sac county man demands jury trial in case of treated seed corn he claims did not perform as promised

8/12/2019 Sac County Man Demands Jury Trial in Case of Treated Seed Corn He Claims Did Not Perform as Promised

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IN THE IOWA DISTRICT COURT IN AND FOR SAC COUNTY

TYSON BETTIN,

Plaintiff,

vs.

SYNGENTA CORPORATION,SYNGENTA CROP PROTECTION, LLC,SYNGENTA SEEDS, INC., and JEFFSCHROEDER,

Defendants.

No. LA __________________

PETITION AT LAW

Plaintiff Tyson Bettin, for his Petition at Law against Defendants, states:

THE PARTIES

1. Plaintiff Tyson Bettin (Bettin) is an individual who is and, at all material times,has been a resident of Early, Sac County, Iowa.

2. Defendant Syngenta Corporation is a corporation organized under the laws of thestate of Delaware with its home office in Wilmington, Delaware. Syngenta Corporation conducts

business in the state of Iowa, is registered with the Iowa Secretary of State as conducting

business in the state of Iowa, and has a registered agent in the state of Iowa for service of

process.

3. Defendant Syngenta Crop Protection, LLC is a corporation organized and existingunder the laws of the state of Delaware and maintains its principal place of business in

Greensboro, North Carolina. Syngenta Crop Protection, LLC conducts business in the state of

Iowa, is registered with the Iowa Secretary of State as conducting business in the state of Iowa,

and has a registered agent in the state of Iowa for service of process.

4. Defendant Syngenta Seeds, Inc. is a Delaware corporation with its principal placeof business in Minneapolis, Minnesota. Syngenta Seeds, Inc. conducts business in the state of

E-FILED 2014 APR 17 4:38 PM SAC - CLERK OF DISTRICT COURT


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Iowa, is registered with the Iowa Secretary of State as conducting business in the state of Iowa,

and has a registered agent in the state of Iowa for service of process.

5. Defendant Jeff Schroeder (Schroeder) is an individual who resides in WallLake, in Sac County, Iowa.

FACTUAL ALLEGATIONS

6. In 2013, and previous years, Tyson Bettin planted and harvested corn in SacCounty, Iowa.

7. Jeff Schroeder was at the times relevant to this petition, an authorizedrepresentative of the Syngenta Defendants, and operated a business located in Odebolt, Iowa,

under the name Schroeder Ag. Mr. Schroeder sold Syngenta products. The website operated by

Syngenta Corporation for itself and its subsidiaries, including the other Syngenta Defendants,

lists Schroeder Ag as an authorized seller of Syngenta products, at the website

www.syngentacropprotection.com.

8. The Syngenta Defendants are the producers of the products identified in thispetition, below.

9. Land in Iowa, and in particular in the area where Mr. Bettin farms, is known tohave the presence of corn rootworm. Rootworms become particularly problematic where corn is

planted in successive years, a practice known as corn-on-corn planting.

10. In advance of the 2013 planting season, Bettin approached Jeff Schroeder, toinquire about obtaining seed corn for use in 2013, and specifically informed Mr. Schroeder that

he needed rootworm protection due to his intended corn-on-corn planting. As a result, the

Defendants were informed of the specific intended use and requirements of the product being

sought.



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11. Mr. Bettin requested from Mr. Schroeder the best product for rootworm resistancefor corn-on-corn planting and Mr. Schroeder selected and represented the best product available

for rootworm resistance was Syngenta seed corn, with a Syngenta treatment of the seed corn

designed to make it resistant to rootworms. The specific treatment warranted in this case was

supplied by one or more of the Syngenta Defendants, and upon information and belief the

specific treatment was a product named Avicta as described immediately below.

12. The Syngenta Defendants written marketing materials and written warrantiesspecifically proclaim the rootworm resistant properties and benefits of their products, and

rootworm treatments including a product sold under the name Avicta Complete Corn 500

(Avicta), and specifically claim the product will protect corn seedlings from corn rootworm.

Whatever treatment was selected by the Defendants, if other than Avicta, failed completely as

described below and all claims made in this petition apply equally to such product.

13. In reliance upon the above described claims and discussions, including with Mr.Schroeder, Bettin purchased from Defendants seed corn sold under the brand Garst, which seed

corn was to be treated by one or more of the Syngenta Defendants at their facilities, with Avicta,

and then delivered to Bettin.

