28
PP Receipt IG
3/912!114
PP Receipt IG
From:
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Search Pay Pal Search
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a .. LogOut
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Transact ion Details
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Payment Sent (Unique Transaction lD # 34356142U 56965733)
Email:
M
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help @ igp rescue.org
H
Business Name:
Iron Gait Percherons (The recipient of this payment is Ver ified)
Business Contact Tnfommtion
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Customer Service Emai l:
help @ irongaitperchcrons.com
Amount sent :
-S I 00 .00 USD
Fee amount:
$0 .00 US D
Net amount:
-S I 00.00 USD
1/2
3/9/?i.-14
PP Receipt IG
Date:
Mar I I, 2013
Time:
O
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PR
Subject:
You have sent S I 00.00 USD to Iron Gait Perc herons with Pay Pal
Note:
Hi Denise. This is for Solly & Ness. Please hug them for me. Carol
Funding Type:
Pay Pal Balance
Funding Source:
S I 00.00 USD - Pay Pal Account
.c
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07:31 :54 PDT
Status:
Completed
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212
Solly & Ness PP
3/712014
Solly & Ness PP
Carol
From :
Normal
Date
02-06-2014 07 :47PM
4/ 19/20 13 Pay ment Sent : Iron Gait Percherons USD - 100 .00 0.00 - 100.00
ID :348 84 11 3SR294543H
Completed
help Iron Gait take care of So lly & Ness
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PR
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Priority:
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Content-Type: text /ht ml
Part 2.html
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PLAINTIFF'S
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PPReceH IG
3/912014
PP Receit IG
Carol
From:
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Date
03-09-2014 12:05 PM
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Priority:
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To:
PR
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Transaction Details
Payment Sent (Unique Transaction lD # 34BR4113SR2945438)
se
Business Name:
Iron Gait Perchcrons (The recipient of this payment is Verified)
H
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Email:
help @ igp rcscue.org
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Customer Service Email :
help @ irongait p crcherons .com
Amount sent:
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-S I 00.00 USD
Fcc amount:
SO.OO USD
Net amount:
-S I 00.00 USD
Date:
Apr 19, 2013
112
3/912014
PPReceHIG
Time:
05:38 :00 PDT
Status:
om
Completed
Note:
Good Morning Denise. This is for Solly & Nessie. Thank you.
Funding Type:
Pay Pal Balance
funding Source:
or
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b .. Contact Us
d .. Privacy
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S I 00.00 USD - Pay Pal Account
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You have sent Sl 00.00 USD to Iron Gait Percherons with Pay Pal
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31512014
(80) Iron Gait Percherons- Rescue
Rich ard
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Recent
201 4
2013
2Gl2
Iron Gait Percherons - Rescue
:-1Jl!ow
Message
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Like
- :<: -~ ··, • (108 cafngs)
8,0051ikes · 519 talldng about this· 779 were here
HOW YOU CAN HELP -
http:/fwww. gorescue. org/dcnat·c's
Ukes
Evencs
\'deus
Post
Photo
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Photos
PR
D s,oos DD-2
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Invite Your Friends to Uke This Page
Type a friend's narre ..
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.~ron Gait Percherons - Rescue was w~h Belinda !3o Couch
and 49 ccherso
16 hours ago
Friend s
Uke Iron Gatt Percherons- Rescue
See A!l
0
ottoni Ferreira Filho
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Dianna Burnett
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Mark Pagliai
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Chat
See All
Reviews
U)
i&.tu.-m
1--
"!eagan Com is key
·>r 1¥ w )< Absolutely Wonderful! Arrezing People, Arrez ing
Horses, Arrezing Rescue! So Thankful to be a part of the Iron Ga~
Farrily .... See More
Uke
~
2 ° about 9 months ago
*
0
Donna W S.,;,zley
Iron Gatt Percherons Equine Rescue in Waleska Ga .. It was f ounded
by Denise Polydor, who has spent her l~e lovrng & sav .. o See More
Like
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1 · over a year ago ·
https:/fw.Nwofacebook.comllronGaitPercherons
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3/5/2014
(80) Iron Gait Percherons - Rescue
DlOM GAIT PERCHEROMS • Dn1t Hone a-a.
