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Count X (WPLLC, Stephenson, and Gherardi) <br /> Fraudulent Non-Disclosure with Respect to the Condition of the Property <br /> 174. Plaintiffs restate and re-allege all preceding paragraphs of this Complaint as <br /> if fully set forth herein. <br /> 175. The physical condition of the Property is a material fact. <br /> 176. WPLLC, Stephenson, and Gherardi learned of the condition of the <br /> Property in the course of their extensive remodeling and subsequent efforts to sell the <br /> Property. <br /> 177. WPLLC's, Stephenson's, and Gherardi's knowledge of the condition of the <br /> Property is special knowledge that only the sellers of the Property and their accomplices <br /> were in a position to reasonably know. <br /> 178. WPLLC, Stephenson, and Gherardi concealed the condition of the <br /> Property by rendering cosmetic repairs for the sole purpose of misleading buyers into <br /> believing that the defects did not exist, and in failing to disclose the condition in any <br /> other way. <br /> 179. WPLLC, Stephenson, and Gherardi intended that Plaintiffs would rely on <br /> their non-disclosures and be induced to buy the Property. <br /> 180. Plaintiffs did reasonably rely on such non-disclosures, combined with the <br /> cosmetically appealing appearance of the Property that disguised underlying defects from <br /> discovery on inspection, in purchasing the Property. <br /> 181. Plaintiffs have suffered damages as a result of WPLLC's, Stephenson's, <br /> and Gherardi's fraudulent non-disclosures with respect to the condition of the Property. <br /> 27 <br />