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

R.S.Mo. § 417.450, Breach Of Fiduciary Duty, and Prima
Facie Tort.
I. Jurisdiction
1. This court has jurisdiction over questions of Missouri
common law in escrow contracts and Missouri statutory law
on trade secrets raised in a timely manner by a plaintiff
that has never slept on his rights.
2. The injury complained of occurred on December 1, 2002.
3. The defendants are moneyed corporations having banking
powers and subject to the statute of limitations of six
years in R.S.Mo. § 516.420.
4. The trade secret misappropriation complained of was
discovered on November 6, 2002.
5. The defendants if not subject to the statute of
limitations of six years in R.S.Mo. § 516.420 are subject
to the five year statute of limitations in R.S.Mo. §
417.461.
II. Venue
6. The plaintiff makes a well pleaded complaint claiming
state common law and state statutory causes of action over
breach of contract to provide escrow services, fraud, trade
secret misappropriation under R.S.Mo. § 417.450, breach of
fiduciary duty, and prima facie tort taking place in
Jackson County. The plaintiff’s complaint is against
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