14. The Syngenta seed corn that was or was supposed to be treated with Avicta isreferred to herein as the Treated Seed Corn.

15. Mr. Bettin wrote his check as payable to Syngenta Seeds, delivered it to JeffSchroeder at Schroeder Ag, and the Syngenta Defendants shipped the Treated Seed Corn to

Schroeder Ag.

16. In late April 2013, and specifically at a date after April 20 of 2013, Bettinacquired the above-described Treated Seed Corn from Schroeder Ag. The Defendants did not, as



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part of this transaction, supply Mr. Bettin with any written paperwork containing a disclaimer of

warranties, limitations of remedies, or otherwise. Prior to Mr. Bettin acquiring the Treated Seed

Corn described above, the Treated Seed Corn had been placed by the Syngenta Defendants into

large crates containing over 2,000 pounds of Treated Seed Corn each, which is the packaging in

which Mr. Bettin obtained the Treated Seed Corn from Schroeder Ag. Mr. Bettin did not observe

on the crates any language regarding limitations of warranties or remedies, nor was he separately

provided with any at the time he acquired the Treated Seed Corn at issue. Schroeder Ag

representatives picked up from Bettin the crates in which the Treated Seed Corn was delivered

shortly after Bettin completed planting.

17. Mr. Bettin began planting the Treated Seed Corn at issue on or about April 29,2013, and completed the planting on or about May 15, 2013.

18. Mr. Bettin is an experienced farmer who followed all appropriate and requiredpractices for the planting of the corn, fertilization, and other care and maintenance of the Treated

Seed Corn at issue. Mr. Bettin purchased and planted various types of seed corn from suppliers

other than the Syngenta Defendants, with various other rootworm treatments in 2013, including

other products planted side by side with the Treated Seed Corn, thereby allowing yield

comparisons.

19. As the corn began to grow in the summer of 2013, Mr. Bettin noted the TreatedSeed Corn was not growing properly and was underperforming. Within a matter of a few days, if

not the same day, that Mr. Bettin first determined there was a problem with the growth and

development of the corn growing from the Treated Seed Corn, he contacted the Syngenta

Defendants, through their representative, Tom Schroeder, to inform the Defendants of the

apparent defects in the Treated Seed Corn.



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20. The Syngenta Defendants acknowledged notice of the defect and responded bysending a representative to tour Mr. Bettins fields, with Mr. Bettin, as well as Tom Schroeder.

21. An inspection of the corn grown from the Treated Seed Corn revealed extensivedamage caused by rootworms.

22. The fact of extensive rootworm damage was confirmed by an Iowa StateUniversity agronomist named Paul Kassell.

23. The yield obtained from the corn grown with the Treated Seed Corn at issuevaried between zero and 50 bushels per acre. Comparatively, the yields in Mr. Bettins other corn

plantings, including that planted side by side with the Treated Seed Corn, averaged closer to 150-

170 bushels per acre.

24. Mr. Bettin planted over 400 acres with the Treated Seed Corn, all in Sac County,Iowa.

25. Mr. Bettin paid approximately $45,000 for the Treated Seed Corn.26. No Defendant replaced the Treated Seed Corn at issue, nor did any Defendant

offer to replace the Treated Seed Corn.

27. No Defendant refunded to Mr. Bettin the purchase price paid for the TreatedSeed Corn, nor offered to refund the purchase price for the Treated Seed Corn.

28. The Treated Seed Corn that was to be delivered to Bettin was not the TreatedSeed Corn that Defendants agreed to deliver. The Treated Seed Corn was specifically

represented that it would be treated with a rootworm resistant treatment. The wholesale failure of

the Treated Seed Corn is demonstrative that it was not, in fact, treated with the rootworm

resistant treatment, or was treated improperly, and, therefore, the agreed to Treated Seed Corn

was not the product which was delivered.



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29. Bettin has suffered damage as a result of the Defendants breach of express andimplied warranties.

COUNT I

BREACH OF EXPRESS WARRANTY

30. Plaintiff re-alleges and incorporates by this reference the allegations contained inparagraphs 1-29 above.

31. The Defendants sold the Treated Seed Corn and expressly warranted the seed cornwould be treated with a product (Avicta) that would make it rootworm resistant, including but

not limited to those warranties and representations as described above.

32. The Treated Seed Corn and Avicta did not conform to the express warranties.33. The breach of express warranty was a cause of the Plaintiffs damage.34. Plaintiff gave Defendants timely notice of the defective and nonconforming

condition of the Treated Seed Corn and Avicta.

