Hangover Joe's Holding Corp. (fka HJOE)

[james885]

Does Seth Kramer the president of KBM ever tell the truth to ANYONE they deal with? Seems he is willing to lie to anyone to steal money.

92. FRAUDULENT MISREPRESENTATION
a)Plaintiffs made aforesaid representation to defendants concerning the loan and the agreement,
and the Plaintiff and its affiliates such that
b)said representations were false;
c)that when made, the representations were known to be false or made recklessly without
knowledge of its truth;
d)that said representations were made with the intention that the defendants rely on them;
e)that the defendants did rely on them; and
f)that the defendants suffered damages as a result thereof.
SECOND COUNTERCLAIM
93. VIOLATION OF NY PENAL LAW §190.40 (CRIMINAL USURY)
a)that the costs of plaintiffs loans bore interest in excess of 150%
b)that said interest rate exceeds the maximum rate allowable in New York State
c)that Defendants are damaged as a result thereof
Case 2:15-cv-07254-SJF-GRB Document 14 Filed 01/26/16 Page 14 of 18 PageID #: 52
THIRD COUNTERCLAIM
94. FRAUDULENT INDUCEMENT
a)that Plaintiffs made knowing misrepresentation of material facts relating to loans made to
defendants;
b)that Plaintiffs had intention to deceive defendants;
c)that defendants relied on said misrepresentations; and
d)defendants suffered injury therefrom


http://www.justice.gov/archive/usao/nys/pressreleases/December11/cambridgesettlementpr.pdf