13:1? 515232443? @1382 E-FILED 2019 MAR 29 4:01 PM STORY - CLERK OF DISTRICT COURT IN THE IOWA DISTRICT COURT FOR STORY COUNTY SYSCO IOWA LAW NO. 13 Plaintiff, vs. AFFIDAVIT OF SCOTT GRIFFEN SCOTT GRIFFEN, LIPS, INC., and OLDE MAIN EREWING COWANY, Defendants. STATE OF IOWA SS: COUNTY or srosr I, Scott Griffen, duly sworn, af?nnatively state and swear that I am competent to testify to the matters stated herein, and state as follows: 1. 1, Scott Griffen, am the President of LJPS, Inc., I am familiar with the above? captioned matter and have ?rst-hand knowledge of the facts contained herein. 2. In approximately 2004, I signed a Credit Application with Plaintiff on behalf of UPS, Inc. . 3. In approximately 2004, I signed a Personal Guarantee related to said Credit Application with Plaintiff. 4. I ensured that LIPS, Inc. consistently made payments on its account with Plaintiff beginning in approximately 2004. I 5. At some point in 2015, Plaintiff contacted me to discuss the alleged past amounts due. #3057773 131332932019 13:1? 515232443? 02302 E-FILED 2019 MAR 29 4:01 PM STORY - CLERK OF DISTRICT COURT 6. A representative of Plaintiff made repeated promises to me that if LIPS, Inc. continued to do business with Plaintiff, Plaintiff would only seek payment of approximately $30,000 of any past due amounts. 7. The most recent conversation wherein Plaintiff promised to only seek payment of approximately $3 0,000 took place on approximately February 2018. 8. I informed the representative of Plaintiff that we were considering terminating Plaintiff services and instead employing the services of a competitor of Plaintiff due to the significant cost savings associated with such a move. 9. Plaintiff?s representative again assured me that Plaintiff would only seek approximately $30,000 in past due debt if LIPS, Inc. continued to utilize the services of Plaintiff. 10. Relying on Plaintiff statement, LIPS, Inc. continued to use the services of Plaintiff to its financial detriment. 11. On December 21, 2013, Plaintiff ?led its Petition seeking nearly $220,000 in dentages, $172,984.44 consisting of alleged past due debt. was Scott Griffen Subscribed and sworn to before ng?lg ,2019. mm ?at/Mend.) Notary Mlic' ?at for the State of Iowa Mymm?ssion Expires 6. 2020 urcm messes Cameron Number senses