35. The Plaintiff was damaged as a result of the breach of express warranties.WHEREFORE, Plaintiff Tyson Bettin prays for judgment against the Defendants in an

amount that will fully and fairly compensate him for his damages, together with the costs of this

action, including attorneys fees, pre and post judgment interest as provided by law, for the costs

of this action, and for such other equitable relief as the Court deems appropriate.

COUNT II

BREACH OF IMPLIED WARRANTY OF

FITNESS FOR PARTICULAR PURPOSE




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37. At the time of the-sale Defendants knew or should have known of Bettinsparticular needs and purpose for the Treated Seed Corn and Avicta, being the need for a

rootworm resistant seed corn.

38. Defendants had reason to know that the Plaintiff was relying upon theDefendants skill or judgment to select the rootworm resistant Treated Seed Corn and Avicta.

39. The Plaintiff relied upon the Defendants skill or judgment.40. The Treated Seed Corn and Avicta were not fit for their particular purpose.41. The failure of the Treated Seed Corn and Avicta to be fit the particular purpose

was a cause of the Plaintiffs damage.

42. Timely notice was given to the Defendants of the failure of the Treated Seed Cornand Avicta to be fit for their particular purpose.

43. The Plaintiff suffered damage as a result of the failure of the Treated Seed Cornand Avicta to be fit for their particular purpose.

WHEREFORE, Plaintiff Tyson Bettin prays for judgment against the Defendants in an




COUNT III

BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY


45. Defendants were merchants of the Treated Seed Corn and Avicta46. The Treated Seed Corn and Avicta were not merchantable.



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47. Timely notice was given to the Defendants of the failure of the Treated Seed Cornand Avicta to be merchantable.

48. The lack of merchantability was a cause of Plaintiffs damage.49. The Plaintiff suffered damage as a proximate result of the failure of the Treated

Seed Corn and to be merchantable.

WHEREFORE, Plaintiff Tyson Bettin prays for judgment against the Defendants in an




JURY DEMAND

Plaintiff Tyson Bettin, pursuant to Iowa Rule of Civil Procedure 1.902, hereby demands a

trial by jury on all issues triable to a jury.

/s/ Matthew L. PrestonMatthew L. Preston, PIN: AT0006314BRADY PRESTON BROWN PC2735 First Avenue S.E.Cedar Rapids, IA 52402Phone: 319/866-9277Fax: 319/[email protected]

ATTORNEY FOR PLAINTIFF



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E-FILED 2014 APR 30 9:23 AM SAC - CLERK OF DISTRICT COURT


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IN THE IOWA DISTRICT COURT FOR SAC COUNTY

V

Tyson Bettin, LAW NO.: LACVl9513Plaintiffs,

APPEARANCE OF SCOTT L. HALBURSyngenta Corporation, Syngenta CropProtection, LLC, Syngenta Seeds, Inc. andJeff Schroeder,Defendants.

COMES NOW Scott L. Halbur of the law firm Faegre Baker Daniels LLP and herebyenter an appearance on behalf of Syngenta Corporation, Syngenta Crop Protection, LLC, andSyngenta Seeds, Inc.

Dated: I|l4ay I,2014 FAEGRE BAKER

Scott L. Halbur 4T0010936scott. halbur@Fae greB D. com

801 Grand Avenue, 33rd FloorDes Moines, Iowa 50309Telephone: 51 5) 248-9000Facsimile: 515) 248-9010ATTORNEYS FOR DEFENDANTSSYNGENTA CORPORATION,SYNGENTA CROP PROTECTION,LLC, and SYNGENTA SEEDS,INC.

)))))))))))

E-FILED 2014 MAY 01 3:58 PM SAC - CLERK OF DISTRICT COURT


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CERTIFICATE OF SERVICEThe undersigned hereby certifies that a ue copy of this Appearance of Scott L. Halburwas served

May 2014.upon the attorneys of record for the parties by U.S. mail and email on the I of

BRADY PRESTON BROWN P.C.Matthew L. Preston2735 First Avenue S.E.Cedar Rapids IA 52402MPrestonfrDCradyPrestonBrown. comATTORNEY FOR PLAINTIFF

us.54106r 80.01



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Tyson Bettin,Plaintiffs,

)))))))))))

LAV/NO.: L4CV019513

VSyngenta Corporation, Syngenta CropProtection, LLC, Syngenta Seeds,Inc. andJeff Schroeder,

APPLICATION FOR ADMISSION PROHAC WCE OF SHANE ANDERSON

Defendants.

