Entertainment from Mario Land.
Mario Pino is piece of work.
Mario suing anyone for Fraud is hilarious! Looks like hes suing 50 people/companies over the refinancing of his house in Arizona and claims all these people conspired to steal his house and his ill gotten gains - LOL! - Priceless!! A conman claiming he was ripped off! - he must need more dough for Crystal Meth.
This appears to be Marios lawyer - Mario is listed as the Plaintiff. Mario Usi, one of the Defendants - that name rings a bell! LOL!
It seems like its mostly written in invisible ink (I pasted it into MS Word to make it visible)
http://actsoffraud.webs.com/
DEAD BEATS (Acts of Fraud)
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DEAD BEATS (ACTS OF FRAUD)
THIS SITE WAS CREATED TO PROTECT INNOCENT GOOD PEOPLE FROM
CREDIT CRIMINALS AND FINANCIAL PREDATORS.
TO MAKE THE PUBLIC AWARE, WHO THEY ARE
AND
WHAT THEY ARE CAPABLE OF:
SCAMMERS LISTED BELOW.
SCAMMERS(1)
TICOR TITLE COMPANY OF ) FRAUD; INTENTIONAL
CALIFORNIA, a California corporation; ) MISREPRESENTATION;
AMERICANA ESCROW CORPORATION, ) NEGLIGENT MISREPRESENTATION;
a California corporation;
BANK OF AMERICA ) CONVERSION; CONCEALMENT
AMERICA, N.A., a Banking Corporation; ) AND NONDISCLOSURE;
NORTH PORT ENTERPRISES, INC., a ) FRAUDULENT PROMISE AND
California Corporation;
JANE UN BAIL ) INTENT NOT TO PERFORM;
ABBA BONDS, INC., a California Corporation; ) BREACH OF DUTY;
CALIFORNIA HOME REMODELING, INC.,) PROFESSIONAL NEGLIGENCE;
a California Corporation;
PACIFIC FIRST MORTGAGE CORPORATION ) UNFAIR AND DECEPTIVE
BANCORP MORTGAGE CORPORATION, ) BUSINESS PRACTICES; AND
a California Corporation;
AL ARZATE, ) CONSPIRACY TO DEFRAUD
an individual;
MARIO TEJADA, an )
individual;
MARIO USI, an individual; )
FEDERICO TRIEBEL, an individual; )
RODRIGO TRIEBEL, an individual; )
HUMBERTO TRINIDAB, an individual; )
IVONNE GOODRICH, an individual; )
SCAMMERS (2)
RJR Consulting Gourp LLC. IR-Scammers And Fraudster
East Coast:
1120 Langdon Street
Suite LL2
Franklin Square, NY 11010
Robert Reynolds - CEO
rob@rjrconsultinggroup.com
Sal Caragliano - VP
sal@rjrconsultinggroup.com
West Coast:
16927 North Saguaro Blvd.
Suite 100
Fountain Hills, AZ 85268
Tom Nelson
tom@rjrconsultinggroup.com
Phone:
Main Office: 516-354-2763
Fax: 516-706-2419
Bogus IR firm please beware and very careful off doing business this IR Firm the have you sign a consulting agreement and send stock, then site on their ass and do nothing just sell stocks, they claim to have call center and have investor ext, they don’t have anything, or any ability.
After signing contract and send them stocks their done, If you ask for stock back they tell you to start litigation to make a claim, they claim they DO NOT have to perform they have a non performance clause in their contract, so that protects them from even performing, they don’t have to do anything at all, just sell your stocks, and they want you to come out pocket to start litigation to get something back from them, but they claim they have deeper pockets, They are complete Scammers and Fraudsters.
