Filing 54230066 E?Filed 03/27/2017 11:12:51 AM

IN THE CIRCUIT COURT OF THE 2ND JUDICIAL CIRCUIT
IN AND FOR LEON COUNTY FLORIDA

.LeCI-airRyan, .a Professional Corporation,
CASE: NO: 2017 CA 000636

 

Prevacus, 

Defendant.

1

Com FLA-INT

 

Plaintiff, Professional Corporation 
through its undersigned attorney, sues Defendant, Prevacus, Inc. 
and alleges:

1. This is an action for damages Which exceeds $15,000.00, and come-S. Within

the of this Court.

2. Plaintiff, LeC-lairRyan, is an for-profit Corpioration, qualified to
do business in the State of Florida, with its principal place- of businesslooated at
919 East Main Street, 24th Floor, Richmond, VA 23219. The event, or- transaction

out- of-which thisrclaim- arose, occurred. in Leon 

Defendant, Prevacus, is. an. active: Delaware for-profit corporation

with its printipal place of business, according :toits most recent? FIOri'c'la COrporation
Annual Report, located at .1408 .N. Piedmont Way. Tallahassee, FL 32208,- and with

a last known. mailing address of 1400 Village Square Blvd, Ste. 3-414, Tallahassee,

FL 32312.

{Client FLIPLEAochmso-ss.oocx 

 Venue is pro-per in this County and Court in accordance with ES. 47.051.

COUNT ONE
(Open Account)"

Plaintiff re-alleges and incorporates by reference the preceding paragraphs,

"the same as if'set forth hereunder in full.

.6. Prevacus engaged LeCIai-rRyan to. provide legal services. and became

indebted to Plaintiff in the sum of on :a mutual open and current
account,- the sum being the balance. due and owing to Plaintiff, founded on. business.
dealings between the. Plaintiff and Defend-ant'on which a systematic record :of the

account has been kept.

.7. Plaintiff rendered to Defendant Invoices and/or Statements of

Accountfg'r such leg-alserviices, respecting four (4) separate matters, which
Prevacus agreed to pay,- and from-time to time, Prevacus made
partial payments without Copies of the-outstanding invoices and/or

statements are attached hereto as Exhibit 

8 Prior to commencement of this action, demand was made. on Defendant
for the payment ofithe- sum .biut Defendant failed or refused to pay

the sum or any part of the sum and, therefore, Plaintiff has been damaged.

39.. Defendant-owes the plaintiff $28,248.88. that isdue by Open Account, plus

interest accruing since March 8, 2.0316, in the sum of $1,341.82, accruing at the rate-
of 4.75% simple. per annum ($111.82 per mg. I $3.68 per day). An Affidavit of

Account, with an Itemized Statement attached, .is- annexed hereto as Exhibit 

{Client 

WHEREFORE, Plaintiff'praiys this Court to grant relief-as" follows:
A- Judgment for'damages again-st Defendant in the Sum of?
$28,248.88 plus interest- aooi?uing from March 8, 20116 through
in the sum of $1,341.82 ($111.81 per mo. I $3.68 per
day) at the annual rate. of 4.735% simple through the date of judgment;
B. Court costs, 'a n-d;
C. Such other, further or different relief as the Court may deem just

and proper.

COUNT TWO
(Account Stated)

10. Plaintiff "re-allegesan'd incorporates "by reference the preceding paragraphs, the

same. as?if set forth hereunder 

11-. Before institution" of this action, Plaintiff'and Defendant had business
transactions between them and they agreed toth'e resulting balance due as
represented by "the InVOices and. Statements of Account render-ed to PreVac-Us
through March 8, 2016, as set forth .in Exhibit annexed hereto; and, as
referenced on theAf?davffofAccount with Itemized ?Statementattached,

annexed here-to as Exhibit: A

12. Dafe-ndant. Prevacus did not object to any-of the Invoices 0r Statements of

Account as rendered, and, from time to time, made partial payments thereon.

{Client 

"13. Defendant entities the plaintiff $28,248.88, that is due by. ACCounthtated, plus
interest since March 2016, in the sum ($111.81 per
ch $33.68 per day), accruing at the rate. of 4.75% simple per 

the date e'f'judg'm'ent.

W-HEREFORE, Plaintiff prays this Court t0 grant relief as follews:
A. Judgment for damages against Defendants in the sum of
$28,248.88 plus interest accruing from November, 201-4 through
February, 201?, in. the sum cf $1,341.82 ($111.81) at the rate of
4.75%, through the date er judgment;
8. CeUrticests, and;
C. Such other, further or different. relief ast'he' Court. may deem just

and proper.

COUNT THREE
MERUIT SERVICES RENDERED)
14. Plaintiff re?alleges and incorporates by reference. the preceding paragraphs, the

same: as i-f'set forth hereunder in full.

'15. At'th?' ?request of Prevacus, Plaintiff performed legal services- for Defendant, as
set forth in, Exhibits and annexed hereto, and the Defendant agreed to
and became bound" ta pay Plaintiff .en'dernand' the reasonable value of said

services.



16. Plain-tiffLeelairRyan claims that. the charges for its. service-s rendered were
.reasenable considering, among ether thin-gs, the cempI-exity of the legal matters

'invelVed and the training and experience required to perform the services:

Plaintiff prays thisCou-?rt te- grant relief. as fellows:
A. Judgment fer. damage-s again-st Defendants in "the sum 0f
$28,248.88 plus interest accruing from Nov-ember, 20.14 through
February, 2017: in the sum inf. ($111.81 per mm] $3.68 "per
clay), at the rate of "through the date ef'judgment;
B. Ceurt-eeSts, and;
C. Such ether, further er different reliefas the Court may. deem just

and proper.

John N. Pappanastos
JOHN 
Fla. Bar 0776661
Attorney fer Plaintiff, LeCilai'rRy'a'n PC

Of Counsel:

The Pap'pan'aS-tns' Law ?Firm, P.C.
RD. 950

Lady Lake, FL. 32153
334-264-8500


 

{Client