each of them, were working for the benefit of Plaintiff and in their particular best interest to obtain for him the best loan and at the best rates available. That at the time Defendants, and each of them, made the foregoing false representations to Plaintiffs they knew that they were untrue and that these representations were material representations, and that no basis in fact existed to support such fraudulent representations. That the foregoing representations were made in order to induce Plaintiffs to act on and take the said loan(s) in order for both defendants to make a substantial amount of money thereby and there from. Plaintiffs were in fact induced to and did take these loans based on the said fraudulent representations. That Plaintiffs were induced to rely and did rely on the representations of these defendants through deception and their reliance was justified as they believed that Defendants, and each of them, were working for their and in his best interests. That by virtue of reasonable reliance and the increased interest Plaintiffs’ they was made to pay, they has been damaged in the loss of their good credit and a higher payment and are now being involved in litigation that they did not bargain for, all to their damage and injury. Plaintiffs have relied on the representations of Defendant, and each of them, and because of this reliance have made various moves to avoid the foreclosure all to no avail, while defendants knew all the time that they were deceiving Plaintiffs. Plaintiffs reliance was justified based upon the false representations of Defendants, and each of them, and had no reason to believe
each of them, were working for the benefit of Plaintiff and in their particular best interest to obtain for him the best loan and at the best rates available. That at the time Defendants, and each of them, made the foregoing false representations to Plaintiffs they knew that they were untrue and that these representations were material representations, and that no basis in fact existed to support such fraudulent representations. That the foregoing representations were made in order to induce Plaintiffs to act on and take the said loan(s) in order for both defendants to make a substantial amount of money thereby and there from. Plaintiffs were in fact induced to and did take these loans based on the said fraudulent representations. That Plaintiffs were induced to rely and did rely on the representations of these defendants through deception and their reliance was justified as they believed that Defendants, and each of them, were working for their and in his best interests. That by virtue of Plaintiffs’ reasonable reliance and the increased interest they was made to pay, they has been damaged in the loss of their good credit and a higher payment and are now being involved in litigation that they did not bargain for, all to their damage and injury. Plaintiffs have relied on the representations of Defendant, and each of them, and because of this reliance have made various moves to avoid the foreclosure all to no avail, while defendants knew all the time that they were deceiving Plaintiffs. Plaintiffs reliance was justified based upon the false representations of Defendants, and each of them, and had no reason to believe
2nd-amended-complaint-e-manuel.docx