Please be careful, do not do business with them…
Please goto the website for more details. www.actsoffraud.webs.com
http://www.free-press-release.com/news/200904/1240461583.html
__________________________________________________________________________
Charles C. Weller, A Professional Corporation
CHARLES C. WELLER, ESQ. (SBN: 207034)
8740 Villa La Jolla Drive, Suite 16
La Jolla, California 92037
Phone (858) 414-7465
Fax (858) 404-0147
Attorney for Plaintiff
MARIO A. PINO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN DIEGO, CENTRAL BRANCH
MARIO A. PINO, an individual; ) Case No. ) Plaintiff, ) )
COMPLAINT FOR DAMAGES:
TICOR TITLE COMPANY OF ) FRAUD; INTENTIONAL
CALIFORNIA, a California corporation; ) MISREPRESENTATION;
AMERICANA ESCROW CORPORATION, ) NEGLIGENT MISREPRESENTATION;
a California corporation; BANK OF ) CONVERSION; CONCEALMENT
AMERICA, N.A., a Banking Corporation; ) AND NONDISCLOSURE;
NORTH PORT ENTERPRISES, INC., a ) FRAUDULENT PROMISE AND
California Corporation; JANE UN BAIL ) INTENT NOT TO PERFORM;
BONDS, INC., a California Corporation; ) BREACH OF DUTY;
CALIFORNIA HOME REMODELING, INC.,) PROFESSIONAL NEGLIGENCE;
a California Corporation; PACIFIC FIRST ) UNFAIR AND DECEPTIVE
BANCORP MORTGAGE CORPORATION, ) BUSINESS PRACTICES; AND
a California Corporation; AL ARZATE, ) CONSPIRACY TO DEFRAUD
an individual; MARIO TEJADA, an )
individual; MARIO USI, an individual; )
FEDERICO TRIEBEL, an individual; )
RODRIGO TRIEBEL, an individual; )
HUMBERTO TRINIDAB, an individual; )
IVONNE GOODRICH, an individual; )
and DOES 1 through 50, inclusive. )
) Defendants. )
______________________________________)
PARTIES AND JURISDICTION
1. Plaintiff MARIO A. PINO (“PINO”) is and was at all times mentioned herein, an individual residing in Maricopa County, Arizona.
2. Defendant TICOR TITLE COMPANY OF CALIFORNIA (“TICOR TITLE”) is a California corporation which does business in the state of California.
3. Defendant AMERICANA ESCROW CORPORATION (AMERICANA”) is a California corporation which does business in the state of California. Based upon information and belief, Defendant FEDERICO TRIEBEL has an ownership interest in this company.
4. Defendant BANK OF AMERICA, N.A. (“BOFA”) is a financial institution which does business in the state of California.
5. Defendant NORTH PORT ENTERPRISES, INC. (“NORTH PORT”) is a California corporation which does business in the state of California. Based upon information and belief, this company is owed by Defendant HUMBERTO TRINIDAB.
6. Defendant JANE UN BAIL BONDS, INC. (“JANE”) is a California corporation which does business in the state of California. Based upon information and belief, this company is owned by AL ARZATE.
7. Defendant CALIFORNIA HOME REMODELING, INC. (“CA HOME”) is a California corporation which does business in the state of California.
8. Defendant PACIFIC FIRST BANCORP MORTGAGE CORPORATION (“PACFIC FIRST”) is a California corporation which does business in the state of California. Based upon information and belief, Defendant MARIO USI used to be President of this company. Based upon information and belief, Defendants FEDERICO TRIEBEL and MARIO TEJADA are affiliated with this company.
9. Defendant AL ARZATE (“ARZATE”) is and was at all times mentioned herein, an individual residing in the state of California.
10. Defendant MARIO TEJADA (“TEJADA”) is and was at all times mentioned herein, an individual residing in the state of California.
11. Defendant MARIO USI (“USI”) is and was at all times mentioned herein, an individual residing in the state of California.
12. Defendant FEDERICO TRIEBEL (“FEDERICO”) is and was at all times mentioned herein, an individual residing in the state of California.
13. Defendant RODRIGO TRIEBEL (“RODRIGO”) is and was at all times mentioned herein, an individual residing in the state of California.
14. Defendant HUMBERTO TRINIDAB (“HUMBERTO”) is and was at all times mentioned herein, an individual residing in the state of California.
15. Defendant IVONNE GOODRICH (“GOODRICH”) is and was at all times mentioned herein, an individual residing in the state of California.
16. Plaintiffs are unaware of the true names, capacities or bases for liability of those Defendants named herein as Does 1 through 50 inclusive. Plaintiffs seek leave of Court to allege their true names and capacities after they have been ascertained. Plaintiffs are informed and believe, and on that basis, allege that each of the Defendants, named herein as Does 1 through 50 inclusive, are, in some manner, liable to Plaintiffs.