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Hanna h Tidwell
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I have 2 special horses from Iron Gait that are very dear to
rre now. I am working with JT¥ paint rrere Jasrrine she is j ust turning 3 and
win be ridlnq soon. and l have Sonny a twh gelding, that i traHride.
Uke
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2 · about 11 months ago ·
J'.....ttq - DrattR-IUdH - - u - Madc:
Come lour the farm & meet all th e HcsCIIL'' llnrscs
Recent Posts by Others on Iron Gait Percherons - Rescue
Clair e Zerefo5 Calderone
om
Ka t ie Courtney
Denise is a rregnificent hurren being. The world is a better place
because she is here.
Uke
4
2 · over a year ago ·
See Ail
Sue Crane
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https://www.etsy .corrVshop/Puzzimals?ref=si_shop Cute ...
10 · March 1 at 7: 52pm
When are you expecting the baby to arrive?
1 · February 24 at !2:55pm
S ··,
Amanda Quesnelle
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lln\'r you r phntn tu l.:t·n wd tll y our frn•ont ~ Km11h1 m ,.hirlltrfl ..f rnmr 1)
Happy birthday' !! ' !!
Draft Horse of a Diffenmt Color,Rare Breeds and Crosses
we are looking for draft foal photos! :) Contest with a priz...
i ·February 20 at 2:00pm
We look Eorwa.rd to meeting YoU !
Belinda 9o Couch and 4" others flke t his.
l have been doing f eral cat rescue for 20 yrs. There are ...
1 D 3 · February 18 at 9:22pm
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Selinda Bo Couch This rre kes rre HAPPYYYYYY!! !
Uke · Rep~ ·
2 · 15 hours ago
I.Jke · Rep~ · 13 hours ago
Iron Gait Percherons ·Rescue Yes it is
Uke · 6 hours ago
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VIew 3
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Kristi Roberts on·Louzader Corey Corriskey, is this the barn
y 'all volunteer at?
se
More Posts
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l<im N3sh
15
Uke · Corrrrent · Share
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15 hours ago
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Michelle Smith Allred - CONGRATUlATIONS!!!
you are our ** 8000* * like ...
Please private message me what size Tshirt you wear , Choice of color (Teai,Purple,Biack or Blue) along with your address ...
I will gladly send you a little care package personally from Iron Gait Percherons
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38 peop:e like t his.
Pa mela Schuck Me? I never win anything.
Uke · Rep~ ·
1 · 15 hours ago
Cheryl Bor os You won! Yahoo!
Uke · R~p~ · 8 hours ago
Irnn Gait Percherons ·Rescue
Yesterday
I would like to thank Allison and Family for coming by for a visit on Sunday and offering to volunteer to help the horses
https://www.facebookcom/lronGaitPercherons
Top Corrrrents
31512014
It was nice meeting you and hope to see you again soon .. .
l ;'<e · Com-ent · s~are
16 peooie ftke this.
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March 3
Show Practice and Class 3.2.14 at Iron Gait .. (35 photos)
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( Photo's by B"''e "!,t(heii)
Thank you 8ntta.oy ::dgertor for taking the t ime to teach our IGP team for this earring years shows. Everyone has done such a great job in practice. I am proud of
everyone.
On our team you will be seeing some new faces this year. We have a very confident team and I feel t hey will do a wonderful job representing Iron Ga~. They are aH
volunteers and WTII gladly answer any questions about our rescue while we are at the show
Ui<e · Corrrnent · 5ha;e
Selinda 8o Couch, Steele Ranch and 110 others like this.
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Bill Byrd Looks like they
Uke · Reply ·
don~
neck rein.
I · March 3 at ll:08pm
Iron Gait Percherons - Rescue it is very rare to find a draft that win neck rein. They are mainly trained for pulting, not riding
U!<e ·
.:
1 · Yesterday at 2: Bam
Iron Gait Percherons- Rescue As for the helmet comments, Thank You for your opinions.
Most of these riders are of 18 yrs. or older are experienced riders & make that option for them se~ .
Those who are not 18 yrs old, their parents were here watching .... ;;ee More
Lke · Rcp:Y ·
] · Yesterday at 2:OOpm
https ://wMN.facebook. com'lronGaitPercherons
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3/5/2014
~ron Gait Percht!rons- Rescue shared Hibiscus Moon's p~oto.
1
March 3
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LOVE This!
