MEMORANDUM AND ORDER
YOUNG, District Judge.
This case arose out of the inadequate renovation of a horse trailer by the defendant James Hutson ("Hutson"). The amended complaint sought relief under four different theories: breach of contract (Count I), violation of Mass.Gen.Laws ch. 93A (Count II), conversion (Count III), and fraud (Count IV). Count IV was based on an alleged misrepresentation made during a telephone call Hutson placed in Arkansas to the plaintiff...
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