Laserfiche WebLink
152. Plaintiffs have suffered damages as a result of the fraud of WPLLC, <br /> Stephenson, and Gherardi with respect to the Conservation Easement. <br /> 153. To the extent these damages can be measured, they include at least the <br /> difference between the value of the Property unencumbered by the Conservation <br /> Easement and the value as encumbered. Recovery of reasonable damages in an amount <br /> greater than $50,000 is sought. <br /> Count VIII (WPLLC, Stephenson, Gherardi, and Coldwell) <br /> Common Law Fraud with Respect to the Condition of the Property <br /> 154. Plaintiffs restate and re-allege all preceding paragraphs of this Complaint as <br /> if fully set forth herein. <br /> 155. The physical condition of the Property is a material fact. <br /> 156. WPLLC, Stephenson, Gherardi, and Coldwell learned of the defective <br /> condition of the Property in the course of their extensive remodeling and subsequent <br /> efforts to sell the Property. <br /> 157. Despite knowing of the substantial defects in the Property, WPLLC, <br /> Stephenson, Gherardi, and Coldwell held out the Property to be in "excellent" condition <br /> in marketing materials, including in the MLS Realist® report for the Property. <br /> 158. WPLLC's contractors, which on information and belief include Brennan <br /> Properties, rendered cosmetic repairs for the sole purpose of misleading buyers into <br /> believing that the defects did not exist. <br /> 159. WPLLC, Stephenson, Gherardi, and Coldwell intended that Plaintiffs <br /> would rely on their false misrepresentations and be induced to buy the Property. <br /> 24 <br />