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In 1968, the Lakota Girl Scout Council decided to hold a fund-raising drive, the proceeds of which would be used to develop year-around facilities at

In 1968, the Lakota Girl Scout Council decided to hold a fund-raising drive, the proceeds of which would be used to develop year-around facilities at its 175-acre campsite near Dayton, Iowa. Four professional fund-raising firms, including Havey Fund-Raising, Inc., were considered to coordinate the campaign. Havey Fund-Raising conducted a survey and informed the Council that it was feasible to raise $325,000-$350,000 for the project. The Council thereupon set its goal at $345,000 and selected Havey Fund-Raising, Inc., to assist it.

On October 1, 1968, the parties executed a contract: Havey Fund-Raising was to provide professional assistance to help the Council reach its goal in return for a fee of $28,000; the Havey firm did not guarantee that any money would in fact be raised. When Havey Fund-Raising failed to perform in accordance with the contract and the campaign fell far short of its goal, the C

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