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VENUE AND JURISDICTION <br /> 3 . This is an action to enforce a redemption agreement and <br /> promissory note as well as to set aside a fraudulent conveyance of <br /> assets. The amount in controversy exceeds $10, 000 and diversity <br /> jurisdiction and venue are proper pursuant to 28 U. S.C. §1332 and <br /> 28 U. S.C. §1391. <br /> GENERAL ALLEGATIONS <br /> 4. On or about July 7, 1977, plaintiffs and Resources <br /> entered into stock redemption agreements, whereby Resources agreed <br /> to purchase shares of its capital stock owned by plaintiffs. <br /> 5. In support of the stock redemption agreements, Resources <br /> executed promissory notes in favor of plaintiffs. <br /> 6. Under the terms of each promissory note Resources was <br /> obligated to make annual principal and interest payments, commenc- <br /> ing on June 1, 1978, with subsequent payments to be made on the <br /> first day of each succeeding June, until the final payment was <br /> made on June 1, 1987. <br /> 7 . Resources has breached the terms of each prommissory note <br /> by its failure to make to each plaintiff the June 1, 1986 payment. <br /> As a result, the total amounts due under the notes, plus accrued <br /> interst, are immediate:y due and payable. <br /> FIRST CLAIM FOR RELIEF <br /> 8. Plaintiff Joseph E. Harker realleges the allegations <br /> contained in paragraphs 1 through 7 hereof. <br /> 9. As a result of its failure to pay according to the terms <br /> of the note, Resources is liable to Joseph E. Harker in an amount <br /> to be determined at trial, but in excess of $350, 000. <br /> WHEREFORE, Plaintiff Joseph E. Harker demands judgment <br /> against Mid-Continent Resources, Inc. in an amount to be <br /> determined at trial, but in excess of $350, 000, toc ::ther with <br /> interest, costs, and disbursements, including reasonable <br /> attorneys fees, and for such othe- and further relief as to the <br /> Court seems proper and just. <br /> 86364/82/01 -2- <br />