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Note:To cover its accreditation with Airlines Reporting Corp., the U.S. national clearinghouse for airline tickets, travel agents are required to post security which would include LCs naming the Reporting Corp. as Beneficiary.

When Beneficiary notified Applicant that its current LC was expiring and requested a new LC, the bank that issued the expiring LC issued a new one which was rejected because it failed to comply with the required format. Applicant then caused another bank to issue an LC which it did. In the meantime, Beneficiary decided to accept the first LC despite its formatting deficiencies. During this time, several of Applicant's checks were dishonored, and Beneficiary threatened to draw on the LC if they were not paid. Beneficiary, however, would not return the first LC and its issuer would not cancel without the Beneficiary's release. When payment was not made, Beneficiary terminated its agreement with Applicant for nonpayment and drew on the LC for the unpaid amount of US$ 2,057.73. Applicant sued the first bank for breach of contract and negligence for failure to timely execute the LC. The bank counterclaimed against Applicant for reimbursement.

Applicant represented himself. He failed to respond to requests for discovery and cancelled a scheduled deposition on the morning it was to be held. Bank's Motion to Compel Discovery was granted and it was awarded costs and attorney's fees. When Applicant failed to pay, Applicant's claim was dismissed by the trial court. On appeal, the Court of Appeals of Minnesota, Lansing, J., affirmed.

The appellate court stated that, "although pro se litigants are given some leeway by the court system, all litigants, whether represented or pro se, are required to follow the rules of civil procedure."

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