17. Jurisdiction is proper as against all Defendants pursuant to CCP §410.10.
18. Venue is proper as against all Defendants pursuant to CCP §395(a).
19. At all times relevant to this action, each Defendant, including those fictitiously named, was the agent, servant, employee, partner, joint venturer, alter ego and/or co-conspirator of the other Defendants and was acting within the course and scope of such agency, employment,
partnership, venture, or employment and/or conspiracy with the knowledge and consent or ratification of each of the other Defendants in doing the things alleged herein.
20. Based upon information and belief, there exists, and at all times herein mentioned there existed, a unity of interest and ownership between the individual defendants and any close corporation in which they claim an interest, such that any individuality and separateness of between the individual defendants on the one hand, and any corporate entity in which they claim an interest involved in these transactions have ceased, and such corporations are the alter ego of the individual defendants. Adherence to the fiction of the separate existence of the corporations as entities distinct from each other and the individual defendants controlling said corporations would permit an abuse of the corporate privilege and would sanction fraud and/or promote injustice.
21. Defendant corporations were, and at all times herein mentioned were, the mere shell, instrumentality and conduit through which the individual defendants carried on their business and their conduct toward Plaintiff, exercising complete control and dominance of such business and transactions to such an extent that any individuality or separateness of the corporations and individual defendants does not, and at all times herein mentioned, did not exist.
22. Such blurring between the business and activities and conduct of the individual Defendants, and the related corporations, Plaintiff is informed and believes and thereon alleges, has resulted in commingling of funds and use of corporate funds and assets without adequate consideration, depleting the assets of the corporation to meet its liabilities and responsibilities, and causing distributions to individuals without consideration, thereby deliberately impairing the solvency of the corporations.
23. Based upon information and belief, such corporations were conceived, intended, and used by Defendants as a device to avoid individual liability and for the purpose of
substituting financially insolvent entities in the place of said individual defendants; and that as a consequence, said corporations are severely undercapitalized such that, compared with the business to be conducted through said entities by defendants and the risks of loss attendant thereon, its capitalization was illusory or trifling and meant solely to insulate the individuals from liability so that continuation of such corporate form is illusory and would allow defendants to escape personal liability for the fraud and conduct herein alleged, such that Plaintiff prays that said corporate forms be disregarded as mere shells and instrumentalities of the individual defendants.
NATURE OF THE ACTION
24. This action arises out of a large real estate fraud whereby the Defendants worked together in concert to deprive the Plaintiff of his house and approximately a million dollars of profits in a real estate transaction. Specifically, the Defendants used a straw buyer to purchase Plaintiff’s house and disbursed nearly all the funds to themselves out of escrow to Plaintiff’s financial detriment (“the Transaction”). Based upon information and belief, the Defendants pulled off this grand scheme by controlling the escrow company, the title company, mortgage brokers, and the lender who originated the loan to a “straw” buyer. Over a year after the real estate transaction concluded, the buyer has still not stepped forward to claim ownership to his multi-million dollar house. Plaintiff believes the buyer to the fraudulent transaction does not even exist. Loan documents, escrow documents, and the Purchase and Sales Agreement appear to have been forged, and the policies and procedures for the escrow company, title company, and lender were not followed in accordance with applicable state and federal regulations. As a result, there is now a cloud on the title. Plaintiff seeks to regain legal ownership of his house and recover compensatory and punitive damages from the Defendants for their wrongdoing
.
GENERAL ALLEGATIONS
25. Plaintiffs reallege and incorporate all of the allegations contained in paragraphs 1 through 24 of this Complaint as though fully contained herein.
26. On or about September of 2007, PINO approached USI in California to refinance his Paradise Valley home located in Maricopa County, Arizona. The physical address of this home is 6630 North 48th Street, Paradise Valley, AZ 85253.
27. USI was unable to refinance PINO’s home, so USI gave the loan application and file to FEDERICO, a California mortgage broker, to see if he could obtain the refinance for PINO.
28. On or about October of 2007, FEDERICO teams up with RODRIGO, loan officer, and HUMBERTO, a California mortgage broker, for additional assistance in refinancing PINO’s house. When it was later discovered that FEDERICO, RODRIGO, and HUMBERTO were unable to do the refinance, FEDERICO and RODRIGO used their mortgage company PACIFIC FIRST to facilitate a fraudulent transaction to get money out of PINO’s house.
29. On or about late October of 2007, FEDERICO and HUMBERTO notified and represented to PINO that the refinance was approved and that PINO would receive approximately five hundred thousand dollars ($500,000.00) out of the refinance.
