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160. Plaintiffs did reasonably rely on such representations, combined with the <br /> cosmetically appealing appearance of the Property that disguised underlying defects from <br /> discovery on inspection, in purchasing the Property. <br /> 161. Plaintiffs have suffered damages as a result of the fraud of WPLLC, <br /> Stephenson, Gherardi, and Coldwell with respect to the condition of the Property. <br /> 162. To the extent these damages can be measured, they include at least the cost <br /> of repairs necessary to correct defects to the Property. Recovery of reasonable damages <br /> in an amount greater than $50,000 is sought. <br /> Count IX (WPLLC, Stephenson, and Gherardi) <br /> Fraudulent Non-Disclosure with Respect to the Conservation Easement <br /> 163. Plaintiffs restate and re-allege all preceding paragraphs of this Complaint as <br /> if fully set forth herein. <br /> 164. The plan to execute and record the Conservation Easement affecting the <br /> Property, in which WPLLC, Stephenson, and Gherardi directly participated, and the <br /> Conservation Easement itself, are material facts, the existence of which substantially <br /> interferes with Plaintiffs' expected use of the Property. <br /> r � <br /> 165. WPLLC, Stephenson, and Gherardi had knowledge of the material fact of <br /> the planned Conversation Easement since at least February 2012. <br /> 166. WPLLC's, Stephenson's, and Gherardi's knowledge of the Conservation <br /> Easement is special knowledge that only the sellers of the Property and their accomplices <br /> were in a position to reasonably know. <br /> 25 <br />