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Count VII (WPLLC, Stephenson, and Gherardi) <br /> Common Law Fraud with Respect to the Conservation Easement <br /> 145. Plaintiffs restate and re-allege all preceding paragraphs of this Complaint as <br /> if fully set forth herein. <br /> 146. The plan to record the Conservation Easement affecting the Property, in <br /> which WPLLC, Stephenson, and Gherardi directly participated, and the Conservation <br /> Easement itself, are material facts, the existence of which substantially interferes with <br /> Plaintiffs' expected use of the Property. <br /> 147. WPLLC, Stephenson, and Gherardi had knowledge of the material fact of <br /> the planned Conservation Easement since at least February 2012. <br /> 148. WPLLC, Stephenson, and Gherardi made false misrepresentations of the <br /> Property, including providing Plaintiffs with the Survey, which purported to be accurate <br /> but failed to disclose the Conservation Easement, leading Plaintiffs to reasonably believe <br /> that they would have full use and enjoyment of the Property, including the right to make <br /> their intended improvements on the Property. <br /> 149. WPLLC, Stephenson, and Gherardi intended to induce the Plaintiffs to <br /> purchase the Property in reliance on such false representations. <br /> 150. Plaintiffs did reasonably rely on such representations in purchasing the <br /> Property. <br /> 151. Plaintiffs did not know, and did not have reason to know, of the existence <br /> of the Conservation Easement. <br /> 23 <br />