The complaint was filed by Valerie Vaughan, attorney in fact for Victoria Vaughan.
Valerie Vaughan is Victoria Vaughan’s agent under a power of attorney dated June 16, 2008.
The plaintiff, through her counsel Rexford C. Kosack, is asking the court to compel Calvo to fulfill two promissory notes and convey to her two lots of real property on Rota, each with clear title and each lot to consist of at least 1,000 square meters.
She is also asking the court to render judgment in his favor against Calvo’s Development Inc. and Calvo in the sum of $15,000 with interest at the rate of 2 percent per annum starting from May 1, 2003; for attorney’s fees; costs of suit; and other relief the court may deem proper.
According to the complaint, Calvo executed two promissory notes to the plaintiff on March 17, 2003 promising to pay $25,000 each for clear titles of two 1,000- square meter properties on Rota.
But Calvo has not conveyed to the plaintiff the title for the two properties.
As a consequence, the plaintiff said Calvo owes her clear title to the properties on Rota.
On the same date, the plaintiff said Calvo also executed a third promissory note stating that Calvo’s Development will pay the plaintiff $15,000 payable at $500 a month, due on the 15th of each month for value received with interest at 2 percent per annum.
The plaintiff said the third promissory note states that Calvo personally guarantees $15,000 loan payable if Calvo Development Inc. is unable to pay for any reason.
The plaintiff said Calvo’s Development has not made any payments upon the third promissory note of $15,000.
The plaintiff is suing the defendants for three causes of action — breach of contracts for the three promissory notes Calvo issued but failed to fulfill.
