E-FILED 2013 SEP 12 4:36 PM SAC - CLERK OF DISTRICT COURT

E-FILED 2013 SEP 12 4:36 PM SAC - CLERK OF DISTRICT COURT

E-FILED 2013 SEP 12 4:36 PM SAC - CLERK OF DISTRICT COURT

E-FILED 2013 SEP 23 9:43 AM SAC - CLERK OF DISTRICT COURT

RETURN OF SERVICE In the Iowa District Court For SAC COUNTY

Case Name: CASEY JACKSON CONSTRUCTION LLC vs SPRING LAKE CONSTRUCTION INC Case No.: LACV019462 Sheriffs File No.: 13018755 Notice recd : 9/17/2013

STATE OF IOWA POLK COUNTY } SS.

I certify that I served a copy of : ORIGINAL NOTICE/PETITION to SPRING LAKE CONSTRUCTION INC Type of service: COMPANY REPRESENTATIVE

by delivering a copy to: DEAN QUIRK a person at least 18 years of age described as AGENT AUTHORIZED TO ACCEPT Address of service: C/O DEAN QUIRK 4123 NW 95TH PLACE POLK CITY, IA 50226 Date and time of service: 9/20/2013 12:03 PM Trips:

Comments:

FEES: PROCESSING FEE ($25.00) MILEAGE FEE ($13.44) Total:$38.44 BILL McCARTHY Sheriff

Polk County, Iowa

JEFF HINRICHS Deputy/Server

E-FILED 2013 SEP 23 9:43 AM SAC - CLERK OF DISTRICT COURT

RETURN OF SERVICE In the Iowa District Court For SAC COUNTY

Case Name: CASEY JACKSON CONSTRUCTION LLC vs SPRING LAKE CONSTRUCTION INC Case No.: LACV019462 Sheriffs File No.: 13018755 Notice recd : 9/17/2013

STATE OF IOWA POLK COUNTY } SS.

I certify that I served a copy of : ORIGINAL NOTICE/PETITION to DEAN QUIRK Type of service: PERSONAL

by delivering a copy to: a person at least 18 years of age described as Address of service: 4123 NW 95TH Pl POLK CITY, IA 50226 Date and time of service: 9/20/2013 12:03 PM Trips:

Comments

BILL McCARTHY

Sheriff

Polk County, Iowa

JEFF HINRICHS Deputy/Server

E-FILED 2013 SEP 25 1:45 PM SAC - CLERK OF DISTRICT COURT

IN THE IOWA DISTRICT COURT FOR SAC COUNTY ________________________________________________________________________ | CASEY JACKSON | CONSTRUCTION, L.L.C. | CASE NO. LACV019462 | Plaintiff, | | v. | | SPRING LAKE CONSTRUCTION, INC. | AND DEAN W. QUIRK | APPEARANCE | Defendants. | ____________________________________ _____ |_____________________________ COMES NOW the undersigned attorney, Thomas P. Tully, hereby enters his appearance on behalf of Defendants, Spring Lake Construction, Inc. and Dean W. Quirk.

THOMAS P. TULLY (AT0011150) TULLY LAW OFFICE, P.C. 212 W. Van Dorn St., Suite E PO Box 214 Polk City, IA 50226 Telephone: (515) 556-4692 Facsimile: (515) 984-9157 Tom@TullyLawOfficePC.com ATTORNEY FOR DEFENDANTS SPRING LAKE CONSTRUCTION, INC. AND DEAN W. QUIRK

E-FILED 2013 OCT 06 1:18 PM SAC - CLERK OF DISTRICT COURT

IN THE IOWA DISTRICT COURT IN AND FOR SAC COUNTY CASEY JACKSON CONSTRUCTION, L.L.C., LAW NO.: LACV019462 Plaintiff, Vs. SPRING LAKE CONSTRUCTION, INC., AND DEAN W. QUIRK, Defendants. COMES NOW the Defendants, SPRING LAKE CONSTRUCTION, INC. and DEAN W. QUIRK, and for their Answer to Plaintiffs Petition states as follows: 1. 2. 3. 4. 5. Paragraph 1 is denied for lack of information. Paragraph 2 is admitted. Paragraph 3 is admitted. Paragraph 4 is denied as overbroad. Paragraph 5 is objected to as to being a compound question. To the extent a response is deemed required, it is admitted as to being president; denied as to personal action. 6. 7. Paragraph 6 is admitted. Paragraph 7 is objected to as to being a compound question. To the extent a response is deemed required, it is denied as to personal action; admitted as to acting agent of the corporation; 8. 9. 10. Paragraph 8 is denied for lack of information and belief. Paragraph 9 is admitted. Paragraph 10 is denied for lack of information and belief. DEFENDANTS ANSWER AND JURY DEMAND

E-FILED 2013 OCT 06 1:18 PM SAC - CLERK OF DISTRICT COURT

11. 12. 13.

