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

195. Plaintiff hereby re alleges the preceding averments of
facts and incorporates them herein.
196. The Defendants breached their contract with Medical
Supply (MSCI) which interests are now assigned to SAMUEL
LIPARI to provide MSCI with a full range of business
banking services, including corporate trust services and
escrow agency to be performed lawfully and professionally
with a “five star guarantee” of quality of service.
197. This contract was executed in writing by the
Defendants and MSCI when their respective agents opened the
Medical Supply Chain Corporate checking account.
198. The Defendants breached their contract with MSCI to
provide MSCI with corporate trust services, escrow agency
and the service of hosting escrow accounts for MSCI and its
candidates.
199. This contract was made while the plaintiff was
influenced by representations over the phone at a distance
of 300 miles between the defendant US BANK’s St. Louis
office and the plaintiff as chief executive officer of MSCI
a customer of US BANK’s Noland Road Independence office in
the regular course of business.
200. No writing or other memorialization of this contract
to provide a full range of banking services with a “Five
Star Guarantee” was referred to or contemplated at any time
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