Enzyme Environmental Solutions Inc (EESO)

[balihi]

VIRGINIA:
IN THE CIRCUIT COURT OF FAIRFAX COUNTY
BELMONT PARTNERS. LLC, Plaintiff,
v.
STRATEGIC CONSULTANTS, INC., et aL Defendants.
Case No. 2009-004101
DEMURRER AND MOTION CRAVING OVER
Defendants Strategic Consultants, Inc., Strategic Solutions Group, Inc., Cucos. Inc., and Enzyme Environmental Solutions, Inc. (collectively, "Defendants"), by counsel and pursuant to Va. Code § 8.01-273 and Rules 3:8 and 4:15 of the Rules of Supreme Court of Virginia, hereby demur to all four counts that Plaintiff Belmont Partners, LLC ("Plaintiff) asserts in the complaint it filed in the above-captioned matter. For the following reasons, this Court should sustain the demurrer to all counts of the complaint filed in this action with prejudice and dismiss this lawsuit.
GROUNDiFQRDEMjURRER
Plaintiff fails to state a claim for which relief can he granted for all four counts of the complaint for the following reasons:
Plaintiff fails to state a cause of action in Count I (Breach of Contract) because (1) the Common Stock Purchase Agreement {''Agreement") upon which Plaintiff bases its breach of written contract claim is unenforceable as a matter of law because it lacks mutuality of
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enforcement; and (2) Plaintiff fails to allege the satisfaction of all conditions precedent, and facts
EXHIBIT
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