Uke · Co~nt · Share
Trlsh A H Johnstone Susan Louyh')l
I.Jke · Reply ·
1 · March 3 at 8:24pm
March 1
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Hope everyone Had a great day today.
We did
Maria helped get the Main Barn clean, Myself and Britteny got
Arena stalls clean as well
Eric, Myself & Britteny Got alot of the trees & brush cleaned up
where Lena and Luna's new barn will go. Still more to do but we
put a dent in it. I am so excited to get it built and put up their
fencing. This way they will have their own little private area (the
way like & they want) and will be out of my aisleway... Lol
Uke · Lo:rrr.ent · Share
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36
peo~!e
like this.
Ukes
See !\U
~ Dana Fowle FOX 5
M
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Sherie Soule Wright Love!
llke · Reply· March 3 at 8:13pm
TopCo~nts
or
Steele Ranch and JOO o;hers like this.
~Journalist
Uke
~ Animal Recove ry Mission
3 friends also ijke this.
Like
F-J
~ ., Hot se Welfare Organizations
5 fnenos also like this.
f'll'll
1111f111
r-btional Rifle Association
272 henos also like this.
(
ASPCA
50 friends also Uke this.
)
llke
iJke
Top Co:r'rT'Cnts
,•
camlyn Contreras So happy for Lena and Luna,they w~l be
Queens of their own "Castle" . They certainly deserve it. Love you
Iron Gait Percherons- Rescue shared Funny Horse
Cartoons's photo.
February 27
both
I.Jke · Reply ·
1 · March 2 at 9:05am
Todays Funny
Lynda King Dear Lena and Luna, just love them. Soul mates!
Uke · Rcp;y ·
1 · March 1 at 8:35pm
https://wNN.facebook.com'lronGai tPercherons
rm not suggesting big horses are stupid, just that ponies are
the ones who have figured us out! - with Equus Equita7iore
~la~sica and ;.1 :}thers.
.A/1'1
31512014
Iton
Ga it Percherons- Resc ue shared
' Rcc~ers
/ Have you eve
thought hultlaHs
111ight be sll!all
In Recovery '"s photo.
- - ,-
'-..ANP fragile
February 26
-i'o~'t be rldicul~ust
They would"'t boss
, us arou"d If that .
'-~s the ease!V
--7/
.
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Here a little laugh for you today ... Lol
Can you imagine seeing this as you drive down the road ... hahaha
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Humor For The Day- with Shannon Brogan and 5 others .
Lke · Corrrrent ·
Sh3 ~ :=
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139 peoole like this.
Ros e Anderson-Bliss cute ... but time to re-think this .. . il l most
intelligent breed of horse=Arabian ... # 2 =Clydesdale .. so
sorry ... lol
or
Like · Reoly · Febnuary 28 at 4:16pm
Uke · Corrrrent · Snare
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Top Comrenls
Shalla Walke r -St ewart For me I would be sitting on my horse : )
Iron Ga it Percherons - Rescue shared Gena Arrington
Oddo's v;deo.
Febnuary 24
3 · February 26 at 7:53pm
M
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i..Jke · Re ply ·
Pa t Ho od Loll Great one!
· f!epiy ·
Like· Reply · Febnuary 28 at 11 :28am
View 3 more ccrlYn'!nts
106 people like this.
Uk~
Jennifer Thompson Lol
Hahahaha ... The Perchy gas strikes again .... .hahahaha
View 5 rrore corrrrents
Okay... I'm sorry... but I can't resist posting this one ... I am
laughing so hard right now. LOLOLOL
• Iron Gdit Percherons - nescue
e
February 24
at
Junior's fir st day off of stall rest besides being in the
arena. (12 photos)
The vet told us at his last vist, to let him out for a wh ile each day as long as
the ground is dry so that he can get some exercise.
As you can see he qutte enjoyed being able to stretch his legs & he is feeling a
R
bt better now
Uk.e · Comrent · St'lare
Top Corrrrents
Billie M1tchell lol athos always does t when I groom his tail.. but
also does it when hes walking . . so yea he does t aH the time !
https:/twww.facebookcomllronGaitPercherons
5112
31512014
(80) Iron Gait Percherons • Rescue
Like · Rep!y ·
. . . Shirley Harvey I showed this to John and he is still laughing.
