TO PLAINTIFF'S ATTORNEY: PLEASE CIRCLE TYPE OF ACTION INVOLVED: TORT- MOTOR VEHICLE TORT - CONTRACT - EQUITABLE RELIEF - OTHER, COMMONWEALTH OF MASSACHUSETTS HAMPDEN, ss SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT CIVEL ACTION NO. ase € lay Church of bod w dhrash Tac. ony, iE loprtant “pein 4 Ne Tenn otler fave b mon 8 “a "___, PLAINTIFF(S) Thai Hosprtal by LLG, Fantson tafe l danagemert luc, Hehe to)» Dilig Mie| __—_, DEFENDANT(S) SUMMONS ‘To the above named defendant: You aré hereby summoned and required to serve upon _ plaintiff's attorney, whose address is 1343. Mar Sweet an answer to the complaint which is herewith served upon é ‘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. You are also required to file your answer to the comiplaint in the office of the Clerk of this court at Springfield either before service upon the plaintiffs attorney or wit reasonable time thereafter. ML BUULL WW atiomes use wunpiuitty Lu se JU Unless otherwise provided by rule 13(a), your answer must stateas a counterclaim any claim which you may have against the plaintiff which arises out of the transaction or occurrerice thatis the subject matter of the plaintiff's claim or you will thereafter be barred from making such claim in any other action, Witness, Judith Fabricant, Esq,, at Springfield the Payot Suke _ in the year of our Lord two thousand seventeen. BL” Ca. Gee jy 4 Of i CB Laura S. Gentile, Esquire ‘B, CLERK OF COURTS a Wd NOTES: 1. This summons is issued pursuant to Rule 4 of the Massachusetts Rules of Civil Procedure 2. When more than one defendant is involved, the names ofall sucl defendants should appear in the caption. Tf separate sunumons is used for each defendant, each should be addressed tothe particular defendant 1U DEEISNDAN 1 — rou nes FORM No. | & 3 3 3 ig 3 £ co a g 3 q 5 3 Z g £ S s g 4 g : 8 q g a # : 5 z § y & > & 3 zCOMMONWEALTH OF MASSACHUSETTS HAMPDEN, SS SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT NO.: PRAISE AND GLORY CHURCH OF GOD IN CHRIST, INC., EPIPHANY DEVELOPMENT CORPORATION, TIMOTHY PAUL BAYMON, Plaintiffs, v. VERIFIED COMPLAINT JHANVI HOSPITALITY, LLC, JAMSAN HOTEL MANAGEMENT, INC., ASHOK PATEL, DILIP PATEL, Defendants. INTRODUCTION This is an action for specific performance of an option to purchase real estate, breach of contract claim, fraud, misrepresentation, bad faith dealing, as well as other equity claims. It is based on the conveyance, development, and subsequent anticipated re-purchase of a real estate parcel located in Springfield, Massachusetts. The Plaintiff Praise and Glory Church of God in Christ, Inc. ("Praise & Glory’) owned the real property located at 143- 147 State Street, Springfield, Massachusetts. In 2006-2007 Praise and Glory sought a developer to carry out the conversion of the property into a hotel, ultimately reaching agreement withthe defendants. Praise and Glory entered into a real estate purchase and sale agreement with defendant Jamsan Hospitality, Inc. (“Jamsan"), one of plaintiffs' several entities. However after extensive negotiations, the parties agreed to create a new entity and thus Jhanvi Hospitality, LLC (“Jhanvi”) was organized on September 4, 2007. Praise and Glory then conveyed the property to Jhanvi Hospitality, LLC on or about September 26 2007. Simultaneously with the conveyance, Praise and Glory and Jhanvi entered into an option agreement granting Praise and Glory the right to repurchase the said real property from Jhanvi once the work had been completed and the hotel was operational. (See Exhibit “A” attached hereto.) The option agreement was entered into by these two parties on September 25, 2007, the same day the deed was executed. The purpose and agreement behind these transactions was for Jhanvi to develop the real property into a hotel, and convey it back to Praise & Glory. An agreed upon price was included in the option agreement, and plaintiff Praise and Glory paid a Fifty Thousand ($50,000.00) Dollar deposit to defendant Jamsan Under the initial option agreement, Praise and Glory would retain the management rights to the hotel once re-purchased by Praise and Glory. However, after subsequent negotiations, the management rights were ceded to Jhanvi, which is reflected in the latest option agreement executed by the parties. Theagreement also granted Praise and Glory the right to enter into @ long-term lease for a parking lot parcel nearby which is part of the property at issue here. Because the defendants have delayed considerably in the development of the property, the option agreement has been extended several times by mutual agreement of the parties. The last option agreement was executed on March 5, 2013 and expired on March 5, 2016. As a result of the various agreements, Plaintiffs Epiphany Development