No. 06-39055-3
Patrick mcgovern § within the county court
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V. § at-law no. 3
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Brian m. Stange and §
Jane allen § tarrant region, tx
Affidavit of patrick mcgovern
The state of texas §
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Region of tarrant §
BEFORE ME, the undersigned power, with this evening personally seemed Patrick McGovern, who swore on pledge the following truth is accurate:
1. Our name is Patrick McGovern and that I am the Plaintiff within the above-titled and designated cause. As a result, I'm approved to create this Affidavit. I've individual understanding of the reality established herein, plus they are all accurate and proper. The reality recited herein are accurate and proper and of my very own personal understanding.
2. During or around the month of March, Offender Stange started discussing particular enterprise possibilities with me concerning the computer engineering area. After repetitive conversations between us, Offender Stange convinced me to participate with him in beginning a company from the title of “ITGURU, ” that was to get and marketplace computing devices and supply it-services to companies. Centered on Offender Stange’s representations regarding his huge and substantial knowledge and encounter within the area of electronics design and computer engineering, which were greatly exagerated, I decided to Offender Stange’s demand that I fund the purchase of particular computers and computer-related equipment for that new company.
3. To be able to help the purchase of such products and centered on his representations (which ended up to become fake), I supplied Offender Stange with a number of charge cards that have been to become used exclusively for that purchase of computers and computer-related equipment for that ITGURU company.
4. Sadly, though Offender Stange acquired a number of of my charge cards under false pretenses, Offender Stange used the charge cards under consideration to buy numerous individual things that had nothing related to the ITGURU company and which charge thousands of pounds. For instance, Offender Stange employed my charge cards to buy products at Neiman Marcus, Hooters, Walmart, Starbucks, National Corvette Liq-O-Rama, Nordstroms, Twenty First Century Autoparts and a number of other places where he acquired products and/or providers for their own individual usage and/or private satisfaction. Due to Offender, Stange, the ITGURU company never started.
5. Though I repeatedly asked Offender Stange concerning the utilization of the charge card bill, Offender Stange wrongfully displayed in my experience he had taken care of the costs under consideration. Again, such representations were fake inasmuch as Offender Stange shipped a number of NSF checks to American Show within the quantity of $17,822.20 allegedly in cost of the costs on my bill. Offender Stange never settled me or my credit card issuers for that products or solutions he wrongfully obtained consequently of the usage of my charge cards. Or did Offender Stange actually return some of such products in my experience.
6. Due to Offender Stange’s lies, deceptions and excessive conduct, including conspiring and talking to acquire resources from me wrongfully, I've sustained substantial problems. Our credit rating, which just before his participation with Offender Stange, was excellent, has experienced significantly. Offender, Stange’s conduct was particularly intented to trigger considerable injurty in my experience and that I genuinely believe that emotional damages ought to be granted against Offender, Stange, within the quantity of atleast, 000.00
7. I've created a number of needs for cost upon Offender Stange; nevertheless, he's declined and proceeds to WOn't create any funds in my experience or else go back to me-any of the home bought with my charge cards. Mary Allen has also loved the advantages of Stange’s inappropriate conduct.
8.in the end authorized offsets and breaks have now been utilized, Defendants today owe the amount of $38,300.64 in my experience. Defendants likewise owe me for that attorney’s costs I sustained consequently of Defendants’ inappropriate deceptive conduct. I've decided to spend Regulations Offices of Jay E. Reedy to follow my statements against Defendants.
Further affiant sayeth not.
Patrick McGovern
ACTIVATED AND SWORN to before me with this % day May, to approve which experience my palm and seal of workplace.
Notary Public in as well as for the
State-Of Arizona
Our Commission Expires
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