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182. 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 XI (WPLLC, Stephenson, Gherardi, Coldwell, and Berg) <br /> Consumer Fraud Under Minn. Stat. §§ 325F.68-325F.70 <br /> 183. Plaintiffs restate and re-allege all preceding paragraphs of this Complaint as <br /> if fully set forth herein. <br /> 184. The Property constitutes "merchandise" under the Minnesota Prevention of <br /> Consumer Fraud Act. <br /> 185. WPLLC, Stephenson, Gherardi, Coldwell, and Berg made <br /> misrepresentations and misleading statements to Plaintiffs and the public as a whole, <br /> engaged in deceptive practices, and sold the Property under the false pretense that it was <br /> not encumbered by the Conservation Easement and that it did not have material defects. <br /> 186. WPLLC, Stephenson, Gherardi, Coldwell, and Berg intended to induce the <br /> Plaintiffs to purchase the Property in reliance on such false representations. <br /> 187. Plaintiffs did reasonably rely on such representations in purchasing the <br /> Property. <br /> 188. Plaintiffs did not know, and did not have reason to know, of the existence <br /> of the Conservation Easement or the defective condition of the Property. <br /> 189. The deceptive practices of WPLLC, Stephenson, Gherardi, Coldwell, and <br /> Berg constitute a violation of the Minnesota Prevention of Consumer Fraud Act, Minn. <br /> Stat. §§ 325F.68-325F.70. <br /> 28 <br />