Like · Replv ·
! ·February 24 at !0:12pm
VIew 7 rrore corrMents
A walk around the farm 2.24.14 (19 photos)
a few of our (Muddy) horses as I walked around today
Lke · Co!'TY""'er:t · Si"'are
Top Co::verts
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260 "eo1 1e like this.
aaudia Oliver Did the ground shake ..
Re?y ·
Iro;, Gait Perc:,erons • Rescue lol yes you can
feel the thunder as he runs by ... Lol
def1n~ely
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Li<e ·
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Betty Jones Is he a percheron?
· ' ...ke · ReJov ·
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Iron Gait Percherons • Rescue
February 24
Iron Gait Pe rcherons • Rescue Yes
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Uke · February 24 at 5:59pm
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Bill Chicano Would love to spend a day around all those beautiful
horses
Ui<e · Rep,y ·
Valkin Bouviers I thought we had to wa~ for the open house.
We would love to VIS~
Uke · Rep.y ·
I · February 24 at 8:50pm
Iron Gait Percherons • Rescue No you dont have to
anyone can make an appointrrent to vis~ anytirre.
Might be warn-er t hough and a little less muddy ... Lol
But, you are welcorre anytirre
wa~,
Like · February 25 at 8:49am
'v1ew 5 rrore convrents
Iron Galt Percherons • Res cue
February 23
https://vww.facebookcOI"TVIronGaitPercherons
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Silver has been Officially Adopted today.
Congratula-tions Miikalah on your new baby girl
5
se
i.Jke · Colll'rent · Share
329 peoo!e like this.
i.Jke ·Reply·
Julie Pavlovec Beautiful
i.Jke · Reply·
i · February 23 at 2:05pm
;:o~nts
Iron Gait Percherons- Rescue
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February 22
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Patricia Dupaln They rmke a beautiful picture'
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Beautiful warm sunny day here today at the Rescue.
Wishing everyone a wonderful weekend .. .. Enjoy!
Uke · ComTent · Snare
Belinda 8o Couch and 112 others like t his.
https:/fw.N.N.facebookcom'lronGaitPercherons
Top Ccrr'f'rents
Too Con-rreots
3/5/2014
Kristiana Von Lange All the snow is gone! It's all gone over here
in Kar.sas as well.
Like · Reply · February 22 at 5:46pm
Iron Gait Per cherons- Rescue It was actually gone 2
days after the big storm . Lol
Like · February 22 at 7:46pm
Brend a Hill Very nice. It would be even better in person.
ira~ Ga~
V~ew
5 n-ore
Percherons- ResCLe repi"ed · 2 Reo!:es
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Llke · Reply ·
comre~ts
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February 21
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* * Teddy -has SEVERE Ringbone and joint fusion going on in both front pasterns which is causing him serious lameness. There are several
options we have that I will post later. Right now we had gotten him injections to help him with his pain until a decision is made on what road
we take. His trip today was $850. and he has many months and trips to UGA yet to go to help his bones fuse faster in his recovery. I will
update after I hear back from our surgeon at UGA.
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** Junior -has ... See More
Like · Conrrent · Share
Top Corrrrencs
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22 people nke this.
14
Sue Crane Do you have aU your horses listed somewhere to choose f rom to sponsor?
Uke · Reply · February 22 at 5:45pm
Iron Gait Per cherons - Rescue Im sorry no I do not, I do have to rreke a page for that yet. Just been busy
Lil<e · February 26 at 3:07pm
e
' Sue Crane Jufie Paine- what happened to Chevy in Florida? So glad he's safe now. And you can vis~ him anytime!
... Like ·
Rep~/
· February 22 at 5:47pm
at
\fiew 7 mlie corrrrents
February 20
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Finally 2 out of 3 on our way back to the farm from UGA. What a
tiring day it has been ... and it aint over yet
Spending my birthday helping the horses
wouldn't have it any
other way! (18 photos)
https://www.facebookcom'lronGaitPercherons
February 20
Trying to get under way to UGA. Had a slight problem with trailer
wires. Stuck at NAPA in Jasper.
Also Cynamon is also coming for tue ride to see if they can help
her. (5 photos)
8/12
3/512014
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Lke · Corrrrent · srare
Top Corrrrents
Belinda Bo Couch and 53 others like this.
,'
oa...., Spalding Happy birthday .. and who is the shorter
grey .. pretty
Uke · Reply ·
Ma ry Jo Willis Beauties!!
