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Lindsey Jovanovski, Plaintiff, v. Pamela Brown, Defendant.

Monmouth County

 

No.  MON-DC-4470-15

 

Superior Court of New Jersey Law Division, Special Part

 

Jovanovski & Myers

v.

Pamela Brown

 

Judge awarded $15,000 judgment to plaintiffs against New Jersey Welsh Pony breeder Pamela Brown in 2013 pony lease matter.

 

February 2017 – $6875 of $15,000 judgment against pony breeder Pamela Brown satisfied


No. L-2739-13

Superior Court of New Jersey Law Division Monmouth County

Plaintiff, Lindsey Jovanovski / Karri Meyers residing in the City of Manalapan, County of Monmouth.

State of New Jersey, complaining of the defendant, states as follows:
1. On June 23rd, 2013, Pamela Brown, Defendant had Pony Tango removed and stolen from Lindsey Jovanovski at Horse Park of New Jersey without paying and or reimbursing for training fees and veterinary care. Pamela Brown gave Ms. Jovanovski possession of Tango on 10/15/2012 in return Ms. Brown was to give a commission on the sale of Tango at the end of 9/16/2013. Ms. Brown tried to steal Tango on March 17, 2013, therefore, was billed for all charges on Pony. Ms. Brown and her attorney did not answer any letters as well as calls. In pursuant to N.J.S.A. 2A:44-52 Ms. Jovanovski put a lien on ownership of said pony.
Superior Court of New Jersey Law Division Monmouth County
Civil Action Verified Complaint
I, Karri Meyers and Lindsey Jovanovski, of full age, hereby certify the following:
1. I am the plaintiff in the above-entitled matter.
2. I am filing this verified complaint about the following reasons: (see attached supporting
documentation).

WHEREFORE, the plaintiff demands judgment as follows:
a. Granting the relief requested, and
b. For such other relief as the Court may deem just and equitable.
3. I certify that the foregoing statements made by me are true. I am aware that if any
of the foregoing statements made by me are willfully false, I am subject to punishment.

Letter Brief in form of Legal Brief in the matter of Meyers/Jovanovski vs. Brown:

In October 2012 Pamela Brown, a welsh pony breeder in Salem NJ, brought Fox
Ridge Tango to Karri Meyers and Lindsey Jovanovski for training. Ms. Jovanovski had
ridden Fox Ridge Tango in a competition in September 2012 and was extremely pleased
with the results. Ms. Brown paid for all expenses of the horse show. She then chose Ms.
Jovanovski and Ms. Meyers to train Fox Ridge Tango. Because Ms. Brown had no
financial means, Ms. Meyers was to train the pony and receive 20%

of

sale in September
of 2013 as well as split the difference after the first $15,000. –

In January 2013 Ms. Meyers contacted Ms. Brown via email as well as

phone

because the pony was not properly registered for horse shows. Ms. Brown informed
Ms.

Meyers

she was having extreme financial problems and did not have health insurance
for herself and could not afford to get her truck fixed. She acted very weird during all
correspondence and was very difficult to deal with. Ms. Meyers offered monetary relief
in exchange for Fox Ridge Tango.

 

Ms. Meyers took Fox Ridge Tango to a horse show March 16, 2013. Ms. Meyers
was approached by several trainers as to the selling status of Fox Ridge Tango. On March
17, 2013, Ms. Brown tried to steal the pony from where Ms. Meyers had the pony boarded.

The State Police were called. The State Police Officer saw the pony had her blankets ripped off.

It was only 30 degrees outside that day and the pony was body clipped. The pony was

thrashing wildly in a trailer and Ms. Brown was calling Ms. Jovanovski a fat ass as well

as saying the pony was too fat. The State Police officer told her to remove the pony and

give to Ms. Jovanovski. The officer also advised her to not come back and not go near

Ms. Jovanovski’s house or she would be arrested.

March 19, 2013, Ms. Meyers hired Ms. Stephanie Hunnel to send a letter to Ms.
Brown advising her the pony was lame and needed veterinary care. Ms. Meyers provided
all care for the pony and had not heard from Ms. Brown after March 17, 2013. Ms. Meyers
sent Ms. Brown bills for the pony as well as boarding because she had upset the training
schedule of Ms. Meyers and violated their agreement to pay Ms. Meyers. Ms. Brown’s
intent in stealing the pony was to avoid paying Ms. Meyers.

May 21, 2013, Mr. Richard Cody, Ms. Brown’s attorney, was advised as well as
Ms. Brown herself there would be a public sale in pursuant to NJ.S.A. 2A:44-52 on June
14, 2013. Mr. Cody was called daily June 12-14, 2013 with no response. On June 15,
2013 Ms. Meyers sold lien along with pony to Lindsey Jovanovski at a public sale for
$15,000. Pamela Brown’s bill from Ms. Meyers, Colts Neck veterinary practice, Joe
Lancaster Farrier service, as well as board was $15,648.00.

On June 20, 2013, Ms. Bernadette Pupilla Garcia called the State Police and said
she was a repo agent for Pamela Brown. Officer State Trooper Crenshaw advised Ms.
Pupilla Garcia to leave Fox Ridge Tango with Ms. Jovanovski. When Ms. Jovanovski
returned to her trailer the pony was gone. The State Police came back and questioned Ms.
Pupilla Garcia. An illegal immigrant with no driver’s license saw Ms. Pupilla Garcia on
Ms. Jovanovski’s trailer taking Fox Ridge Tango.

Ms. Brown refuses to cooperate with the State Police regarding the investigation
of the stolen pony. The State Police as of July 16, 2013, told us to go to court and retain
an order to show cause. There have been many internet threats to ship the pony to
Kentucky and Georgia, on July 25, 2013.

 

Ms. Pupilla Garcia threatened a lawyer on February 28, 2013, to turn ponies into hamburgers

if people did not pay her blackmail money. Ms. Brown has neither capability nor financial

means to properly train and care for Fox Ridge Tango. Has already done damage to

the ponies mental as well as physical health as shown by her actions of March 17, 2013.

 

We are seeking immediate action by the court to find Fox Ridge Tango as well as
retain possession of Fox Ridge Tango. We are extremely concerned about Fox Ridge
Tango’s mental and Physical condition because they have threatened to cut her tendons in
her legs if we try to get her back. Ms. Meyers and Ms. Jovanovski maintain Fox Ridge
Tango’s health insurance at a cost of $1,400 annually and if Fox Ridge Tango is not
found, they will receive a claim of $15,000. As you can see by the above statement it is
not about the money.

 

View Complaint

 

Case dismissed without prejudice due to plan to refile at later date