Pursuant to Iowa Court Rule 31 .14, and Iowa Code 602.10111, Scott L. Halbur, amember of the Bar of Iowa and this Court, respectfully moves this Court to admit ShaneAnderson, of the law firm of Faegre Baker Daniels, LLP, to pracLice pro hac vice as counsel forDefendants Syngenta Corporation, Syngenta Crop Protection, LLC, and Syngenta Seeds, Inc. inconnection with this lawsuit.

A verified statement of Shane Anderson, attached hereto in support of this Motion shows:1. Shane Anderson is a practicing attorney with the law firm of Faegre Baker

Daniels LLP with offices at2200 Wells Fargo Center, 90 South Seventh Street, Minneapolis,MN 55402-3901, telephone: 612-7 66-7261.

2. Mr. Anderson's residence address is: 6353 Neddersen Circle North, BrooklynPark, Minnesota 55445.

3. The clients sought to be represented are Defendants:Syngenta CorporationShipley Building, Concord Plaza3411 Silverside Road, Suite 100Wilmington, DE 19810



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Syngenta Crop Protection LLCP.O. Box 18300Greensboro NC 27419Syngenta Seeds Inc.1 1 055 W ayzata BoulevardMinnetonka MN 55305

4. Mr. Anderson is currently licensed in good standing and admitted to practice inthe following jurisdictions and courts:

Court Date AdmittedMinnesota Supreme Court October 27 2006Eighth Circuit Court of Appeals November 5 2007U.S. District Court for the District of Minnesota January 24 2007U.S. District Court for the Northern District of Florida January 29 2013U.S. District Court for the Central District of Illinois ili4ay 16 2073U.S. District Court for the Northem District of Illinois December ll 20135. Mr. Anderson has not been denied admissionpro hac vice inthis State has not

had admissionpro hac vice revoked in this State and has not been denied admission in anyjurisdictions.

6. Mr. Anderson has not been formally disciplined or sanctioned by any court in thisState has not been the subject ofany injunction cease and desist order or other action arisingfrom a finding that he engaged in the unauthorized practice of law in this State or elsewhere andhas not been the subject of any formal disciplinary proceeding brought by any disciplinaryauthority or unauthorizedpractice of law in any other jurisdiction.

2



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7. Mr. Anderson has not been placed on probation by any disciplinary authority inany other jurisdiction. or held in contempt or otherwise sanctioned by any court in a writtenorder in the last five years for disobedience to its rules or orders.

8. Mr. Anderson has not filed an application to appear pro hac vice in this Statewithin the preceding two years.

9. Mr. Anderson is familiar with the Rules of Professional Conduct, the disciplinaryprocedures of this State, the standards of professional conduct, the applicable local rules, and theprocedures of the Court, and agrees to the jurisdiction of the courts of Iowa with respect to anymatter arising out of his conduct in this proceeding and agrees to be bound by the Code ofProfessional Responsibility applicable to Iowa lawyers and the interpretation thereof by the Iowacourts.

10. The following attorney will be of record and sponsor for Mr. Anderson s pro hacvice request: Scott L. Halbur, Faegre Baker Daniels LLP, 801 Grand Avenue, 33rd Floor, DesMoines, Iowa 50309, telephone 515-447-4723. As required by Rule 31.14(3), the undersignedlocal counsel states that he will actively participate in this proceeding and will fulfill all of theduties set forth in Rule 31.1a(3)(a-d).

11. Mr. Anderson acknowledges that service upon the in-state lawyers identifiedabove in all matters connected with the proceeding will have the same efTect as if personallymade upon Mr. Anderson.

12. A copy of this Motion for Admission Pro Hac Vice will be served on all partieswho have appeared in this proceeding.

J



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WHEREFORE, the undersigned respectfully requests an Order from this Court admittingShane Anderson to practice pro hac vice as counsel for Defendants Syngenta Corporation,Syngenta Crop Protection, LLC, and Syngenta Seeds, Inc. in this proceeding.

Dated: May , 2014 FAEGRE BAKER DANIELS

Halbur 4T001 6scott.halbur @F ae gr eB[. com801 Grand Avenue, 33rd FloorDes Moines,Iowa 50309Telephone: 515) 248-9000Facsimile: 515) 248-9010ATTORNEYS FOR DEFENDANTSSYNGENTA CORPORATION,SYNGENTA CROP PROTECTION,LLC, and SYNGENTA SEEDS,INC.