Corporation, Inc. (“Epiphany”) and Timothy Paul Baymon (“Baymon”) fronted large amounts of money towards the development of the property. This was done at the request of defendants Ashok Patel and Dilip Patel (“The Patels”). During the rehabilitation of the property the defendants failed to pay numerous obligations including contract work, taxes, Business Improvement District fees, and other large expenses. Plaintiffs had to intervene and pay for these obligations on behalf of the Defendants, and negotiate collection of unpaid invoices and utilities. Prior to the expiration of the option, the Plaintiff Praise & Glory gave timely and proper notice to the Defendant Jhanvi that Praise & Glory was ready, willing and able to exercise the option to purchase. Defendant Jhanvi has refused and continues to refuse to sell the property to the Plaintiff under the terms agreed upon in the option agreement.VENUE Venue is proper under M.G.L. c. 254, § 5, as the real Property subject of this action is located at 143-147 state Street, Springfield, Hampden County, Massachusetts, and presently owned by Defendant Jhanvi Hospitality, Inc. PARTIES The Plaintiff, Praise and Glory Church of God in Christ, Inc., is a Massachusetts non-profit corporation with a principal place of business at 205 Eastern Avenue, Springfield, Hampden County, Massachusetts. The Plaintiff, Epiphany Development Corporation, is a Massachusetts non-profit corporation with a principal place of business at 145 State Street, Springfield, Hampden County, Massachusetts. The Plaintiff Timothy Paul Baymon is an individual residing at 57 Thompson Street, Springfield, Hampden County, Massachusetts. The Defendant Jhanvi Hospitality, LLC is a Massachusetts limited liability company, with a principal place of business at 440 Bedford Street, Lexington, Middlesex County, Massachusetts. The Defendant, Jamsan Hotel Management, Inc. is a Massachusetts corporation, with a principal place of10. ql. business at 440 Bedford Street, Lexington, Middlesex County, Massachusetts. The Defendant Ashok Patel is an individual residing at 44 Eddy Street, Waltham, Middlesex County, Massachusetts. The Defendant Dilip Patel is an individual residing at 44 Eddy Street, Waltham, Middlesex County, Massachusetts. STATEMENT OF FACTS The plaintiffs restate and reaver the allegations contained in paragraphs 1 through 7 of the complaint. On or around March 5, 2013, the parties Praise & Glory and Jhanvi entered into a written option agreement for the purchase of real estate property located at 143-147 State Street, Springfield, Massachusetts. By the terms of the agreement, the plaintiff Praise and Glory acquired a three-year option to purchase the real property located at 143-147 State Street, Springfield, Massachusetts, said option having expired on March 5, 2016. By the terms of the agreement, in order for the plaintiff Praise and Glory to exercise its option, it was required to give notice to the Defendant Jhanvi, prior to March 5, 2016, of its intention to exercise the option to purchase the said real property located at 143-147 State Street, Springfield, Massachusetts.12. 13. 14, 1s. 16. By the terms of the agreement, the plaintiff Praise and Glory was entitled to schedule a closing date within one hundred and twenty (120) days from March 5, 2016. In addition, the agreement provided that if plaintiff Praise and Glory was not able to close the transaction within the 120-day closing period, plaintiff had an additional 30 days to do so. On March 3, 2016, the plaintiff Praise and Glory gave written notice to the defendant Jhanvi that plaintiff wished to exercise the option and purchase the said property located at 143-147 State Street, Springfield, Massachusetts. On June 7, 2016, the Plaintiff Praise and Glory gave a second notice to the Defendant Jhanvi that plaintiff was ready, willing and able to exercise the option and proceed to closing. On June 30, 2016, the Plaintiff Praise and Glory gave a third notice to the Defendant Jhanvi that Plaintiff was ready, willing and able to exercise the option and proceed to closing. Defendant Jhanvi has refused to honor or even answer the notice of exercise of the option agreement by Plaintiff Praise and Glory.17. 18. 19. 20. 21. 