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

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on November 1st and the resulting effects of that delay on its projected financials including lost profit of $51,795,005.00 lost increase in average valuation of $155,385,015.00 Candidate lost revenue of $15,499,788.00. 180. The email explained that these injuries would be far greater if a December 1st deadline is missed and if the company does not recover from US Bank’s denial of the escrow accounts the total third year losses of the company would be as follows: lost profits $51,795,005.00 loss of increased company avg. valuation of $155,385,015.00 Candidate lost revenue of $15,499,788.00 and Customer losses of $697,486,200.00. 181. On or about Wednesday 10/30/02, US BANCORP’s counsel sent a letter to the court dismissive of Medical Supply’s complaint and stating that it would oppose all requested relief. 182. On or about Thursday 10/31/02, Medical Supply called US BANCORP’s counsel explaining the necessity of the relief sought and specifically the relief requested under paragraph 66 of the first federal complaint seeking to stop US BANK from reporting negative information about Medical Supply under the USA PATRIOT Act. 36
183. US BANCORP’s counsel reiterated his belief Medical Supply needed to find another bank and that no liability existed. 184. Medical Supply’s counsel explained that SAMUEL LIPARI will not risk a hundred million dollar company that requires high level banking services to future damage from a secret USA PATRIOT Act report that has misinformation in it and would create a black mark preventing them from ever being able to do any business. 185. US BANCORP’s counsel said it would not agree to even just the relief sought in paragraph 66 of the first federal complaint. 186. Medical Supply asked US BANCORP’s counsel if his firm would act as an escrow agent for accounts to be deposited in US BANK, since Shook, Hardy and Bacon had declined to do so. 187. US BANCORP’s counsel refused to do so stating that US Bank did not owe any duty to Medical Supply. Defendants’ Intellectual Property Misappropriation 188. Realizing there was no immediate solution to this matter, and the fact that a previous business model pricing system developed by SAMUEL LIPARI in 1993-1995 was appropriated by HSCA, Medecon and Cardinal Healthcares’ subsidiary Owen Healthcare through exploitation of a 37
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 and 12: thereby reducing costs up to 40% in
Page 13 and 14: 50. The account was opened in the n
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: 175. Medical Supply counsel called
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

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

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