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11-15-2013 - Legal Doc: amend. summons, complaing, civil cover sheet
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11-15-2013 - Legal Doc: amend. summons, complaing, civil cover sheet
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8/22/2023 4:30:44 PM
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4550
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Wolverton
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4550 Wolverton Place
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Misc
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3111823310013
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190. Plaintiffs have suffered damages as a result of the deceptive practices of <br /> WPLLC, Stephenson, Gherardi, Coldwell, and Berg with respect to the Conservation <br /> Easement and the defective condition of the Property. <br /> 191. Pursuant to the Minnesota Private Attorney General Statute, Minn. Stat. § <br /> 8.31, Subd. 3a, and the Minnesota Prevention of Consumer Fraud Act, Minn. Stat. §§ <br /> 325F.68-325F.70, Plaintiffs are entitled to damages, together with costs and <br /> disbursements, including costs of investigation and reasonable attorney's fees. To the <br /> extent these damages can be measured, they include at least (i) the difference between the <br /> value of the Property unencumbered by the Conservation Easement and the value as <br /> encumbered, and (ii) the cost of repairs necessary to correct the defects to the Property. <br /> Recovery of reasonable damages in an amount greater than $50,000 is sought. <br /> 192. Pursuant to the Minnesota Private Attorney General Statute, Minn. Stat. § <br /> 8.31, Subd. 3a, and the Minnesota Prevention of Consumer Fraud Act, Minn. Stat. §§ <br /> 325F.68-325F.70,this Court may issue an injunction prohibiting WPLLC, Stephenson, <br /> Gherardi, Coldwell, and Berg from further fraudulent marketing and sale of the Property <br /> and Adjacent Land and prohibiting such Defendants from engaging in similar, future acts <br /> as applied to any other real property. <br /> 193. Besides serving to provide a remedy to Plaintiffs themselves, Plaintiffs' <br /> claim benefits the public as a whole in that WPLLC, Stephenson, Gherardi, Coldwell, <br /> and Berg deceptively held out the Property to the public. The claim helps protect the <br /> public from WPLLC, Stephenson, Gherardi, Coldwell, and Berg engaging in similar <br /> fraudulent and deceptive acts in the course of future real property transactions. <br /> 29 <br />
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