STATE OF NORTH DAKOTA COUNTY OF BURLEIGH

STATE OF NORTH DAKOTA COUNTY OF BURLEIGH Larson Latham Huettl LLP, Plaintiff vs. Kelly A. Hallworth a.ok.a Kelly A. Bell, Defendant. IN DISTRICT COURT SOUTH CENTRAL JUDICIAL DISTRICT COMPLAINT Case No. 08-2022-CV-01228 1.Plaintiff Larson Latham Huettl LLP, for its reason for motion in opposition to the Defendant Kelly A. Hallworth, alleges and exhibits the Courtroom as follows: 2.Plaintiff Larson Latham Huettl LLP (LLH) was, and is, a legislation agency positioned in Bismarck, North Dakota. 3.Defendant Kelly A. Hallworth (Hallworth) retained Plaintiff LLH to carry out authorized providers concerning a disorderly conduct restraining order petition. 4.On or about Could 29, 2018, Defendant Hallworth executed a written settlement with Plaintiff LLH agreeing to pay Plaintiff LLH for authorized prices incurred whereas representing Defendant Hallworth within the disorderly conduct restraining order petition motion. 5.Plaintiff LLH attended Defendant Hallworth’s petition listening to held on February 12, 2019, and supplied providers for and on behalf of Defendant Hallworth in accord with the Price Settlement. 6.Plaintiff LLH incurred 600 nineteen {dollars} and forty-eight cents ($619.48) of lawyer charges for phone conferences with the consumer, authorized analysis, assembly with the consumer, getting ready for the listening to, illustration on the listening to, journey to and from the courthouse, and negotiations with opposing counsel. Defendant Hallworth was billed this quantity per and in accord with the phrases of the Price Settlement and, thus far, mentioned quantity stays unpaid. 7.Regardless of quite a few makes an attempt made by Plaintiff LLH to gather the excellent steadiness from Defendant Hallworth, Defendant Hallwroth nonetheless refuses to pay. 8.Defendant Hallworth’s present obligation to Plaintiff LLH, as of June 2, 2022, is 9 hundred thirty-three {dollars} and eighty-seven cents ($983.87). Late fee prices proceed to accrue at 1.5 % monthly per the Price Settlement entered into by the events. 9.WHEREFORE, Plaintiff LLH prays for judgment in opposition to Defendant Hallworth as follows: A. Prejudgment and post-judgment curiosity as supplied by the Price Settlement to the extent permitted by North Dakota legislation; B. Restoration of prices and disbursements; C. Affordable lawyer’s charges and bills as supplied within the Price Settlement and to the extent permitted by North Dakota legislation; and, D. Such different and additional reduction because the Courtroom deems simply and equitable. Respectfully submitted this 2nd day of June, 2022. LARSON LATHAM HUETTL LLP Lawyer for the Plaintiff 1100 School Drive Bismarck, ND 58502-2056 (701) 223-5300 /s/ Miguel A. Surun (June 8, 2022) 71162