22. STATEMENT OF CLAIMS couNT I BREACH OF CONTRACT The plaintiffs restate and reaver the allegations contained in paragraphs 1 through 16 of the complaint. On or about March 5, 2013, the parties Praise and Glory and Jhanvi entered into a certain contract granting the Plaintiff Praise and Glory the option to purchase the real estate located at 143-147 State Street, Springfield, Massachusetts at any time prior to March 5, 2016. In and by the contract, the plaintiff Praise and Glory was entitled to exercise said option at any time prior to March 5, 2016. The plaintiff Praise and Glory gave proper and timely notice of its intention to exercise the option to the Defendant Jhanvi on or about March 3, 2016. The plaintiff Praise and Glory was ready, willing and able and did in fact perform its obligations under the contract by providing proper and timely written notice to the defendant Jhanvi of plaintiff's intention to exercise the option to purchase real estate. On or about March 6, 2016, and continuing thereafter, the defendant Jhanvi breached said contracts by refusing to sell the real property subject thereof to Plaintiffs. 723. The defendant Jhanvi has failed and refused to remedy the breach of contract, as a result thereof the Plaintiffs have incurred substantial financial damages. WHEREFORE, the Plaintiffs demand judgment, with costs, against the defendants. 24. 25. 26. 21. COUNT IT SPECIFIC PERFORMANCE The Plaintiffs restate and reaver the allegations contained in paragraphs 1 through 23 of the complaint. At the time plaintiff Praise and Glory and defendant Jhanvi entered into the agreement referred to in Paragraph 9 herein above, the consideration Plaintiff was to pay under the agreement was adequate and the agreement is just and reasonable as to defendants, as the agreed sales price reflected at the time the agreement was entered into, is the fair market value for the property. Within the time prescribed by the agreement, plaintiff Praise and Glory has offered to pay the full consideration called for in the agreement and continues to be ready, willing, and able to pay the consideration to Defendant. Plaintiff Praise and Glory has demanded that defendant Jhanvi convey the property described herein above, under the terms of the agreement described in Paragraph 6 through 9 of the complaint herein,28. 29. 30. 31. Defendant Jhanvi has refused and continues to refuse to convey to Plaintiff the property described in Paragraph 9 herein above, as required by the terms of the Agreement described therein. Plaintiff Praise and Glory has no adequate remedy at law to enforce the provisions of the agreement described in said Paragraph 9 other than specific enforcement of the agreement. Plaintiff Praise and Glory is entitled to specific performance of the terms, conditions, and provisions of the agreement described in Paragraph 9 through 12 herein above, by court decree, among other things, ordering defendant to complete conveyance of the property described in Paragraph 2. Plaintiffé Praise and Glory is entitled to compensation incidental to a decree of specific performance by virtue of the delay of defendant Jhanvi in conveying of the property described in Paragraph 9 in that Plaintiff was deprived of fair rental value of the property during the period of the delay. WHEREFORE, Plaintiffs pray for damages and costs as follows against the defendants a. For an order decreeing that defendants shall convey the Property described in Paragraph 6, and plaintiff to pay the32. 33. 34, 35. Purchase price of $9,500,000.00, as set forth in the agreement described in said Paragraph 9. b. For compensation incidental to the decree of specific performance as set forth above, according to proof; Attorney fees and costs according to proof; d. Such other and further relief as the Court deems just and proper. count rrr BAD FAITE AND UNFAIR DEALING The Plaintiffs restate and reaver the allegations contained in paragraphs 1 through 31 of the complaint. On or about March 5, 2013, the parties Praise and Glory and Shanvi entered into certain option agreement for the conveyance of real property. In and by the contracts, the defendant Jhanvi agreed to convey a certain real property located at 143-147 state Street, Springfield, Massachusetts to the plaintiff Praise and Glory in exchange for adequate consideration. The plaintiff Praise and Glory is ready, willing and able and did in fact perform its obligations under the contract by providing proper and timely notice, and other good and valuable benefits to the defendant Jhanvi as consideration, all in exchange for expected conveyance of the said real property as agreed by defendant. 1036. 37. The defendant Jhanvi's conduct in refusing to convey the property, or even responding to the plaintiff Praise and Glory, and refusing to honor the contract constitutes bad faith and unfair dealing. As a result of the defendant Jhanvi’s bad faith and unfair dealing, the plaintiff Praise and Glory has incurred substantial financial damages. WHEREFORE, the Plaintiffs demand judgment, with costs, against the defendants. 38. 39. 