John Hickox has filed a breach of contract complaint against Todd Rasch, alleging Rasch failed to repay a $55,000 promissory note that was to be used for home repairs.

The lawsuit was filed in Madison County Circuit Court on July 7.

Hickox claims he loaned Rasch $55,000 on Jan. 1, to be used for repairs and improvements to property located at 2083 Jolly Rogers Drive in Edwardsville.

According to Hickox, Rasch promised to repay the principal amount plus 14 percent per annum.

"Pursuant to the terms of the Note, full payment was due on or before June 30, 2008," the complaint states.

"To date, Todd S. Rasch failed to pay John C. Hickox any of the amount due under the Note," the complaint adds.

Hickox also claims as part of the loan agreement, Rasch agreed to execute and record a mortgage or deed of trust on the property to secure the note but never did.

"Todd S. Rasch failed and refused, and continues to fail and refuse, to perform his obligations under the agreement," the complaint states.

Hickox is seeking a judgment in excess of $55,000, plus an order forcing Rasch to execute a mortgage on the property so that he can secure payment.

Hickox is represented by Sandra Tatoian of Edwardsville.

The case has been assigned to Circuit Judge Andy Matoesian.

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