him millions of dollars.

Mr. David Dodwell, who won the Island's top award as managing director of the Reefs Beach Club, in Southampton, on Saturday, says he has not been told about the complaint by his partner Mr. Lee Koehler of Baltimore.

In a formal United States District Court for the District of Maryland writ Mr.

Koehler is demanding that Mr. Dodwell be summoned to appear on counts of breach of fiduciary duty and negligent misrepresentation.

And he is demanding money amounting to more than $3 million as well as interest and costs through the court.

Mr. Dodwell is described in the writ as a "consultant, entrepreneur and employed as a managing director of at least two resort hotel operations.'' It states that from May 23, 1980, to July 17, 1981, Mr. Koehler and Mr.

Dodwell worked together to acquire the ownership of the The Reefs. Mr. Dodwell had worked at The Reefs since 1973 as manager and general manager and had tried unsuccessfully to finance complete ownership on his own.

The writ says: "The Defendant contacted the Plaintiff on May 23, 1980, to secure Plaintiff's assistance and expertise in structuring an acquisition of The Reefs.

"Pursuant to this telephone conversation, Defendant traveled to Baltimore, Maryland, for discussions with the Plaintiff on June 5, 1980.

"Defendant and Plaintiff agreed at that meeting to join their knowledge, skills and resources to acquire The Reefs.'' Along with a third party from Baltimore the pair were successful in acquiring 100 percent ownership. Mr. Dodwell owned a 51 percent equity and 60 percent voting interest while Mr. Koehler had a 29 percent equity and 24 percent voting interest in The Reefs Beach Club Ltd.

Over the next year Mr. Koehler accuses Mr. Dodwell of charging out-of-pocket expenses during a search of the Caribbean for additional hotels, to an undisclosed account on the books of RBCL. During that time Mr. Koehler had personally paid all his own expenses.

The pair had found another hotel in the West Indies and secured a debt financing commitment from the Bank of Bermuda for $5,500,000. That was composed in part of two personal loans to the two men.

Mr. Koehler's loan required quarterly interest payments but he claims Mr.

Dodwell never made them.

The writ states: "Therefore, the Defendant negligently and wrongfully misapplied said interest reserve and, without the Plaintiff's knowledge or consent, placed his personal loan in default and his personal guarantees at risk.'' Mr. Koehler found out about the "precarious financial position'' and suggested a plan to help matters but he says that Mr. Dodwell refused to support it.

He claims that his partner "violated his obligations'' by concealing the problems and is demanding more than $3 million in damages.

Mr. Dodwell said he could not comment on the writ because he had not received it.