40. COUNT IV UNJUST ENRICHMENT, QUANTUM MERUIT, QUASI-CONTRACT The Plaintiffs restate and reaver the allegations contained in paragraphs 1 through 37 of the complaint. Since September 2007 through and including the present, the Plaintiffs performed substantial services for the defendants by providing advanced costs for the rehabilitation of the real property located at 143-147 State Street, Springfield, Massachusetts, by providing dispute resolution services, management services, and administrative services, all for the benefit of the defendants. As a result of such services performed by the Plaintiffs the Defendants received a substantial benefit and have otherwise been enriched by and from such services provided by the Plaintiffs. 141. 42. 43. 44a. The Plaintiffs expected the defendant Jhanvi to convey to plaintiff Praise and Glory the real property subject of the contract described in Paragraph 9 above, and otherwise to be compensated for the services and other valuable benefits provided to or for the benefit of the defendants by the Plaintiffs, and the Defendants acted with full knowledge of said expectation in inducing Plaintiffs to perform the contracted services without objection The Defendants have retained all benefits and enrichment conferred by the Plaintiffs, to Plaintiffs’ detriment, in that the Plaintiffs made large capital investments, incurred out of pocket expenses, have not been compensated for any of their work or expenses and services to the Defendants in connection with the rehabilitation of the property located at 143-147 State Street, Springfield, Massachusetts, subject of the agreement. The enrichment conferred upon defendants by Plaintiffs is unjust in that the Plaintiffs have incurred great debts and liabilities, and out of pocket expenses, have not been fully compensated, and now face certain failure bankruptcy, the loss of all income, and the risk of loss of personal assets as a result of Defendants' conduct. The Plaintiffs are entitled to compensation from the Defendants based on quantum meruit, unjust enrichment 12and/or quasi-contract theory. WHEREFORE, the Plaintiffs demand judgment, with costs, against the defendants. 45. 46. 47. 48. coUNT_V ESTOPPEL The Plaintiffs restate and reaver the allegations contained in paragraphs 1 through 44 of the complaint. The defendant's conduct constituted misrepresentations intended to induce the Plaintiffs to invest their money into the property subject of the agreement breached by the defendant Jhanvi, to provide services and work, as well as make other equitable contributions to or for the benefit of the defendants. The Plaintiffs relied to their detriment on the Defendants’ misrepresentations, and were induced to perform obligations under and outside of the contract by providing funds, rehabilitation services and making large capital investments into the real property, as well as making financial investments as consideration, without having been compensated therefor. The defendant Jhanvi is estopped from termination of the contract and from withholding the compensation due Plaintiffs and from refusing to convey the property to plaintiff Praise and Glory. 13WHEREFORE, the Plaintiffs demand judgment, with costs, against the defendants. 49. 50. 51. 52. 53. COUNT VI ‘FRAUD The Plaintiffs restate and reaver the allegations contained in paragraphs 1 through 48 of the complaint. The Defendants made misrepresentations to Plaintiffs in order to induce Plaintiffs to act on behalf of Defendants to spend large sums of money, to spend considerable amounts of time resolving disputes against Defendants, and to manage in whole or in part the rehabilitation of the property subject of the complaint. The Defendants made these misrepresentations of fact to the Plaintiffs related to their requests for help and assistance in resolving claims and lawsuits raised against Defendants by third parties The Defendants also made misrepresentations of fact to the Plaintiffs related to defendants’ intention to convey the real estate located at 143-147 State Street, Springfield, Massachusetts to one or more of the Plaintiffs. The Defendants made these misrepresentations with the intention to induce one or more of the Plaintiffs to act upon said misrepresentations. 1454. 55, 56. 57. The Defendants made these misrepresentations with the knowledge that they were false. The Defendants made these misrepresentations with the intention that Plaintiffs act upon them, and Plaintiffs did in fact act upon defendants’ misrepresentations by spending money, time and effort resolving many of Defendants disputes, paying for expenses related to the property, and managing the work done at the property, all with the expectation that Plaintiffs would be compensated and/or reimbursed, and for the property to be conveyed to plaintiff Praise and Glory The Defendants knew that Plaintiffs made such undertakings on behalf of Defendants with these expectations. As a direct result of these misrepresentations by Defendants, the Plaintiffs incurred extensive monetary damages, loss of earning potential and loss of personal property. WHEREFORE, the Plaintiffs demand judgment, with costs, against the defendants. 