12612 DEC -4 P It 32 I - San Diego Reader

ecover from defendant its reasonable attorneys fees, costs and disbursements incurred in this matter.
SECOND CAUSE OF ACTION
(Open Book Count against Defendants Equustria and Remley)
15. Plaintiff refers to Paragraphs I through 14 hereinabove, and hereby incorporates the same as
though fully set forth herein.
16. Within the last two years defendants Equustria and Remley and DOES 1 though 10, inclusive,
became indebted to Plaintiff on an open book account in the sum of $1,081,084.20 for money due
Plaintiff.
17. Neither the whole nor part of this sum has been paid, although demand therefor has been
made, and there is now due, owing and unpaid the sum of $1,081,084.20, which is the reasonable
value, with interest therein at the rate of 1.5% per month, or the maximum allowed by law, from
November 21, 2012.
THIRD CAUSE OF ACTION
- (Account Stated Count against Defendants Equustria and Reniley)
18. Plaintiff refers to Paragraphs 1 through 17 hereinabove, and hereby incorporates the same as
though fully set forth herein.
19. Within the last two years defendants Equustria and Remley and DOES 1 though 10, inclusive,
became indebted to Plaintiff because an account was stated in writing by and between Plaintiff and
defendants in which is was agreed that defendants were indebted to Plaintiff in the sum of
$1,081,084.20.
20. Neither the whole nor part of this sum has been paid, although demand therefor has been
made, and there is now due, owing and unpaid the sum of $1,081,084.20, which is the reasonable
value, with interest therein at the rate of 1.5% per month, or the maximum allowed by law, from
November 21, 2012.
FOURTH CAUSE OF ACTION
(Common Count for Work, Labor, Services and Materials Rendered against Defendants
Equustria and Remley)
21. Plaintiff refers to Paragraphs 1 through 20 hereinabove, and hereby incorporates the same as
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Complaint