IN THE MAGISTRATE COURT OF CATOOSA COUNTY STATE OF GEORGIA Abby Evans or Justin Evans, Plaintiff, * *s, » cast No: AOIF-62 CC Stephen Kinder and/or Jane ‘ Doe d/b/a Kinder Dog Training, @cor™ : Upon knowledge and belief, Defendant is a Sole Proprietorship operating a d/b/a called “Kinder Dog Training” in Bradley County Tennessee and can be served at 3505 Adkisson Road Suite 104, Cleveland, TN 37312. Plaintiff isa resident of Walker County Georgia. 3 Plaintiff and Defendant entered into a contract for services which was consummated in Catoosa County Georgia. 4 Defendant advertises and solicits business within the State of Georgia and specifically Catoosa and Walker Counties. CATOOSA CO. MAGISTRATE CT. FILED IN OFFICE, Page 1of 4This honorable court has personal jurisdiction over the defendant due to the execution of the aforementioned contract within the jurisdiction of this honorable court. 6. This honorable court is the proper venue for this action per O.C.G.A. §15-102 Defendant promised certain services related to the care and training of the canine, “Yank” owned by the Plaintiff. 8. Plaintiff relied on the promises and advertisements of the Defendant before agreeing to the contract. % Defendant breached the contract by failing to provide training as promised. 10, Defendant abused Tank. i. Defendant caused actual damages to Plaintiffs to wit: Veterinary bills, grooming bills. monies to retrain Tank, monies to rechome ‘Tank due to the negligence and breach of contract by Defendant. 12. Plaintiff has attempted on numerous occasions to avoid litigation on this mauter. To wits Plaimtll has accepted several promises of a return of money paid plus Veterinary Bills which Detendant has failed to honor, Page 2 of 413. Plaintiff has worked diligently to minimize his losses as a result of the Defendant's actions, i. Plaintiff has attempted to work with Defendant in this matter to avoid the need for court intervention. 12. Due to Defendant’s unwillingness to work with Plaintiff on the matter, Plaintiff has been forced to file this Complaint for Money Damages with this honorable court and has incurred attorney's fees and court costs and other expenses as a result. 13, WHEREFORE, Plaintiff prays that this court order the Defendant: 1 2. Pay to Plaintiff the sum of $4,600.00 in actual and projected damages; Pay to the Plaintiff the sum of $1,500.00 for attorney's fees related to this action in accordance with O.C.G.A. §13-6-11; Pay to the Plaintiff the cost of filing and serving this action the amount published by the Magistrate Court Clerk's offices Provide that the Defendant pay post judgment interest at the legal rate set forth by Georgia Statute starting 30 days alter the judgment is entered; Provide other remedies as this honorable court sees fit based on the facts contained herein and/or facts learned during any hearing that may come from this pleading. Page 3 of 4