30. Behind the scenes, USI, FEDERICO, and HUMBERTO had decided to get equity out of PINO’s house by selling the house to a “straw” buyer for a sales price of $2,380,000.00. USI, FEDERICO, and HUMBERTO figured that because PINO had a serious drug addiction at the time, they could take advantage of him and get him to sign any document for his “refinance money” of approximately five-hundred thousand dollars ($500,000.00).
31. Based upon information and belief, HUMBERTO had a contact at BOFA who agreed to help push a loan through the system to facilitate this fraudulent real estate transaction.
32. Still during the period of October of 2007, ARZATE and JANE agree to work with USI, FEDERICO, and HUMBERTO to help pull together this fraudulent transaction in exchange for a kick back on the profit that the Defendants will share in. ARZATE and JANE agree to put up thirty-thousand dollars ($30,000) as a deposit for opening escrow with AMERICANA.
33. Based upon information and belief, HUMBERTO has an ownership interest in AMERICANA, and HUMBERTO works as a loan officer for the same office that AMERICANA is located in. HUMBERTO used his connection with AMERICANA to ultimate close the fraudulent transaction which deprived PINO of his house and over five hundred thousand dollars ($500,000.00).
34. HUMBERTO used TEJADA as a straw buyer for the Transaction. TEJADA was to receive fifty thousand dollars ($50,000) for his role in this fraudulent scheme.
35. TITOR TITLE and AMERICANA both used GOODRICH to work on PINO’s transaction. Based upon information and belief, GOODRICH conspired with the rest of the Defendants to carry through the fraudulent scheme and complete the Transaction. Based upon information and belief, immediately after PINO’s transaction closed, GOODRICH quit working.
36. On or about November 15, 2007, Albert Pino, PINO’s father, went over to AMERICANA to sign escrow closing documents on PINO’s behalf. Albert Pino had an authorized power of attorney to act on PINO’s behalf in this real estate transaction. Albert Pino waited at the AMERICANA offices all day but never signed one document. At the end of the day Albert Pino was told that the escrow closed and was given a check for approximately thirty thousand dollars ($30,000) for PINO.
37. PINO was expecting to receive approximately five hundred thousand dollars ($500,000) from this transaction and not just thirty thousand dollars ($30,000), so naturally PINO was extremely shocked.
38. PINO never received any documents from TICOR TITLE or closing statements from AMERICANA. PINO also never received a final Hud-1 Settlement Statement as required by law.
39. The Transaction closed on Number 15, 2007. The closing statement provided by AMERICANA shows the blatant fraud in this case. According to the closing statement $1,824,000.00 was the total consideration for the transaction which consisted of the loan funded by BOFA. However, the transaction recorded for the selling price of $2,280,000. The down payment of twenty percent (20%) consisting of $456,000 is missing from the closing statement, and as such those funds were never disbursed out of escrow. These were missing profits in the Transaction which should have gone to the seller but, based upon information and belief, the Defendants’ converted those funds to their own use.
40. Based upon information and belief, TICOR TITLE, AMERICANA, and BOFA knew that the down payment was missing from the Transaction yet the loan from BOFA was funded and it closed.
41. The closing statement also indicates that there was an additional loan payoff of $42,992 in addition to main loan payoff of $1,189,490.72. However, there was only one loan on the house at the time. Based upon information and belief, the Defendants’ pocketed this money too.
42. The Defendants deprived the Plaintiff of his profits from the Transaction as they received the following improper disbursements out of escrow:
a) Payment of $30,000 to ARZATE;
b) Payment of $100,000 to NORTH PORT;
c) Payment of $21,000 to JANE;
d) Payment of $30,000 to CA HOME;
e) Payment of $40,000 to FEDERICO; and
f) Payment of $24,000 to USI.
43. The closing statement indicates that there was a reserve fund of $18,949. Based upon information and belief, this amount was never paid out but was wrongfully taken by the Defendants.
44. As indicated by the closing statement, there was a check “herewith” which was made for the amount of $37,945.47. The Plaintiff never received this amount of the escrow of the Transaction either.
45. There are additional inflated expenses on the closing statement as well. Based upon information and belief, the Defendants embezzled these additional funds and deprived the Plaintiff of his profit from the Transaction.
46. The total unauthorized disbursement to third parties at closing of the Transaction was $463,286. Adding this number to the missing down payment of $456,000 equals a total of $919,286 taken by fraud by these Defendants.
