IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION
SUMMONS
TO THE DEFENDANT:
TO: DARREN K. MUSGRAVE
1188 Windermere Lane Champaign, Illinois 61822
YOU ARE HEREBY SUMMONED and required to file an answer or otherwise file an appropriate appearance in the above-captioned case, which has been commenced against you in the Circuit Court of Cook County, Illinois, County Department, Law Division, by the Plaintiff, GREENFIELD AGRICULTURAL PARTNERS LLC, a Delaware limited liability company.
A Complaint has been filed in the Circuit Court of Cook County, Illinois, County Department, Law Division, on May 9, 2022, by and through Plaintiff's attorneys:
Calderwood & Harkness LLP 225 West Wacker Drive, Suite 4000 Chicago, Illinois 60606
Attention: Francesca Morano
The nature of this action is as follows: Breach of contract, breach of personal guaranty, account stated, and unjust enrichment, arising out of the failure to pay amounts due under a Master Grain Purchase and Off-Take Agreement dated March 15, 2019, by and between Plaintiff and Defendant Prairie Basin Grain Co., and a related personal guaranty executed by Defendant Darren K. Musgrave in connection therewith.
RESPONSE DEADLINE AND CONSEQUENCES OF DEFAULT
You, DARREN K. MUSGRAVE, must file your answer or appearance within thirty (30) days after service of this Summons upon you, exclusive of the day of service.
IF YOU FAIL TO DO SO, A JUDGMENT BY DEFAULT MAY BE TAKEN AGAINST YOU FOR THE RELIEF REQUESTED IN THE COMPLAINT. The Complaint seeks, among other things, damages in the principal amount of $4,870,050.00, plus accrued interest thereon, attorneys' fees, and costs of suit. The personal guaranty claim asserted against you, Darren K. Musgrave, individually, is capped at $2,000,000.00 pursuant to the terms of the personal guaranty, together with such additional amounts for interest, attorneys' fees, and costs as may be allowed by law and the terms of the guaranty instrument.
FILING INSTRUCTIONS
Your answer or appearance must be filed in the office of:
Clerk of the Circuit Court of Cook County, Illinois Richard J. Daley Center 50 West Washington Street Chicago, Illinois 60602
A copy of your answer or appearance must also be served upon Plaintiff's attorneys at the address stated above:
Calderwood & Harkness LLP 225 West Wacker Drive, Suite 4000 Chicago, Illinois 60606
Attention: Francesca Morano
CLERK'S CERTIFICATION
WITNESS the Honorable Chief Judge of the Circuit Court of Cook County, Illinois, and the Seal of the Circuit Court of Cook County, at Chicago, Illinois.
Date of Issuance: May 9, 2022
[SEAL OF THE CIRCUIT COURT OF COOK COUNTY]
________________________________________
Clerk of the Circuit Court of Cook County, Illinois
By: ________
Deputy Clerk
ATTORNEY INFORMATION
Prepared by / Attorney for Plaintiff:
Francesca Morano Attorney No. 6340982 Calderwood & Harkness LLP 225 West Wacker Drive, Suite 4000 Chicago, Illinois 60606 Telephone: (312) 555-7400 Facsimile: (312) 555-7401
Attorney for Plaintiff Greenfield Agricultural Partners LLC
GREENFIELD AGRICULTURAL PARTNERS LLC,
a Delaware limited liability company,
<!-- indent:2 -->Plaintiff,<!-- /indent -->
v.
PRAIRIE BASIN GRAIN CO., an Illinois corporation,
and DARREN K. MUSGRAVE, individually,
<!-- indent:2 -->Defendants.<!-- /indent -->