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11-15-2013 - Legal Doc: amend. summons, complaing, civil cover sheet
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11-15-2013 - Legal Doc: amend. summons, complaing, civil cover sheet
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8/22/2023 4:30:44 PM
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4550
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Wolverton
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4550 Wolverton Place
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Misc
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3111823310013
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70. Stephenson, WPLLC, Gherardi, and Berg provided Plaintiffs with the <br /> misleading Survey, which failed to disclose the planned Conservation Easement. <br /> 71. Stephenson and Plaintiffs entered into an Amendment to Purchase <br /> Agreement dated February 27, 2013, which became part of the Purchase Agreement, <br /> attached as an individual document hereto as Exhibit E, and included with all addenda to <br /> the Purchase Agreement in Exhibit A. <br /> 72. The February 27, 2013 Amendment to Purchase Agreement states that the <br /> closing date is April 10, 2013. <br /> 73. The February 27, 2013 Amendment to Purchase Agreement also represents <br /> that the Survey is an accurate depiction of the Property, stating that "Buyer and Seller <br /> agree that the land being conveyed is as described by Proposed Tract B (5.05 Ac.) on the <br /> certificate of survey for PID 31-1 18-23-005 by Schoborg Engineers dated March 25, <br /> 2012" (i.e., the Survey). <br /> 74. Coldwell, through its employee and/or agent Deb Shafer, again sent the <br /> misleading Survey to Plaintiffs' real estate agent in May 2013,post-closing, stating, <br /> "Nothing has changed so the survey from 3/25/12 is still the same." <br /> 75. WPLLC, Stephenson, Gherardi, Berg, and Coldwell delayed recording the <br /> Conservation Easement until the day of closing in order to ensure that Plaintiffs would <br /> not have notice of the Conservation Easement prior to closing. <br /> 76. Plaintiffs did not know, and did not have reason to know, of the existence <br /> of the Conservation Easement. <br /> 13 <br />
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