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COMES NOW Plaintiff Kasey King, by and through his attorney Prince Adebayo
Ogunmeno, and for his cause of action against the defendants My Town Media, Inc., Lori
PARTIES
1. The plaintiff Kasey King is an individual person, and a resident of Crawford County,
Kansas.
the State of Kansas and doing business in Crawford County, State of Kansas.
5. Jurisdiction and venue is proper in this court pursuant to K.S.A. 60-603 and K.S.A.
60-604 in that all the defendants are resident of Crawford County and all the acts or
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omissions which gave rise to this cause of action occurred within Crawford County,
Kansas.
COUNT I
BREACH OF CONTRACT CLAIM
AGAINST DEFENDANT MY TOWN MEDIA, INC.
reference.
7. On February 16, 2015, the plaintiff entered into a radio advertisement contract with
8. The defendant My Town Media, Inc., promised to create the content and produce a
radio advertisement for plaintiffs signature drive for a grand jury petition; in
exchange the plaintiff promised to pay defendant its usual and customary charges for
9. In addition, the parties agreement imposes the general contractual duties and
10. The plaintiff fully performed his obligations under the parties contract by payment to
11. However, the defendant breached the parties contract when it unilaterally cancelled,
withdrew and refuses to continue to run plaintiffs signature drive radio campaign for
30 days agreed to in the parties contract without any just cause or legal excuse to do
so.
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12. As a direct and proximate result of the defendant My Town Media, Inc.s breach of
the parties contract, plaintiff suffered damages for which he is entitled to recover
WHEREFORE, plaintiff prays the court for judgment against the defendant My
Town Media, Inc., in an amount provable at trial that is just and reasonable, for his costs,
including reasonable attorney fees, if appropriate, and for all other reliefs the court find
COUNT II
TORTIOUS INTERFERENCE WITH CONTRACTUAL RELATIONS
CLAIM AGAINST DEFENDANT FLEMING AND LOY
13. The allegations contained in the above paragraphs are incorporated herein by
reference.
14. On February 19, 2015, there was in existence a valid contract between plaintiffs and
15. Defendant Fleming and Loy possessed knowledge of the existing grand jury signature
drive campaign radio advertisement contract between plaintiff and My Town Media,
Inc.
16. Defendants Fleming and Loy willfully and intentionally interfered and brought about
the breach and termination of the existing radio advertisement contract between the
17. The defendant Fleming and Loy have no legal excuse or legal justification to interfere
and to cause the breach or termination of the existing contract between plaintiff and
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18. As a direct and proximate cause of the defendants wrongful and intentional
interference with plaintiffs contractual relations with My Town Media., Inc., plaintiff
WHEREFORE, the plaintiff prays the court for judgment against the defendant
Fleming and Loy in an amount in excess of $75, 000.00, award of punitive damages, for
plaintiffs costs, and for all other reliefs the court find just and proper.
Plaintiff demands trial to the jury of all disputed issues in this cause pursuant to
K.S.A. 60-238.
Respectfully submitted,