15The Plaintiffs demand a jury trial in Superior Court on all counts. Date: May 2, 2017 16 THE PLAINTIFFS, By Their Attorney BBO#65 1242 Main Street, Suite 308 Springfield, MA 01103 Tel. 413-657-6762 Fax. 413-233-4908Date: May 1, 2017 VERIFICATION I verify that I have read all the allegations contained in the Complaint, that I have personal knowledge of the facts and circumstances contained therein, and such facts and circumstances stated in the Complaint are true, except those facts alleged in the affidavits of others, which upon information and believe, as to to be true. I verify that I have read all the allegations contained in the Complaint, that I have personal knowledge of the facts and circumstances contained therein, and such facts and circumstances stated in the Complaint are true, except those facts alleged in the affidavits of others, which upon information and believe, as to thos I believe them to be true. Fey teh David J. Billys, sTreoswre- I verify that I have read all the allegations contained in the Complaint, that I have personal knowledge of the facts and circumstances contained therein, and such facts and circumstances stated in the Complaint are true, except those facts alleged in the affidavits of others, which upon information and believe, as t¢ thoge/facts, I believe them to be true. GOD IN CHRIST, _INC. Pa Timothy © ren, resident men M7EXHIBIT A Option To Purchase Real Estate 18Fe Exhibit A fie 2-06-2014 8 BPE<4e EXTENSION OF OPTION TO REPURCHASE This Agreement is made this Sth day of March , 2013 and is by and between ib ‘Bedford Street, Lexington, ‘Ihanvi Hospitality LLC, having an address in care of 440. é ‘Massachusetis (“Optionor”) and Praise and Glory. Church of God in Christ, inc., ornomince, F havin an address of 145 State Street, Springfield, Massachusetts 01103 and 1111-1127 Main Street Springfield, MA. 01103 (“Optionee”) with respect to the property known 25 143-147 State Street, Springfield, Massachusetts (the “Propezty”). ar WHEREAS, Optionor and entered into a contract for the parchase of the Property; WHEREAS, es part consideration for the sale Optioneee has requested and Optionor has agreed to grant Optionee a right to repurchase the Property for a fixed price. NOW, THEREFORE for one dollar and other valuable consideration the receipt whereof is, hereby acknowledged the parties hereto agree as follows: 1. Optionee shall have, from the period of time commencing on the later of March 5, 2013 or the ED) MA. 01183 from the Optionor at a purchase price to be determined as follows: Thousand Dollars times the number of keys or rooms then approved at the Property) minus Fifty Thousand. ‘Dollars (the “Purchase Price”). 2 Toners his sight tbe Opione sal nthe Opin, a weting teas St fot TREET SPICING HELD, MA ot/ 48 ~12) MAin sree spengl, hl tdi i Bing fh asi os ence eee Oe Closing Date”). Should the Optionee fail to close by the Extended Option Closing Date then its cori cenchae til poeta eit tn eis Se aes the Property hereunder shall have thereafter expired. “Failure To Close” shall. be defined as Fl te icles of ie pies bese isding Optaost SoG taal ry good and marketble title free and clear of material encumbrances), then Optionee shall be entitled to all remedies at law, including specific performance. 3. The closing called for in paragraph 2 hereof shall take place at the offices of the Optionee’s. attomey in Springfield, Massachusetts or such other place as may be agreed upon by the Optionar and the Optionee at which time the Optionor shall deliver a Quit Claim Deed to the Opsionee upon receipt ofthe Purchase Price which Purchase ice shal be sje fac ars and the like as are customary in the hotel/motel closings. Wws-147 snqTe ¢ TL Book Jbl Phe yoessence) or notify Optionor in accordance herewith and, thereafter fail to close in accordance with the provisions of paragraphs 2 and 3 hereof or 2s set forth above, then its option to, shall automatically terminate and all rights that Optionee had to repurchase the Property hereunder shall have thereafter expired. 11. Any notice, payment, demand or communication required or permitted to be given by any. provision of this Agreement will be deemed to have-been given when delivered personally to the party designated to receive such notice or, on the third (3rd) business day after the same is sent by certified mail, postage and charges prepaid, or on the first (1st) business day after the same is sent by a recognized national overnight delivery company such as Federal Express, postage and charges prepaid, directed to the following addresses or to such other or additional addresses as ‘any party might designate by written notice to the other parties. To Optionor in-care of Jamsan Hotel Management * 440 Bedford Street Lexington, Massachusetts,New Haven, CT 05510 gery Aca ee P23 ee To Optionor Praise and Glory Church of God in Christ, Ine. with a copy to: Mark R. Draymore, Bsq. 46% Lor Omereiere Deymas uc His 734 26% Sovereign Bank Building 1350 Main Stece. 