Dawn Estep Sued

JOHN H.
THALER, SBN 150290

1 LAW OFFICES OF JOHN H. THALER
18034 Ventura Boulevard, #289
2 Encino, CA 91316
818-206-4402 ** fax 818-206-4473
3
4
Attorney for Plaintiff **** **** ****
5
8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA

9 FOR THE COUNTY OF LOS ANGELES, WEST DISTRICT
10
***** ***** *****, an individual,) Case No.:
11 )
) PLAINTIFF’S COMPLAINT FOR:
12
Plaintiff, )
) 1. Breach of Oral Contract;
13
vs. ) 2. Specific Performance
) 3. Promissory Estoppel
14 DAWN ESTEP, an individual, aka DAWN ) 4. Fraud
STROUD, an individual, MURDOCH ) 5. Fraud
15 GROUP LIMITED, LLC, a Nevada limited ) 6. Negligent Misrepresentation
liability company, MURDOCH GROUP, ) 7. Promissory Estoppel
16
INC., a Wyoming corporation, and DOES 1 ) ) 8. Injunction
17 through 25, inclusive, )
)
18 )
Defendants. )
19
20
Plaintiff alleges the following:
21
GENERAL ALLEGATIONS
22
1. At all relevant times herein, Defendant Dawn Estep was a resident of the State of
23
California, County of Los Angeles.
24
2. At all relevant times mentioned herein, Defendant Estep used the name “Dawn
25
Stroud” in her personal and business dealings.
26
27
28
PLAINTIFF’S COMPLAINT FOR DAMAGES

1 3. At all relevant times mentioned herein, Defendant Estep was and is the sole owner
2 of MURDOCH GROUP LIMITED, LLC (“Company”), a Nevada limited liability company
3 doing its principal business in the State of California.
4 4. Plaintiff is informed and believes and thereon alleged that at all relevant times
5 mentioned herein, Defendant Estep was and is the sole shareholder of MURDOCH GROUP,
6 INC., a Wyoming corporation (“Corporation”) that has its principal place of business in Las
7 Vegas, Nevada.
8 5. At all relevant times mentioned herein, Plaintiff was and is an individual residing
9 in Santa Monica, California and was and is the sole shareholder of *******, Inc. Said
10 corporation operates a business entitled, “*******.” At all relevant times mentioned herein,
11 ******* was a retail seller of women’s apparel.
12 6. The true names and capacities, whether individual, corporation, partnership,
13 associate, or otherwise, of DOES 1 through 25, inclusive, are unknown to Plaintiff who therefore
14 sues these Defendants by such fictitious names. Plaintiff will amend this Complaint to allege the
15 true names of such fictitious Defendants and their capacities such as ascertained. Plaintiff is
16 informed and believes and thereon alleges that each Defendant is contractually or tortiously
17 liable to Plaintiff for the actions alleged herein and the resulting damages to Plaintiff.
18 7. Plaintiff is informed and believes and thereon alleges that each of the defendants
19 sued herein was the agent and employee of the remaining defendants and was acting within the
20 scope and purpose of said agency or employment and with the permission and consent of the
21 other co-defendants with a prime knowledge, ratification, consent of each co-defendant.
22 8. As between Estep, Corporation and Company, at all relevant times mentioned
23 herein there existed a unity of interest and ownership such that any individuality and
24 separateness between said parties had ceased, and thus Defendant Estep’s limited liability
25 company was and is the alter ego of Corporation and of Company for the following reasons:
26 Corporation and Company were undercapitalized and were underinsured; the assets of
27 Corporation and Company were co-mingled with Estep; no formalities were observed with
28

