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Case Filing
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION
Volt Bank, Inc.
Plaintiff
v.
Sagamo2008
Defendant
COMPLAINT
The Plaintiff complain against the Defendants as follows:
The Defendant defaulted on two separate loan agreements with the Plaintiff by failing to make any required monthly interest payments and failing to repay principal amounts, in direct violation of both Loan Agreements, constituting Breach of Contract.
I. PARTIES
1. Volt Bank, Inc.2. Sagamo2008
II. FACTS
1. On 23 October 2025, the Defendant executed a Loan Agreement with Volt Bank, Inc. (P-001)2. The Defendant signed the First Loan Agreement on 23 October 2025. (P-002)
3. Under the First Loan Agreement, Plaintiff extended a loan to the Defendant in the principal amount of $50,000. (P-003)
4. The First Loan Agreement bears interest at a rate of 10% per month (simple interest) and has a loan term of 10 months. (P-003)
5. The Repayment Schedule specifies "monthly interest payments with principal repayment at the end", requiring monthly interest payments of $5,000 ($50,000 x 10% = $5,000). (P-003)
6. Section 2.4 of the First Loan Agreement provides that the Defendant granted Plaintiff a security interest in Plot s079 as collateral. (P-004)
7. The first monthly interest payment of $5,000 was due on 23 November 2025. (P-003)
8. The Defendant has failed to make the monthly interest payment due on 23 November 2025, which is now 27 days overdue as of 20 December 2025. (P-003)
9. On 4 November 2025, the Defendant executed a second Loan Agreement with Volt Bank, Inc. (P-005)
10. The Defendant signed the Second Loan Agreement on 4 November 2025. (P-006)
11. Volt Bank, Inc. formally executed the Second Loan Agreement on 9 November 2025 when the VSP-3 bond was officially listed on the National Exchange of Redmont, as required by the loan's coupling addendum. (P-007)
12. Under the Second Loan Agreement, Volt Bank extended a loan to the Defendant in the principal amount of $130,000. (P-008)
13. The Second Loan Agreement bears interest at a rate of 15% per month (simple interest) and has a loan term of 10 months with a maturity date of 9 September 2026. (P-008)
14. The Repayment Schedule specifies "monthly interest payments with loan balance paid at the end", requiring monthly interest payments of $19,500 ($130,000 x 15% = $19,500). (P-008)
15. The Second Loan Agreement contains no collateral – it is an unsecured loan. (P-008)
16. The Addendum to the Second Loan Agreement states that the loan is "strictly coupled to bond VSP-3" and that "principal shall be paid out as the VSP-3 payments come in from selling the bond on the NER. Interest shall only apply on the amount of the principal paid to the borrower, prorated accordingly." (P-009)
17. The first monthly interest payment of $19,500 under the Second Loan Agreement was due on 9 December 2025. (P-008)
18. The Defendant has failed to make the monthly interest payment due on 9 December 2025, which is now 11 days overdue as of 20 December 2025. (P-008)
19. Section 3.1 of both Loan Agreements defines "Missed Payment" as an Event of Default: "The Borrower fails to make any scheduled payment in full by the due date as per the Repayment Schedule, without prior written agreement from the Lender for an extension or alternate arrangement." (P-010)
20. The Defendant has made zero payments on either loan since disbursement.
21. Section 3.3 of both Loan Agreements provides that upon an Event of Default, the Lender may (P-011):
- Accelerate the entire debt and declare all amounts immediately due and payable
- Assess late payment penalties of 1% per day on each overdue payment
- Seize collateral (for secured loans)
- Pursue legal action to recover amounts due plus legal fees
III. CLAIMS FOR RELIEF
Breach of Contract
Section 7 of the Contracts Act states:The Defendant breached both Loan Agreements under Section 7 of the Contracts Act by failing to fulfil contractual payment obligations. Specifically, the Defendant:7 - Breach of Contract
(1) A breach of contract occurs when a party fails to fulfil its contractual obligations.
(a) Remedies for breach may include damages, specific performance, or other equitable relief.
- Failed to make the required monthly interest payment of $5,000 due on 23 November 2025 under the First Loan Agreement, in direct violation of Sections 2.1 and 2.2 of that agreement;
- Failed to make the required monthly interest payment of $19,500 due on 9 December 2025 under the Second Loan Agreement, in direct violation of Sections 2.1 and 2.2 of that agreement;
- Triggered Events of Default under Section 3.1 of both Loan Agreements by missing scheduled payments without any prior written agreement from Volt Bank for an extension or alternate arrangement;
- Failed to repay the accelerated debt after Volt Bank exercised its contractual right to declare the entire remaining loan balances immediately due and payable pursuant to Section 3.3 of both agreements.
IV. PRAYER FOR RELIEF
The Plaintiff respectfully request that this Court grant the following relief:1. A Court Order immediately transferring ownership of Plot s079 to Volt Bank, Inc. pursuant to Section 3.3 of the First Loan Agreement, as the Defendant has forfeited all rights to the collateral upon Event of Default.
2. $207,995 in Compensatory Damages representing the principal and accrued interest and late payment fees from both Loan Agreements, Pursuant to Legal Damages Act, Section 4.
First Loan:
- Principal: $50,000
- Accrued Interest: $5,000
- Late Payment Penalty: $1,350
- Total: $56,350
- Principal: $130,000
- Accrued Interest: $19,500
- Late Payment Penalty: $2,145
- Total: $151,645
4. 30% Legal Fees pursuant to Legal Damages Act, Section 9.
EVIDENCE
See Volt Loan Agreement (Sagamo2008) 2025_10_30-1.pdf
See Volt Loan Agreement (Sagamo2008) 2025_11_4-1.pdf
By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.
DATED: This 20th day of December 2025