L:ke · Reply ·
1 · February 20 at 11: 18pm
Ala n Page Good luck safe tralves
.,_
Iron Gait Percherons - Rescue YaY.. . FinaOy home
Thank you everyone for the birthday wishes
Hugs t o you all ...
I.Jke · Reoiy ·
Like · Reply ·
1 · February 20 at 1: 13prn
View 2 rrore ccf'!"T""ents
1 · February 20 at 11 : 57prn
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rrc'1 Gait Oercr-erons- RescLe repi:ed . 2 Rep!ies
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Bewnda Bo Couch and 148 others like this.
February 19 · Edted
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Tomorrow Februaury 20th; I will be spending my entire Birthday helping Teddy and Junior make their trip to UGA..
Cant get a better present than helping these 2 wonderful boys
Teddy will be getting evaluated and we will find out what treatment he will be getting.
Junior is going for his monthly shoe adjustment.
If you would like to help with the Hospital Costs it would be greatly appreciated.
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You can help by Paypal:
[email protected]
Or Mail:
Iron Gait Percherons, Inc .... See More
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Billie Mitchell Lynda king this is what i found out in your area . . the she~er there has a hurrane society
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Like· Reply ·
1 · February 19 at !1 :18am
Lynne Maggard Post a pic of teddy at th e vets
I.Jke · Reply ·
\ftew 4 iTore
1 ·February 19 at !0:56am
corrrrl::!n~s
Iron Gait Per cheron s- Rescue shared K!rn N~sh's ohoto.
February 18
Anyone need a good barn kitty(s)? all shots and already fixed
~ttps :/Jwww.facebookcom'lronGaitPercherons
Top Corrrnents
3/5/2014
Uke ·
C orrren~.
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I have been doing feral cat rescue for 20 yrs. There are many ferals I'm trapping who need to be relocated. They earn their keep keeping
mice away from your feed ! I will have them spayed/neutered, and will provide guidance on helping them adjust, and on their care. Adopt
one or several. I am looking for those willing to provide food and clean water daily AND a warm shelter out of the ra in when necessary.
Please pm me. And thank you, Denise, for all your hard work and for letting me post here!
· Snare
I r on Gait Pe rc heron,; • Rescue Please contact Kim Nash. Thank you
Uke · Reply · February 19 at 1:42pm
Mechele Pruit t
Uke · Reoiy ·
r sent you a pm @ Kim Nash.
l · February 19 at 6: 17pm
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Iron Gait Perc herons- Rescue
February 17 · Edited
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FYIFor those of you passing this around thinking that you are helping.
This is a false report ..
This company is changing management and are looking for good homes only for these horses. They are NO WAY going to kill their horses ...
Thank you
Gary Schwalm is the Manager who is selling his horses and is looking for good homes. 1-717-647-9342 is the phone number he is giving out
for interested people to call.
https:/fw.Nw.facebookcom'lronGaitPercherons
3/5/201 4
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Resort
CLQSING
Horses need homes or
else they will be !mlt!lan!Z~~
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For more information
call570·384-4899
Or Chris 570-956·•1"248
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Uke · Ccrrrrent · Share
I
:
webs~e?
Erin I ng le Are there adoption fees? Or pictures on a
Uke · Reply · February 18 at !2:17am
Iron Gait Percherons- Rescue rep!;ed · 2 Replie s
or
o.;:_
40
Top
Corrrre~ts
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Iron Gait Perchero ns- Rescue Gary Schwalm is the Manager who is selling his horses and is looking for good homes. 1-717-647-9342 is the phone nurrber
, ._,... he is giving out for interest ed people to call.
Uke · Reply ·
co~nts
Iron Gait Percherons • Rescue
M
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February 17
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View 9 rrore
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Look how sweet this little guy is. I found him in a corner on my
deck this morning. Never seen a furry bat before.
I wrapped him in a towel and hid him from the cats until he
wakes up tonight
(5 photos)
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137 peop!e like this.
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J am ie Ayres· Gazzana He's adorable. I wonder if he fell out of
your roof/ eaves? Seems they rmve around quite a bit during
hibernation to keep their terJll steady. Hope he does well tonight' Gad
I'm not t he only one t hat saves th em!
Uke · Reply·
·-
!ron Gatt Percherons- Rescue rer;!icd · 2 Repries
.
