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E-FILED 2017 JUL 28 3:16 PM SAC - CLERK OF DISTRICT COURT

IN THE DISTRICT COURT FOR SAC COUNTY

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SMITH PRODUCTIONS, LTD, and )
)
Plaintiffs, ) Case No. ______________________
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v. ) PETITION
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SHERYL A. STENOIEN, )
Defendant. )
)

COMES NOW this 28th day of July , 2017, the Plaintiff, Smith Productions, Ltd., for its
cause of action against Defendant, Sheryl A. Stenoien, states as follows:

1. That the Plaintiff, Smith Productions, Ltd., is an Iowa corporation having its
principal place of business at 610 Walnut Street, Box 777, Aurelia, Iowa 51005, and is
authorized to transact business in the State of Iowa.
2. That the Defendant, Sheryl A. Stenoien, has at all times herein resided at 217 Hwy
59, Avoca, Iowa 51521-3304.
3. That the action is for breach of an agreement. The terms of the agreement
required performance in Sac County, Iowa.
4. The Plaintiff is in the business of construction.
5. The Defendant requested the services of the Plaintiff with respect to roofing of a
structure, and related work and materials, located on land which has been formerly known as the
Adams Ranch, located south of Odebolt, Iowa. The work was submitted by bid, and accepted
by the Defendant. Billing for the work was provided by the Plaintiff to the Defendant, per the
bid. The updated billing invoice showing all of the itemized time and materials, and allowing for
all payments made by Defendant to Plaintiff for such work, is in the amount of $57,097.18. (The
updated billing invoice is attached hereto as Exhibit A, incorporated herein.)
6. The Plaintiff has fully performed all work as agreed to be performed.
7. The Verification of Account, Identification of Debtor and Certificate RE Military

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E-FILED 2017 JUL 28 3:16 PM SAC - CLERK OF DISTRICT COURT

Service is attached hereto as Exhibit B and incorporated herein.

WHEREFORE, Plaintiff prays for Judgment against the Defendant in the amount of
$57,097.18, plus interest and court costs of this action.

MURRAY & MURRAY, P.L.C.

_____/s/ John M. Murray_____________________


John M. Murray (ICIS PIN #AT0005555)
530 Erie Street
P.O. Box 27
Storm Lake, IA 50588
(712) 732-8181
fax: (712) 749-5089
jmmurray@iw.net

ATTORNEY FOR THE PLAINTIFF,


SMITH PRODUCTIONS LTD.

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E-FILED 2017 JUL 28 3:16 PM SAC - CLERK OF DISTRICT COURT
E-FILED 2017 JUL 28 3:16 PM SAC - CLERK OF DISTRICT COURT
E-FILED 2017 SEP 19 1:31 PM SAC - CLERK OF DISTRICT COURT