1 respect to the operations of Corporation and Company; and assets were consistently diverted
2 from Corporation and Company to Estep.
3 9. As a result, adherence to the fiction of the separate existence of Corporation and
4 Company, on the one hand, and Estep would permit an abuse of the corporation privilege and the
5 LLC privilege and would sanction a fraud as well as permit an injustice.
6 10. Plaintiff is informed and believes and thereon alleges that each of the defendants
7 sued herein was the agent and employee of the remaining defendants and was acting within the
8 scope and purpose of said agency or employment and with the permission and consent of the
9 other co-defendants with a prime knowledge, ratification, consent of each co-defendant.
10 11. In or about 2005, Plaintiff was introduced to Defendant Estep by a mutual friend.
11 Plaintiff is informed and believes that Defendant Estep had been requested by said mutual friend
12 to gather information at a ******* event for said mutual friend so said mutual friend could write
13 an article.
14 12. At the time of their first meeting, Defendant Estep represented to Plaintiff that she
15 was a very successful employment recruiter for high tech companies.
16 13. Thereafter, from mid June 2007 through late 2007, Defendant Estep and Plaintiff
17 developed a friendship wherein they discussed the development of Plaintiff’s business.
18 A. SALE OF VMWARE COMMON STOCK
19 14. Beginning in or about June 2007, Defendant Estep represented to Plaintiff that she
20 was Initial Public Offering consultant being paid as such concerning the initial public offering of
21 a company called VMWare. In or about July 2007, Defendant Estep represented to Plaintiff that
22 VMWare was intending to provide to her certain restricted shares of stock in consideration for
23 the services she provided. Defendant Estep further represented that she was willing to sell a
24 portion of those shares to Plaintiff for the sum of $12,600.00.
25 15. In further discussions, Defendant Estep represented that if Plaintiff provided to
26 her the sum of $12,600.00, she would obtain 31,500 shares from VMWare and that said shares
27 would be placed in Plaintiff’s name under his social security number. She also represented that
28 the shares would be “locked up” (not permitted for sale) for a period of six (6) months.

1 Moreover, per Estep’s representations, Plaintiff is informed and believes that the lock up on the
2 shares was set to expire on or about February 1, 2008.
3 16. Based on the representations of Defendant, during the period of August 10, 2007
4 through August 24, 2007, Plaintiff wire transferred the sum of $12,600.00 to Defendant’s bank
5 account. Also, at Estep’s request, he provided to her his social security number.
6 17. Beginning in or about December 2007, Plaintiff requested that Defendant Estep
7 provide to him the share certificates. During his initial requests, Defendant Estep represented
8 that she had obtained the share certificates and that she was holding certificates in Plaintiff’s
9 name in her safe deposit box.
10 18. In late February 2008, Defendant Estep told Plaintiff that she intended to send
11 him the share certificates by Federal Express.
12 19. But having not received any shares and after inquiring further, on or about March
13 5, 2008, Estep stated the following: “I still have the shares locked away in a safety deposit box.
14 We all know I’m a lazy ass. Since I’ve gotten two kids, I’m so freakin lazy.” On or about May
15 26, 2008, Estep stated: “It’s Dawn, the stock is in your name, it’s been in your name since day
16 one, it’s been in your social, and it’s just I’ve had it with my transfer agent. Not my transfer
17 agent, the transfer to me. It has been in the safety deposit box with my stuff.”
18 20. To date, Plaintiff has not received any share certificates.
19 21. In or about June 2008, Plaintiff contacted the transfer agent for VMWare. During
20 his conversation with the agent, the agent represented that no shares were ever placed in
21 Plaintiff’s name and that the agency was unaware of any shares where Plaintiff was designated
22 as the beneficial owner.
23 22. Since June 2008, Plaintiff has made numerous demands, including demands in
24 writing, that Defendant Estep provide to him the shares she allegedly purchased for him.
25 Defendant Estep has ignored all requests.
26 B. SALE OF *******, INC.
27
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1 23. During the first half of 2007, Plaintiff was actively searching for a buyer for his
2 company, *******. In fact, Plaintiff received written offers that he was considering.
3 Specifically, Plaintiff was offered $1.2 million for the purchase of *******, Inc. stock shares.
4 24. After receipt of the offer, Plaintiff entered into negotiations for the sale of
5 *******. During the negotiations, Plaintiff verified that the buyer had the necessary funds to
6 complete the purchase.
7 25. In or about June 2007, Plaintiff informed Defendant Estep that he had a buyer for
8 the company. Defendant Estep told Plaintiff she wanted to find an investor and that she could do
9 it within days to weeks. She said Plaintiff would be “stupid” to sell the company, that her
10 friends/clients were billionaires and that she could bring in an investor in days to weeks. She
11 further stated, “Your company is worth so much more; not based on how much it’s worth today,
12 but the future value [because of its database].”
13 26. As a direct result of Defendant Estep’s representations, Plaintiff cancelled any
14 further negotiations and agreed to permit Defendant Estep to seek capital.
15 27. On July 12, 2007, Estep emailed and called to say, “we have capital.” On July 24,
16 2007, Estep wrote, “I anticipate being funded within three weeks.” Shortly thereafter, Defendant
17 Estep told Plaintiff that she had secured the necessary funding from Peter Norton, a former high
18 tech executive who founded Norton Utilities.
19 28. In or about August 2007, Defendant Estep stated that Norton had faxed an offer
20 regarding his investment in ******* but that she decided to disregard the offer as viable in that
21 Norton wanted too much interest in the company.
22 29. Shortly thereafter, Defendant Estep represented that she had spoken to Ross
23 Estep, apparently a relative, and that he stated he would provide the funding for *******. Over
24 the next several months, Defendant Estep represented to Plaintiff that she was having meetings
25 with Ross Estep to secure the deal.
26 30. However, in or about October 2007, without further mention of Ross Estep,
27 Defendant Estep represented that she had connections at Google and would attempt to make a
28 deal with that company. On or about January 11, 2008, Estep sent an e-mail to Plaintiff stating

