in the circuit court of jackson county, missouri, at independence

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(Medical Supply) began a process of selecting a corporate bank for the rollout of its healthcare supply chain empowerment program that produces significant benefits to healthcare and its patients. 46. SAMUEL LIPARI sought input from associates and advisors concerning selection of an appropriate national bank that would be capable of a full range of corporate banking services, including nation wide checking, escrow services, short and long term credit facilities, receivables financing and international clearing of transactions between thousands of health systems and their suppliers. 47. Several national banks were evaluated but US BANCORP NA was selected because it also had an investment banking relationship with Piper Jaffray. 48. Piper Jaffray had targeted healthcare customers and participated as underwriter and funds manager for pre IPO healthcare manufacturers and service providers and US BANCORP NA acted as underwriter for corporate bonds of healthcare companies. 49. On or about 4/15/02 SAMUEL LIPARI arranged for Medical Supply’s corporate account to be opened at US BANK’s SW Topeka branch. 12
50. The account was opened in the name of Medical Supply Chain, Inc., using Medical Supply’s federal tax I.D. number with a cashier’s check in the name of Medical Supply’s agent and drawn on Miner’s State Bank of Frontenac Kansas for $7,500.00. 51. On or about 4/25/02 SAMUEL LIPARI opened a personal account in his name at US BANK’s neighborhood branch at 3640 S. Noland Road, Independence, MO. 52. Before opening the checking account, the US Bank employee reviewed SAMUEL LIPARI’s account application and submitted SAMUEL LIPARI’s personal data to Chex Systems, Inc. for a background check, evaluation and verification of eight years of his previous banking history at other banking institutions. 53. SAMUEL LIPARI was approved for a personal checking account and an electronic debit card. 54. SAMUEL LIPARI initially used the personal account to pay expenses of Medical Supply with reimbursement from the corporation. US BANK and US BANCORP’s Knowledge of Medical Supply 55. On 6/5/02 SAMUEL LIPARI contacted Piper Jaffray’s Minneapolis headquarters to speak to Heath Lukatch, managing director of the Piper Jaffray healthcare venture 13
Page 1 and 2: IN THE CIRCUIT COURT OF JACKSON COU
Page 3 and 4: defendants that regularly do busine
Page 5 and 6: defendants was denied and the inter
Page 7 and 8: conduct designed to cause Medical S
Page 9 and 10: 32. The Kansas District Court Judge
Page 11: thereby reducing costs up to 40% in
Page 15 and 16: after the New York Times had began
Page 17 and 18: Medical Supply’s Internal Capital
Page 19 and 20: detailed evaluation of resumes, job
Page 21 and 22: language of paragraph 10 “Securit
Page 23 and 24: November 1st deadline, which requir
Page 25 and 26: Repudiation of Agreement to Provide
Page 27 and 28: 129. At 9 a.m. the following mornin
Page 29 and 30: Defendants’ Knowledge of Breach 1
Page 31 and 32: 153. SAMUEL LIPARI instructed him n
Page 33 and 34: 164. Medical Supply stated that it
Page 35 and 36: 175. Medical Supply counsel called
Page 37 and 38: 183. US BANCORP’s counsel reitera
Page 39 and 40: 196. Medical Supply became fearful
Page 41 and 42: defendants breach, this time with a
Page 43 and 44: an agreement, GHX, L.L.C. and Neofo
Page 45 and 46: Circuit Court of Appeals to uphold
Page 47 and 48: during its negotiation and formatio
Page 49 and 50: COUNT II CAUSE OF ACTION FOR FRAUD
Page 51 and 52: main reason is to know your custome
Page 53 and 54: provided you a bid and we certainly
Page 55 and 56: why this patriot act was brought in
Page 57 and 58: going to constantly come back to th
Page 59 and 60: Lars Anderson US Bancorp; “Ok, we
Page 61 and 62: Group Purchasing Organization (“G
Page 63 and 64:
233. The Defendants were at the tim
Page 65 and 66:
used a change in federal law as a p
Page 67 and 68:
e. causing a Kansas attorney discip
Page 69 and 70:
enefits, dental coverage is being c
Page 71 and 72:
financials in possession of US BANK
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in the circuit court of jackson county, missouri, at independence

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