47. Several months after the Transaction closed, the Defendants took an additional $100,000 loan on the property. The same loan agent for the Transaction funded the second loan with BOFA again in the name of the “straw” buyer against Plaintiff’s house. The total amount of money stolen by Defendants from Plaintiff exceeds $1,019,286.
FIRST CAUSE OF ACTION
(For Intentional Misrepresentation)
(Against Defendants AMERICANA, NORTH PORT, JANE, CA HOME, PACIFIC FIRST, ARZATE, TEJADA, USI, FERERICO, RODRIGO, and HUMBERTO)
48. Plaintiff realleges and incorporates all of the allegations contained in paragraphs 1 through 47 of this Complaint as though fully contained herein.
49. Defendants and each of them made intentional misrepresentations of material facts to Plaintiff, knowing such statements were untrue with the intent to induce Plaintiff to engage in the Transaction and to mislead Plaintiff to his detriment. Such representations included, without limitation, that Plaintiff was refinancing his house, that Plaintiff was going to retain title to his house once the Transaction was over, that Plaintiff would receive approximately $500,000 from the transaction, and that Plaintiff was executing the necessary and proper forms to accomplish this goal. The true facts were that such representations by Defendants and documents presented were solely intended to run a scam on Plaintiff to take advantage of the Plaintiff’s current medical condition and steal money from him. Plaintiff is informed and believes that this fraudulent scheme was to generate financial gain to all the Defendants.
50. Plaintiff reasonably and justifiably relied on such representations and as a consequence thereof, was damaged.
51. As a consequence of Defendants’ misconduct, Plaintiff has been damaged in an amount yet to be ascertained, including the suffering of mental and physical distress, the loss of approximately $1,000,000.00 from the Transaction, plus special damages in an amount to be determined, such additional damages being in excess of $1,000,000.00.
52. Defendants engaged in such despicable conduct, including fraud and conscious disregard of the rights of Plaintiff, such that punitive damages should be assessed against them.
SECOND CAUSE OF ACTION
(For Negligent Misrepresentation)
(Against Defendants AMERICANA, NORTH PORT, JANE, CA HOME, PACIFIC FIRST, ARZATE, TEJADA, USI, FERERICO, RODRIGO, and HUMBERTO)
53. Plaintiffs reallege and incorporate all of the allegations contained in paragraphs 1 through 52 of this Complaint as though fully contained herein.
54. Defendants, and each of them, made false misrepresentations of material facts to Plaintiff, without reasonable grounds for believing such misrepresentations to be true, and with the intent to induce Plaintiff to participate in a fraudulent real estate transaction to Plaintiff’s detriment.
55. Plaintiff reasonably and justifiably relied on such representations and as a consequence thereof, was damaged.
56. As a consequence of Defendants’ misconduct, Plaintiff has been damaged in an amount yet to be ascertained, including the suffering of mental and physical distress, the loss of approximately $1,000,000.00 from the Transaction, plus special damages in an amount to be determined, such additional damages being in excess of $1,000,000.00.
57. The fiduciary Defendants engaged in such despicable conduct, including fraud and conscious disregard of the rights of Plaintiff, such that punitive damages should be assessed against them.
THIRD CAUSE OF ACTION
(For Conversion)
(Against Defendants AMERICANA, NORTH PORT, JANE, CA HOME, PACIFIC FIRST, ARZATE, TEJADA, USI, FERERICO, RODRIGO, and HUMBERTO)
58. Plaintiffs reallege and incorporate all of the allegations contained in paragraphs 1 through 57 of this Complaint as though fully contained herein.
59. The aforementioned Defendants wrongfully took Plaintiff’s funds in the Transaction by improperly disbursing $463,286 in funds to themselves directly out of escrow and by converting Plaintiff’s $456,000 which would he never received as the Defendants had embezzled the down payment.
60. As a consequence of Defendants’ misconduct, Plaintiff has been damaged in an amount yet to be ascertained, including the suffering of mental and physical distress, the loss of approximately $1,000,000.00 from the Transaction, plus special damages in an amount to be determined, such additional damages being in excess of $1,000,000.00.
FOURTH CAUSE OF ACTION
(For Concealment and Nondisclosure)
(Against All Defendants)
61. Plaintiffs reallege and incorporate all of the allegations contained in paragraphs 1 through 60 of this Complaint as though fully contained herein.