1 that she was “scheduling the first of several meetings with Google.” Thereafter, Defendant Estep
2 represented that she had set up meetings with Google and that Plaintiff needed to prepare a
3 presentation. Further, Defendant Estep represented that she had retained her half-brother,
4 Lowell, to prepare the artwork for the presentation. Upon receipt of the artwork, Plaintiff placed
5 it inside the presentation he had created.
6 31. Over the next several months, Defendant Estep represented that she and
7 representatives of Google had met at least three times to discuss financing *******.
8 32. In or about February 2008, Defendant Estep represented that Google was
9 interested in a business arrangement with ******* and that she was seeking $15 million would
10 enter into a financing arrangement for ******* and that her attorneys would prepare an
11 agreement wherein Google would provide $15 million in initial funding via a combination of
12 stock and cash.
13 33. Thereafter, Plaintiff and Defendant Estep had meetings wherein they discussed
14 how ******* would use the money and discussed Estep’s desire to be the company’s chief
15 operating officer. Despite repeated requests for a copy of the agreement, none was ever
16 produced. However, Defendant Estep represented that the “attorneys” who had prepared the
17 agreement included and Joseph Curtis Edmonson, an attorney admitted to practice law in the
18 state of California who resided in Oregon.
19 34. In or about June 2008, Defendant Estep told Plaintiff that the contracts with
20 Google had been completed. Defendant Estep further represented that she had executed the
21 agreement on behalf of ******* despite never having been authorized to execute any agreements
22 on behalf of *******, *******, Inc. or Plaintiff. Plaintiff then demanded to be provided a copy
23 of the contract however none was ever forthcoming.
24 35. As a result of Defendant’s failure to provide any agreements or any details of any
25 transactions, Plaintiff terminated the relationship with Defendant Estep.
26 36. In or about July 2008, Plaintiff contacted Google to determine whether that
27 company had entered into any agreements with *******. He was informed that no agreements
28 had ever been negotiated and that Google was unaware of *******.

