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<br /> <br />41. More made those misrepresentations and concealed those facts with the intent that <br />Halsnes rely on those misrepresented and concealed facts. <br />42. Halsnes justifiably relied on those misrepresentations and concealed facts and his reliance <br />was reasonable. <br />43. Halsnes has incurred damages as a result of those misrepresentations and concealments. <br />44. More's actions and statements were attended by circumstances of willful and wanton <br />conduct and a complete disregazd of Halsnes' rights entitling him to punitive damages. <br />WHEREFORE, Halsnes prays for judgment against More in an amount.to be determined <br />at trial, for actual, consequential and punitive damages, costs, reasonable attorneys' fees and <br />interest as provided by law, and for such other and further relief that the Court deems just and <br />proper. <br />FIFTH CLAIM FOR RELIEF <br />(Promissory Estoppel) <br />45. .Halsnes incorporates each allegation set forth above as if set forth verbatim herein. <br />46. More, in a series of written and oral promises, entered into the Lease/Purchase Option <br />with Halsnes as set forth above. <br />47. In making those promises, More knew that Halsnes would be induced to undertake the <br />necessary steps to implement a gravel operation on the Real Property. <br />48. In reliance upon the promises made to him by More, Halsnes undertook the necessary <br />steps to implement a gravel operation on the Real Property. <br />49. It would be unjust to allow More to profit by failing to live up to and keep its promises, <br />and the promises of More should be enforced by this Court to avoid injustice to Halsnes. <br />WHEREFORE, Halsnes prays for judgment against More in an amount to be determined <br />at trial, for actual, consequential and punitive damages, costs, reasonable attorneys' fees and <br />interest as provided by law, and for such other and further relief that the Court deems just and <br />proper. <br />SIXTH CLAIM FOR RELIEF <br />(Quantum Meruit, Implied Contract or Unjust Enrichment) <br />50. Halsnes incorporates each allegation set forth above as if set forth verbatim herein. <br />6 <br />