1ttps://vwwv.facebook.corn/lronGaitPercherons
315/2014
Ircn GJ'it Percherons • Rescue This is our bat defin~ely ... . I think~
rright be a young one .. ! have him safely in a little cave that I made out of
a towel. When I put him in there he looked at me like thank you and crawled
up to roost. .. ! have him in a safe spot away from animals ... See ·'1o•e
Species Profiles
www.batcon.org
Bat images,Portra~,bats,bat, bat research,
conservation
Uke · Reply ·
6 · February 18 at 11 :57am
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View 28 rrore corrrrents
Create Ad
Create Page
Developers
Careers
Pnvacy
Terrrs
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Facebook © 2014 · Eng!ish (US)
Cook.es
1ttps://wMN.facebook.com'lronGaitPercherons
Help
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About
3/512014
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2014· Year of the Horse ·
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IGP is a registered chanty
with eBay Giving Works.
List us as one of your favorite
causes and you can donate
a percent of sales to IGP or
make a donation directly
Thank you so much for your
continued support!
A Year Full of True Spirit, Grit,
Determination, Vitality and
Endurance•
• And that's what IGP is ALL
about•
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) Giving Works
•Rescue the Week and Needy;
Deliver them from the hand of the
wicked•
Psalm 82.4
http:/NN.w.i g prescue.org /
•*•*•*•*•*•*•
1/11
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8,005 people like
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9 Feb
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CONTACT INFO.
email : [email protected]
Phone: (770) 796·2598
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•20141ron Gait T·Shirts now available•
http://vvwN.ig prescue.org I
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3/5/2014
Please help provide shelter
for the rescue horses
http://WvWJ.igprescue.org/
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Some of our rescued horses have emotional issues with
being placed in a stall.
We have already bought and put one of these buildings
up
as a run in shelter for the outside horses in one of their
pastures.
*With helping more horses now, We are asking for your
help
to be able to provide adequate shelter in another
pasture for horses with stall issues.
*With this shelter it will help keep them out of the
weather and provide shade in the summer.
*The more shelters we can provide the more horses we
can help.
To help please PayPaiEmail: [email protected]
Mail a check:
Iron Gait Percherons, Inc.
114 Hancock Mountain Trail
Waleska, Ga. 30183
For any questions or Concerns please Phone:
(770)796-2598
Thank you again :)
Team IGPR
H
.Join us
Helping to educate the future
generation
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the need for rescuing horses
the love we need to share with our equine
friends!
http://I.'MW.i g prescue.org/
Iron Gaits'
Children's Summer D
Camp
Iron Gait Percher on Rescue
3/5/2014
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Please email/ call now to enroll your child
Limited spaces
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Camp weeks:
CONTACT INFO.
email : [email protected]
Phone: {770) 796·2598
SEVA- YOGA TEAMS UP Wl1ll
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IRON GAIT PERCHERONS RESCUE
TOBRJNG YOU
YOU. YOGA AND A HORSE!! !!!
It's trmc for SOfT't"'thmg Nf:rA1 Jnd REFHESH/NG.J H Okay) NOW tf;; YOGA
or
for Horsa-lovers . everyon~ t$ !nvited ro tfldulge $arni )itck.son, certifted
yoga tnstructor and owne; ot Sev.l·Yog.l 1n Ball Ground, GA IS bringing You,
Yogd & .4 rlorse to Iron Gait Percluuons Rescue in Waleska, GA . Ht!i;;
u~ !1~/o the ilor~s .uw this <~m<~Liny orgJfJIU tion t hdt goes thdi extrfl mlf~:tl
horse expen'~::nce nec~st;.Jry! So if you wa nt to laugh, get .'1~.:Jithy msnt;,~l!y
.M d physJcafty dr:d br- in ~he company of somP of tht> coolttr:.t sp1nts 0'1' the
pl;met.. you h.:~ve to show up and get all tile deliJil'i 1
Be sure to reserve your mat and
horse today! Classes are held on
the 2ND & 4TH Sundays of the
month from lOam to 12pm. For
more class info please visit:
www.seva-yoga.com
Or contact [email protected]
Call or text 916-214-6535
!rJtf'od~K"tory
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::,pea<el: 8rmg
rnm1d and for., $40 cWn.,Uon yCJu
both c:un enjoy two "ours of horsing
Mound Jtnd g.etttng he11lt:h)'!