1
4 FIRST CAUSE OF ACTION

5 (Breach of Oral Contract v. all defendants)
6 37. Plaintiff realleges and incorporates herein by reference paragraphs 1 through 36
7 of his General Allegations as though fully set forth hereat.
8 38. In or about August 2007, Plaintiff and Defendant Estep entered in to an agreement
9 whereby she would provide to Plaintiff 31,500 shares of VMWare common stock in exchange
10 for the sum of $12,600.00.
11 39. Shortly thereafter, Plaintiff wired to Defendant Estep the sum of $12,600.00
12 receipt of which Estep acknowledged.
13 40. Plaintiff performed all obligations required of him under the terms of the
14 agreement.
15 41. Defendant Estep breached the agreement by failing to provide to Plaintiff 31,500
16 of VMWare common stock.
17 42. As a direct and proximate result of said breach, Plaintiff has been damaged in an
18 amount according to proof at time of trial that currently exceeds $500,000.00.
19 SECOND CAUSE OF ACTION
20 (Specific Performance v. all defendants)
22 of his General Allegations and paragraphs 38 through 41 of his First Cause of Action as though
23 fully set forth hereat.
24 44. Plaintiff is informed and believes and thereon alleges that Defendant Estep
25 purchased the shares of VMWare stock using Plaintiff’s money and that said shares were placed
26 in the name of Corporation or of Company.
27
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1 45. The consideration set forth in the agreement was the fair and reasonable value of
2 the stock shares and therefore the value defendants were receiving was fair and reasonable at the
3 time they received it.
4 46. Plaintiff has performed all conditions, covenants and promises of the agreement.
5 47. Defendants and each of them have failed and refused and continue to fail and
6 refuse to perform the conditions of the contract in that they have failed to provide Plaintiff with
7 the shares of stock purchased with his money.
8 48. Plaintiff has no legal remedy in that the current value of the shares so greatly
9 exceeds the purchase price that it is unlikely that Defendants could cover a monetary judgment.
10 49. Defendants are estopped from relying on the statute of frauds as they were
11 expected to perform the terms of the agreement within one year.
12 50. Therefore, Plaintiff requests that this Court order defendants to provide 31,500
13 shares of common stock in VMWare forthwith.
14 THIRD CAUSE OF ACTION
15 (Promissory Estoppel v. all defendants)
19 52. In or about August 2007, Defendant Estep promised Plaintiff that if he paid to her
20 the sum of $12,600.00, she would obtain for him 31,500 shares of common stock in VMWare.
21 53. In reliance thereon, Plaintiff paid to Defendant Estep said sum.
22 54. In so providing said sum, Plaintiff relied on Defendant Estep’s statements and
23 said reliance was reasonable in that Estep had represented consistently to Plaintiff that she was
24 acting as a business consultant to VMWare.
25 55. Defendant Estep breached the promise by failing to provide to Plaintiff the shares
26 of VMWare common stock. Said shares have a current market value of more than $500,000.00.
27 56. Injustice can be avoided only by providing to Plaintiff the benefit of the bargain
28 he made based on the promises of Estep in an amount according to proof at time of trial.

1
5 FOURTH CAUSE OF ACTION

6 (Fraud v. all defendants re: Purchase of VMWare common stock)
10 58. Beginning in or about August 2007, Estep represented that she or her Company or
11 her Corporation would purchase for Plaintiff 31,500 of VMWare shares of common stock in
12 exchange for Plaintiff’s payment of $12,600.00.
13 59. At the time Defendant Estep made the representations, they were false and she
14 knew them to be false in that she had no intention of obtaining any shares of VMWare for
15 Plaintiff. Estep intended Plaintiff to rely on her representations so that he would provide her the
16 sum of $12,600.00.
17 60. Plaintiff relied on Estep’s representations and said reliance was reasonable in that
18 Plaintiff had been informed previously that Estep, by and through her Company and her
19 Corporation, was consulting with VMWare and that Estep was able to purchase shares of stock
20 as part compensation for services she was providing to VMWare.
21 61. In relying on Estep’s statements, Plaintiff provided to Estep the sum of
22 $12,600.00 in August 2007 by wire transfer to Estep’s account. Also in reliance thereon, he
23 provided to Estep his social security number.
24 62. Plaintiff is informed and believes that at or shortly after receipt of the funds from
25 Plaintiff, either Estep or Corporation or Company received shares of VMWare common stock
26 but that said shares were placed in the name of Estep and/or Company and/or Corporation.
27
28