CERTIFICATE OF SERVICEThe undersigned hereby certifies that a true

Hac Vce of Shane Anderson was served upon themail and email on the 7 auy of May 2014.copy of this Application for Admission Proattorneys of record for the parties by U.S.

BRADY PRESTON BROWN, P.C.Matthew L. Preston2735 First Avenue, S.E.Cedar Rapids, IA 52402MPreston@CradyPre stonBrown. comATTORNEY FOR PLAINTIFF

4

dms.us.54106217.02



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IN THE IOWA DISTRICT COURT FOR SAC COI.INTY

Tyson Bettin,Plaintiffs,

Syngenta Corporation, Syngenta CropProtection, LLC, Syngenta Seeds, Inc. andJeff Schroeder,

LAW NO.: LACV19513

VERIFIED STATEMENT OFSHANE ANDERSON IN SUPPORTOF APPLICATION FOR ADMISSIONPRO HAC WCE

)))))))))))efendants.

I, Shane Anderson, hereby affirm, on penalty of perjury, that the statements made in theaccompanying Motion for Admission Pro Hac Vice are true and correct.

Dated: uy b,zot+ F DANIELS LLP

Andersonshane. anderson@Fae greBD. com2200 Wells Fargo CenterMinneapolis, MN 55402Telephone: 612) 7 66-7261Facsimile: 612) 766-1600

5



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Tyson Bettin,

Plaintiffs,

v.

Synenta Co!"o!ation, Synenta C!o"

P!ote#tion, $$C, Synenta See%s, In#. an%&eff S#'!oe%e!,

Defen%ants.

(

(

((

((

(

((

(

(

$AW NO.) $AC*+-/

ORDER GRANTING APPLICATION

FOR ADMISSIONPRO HAC VICE OF

SHANE ANDERSON

On 0ay 111, 2+3, S#ott $. Hal45!, atto!ney fo! Defen%ants Synenta Co!"o!ation,

Synenta C!o" P!ote#tion, $$C, an% Synenta See%s, In#, file% a 0otion fo! A%6issionPro Hac

Viceof S'ane An%e!son. T'e 0otion #o6"lies 7it' R5le /.3. T'e a""li#ant is f5!t'e!

!e6in%e% of R5le /.38/(.

ORDER

IT IS THEREFORE ORDERED t'at t'e 0otion fo! A%6issionPro Hac Viceof S'ane

An%e!son is 'e!e4y !ante%.

Date% t'is 11111 %ay of 0ay, 2+3.

111111111111111111111111111111Dist!i#t Co5!t &5%e

Cle!9 to fo!7a!% #o"ies to)

All #o5nsel of !e#o!%

US.3+:2;.+2

E-FILED 2014 MAY 12 6:22 AM SAC - CLERK OF DISTRICT COURT


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State of Iowa Courts

Type: OTHER ORDER

Case Number Case Title

LACV019513 TYSON BETTIN VS. SYNGENTA CORPORATION ET AL

So Ordered

Electronically signed on 2014-05-12 06:22:29 page 2 of 2

E-FILED 2014 MAY 12 6:22 AM SAC - CLERK OF DISTRICT COURT


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CLERK OF DISTRICT COURTSAC COUNTY COURTHOUSE

100 NW STATE STREET, SUITE 12

SAC CITY IA 50583

(712) 662-7791

Notice to Attorney Admitted Pro Hac ViceAs indicated in the attached notice, this case is in electronic format. As an attorney admitted pro hac vice on the

case, you need to follow some special steps to register for e-filing.When you register, select the Pro Hac Vice option under User Role. On the page where you enter your User

Account information, enter the information according to the instructions, with the special exception that you

enter the PHV PIN we have assigned to you in the ICIS ID field.

Complete your account registration.Chapter 16 Rules and eFiling training documents are available at:

http://www.iowacourts.gov/Online_Court_Services/EDMS/Online_Documentation/index.asp

Please register within 10 calendar days from the date of this notice.