Paragraph 11 is denied for lack of information and belief. Paragraph 12 is denied for lack of information and belief. Paragraph 13 of the Complaint contains conclusions of law to which no response is required.

14. 15.

Paragraph 14 is admitted. Paragraph 15 is admitted as to receipt of a letter from plaintiffs counsel in August 2012.

16. 17. 18.

Paragraph 16 is denied for lack of information and belief. Paragraph 17 is denied. Defendant denies Plaintiffs Prayer.

WHEREFORE, the Defendants, SPRING LAKE CONSTRUCTION, INC. and DEAN W. QUIRK, and respectfully requests the Court dismiss Plaintiffs Petition as to them and assess the costs to the Plaintiff. JURY DEMAND The Defendants, SPRING LAKE CONSTRUCTION, INC. and DEAN W. QUIRK hereby demand trial by jury on all above-captioned claims.

. THOMAS P. TULLY (AT0011150) TULLY LAW OFFICE, P.C. 212 W. Van Dorn St., Suite E, PO Box 214 Polk City, IA 50226 Telephone: (515) 556-4692 Facsimile: (515) 984-9157 Tom@TullyLawOfficePC.com ATTORNEY FOR DEFENDANT ORGINAL FILED

E-FILED 2013 OCT 06 1:18 PM SAC - CLERK OF DISTRICT COURT

IN THE IOWA DISTRICT COURT IN AND FOR SAC COUNTY CASEY JACKSON CONSTRUCTION, L.L.C., LAW NO.: LACV019462 Plaintiff, Vs. SPRING LAKE CONSTRUCTION, INC., AND DEAN W. QUIRK, Defendants. COMES NOW the Defendants, SPRING LAKE CONSTRUCTION, INC. and DEAN W. QUIRK, and for their Answer to Plaintiffs Petition states as follows: 1. 2. 3. 4. 5. Paragraph 1 is denied for lack of information. Paragraph 2 is admitted. Paragraph 3 is admitted. Paragraph 4 is denied as overbroad. Paragraph 5 is objected to as to being a compound question. To the extent a response is deemed required, it is admitted as to being president; denied as to personal action. 6. 7. Paragraph 6 is admitted. Paragraph 7 is objected to as to being a compound question. To the extent a response is deemed required, it is denied as to personal action; admitted as to acting agent of the corporation; 8. 9. 10. Paragraph 8 is denied for lack of information and belief. Paragraph 9 is admitted. Paragraph 10 is denied for lack of information and belief. DEFENDANTS ANSWER AND JURY DEMAND

E-FILED 2013 OCT 06 1:18 PM SAC - CLERK OF DISTRICT COURT

11. 12. 13.

Paragraph 11 is denied for lack of information and belief. Paragraph 12 is denied for lack of information and belief. Paragraph 13 of the Complaint contains conclusions of law to which no response is required.

14. 15.

Paragraph 14 is admitted. Paragraph 15 is admitted as to receipt of a letter from plaintiffs counsel in August 2012.

16. 17. 18.

Paragraph 16 is denied for lack of information and belief. Paragraph 17 is denied. Defendant denies Plaintiffs Prayer.

WHEREFORE, the Defendants, SPRING LAKE CONSTRUCTION, INC. and DEAN W. QUIRK, and respectfully requests the Court dismiss Plaintiffs Petition as to them and assess the costs to the Plaintiff. JURY DEMAND The Defendants, SPRING LAKE CONSTRUCTION, INC. and DEAN W. QUIRK hereby demand trial by jury on all above-captioned claims.

. THOMAS P. TULLY (AT0011150) TULLY LAW OFFICE, P.C. 212 W. Van Dorn St., Suite E, PO Box 214 Polk City, IA 50226 Telephone: (515) 556-4692 Facsimile: (515) 984-9157 Tom@TullyLawOfficePC.com ATTORNEY FOR DEFENDANT ORGINAL FILED