1 63. In or about December 2008, Estep represented that she had Plaintiff’s shares and
2 that said shares were located in her safe deposit box and that said shares were issued in
3 Plaintiff’s name.
4 64. However, to date, Plaintiff has not received any shares and has been informed by
5 VMWare’s transfer agent that no shares were ever issued in his name.
6 65. As a proximate result, Plaintiff has been damaged in the loss of value of the
7 VMWare shares, an amount of at least $500,000.00 according to proof at time of trial.
8 66. Also as a proximate result of Estep’s actions, Plaintiff has suffered from anxiety,
9 restlessness, emotional upset, insomnia and other related disruptions to his system all to his
10 general damage in an amount according to proof at time of trial.
11 67. Defendant Estep’s actions and the actions of her Corporation and Company in
12 making false representations to Plaintiff in order to obtain his money and then placing his shares
13 in Corporation or Company and failing to provide the same to Plaintiff was willful, wanton,
14 malicious and undertaken in conscious disregard for the rights of Plaintiff thus justifying an
15 award of exemplary and punitive damages in an amount to be determined at time of trial.
16 FIFTH CAUSE OF ACTION
17 (Fraud v. all Defendants re: Sale of *******)
19 of his General Allegations, paragraphs 38 through 41 of his First Cause of Action, and
20 paragraphs 58 through 64 of his Fourth Cause of Action as though fully set forth hereat.
21 69. In or about June 2007, Estep represented that if Plaintiff terminated the sale of his
22 company, *******, she could and would develop Plaintiff’s company to where it could make an
23 initial public offering. Defendant Estep further represented that she could locate an investor to
24 provide the requisite capital. Defendant Estep stated further that she intended to secure a
25 minimum of $3 million.
26 70. Shortly thereafter, Estep represented that Peter Norton had agreed to finance
27 *******. Thereafter, in or about February 2008, Defendant Estep represented that Google
28 would enter into a financing arrangement for ******* and that her attorneys would prepare an
10

1 agreement wherein Google would provide $15 million in initial funding in stock and in cash.
2 And in June 2008, Estep represented that Google had executed an agreement to provide said
3 funding to *******.
4 71. The aforementioned representations concerning Norton and Google were false
5 and Estep knew they were false at the time she made them. At the time they were made, she
6 intended that Plaintiff would rely on them and forego any sale of *******.
7 72. Plaintiff is informed and believes and thereon alleges that Estep made the false
8 representations for two reasons: firstly, she thought she could make money from the funding and
9 initial public offering of ******* and therefore did not want Plaintiff to sell his company; an
10 secondly, Estep wanted to puff up her credentials with Plaintiff so that he would permit her to
11 make various deals concerning *******.
12 73. In reliance on Estep’s representations, Plaintiff terminated the sale of *******
13 and made no other attempts to locate a purchaser.
14 74. Plaintiff is informed and believes that Estep never had any meetings with Norton
15 or Google, and had no prior business dealings with Google.
16 75. Plaintiff’s reliance on Estep’s statements concerning Norton and then concerning
17 Google was reasonable in that he had been informed previously by Estep that she had been
18 engaged in a consulting arrangement with Google. Further, reliance was reasonable because
19 every time Plaintiff inquired as to the status of the deal with Google, Estep continually provided
20 the names of attorneys she was allegedly using to prepare the deal and provided the names of
21 Google executives with whom she allegedly was meeting.
22 76. As a direct and proximate result of Estep’s false statements and Plaintiff’s
23 reliance thereon, Plaintiff did not sell ******* and therefore did not receive the sum of $1.2
24 million all to his damage in an amount according to proof at time of trial.
25 77. Further, as a proximate result of Estep’s actions, Plaintiff has suffered from
26 anxiety, restlessness, upset, insomnia and other related disruptions to his system all to his
27 general damage in an amount according to proof at time of trial.
28
11

1 78. The actions of Estep in lying about a transaction with Google for the purposes of
2 concealing her failure to secure funding for ******* was willful, wanton, malicious and
3 undertaken in conscious disregard for Plaintiff thus justifying an award of punitive and
4 exemplary damages in an amount according to proof at time of trial.
5 SIXTH CAUSE OF ACTION
6 (Negligent Misrepresentation v. all defendants)
8 of his General Allegations, paragraphs 38 through 41 of his First Cause of Action, paragraphs 58
9 through 64 of his Fourth Cause of Action, and paragraphs 69 though 75 of his Fifth Cause of
10 Action as though fully set forth hereat.
11 80. If the actions of Estep were not fraudulent, then they were negligent in that Estep
12 owed a duty to Plaintiff not to mislead him or lie to him about the status of her attempts to secure
13 funding for *******.
14 81. Estep breached her duty by making the false representations set forth in
15 paragraphs 68 and 69.
16 82. Plaintiff reasonably relied on Estep’s representations and Estep knew or should
17 have known that Plaintiff would rely.
18 83. As a proximate result, Plaintiff did not conclude the sale of ******* all to his
19 detriment in the amount of $1.2 million.
20 84. Further, as a proximate result of Estep’s actions, Plaintiff has suffered from
21 anxiety, restlessness, emotional upset, insomnia and other related disruptions to his system all to
22 his general damage in an amount according to proof at time of trial.
23 SEVENTH CAUSE OF ACTION
24 (Promissory Estoppel v. all defendants)
12