4° Floor Springfield, MA 01103 8. This instrument (including the schedules attached 2s a part hereof) constitutes the entire and final agreement among the parties and there ere no agreements, understandings, warranties or representations among the parties except as set forthherein. 2 The perk il ies in Dan ed aed eee - Tepresentatives, successors and/or assigns of the parties hereio. 1o Nang xin in ie Ape wl be deme ce tee ya ‘between the parties hereto and any other party, aoa to be liable or responsible in any way for the actions, liabilities, ‘party hereto. LL. The invalidity or unenforceability of any provisions(s) herein which do not materially affect | the material benefits expected to be realized by the parties through the consummation ofthe ‘transaction contemplated hereby shall not render any other provision invalid or unenforecable, 12, Paragraph or other headings contained in this Agreement are for reference purposes only and are not intended to affect in any way the meaning or interpretstion of this Agreement.13, This Agreement may! segue ce iim original document, but all of which will constitate « single document. 7 ‘on or constitute evidence of a contract between the pertirs tm pa cosnsrae oe eee ed to each other party to ‘this Agreement. 5 : 14, This Agroament will be interpreted and construcd under the internal ire of the Commonwealth of] regardless of the doaticile of any party and will be deemed for such purposes to have been made, executed and performed in Springfield, Massachusetts. 1§. Prior to and at all times following the execution of this Agreement, the parties agree to ‘execute and deliver, ar to cause to be executed and delivered, such documents and to do, or canse ‘to be done auch other acts and things as might reasonably be requested by any party to this, Agreement to assure that the benefits of this Agreement are realized by the parties. 16, Neither this Agreement nor any of the provisions hereof can be changed, waived, discharged. or terminated, except by an instrament in writing signed by the party against whoa enforcement of the change, waiver, discharge or termination is sought. EXECUTED onthe dates cafe opcifed tne a the date soc teney the person(s), or the entity upon behalf of. - i pose) are emo a arom WITNESS my hand and official seal: ‘ DONALD E ASHE, REGISTER ‘ HAMPDEN COONTY REGISTRY OF DEEDS‘GOGRET Ronan Trial Court of Massachusetts CIVIL ACTION COVER SHEET ‘The Superior Court AINTERIS: Pre & Gy Chur of God Cn. spay Devoe mr eee Hamden = [A0ORESS: Copan, Re. Tint Pa amon ts Eatrn Av, Sgt MA; 45 Se ret Steg MA sed 7 Tompson S__DEFEROANTISE: urd Howto LC anton Hoe regent ne ek Pat Spiga MA, ip Patt ArroRY: — cynmaLopez |avoness: 1242 an Set, Ste 308, Srna MA C1103 ADDRESS: 40 Bed Set Ln, MA: 40 Berd Sex Lene MA srr ren tecet9. 2084008 “ett Set, Wan, MA 44 Ey St Vs MA a00. 8 “TYPE OF ACTION AND TRACK DESIGNATION (see reverse side) ove No. “TYPE OF ACTIN (pect) ‘Rack A JURY CLAIM BEEN MADE? DoT,AGG,BEt __Spacic Peron; Brooch of Contract A ves LN It “Other" please describe: buses ot Fras ‘orm ES oa |e olowig is aa erized anc deta statement ofthe facts on wich the underignes lan or pint counsl reso determine money damages, Fo fs form, dstegard double or rele Gamage clas; indicate single damages only. TORTCLAMS {attach adaliional sheets as necessary) ‘4 Total physical Worapy expenses 6. Total ter expenses (desorbe below). '. Documented lot wages and compensation to date. 1c Documented propery damages to date. —— ' Reasonebly antipated future mecical and hoaptl expenses wn. . mo IE Reasonably antispated lst wages . . ‘Otrer documented items of damages (describe Below) non : a HE (. Bietly describe plaints nur, including the nature and extent of nur TOTAL (AAS ‘CONTRACT CLAIMS (ettach addtional sheets as necessary) Provide eta deacon of inst) Defendants broachedietused Io honor contractor conweyance oeal estate, commited fraud and misepresentation, TOTAL:$ —s4seoom000 ‘and converted property, |Signature of Attorney/Pro Se Plaintiff X Please pi CERTIFICATION PURSUANT TO SIC RULE 4:18 hereby erty that | have complied with requirements of Rule 5 ofthe Supreme Judicial Court Uniform Rules on Dispute Resenien 1a or et that provide my chents wit information about geut-connected dispute resoiton services and discuss with hem the Seca reetaas Doe arate ® ( be fadfape ow mason