{Single f''ke $30.)
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We will be stretch ing O!Jt the m;rts domg yogiJ and workmg ar. bre.1th1ng
rcchniquef:\ Cdlmmg onc~;elf calming one·s horse; t~tk i ng thiJt centered
energy Jnd workmg with hcrses ( "'·'~ ·' ltmg, groommg, stretching) . tiJo yoga or
http:/ivMw.ig prescue.org I
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SHERIFF'S ENT Y OF SERVICE
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Name and Address of Party to be Served.
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Date Filed
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SHERIFF'S ENTRY OF SERVICE
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I have this day served the defendant - - - - - - - - - - - - - - - - - - - - - - - - - - - p e r s o n a l l y with a copy of
the within action and summons.
I have this day served the defendant _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ by leaving a
copy of the action and summons at his most notorious place of abode in this County.
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Delivered same into hands of - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - d e s c ribed as follows:
age, about _ _ _ _ years; weight ____ pounds; height, about _ _ _ _ feet and _ _ _ _ inches, domiciled at the residence of
or
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defendant.
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Served the defendant _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ a corporation
by leaving a copy of the within action and sununons with _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
c.:
in charge of the office and place of doing business of said Corporation in this County.
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I have this day served the above styled affidavit and summons on the defendant(s) by posting a copy of the same to the door of the
premises designated in said affidavit, and on the same day of such posting by depositing a true copy of same in the United States Mail,
First Class in an envelope properly addressed to the defendant(s) at the address shown in said summons, with adequate postage affixed
thereon containing notice to the defendant(s) to answer said summons at the place stated in the summons.
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Diligent search made and defendant
not to be found in the jurisdiction of this Court.
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This ____ day of _ _ _ _ _ _ _ _ , 20 _ _ __
DEPUTY
SHERIFF DOCKET _ _ _ _ PAGE _ _ __
WHITE-CLER K
CANARY- PLAINTIFF
PI NK-DEFENDANT
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SC-85-2
SHERIFF'S ENT.RY OF SERVICE
Superior Court
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Juvenile Court
Civil Action N o . - - - - - - - - - - - - - - -
DateFiled·3:S-·~~ -~
Magistrate Court
Probate Court
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Name and Address of Party to be Served.
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the within action and summons .
I have this day served the defendant _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ by leaving a
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Delivered same into hands of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ described as follows:
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age, about _ _ _ _ years; weight _ _ _ pounds; height, about _ _ _ _ feet and _ _ _ _ inches, domiciled at the residence of
defendant.
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Served the defendant _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ a corporation
by leaving a copy of the within action and summons with _ _ __ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
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I have this day served the above styled affidavit and summons on the defendant(s) by posting a copy of the same to the door of the
premises designated in said affidavit, and on the same day of such posting by depositing a true copy of same in the United States Mail,
First Class in an envelope properly addressed to the defendant(s) at the address shown in said summons. with adequate postage affixed
at
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This _ _ _ dayof _ _ _ _ _ _ _ _ ,20 _ _ __
DEPUTY
WHITE-CLERK
CANARY-PLAINTIFF
PINK-DEFENDANT
SC-85-2
Superior Court
State Court
Juvenile Court
Civil Action N o . - - - - - - - - - - - - - - - Date Filed~"\.'C)-~
Magistrate Court
Probate Court
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the within action and summons.
I have this day served the defendant _ _ _ _,--_ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ by leaving a
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Delivered same into hands of - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - d e s c r i b e d as follows:
age, about _ _ _ _ years; weight _ _ _ pounds; height, about _ _ _ _ feet and _ _ _ _ inches, domiciled at the residence of
or
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defendant.
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Served the defendant _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ a corporation
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by leaving a copy of the within action and summons with _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
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I have this day served the above styled affidavit and summons on the defendant(s ) by posting a copy of the same to the door of the
premises designated in said affidavit, and on the same day of such posting by depositing a true copy of same in the United States Mail ,
First Class in an envelope properly addressed to the defendant(s) at the address shown in said summons, with adequate postage affixed
at
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This ____ day of _ _ _ _ _ _ _ _ , 20 _ _ __
DEPUTY
WHITE-CLERK
CANARY·PLAINTIFF
PINK-DEFE NDANT

View Complaint and Exhibits

Transcription

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