1 86. In or about June 2007, Estep represented that Plaintiff should terminate the sale of
2 his company, *******, so that she could develop Plaintiff’s company to where it could make an
3 initial public offering. Defendant Estep further represented that she could locate an investor to
4 provide the requisite capital. Defendant Estep stated further that she intended to secure a
5 minimum of $3 million.
6 87. In or about August 2007, Estep represented that Peter Norton would invest in
7 *******. In January 2008, Defendant Estep represented that Google would enter into a
8 financing arrangement for ******* and that her attorneys would prepare an agreement wherein
9 Google would provide $15 million in initial funding in stock and in cash. And in June 2008,
10 Estep represented that Google had executed an agreement to provide said funding to *******.
11 88. From February 2008 through December 2008, Estep represented to Plaintiff that
12 because of the agreement with Google, Plaintiff could not sell ******* nor could he encumber it
13 or develop the business without the express authority of Google.
14 89. In reliance on Estep’s representations, Plaintiff terminated the sale of *******
15 and thereafter did not take any steps in contravention of that which he believed was required by
16 Google.
17 90. Plaintiff’s reliance of Estep’s representations was reasonable in that every time
18 Plaintiff inquired as to the status of the deal with Google, Estep continually provided the names
19 of attorneys she was allegedly using to prepare the deal and provided the names of Google
20 executives with whom she allegedly was meeting.
21 91. As a direct and proximate result of his reliance, Plaintiff’s business suffered
22 severe diminution in value in an amount according to proof at time of trial.
23 EIGHTH CAUSE OF ACTION
24 (Injunction v. all defendants)
25 92. Plaintiff realleges and incorporated herein by reference paragraphs 1 through 34
13

1 93. Plaintiff is informed and believes and thereon alleges that Defendants purchased
2 shares of VMWare common stock that otherwise are owned by Plaintiff. Unless otherwise
3 enjoined from selling or transferring the shares, Defendants will have the ability to hide the
4 shares in a manner where Plaintiff may not be able to locate them.
5 94. Therefore, Plaintiff seeks a preliminary and permanent injunction from this Court
6 ordering that defendants may not sell, transfer or otherwise encumber any shares of VMWare
7 stock in their possession.
8 Wherefore, Plaintiff prays for damages as follows:
9 FIRST CAUSE OF ACTION
10 1. For the value of the shares of VMWare common stock in an amount according to
11 proof;
12 SECOND CAUSE OF ACTION
13 2. For an Order that defendants provide to Plaintiff 31,500 shares of VMWare
14 common stock;
15 THIRD CAUSE OF ACTION
17 proof;
18 FOURTH CAUSE OF ACTION
20 proof;
21 5. For general damages in an amount according to proof;
22 6. For punitive and exemplary damages in an amount to be determined at time of
23 trial;
24 FIFTH CAUSE OF ACTION
25 7. For the value of the sale of ******* in an amount according to proof;
27 9. For punitive and exemplary damages in an amount to be determined at time of
28 trial;
14

1 SIXTH CAUSE OF ACTION
2 10. For the value of the sale of ******* in an amount according to proof;
4 SEVENTH CAUSE OF ACTION
5 12. For the loss in value to *******;
6 EIGHTH CAUSE OF ACTION
7 13. For an injunction that prevents defendants from selling, transferring or otherwise
8 encumbering any shares in their possession of VMWare.
9 ALL CAUSES OF ACTION
10 14. For costs of suit incurred;
11 15. For prejudgment interest;
12 16. For all other relief this Court deems just and proper.
13 Dated: March 11, 2009 LAW OFFICES OF JOHN H. THALER
14
By:______________________________
15
JOHN H. THALER, Attorney for
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Plaintiff *******
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Dawn Estep Sued

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JOHN H.

THALER, SBN 150290

8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

4 FIRST CAUSE OF ACTION

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

5 FOURTH CAUSE OF ACTION

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

PLAINTIFF’S COMPLAINT FOR DAMAGES

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