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| Suzette Jerez Neal National Petroleum Liar. Circumventer. Scammer. Burnsville, Minnesota |
| 31st of Dec, 2011 by User905438 |
| Liar. Circumventor. Scammer. Remember: Her client is her victim! Modus operand is to get buyer to sign a contract, then in order to "save the contract" she gets buyer to “put some skin in the game.†Once a buyer gives her money, that game is over! Few actually sue, which is what she knows all too well. She has a criminal conviction from 2010 (don’t take my word for it, for more details call criminal court records 1-612-348-2040), and a more recent Federal civil case lodged August 2, 2011 in Minnesota District Court (details are online): Generadora San Felipe Limited Partnership v. Neal et al Plaintiff: Generadora San Felipe Limited Partnership Defendants: Suzette Jerez Neal, World Gas Belize Limited and National Petroleum Corporation If you’re a broker or a buyer and you meet up with this witch (or any of her office cronies) online or by phone, then run like hell! |
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Some of the records from pacer.gov are scanned and uploaded below
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CASE 0:11-cv-02193-DWF-SER Document 1 Filed 08/02/11 Page 1 of 6
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» UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Generadora San Felipe Limited Partnership, CASE NO. 11-___j .4
Plaintiff,
E
vs.
COMPLAINT AND JURY DEMAND
Suzette J erez Neal, World Gas Belize Limited, «
and National Petroleum Corporation,
Defendants.
This is a commercial dispute between Plaintiff Generadora San Felipe Limited
Partnership (“Generadora”) and Defendants Suzette Jerez Neal, World Gas Belize Limited '
(“World Gas Belize”), and National Petroleum Corporation (“National Petroleum”) arising out of n
the Defendants’ breach of a contract for the purchase of fuel oil. In support of its claims,
Generadora states:
INTRODUCTION ’
l. Generadora and the Defendants entered into two contracts for the purchase of fuel
oil #6. Generadora advanced a total of U.S. $1, 726, 806.66 to the Defendants towards the
purchase price of the fuel oil. To date, the Defendants have never delivered the fuel oil to ‘
Generadora and have simply retained the $1, 726, 806.66 paid by Generadora. Generadora now P
seeks to recoup the monies advanced towards the purchase of the fuel oil and to recover all other
damages it has incurred as a result of the Defendants’ breach of contract.
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CASE 0:11-cv-02193-DWF-SER Document 1 Filed 08/02/11 Page 2 of 6
PARTIES
2. Plaintiff Generadora San Felipe Limited Partnership is a partnership organized
and existing under the laws of the Turks and Caicos Islands with its principal place of business in
the Dominican Republic.
3. On information and belief, Defendant Suzette Jerez Neal is a resident of, and
domiciled in, the State of Minnesota.
' 4. On information and belief, Defendant World Gas Belize Limited is a Texas
corporation with its principal place of business in Minnesota. Moreover, World Gas Belize is an
assumed name of Suzette Jerez Neal. At all relevant times, World Gas Belize has conducted
business in Minnesota.
5. On information and belief, Defendant National Petroleum Corporation is a
Minnesota corporation with its principal place of business in Minnesota. At all relevant times,
National Petroleum has conducted business in Minnesota.
JURISDICTION AND VENUE
6. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §l332 because
Generadora is a citizen of a foreign state and the Defendants are citizens of different states and
the matter in controversy exceeds $75, 000.00 exclusive of interest and costs. Additionally,
jurisdiction is proper because the Parties’ contract dated May 13, 2011 (the “2011 contract”)
contains a Consent-to—Jurisdiction clause which provides, in relevant part, that “each party
hereby irrevocably consents to the non—exclusive jurisdiction of the ...United States District
Court for the District of Minnesota, in connection with any action, suit or other proceeding
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CASE 0:11-cv-02193-DWF-SER Document 1 Filed 08/02/11 Page 3 of 6
arising out of or relating to this agreement or any action taken or omitted hereunder.”
7. Venue is proper in this Court pursuant to 28 U.S.C. §1391 because a substantial
part of the events or omissions giving rise to Generadora’s claims occurred in the District of
Minnesota. Venue is also proper because, on information and belief, the Defendants transact or
have transacted business in the District of Minnesota and are subject to personal jurisdiction in
the District of Minnesota.
GENERAL ALLEGATIONS
8. Generadora and World Gas Belize entered into a contract dated July 16, 2010 (the
“2010 contract”) for the purchase of fuel oil #6.
_ 9. Generadora advanced U.S. $1, 626, 806.66 to World Gas Belize and U.S.
