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Count XII (WPLLC, Stephenson, Gherardi, Coldwell, and Berg) <br /> False Advertising Under Minn. Stat. §325F.67 <br /> 194. Plaintiffs restate and re-allege all preceding paragraphs of this Complaint as <br /> if fully set forth herein. <br /> 195. Statements made and materials distributed by WPLLC, Stephenson, <br /> Gherardi, Coldwell, and Berg in promotion of the sale of the Property constitute <br /> advertisements under the Minnesota False Statement in Advertisement Act. <br /> 196. WPLLC, Stephenson, Gherardi, Coldwell, and Berg made <br /> misrepresentations and misleading statements, engaged in deceptive practices, and sold <br /> the Property under the false pretense perpetuated by advertising materials held out to the <br /> public, including but not limited to the Survey, suggesting that the Property was not <br /> encumbered by the Conservation Easement and that it did not have material defects. <br /> 197. WPLLC, Stephenson, Gherardi, Coldwell, and Berg intended to induce the <br /> Plaintiffs or another buyer to purchase the Property in reliance on such false <br /> representations. <br /> 198. Plaintiffs did reasonably rely on such representations in purchasing the <br /> Property. <br /> 199. 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 /> 200. The deceptive advertising practices of WPLLC, Stephenson, Gherardi, <br /> Coldwell, and Berg constitute a violation of the Minnesota False Statement in <br /> Advertisement Act, Minn. Stat. § 325F.67. <br /> 30 <br />