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167. WPLLC, Stephenson, and Gherardi concealed their scheme to file a <br /> Conservation Easement by failing to disclose their plans to Plaintiffs and holding off on <br /> recording the Easement until the day of the closing. <br /> 168. By delaying recording of the Conservation Easement, WPLLC, <br /> Stephenson, and Gherardi intended to conceal the material fact of the Conservation <br /> Easement's existence by ensuring that the Conservation Easement would not become <br /> known to Plaintiffs. <br /> 169. WPLLC, Stephenson, and Gherardi intended to induce Plaintiffs to <br /> purchase the Property in reliance on such non-disclosures. <br /> 170. Plaintiffs did reasonably rely on such non-disclosures when purchasing the <br /> Property. <br /> 171. Plaintiffs did not know, and did not have reason to know, of the existence <br /> of the Conservation Easement. <br /> 172. Plaintiffs have suffered damages as a result of WPLLC's, Stephenson's, <br /> and Gherardi's fraudulent non-disclosures with respect to the Conservation Easement. <br /> 173. 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 /> 26 <br />