Your uniquely assigned pro hac vice pin is: PHV000407

Name:Shane Anderson

Case:02811 LACV019513

http://www.iowacourts.gov/Online_Court_Services/EDMS/Online_Documentation/index.asphttp://www.iowacourts.gov/Online_Court_Services/EDMS/Online_Documentation/index.asp


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IN THE IOWA DISTRICT COURT, IN AND FOR SAC COUNTYCase No.: 02811 LACV019513

NOTICE OF ELECTRONIC FILING REQUIREMENTYOU ARE HEREBY NOTIFIED THAT YOU ARE ATTEMPTING TO FILE IN A COUNTY THAT

UTILIZES ELECTRONIC FILING. YOUR PAPER FILINGS ARE BEING RETURNED TO YOU

AND HAVE NOT BEEN ACCEPTEDAT THIS OFFICE.You are required to register through the Iowa Judicial Branch website at

https://www.iowacourts.state.ia.us/EFile/and obtain a log in and password for the purposes of filing and

viewing documents on your case and of receiving notification of filings, court rulings and events. REFER

TO THE IOWA COURT RULES CHAPTER 16 PERTAINING TO THE USE OF THE ELECTRONIC

DOCUMENT MANAGEMENT SYSTEM (EDMS). For court rules on the protection of personal information

in court filings, refer to Division VI of Iowa Court Rules Chapter 16.

ELECTRONIC FILING IS MANDATORY:Electronic filing of new court cases and filings in cases that have been converted to electronic is mandatory in

counties where the EDMS has been implemented, unless otherwise required or authorized by the Chapter16:

Rules Pertaining to the Use of the Electronic Document Management System.YOU MUST REGISTER TO USE THE EDMS:Registration is required before you can use the EDMS. You are required to have a current e-mail account for

use with EDMS. When you have completed your registration and received you login (username) and password,you can begin filing and receiving documents immediately. Your registration constitutes your request for, and

consent to, electronic service of court-generated documents and documents filed electronically by other parties.EXCEPTIONS:For good cause, the court, or clerk if no judge is available, may authorize a filer to submit a document in paper.

Upon showing of exceptional circumstances, the chief judge of the district in which a case is pending may grant

you an exemption from registering and filing electronically.READ CHAPTER 16: RULES PERTAINING TO THE USE OF THE ELECTRONIC DOCUMENT

MANAGEMENT SYSTEM (EDMS), available on the Iowa Judicial Branch Filer's Interface at https://www.iowacourts.state.ia.us/EFile/, before you register for or use the Electronic Document Management

System.

https://www.iowacourts.state.ia.us/EFile/https://www.iowacourts.state.ia.us/EFile/https://www.iowacourts.state.ia.us/EFile/https://www.iowacourts.state.ia.us/EFile/


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Tyson Bettin,

Plaintiffs,

v.

Syngenta Corporation, Syngenta Crop

Protection, LLC, Syngenta Seeds, Inc. andJeff Schroeder,

Defendants.

))

)))

)

)

))

)

)

LAW NO.: LACV019513

APPEARANCE OF SHANE ANDERSON

COMES NOW Shane Anderson of the law firm Faegre Baker Daniels LLP and hereby

enters an appearance on behalf of Syngenta Corporation, Syngenta Crop Protection, LLC, and

Syngenta Seeds, Inc.

Dated: May 16, 2014 FAEGRE BAKER DANIELS LLP

/s/ Shane Anderson

Shane [email protected]

2200 Wells Fargo Center

Minneapolis, MN 22402Telephone: (612) 766-7261

Facsimile: (612) 766-1600

Scott L. Halbur AT0010936

[email protected] Grand Avenue, 33rd Floor

Des Moines, Iowa 50309Telephone: (515) 248-9000

Facsimile: (515) 248-9010

ATTORNEYS FOR DEFENDANTS

SYNGENTA CORPORATION,

SYNGENTA CROP PROTECTION,

LLC, and SYNGENTA SEEDS, INC.



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CERTIFICATE OF SERVICE

I hereby certify that I caused a true and correct copy of this Appearance of Shane

Andersonto be served upon the attorneys of record for the parties by U.S. mail and email on the

16th day of May 2014.

_/s/ Shane Anderson_________

Shane Anderson

BRADY PRESTON BROWN, P.C.

Matthew L. Preston

2735 First Avenue, S.E.

Cedar Rapids, IA [email protected]

ATTORNEY FOR PLAINTIFF

JEFF SCHROEDER

P.O. Box 215403 W. 1st Street

Wall Lake, IA 51466


sac county man demands jury trial in case of treated seed corn he claims did not perform as promised

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