Magistrate Court of Lowndes County
Statement of Claims
1. The court has jurisdiction over the defendant.
2. Plaintiff says the defendant is indebted to the plaintiff as follows:
The first week of November 2012, I had given Melissa a deposit for a horse named Elvis. I had him checked out by Dr. Rogers, my veterinarian, and we discovered that he had a lameness problem that was permanent. Also, we discovered that he had been drugged before the exam as evidenced by a lab.
I returned this horse to Melissa in January, and she told me about Reload (another horse she had for sale) and said that she would transfer my deposit over to him. After trying Reload, I had Dr. Rogers do the pre-purchase exam. He developed an abscess, and was lame, so we did not finish the exam. However, Dr. Rogers had already drawn the blood sample so, in light of my previous experience, we sent it in to the testing lab. As you can see from the attached paperwork, he too was drugged. Melissa signed a seller’s statement which indicated the horse was free of any drugs for a least the previous 30 days. Before receiving the blood work results, I talked with Melissa about coming back out to see him and inquired about the abscess. She informed me that Reload had died.
continued in complaint