$100, 000.00 to National Petroleum toward the purchase price due under the 2010 contract.
10. The Defendants never delivered the fuel oil #6 contracted for under the 2010
contract.
11. In February 2011, Generadora demanded the return of the U.S. $1, 726, 806.66 it
had advanced towards the purchase of fuel oil # 6 under the 2010 contract and reserved its rights
to recover additional damages as a result of the Defendants’ breach of the 2010 contract.
12. In an attempt to resolve the dispute between Generadora and the Defendants
relating to the Defendants’ breach of the 2010 contract, Generadora entered into the 2011
contract, with Suzette J erez Neal, World Gas Belize, and National Petroleum for the purchase of
fuel oil #6.
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CASE 0:11-cv-02193-DWF-SER Document 1 Filed 08/02/11 Page 4 of 6
13. Under the terms of the 2011 contract, the Defendants agreed to credit the amounts
advanced by Generadora under the 2010 contract towards the purchase price of the fuel oil #6
under the 2011 contract by deducting U.S. $1, 726, 806.66 from the purchase price under the 2011
contract.
14. Under the terms of the 2011 contract, the Defendants were obligated to deliver the
fuel oil #6 within 21 days following the Defendants’ receipt of con?rmation from Citibank that a
letter of credit in favor of National Petroleum had been issued.
15. On July 5, 2011, the Defendants received con?rmation from Citibank that it had
issued the letter of credit issued in favor of National Petroleum. Accordingly, the Defendants
were obligated to deliver the fuel oil #6 on or before July 26, 2011.
16. The Defendants did not deliver the fuel oil #6 to Generadora by July 26, 2011. In
fact, to date, the Defendants have not delivered any of the contracted-for fuel oil #6 to
Generadora.
COUNT I—BREACH OF CONTACT
17. Plaintiff incorporates herein the allegations contained in Paragraphs 1 to 16.
18. Pursuant to the 2011 contract, the Defendants agreed to deliver a speci?ed
amount of fuel oil #6 to Generadora on or before July 26, 2011 in exchange for the purchase
price minus the credit for the US. $1, 726, 806.66 Generadora advanced to National Petroleum
and World Gas Belize under the 2010 contract.
19. The Defendants breached the 2011 contract by failing to deliver the fuel oil #6 to
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CASE 0:11-cv-02193-DWF—SER Document 1 Filed 08/02/11 Page 5 of 6
Generadora as required.
20. Moreover, the Defendants have refused to return the amounts advanced by
Generadora under the 2010 contract which was a portion of the consideration for the 2011
contract.
21. As a direct and proximate result of the Defendants’ breach of contract,
Generadora incurred substantial ?nancial and pecuniary harm, as well as direct and
consequential damages in excess of $75, 000.
COUNT II—UNJUST ENRICHMENT
22. Plaintiff incorporates herein the allegations contained in Paragraphs 1 to 21.
23. As a result of the Defendants’ failure to deliver the contracted-for ?iel oil and
refusal to return the amounts advanced by Generadora towards the purchase of fuel oil, the
Defendants have realized and appreciated a bene?t from the consideration of U.S. $1, 726, 806.66
Generadora paid to the Defendants.
24. Retention of this bene?t and all pro?ts and revenues resulting from this benefit by
the Defendants would be inequitable and unjust.
25. In fairness, the Defendants should be required to return to Generadora the U.S.
$1, 727, 806.66 Generadora advanced to the Defendants and to disgorge their pro?ts and revenue
as a result of the bene?t the Defendants realized.
WHEREFORE, Plaintiff prays forjudgment as follows:
a. Judgment against defendants Suzette Jerez Neal, World Gas Belize Ltd., and
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CASE 0:11-cv-02193-DWF-SER Document 1 Filed 08/02/11 Page 6 of 6
National Petroleum Corporation in the sum of $1, 726, 806.66;
' b. Awarding Generadora prejudgment and post-judgment interest;
c. Awarding Generadora its attorneys’ fees, costs, and disbursements; and,
d. Such other and ?lrther relief as the Court deems just and equitable.
August 2, 2011 ZELLE, HOFMANN, VOELBEL, &
MASON LLP
/s/ Eric E. Caugh .
Eric E. Caugh
(MN Bar No. 026703X)
500 Washington Avenue South
Suite 4000
Minneapolis, Minnesota 55415
Phone: 612-339-2020
Fax: 612-336-9100
ATTORNEY FOR PLAINTIFF
GENERADORA SAN FELIPE LIMITED
PARTNERSHIP |
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