On an admittedly quick read, I'd give that complaint a very small chance of surviving a motion to dismiss.
Fraud is pled in conclusory terms. Basically no particular facts alleged supporting fraud. Must have been fraud because of the defendants' negligence in not realizing what they should have realized. That ain't fraud.
One person's (someone learned) opinion.
Last edited by Snapolit1; 02-13-2020 at 09:10 AM.
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