No. GV 12000644
COMES NOW the Plaintiff, SAMANTHA LAWTON DUTHIE, by counsel, and for her Complaint states as follows:
1. The Plaintiff Samantha Lawton Duthie, is,a resident of Loudoun County, Virginia.
2. The Defendant, Amber Hill Farm, LLC, is a limited liabitity company registered in the state of New Jersey: The registered office for Amber Hill, LLC, is located at 2105 Lamington Road, Bedminster, New Jersey 07921. The registered agent for Amber Hill, LLC, is Elizabeth Mandarino.
3. The Defendant regularly conducts business in the Commonwealth of Virginia as it specializes in the training and sale of horses and ponies in Virginia. Furthermore, the Defendant regularly competes horses and ponies and conducts business at the Horse Shows in the Sun (“HITS’) in Culpeper, Virginia; and the Middleburg Classic Horse Show in Loudoun County, Virginia.
4. The Plaintiff is the owner of a pony named “Blue Moon’s Double O Seven” (“Ian”), which is a Connemera Cross, 14.1-hand, Gelding, foaled in 2004, and grey in color. The pony’s United States Equestrian Federation Number is 5110162.
5. In August 2011, the Defendant requested that the Plaintiff deliver Ian to her at the HITS show grounds in Culpeper, Virginia, so that she might show lan to potential clients and customers who, were interested leasing a pony of lan’s size and competitive caliber.