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HomeMy WebLinkAbout98-01497 J ::I -s:: Co ~, ~ ;z ,'~ Q ~. ,~ ~..:.{ ~, >-- . ~ 1/\- ~ ~ \J 11~. ) ~ ~ f! - . - l:) '- CJ 0.. ~ t- O"- ::r- - . . Q ~ 5, The terms of said Agreement were that Defendant would pay the tax in the amount of $270,00 up front, and on November 21, 1997, Defendant made a payment of $270,00, A true and correct copy of the receipt is attached hereto as Exhibit "B", 6. Plaintiff, in accordance with the terms of the Agreement, gave possession of the diamond solitaire ring to Defendant on December 19, 1996, 7, By correspondence dated January 7, 1998, from Plaintiff's counsel to Defendant, Plaintiff attempted to resolve this issue by requesting Defendant to contact Plaintiff's counsel by January 16, 1998. A true and correct copy of this correspondence is attached hereto as Exhibit "C". 8, Defendant spoke with Plaintiff's counsel thereafter and promised to pay the balance due on the ring, however, has not done so, 9, Notwithstanding the terms of the Agreement to pay the balance in full by April 30, 1997, the Defendant is in default under the terms of the Agreement, in that no payments have been rnade since the payment of $270,00 on Novernber 21, 1997. 10, By reason of Defendant's default in payment, Plaintiff has an immediate right to possession of the diamond solitaire ring, which is presumably still held by Defendant, and/or his fiance, 11. Upon information and belief, the appraised value of the ring is $8,400,00. ~ ~ ~ .:s- ~ -Q\o 1-..[") I~ .. - 8~~ ~ - ~ - u~ Q.. ?~ co g: 3z UJ 0:: a:~ . C>.., j:: .. l;J "1 x r -""'\ ~ ~, a3 ..1: f'. /'f'l ::> C7' u. ~ V'l r-- .. "" r1 ~ @) ct ~~'< ~ ~ s i' ....J u :.;' ~ ~ o. ~ ~~ ~ .;: '" 1-- ...J f: ~o N {ff3 ;5::, r:i:!. ::r.: -)~. ~ r") ., ( ,...,..... gr::: a.. ... :;'l ~ :; ~ C Cl ;;i 0 !:.ill: 'f') ~~~ .;>- - "5 !i) () ~ Ct; iE' - i'f/~ '=tI ~ .~ I..J.Z ~ ::;, '.!J1i: ~ , ri /l:) :5 d en (J " i'r; 01 1; C',t ~ IN .::. wt:;! 8'~ H:~ ( ~ :t: ~ ~r- Cl... q;-J c> ~Ifi: Ln :sr9 0:: VI .'- :.~z :':,J1.I3 Fl:. ::J !2~u.. -, 1.1. -, 0 co ::1 0' (J ...