62. Defendants purposely concealed and/or fiduciary Defendants failed to disclose material facts to Plaintiff constituting constructive fraud, including that the down payment was missing from his Transaction, that improper third-party disbursements were being made out of escrow, and, inter alia, on information and belief, by purposefully not even attempting to contact him directly to have him sign documents associated with the Transaction.
63. As a consequence of Defendants’ misconduct, Plaintiff has been damaged in an amount yet to be ascertained, including the suffering of mental and physical distress, the loss of approximately $1,000,000.00 from the Transaction, plus special damages in an amount to be determined, such additional damages being in excess of $1,000,000.00.
64. Defendants engaged in such despicable conduct, including fraud and conscious disregard of the rights of Plaintiff, such that punitive damages should be assessed against them.
FIFTH CAUSE OF ACTION
(For Fraudulent Promise Without Intent to Perform)
(Against Defendants AMERICANA, NORTH PORT, JANE, CA HOME, PACIFIC FIRST, ARZATE, TEJADA, USI, FERERICO, RODRIGO, and HUMBERTO)
65. Plaintiffs reallege and incorporate all of the allegations contained in paragraphs 1 through 64 of this Complaint as though fully contained herein.
66. Defendants made material promises to Plaintiff that the transaction with his property was appropriate and suitable; that the forms and documents placed before him were necessary and proper in the regular course of such a real estate transaction; and that the net profits to Plaintiff would be nearly a million dollars ($1,000,000.00). In fact, Defendants never intended that Plaintiff receive the monies owed to him from the sale of his property. Instead, Defendants participated in a scheme to take advantage of Plaintiff’s financial situation and current condition so that Defendants could financially benefit with complete disregard as to the effect on Plaintiff’s life, and without regard to the fact that the entire Transaction was a fraud to generate money and benefits for themselves.
67. As a consequence of Defendants’ misconduct, Plaintiff has been damaged in an amount yet to be ascertained, including the suffering of mental and physical distress, the loss of approximately $1,000,000.00 from the Transaction, plus special damages in an amount to be determined, such additional damages being in excess of $1,000,000.00.
SIXTH CAUSE OF ACTION
(For Breach of Duty)
(Against All Defendants)
68. Plaintiffs reallege and incorporate all of the allegations contained in paragraphs 1 through 67 of this Complaint as though fully contained herein.
69. Defendants and each of them owed a duty of loyalty, due care, and good faith; and/or a fiduciary duty, to Plaintiff. By reason of the acts and omissions herein described, - 14 - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Defendants breached such duties to Plaintiff, and the resulting damage and detriment to Plaintiff was foreseeable.
70. As a consequence of Defendants’ misconduct, Plaintiff has been damaged in an amount yet to be ascertained, including the suffering of mental and physical distress, the loss of approximately $1,000,000.00 from the Transaction, plus special damages in an amount to be determined, such additional damages being in excess of $1,000,000.00.
71. Defendants committed such offenses and engaged in such despicable conduct, including fraud and conscious disregard of the rights of Plaintiff, such that punitive damages should be assessed against them.
SEVENTH CAUSE OF ACTION
(For Professional Negligence)
(Against All Defendants)
72. Plaintiffs reallege and incorporate all of the allegations contained in paragraphs 1 through 71 of this Complaint as though fully contained herein.
73. Defendants, and each of them, committed professional negligence, in that they purported to act as professionals in providing specific services that resulted in the loss of approximately one million dollars $1,000,000.00 in the Transaction they provided services within.
74. The Defendants, and each of them, fell below the standard of care in providing their specific services.
75. As a consequence of Defendants’ misconduct, Plaintiff has been damaged in an amount yet to be ascertained, including the suffering of mental and physical distress, the loss of approximately $1,000,000.00 from the Transaction, plus special damages in an amount to be determined, such additional damages being in excess of $1,000,000.00.
EIGHTH CAUSE OF ACTION
(For Unfair and Deceptive Business Practices)
(Against All Defendants)
76. Plaintiffs reallege and incorporate all of the allegations contained in paragraphs 1 through 75 of this Complaint as though fully contained herein.
77. Defendants, and each of them, engaged in unfair and deceptive business practices in provided services to Plaintiff herein. Defendants misrepresented their authority, misrepresented the real estate selling process, and engaged in scheme of defrauding the Plaintiff into relying upon their professional expertise while, in fact, Defendants completely disregarded
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