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.~ <br />56. The Defendant made the representations with the intent that the Plaintiff act <br />in reliance on the representations. <br />57. The Plaintiff relied on the representations. <br />58. The Plaintiff s reliance was justified. <br />59. This reliance caused damage to the Plaintiff. <br />WHEREFORE, Plaintiff asks this Court for the following relief: <br />1. That this Court order rescission of the Agreement between Robco and the <br />City on the basis of fraud or misrepresentation. <br />2. In the alternative, that this Court decree that the City is entitled to specific <br />performance of the Agreement and order Robco to perform its contractual obligations. <br />SIXTH CLAIM FOR RELIEF <br />60. Plaintiff incorporates paragraphs 1 through 59 as if the same were set forth <br />herein. <br />61. Defendant Robco breached its agreement with the City knowingly, fraudu- <br />lently, maliciously and with a wanton and reckless disregard for the Plaintiff s rights and <br />feelings. <br />WHEREFORE, Plaintiff asks for a judgment in its favor and against Defendant <br />Robco, awarding Plaintiff exemplary damages in an amount reasonably stated to be <br />$500,000.00 for its acts in deliberate, knowing, reckless, willful and wanton disregard for <br />the City's rights, and such further relief as the Court deems proper. <br />Respectfully submitted, <br />Plaintiffs address: <br />44 Union Boulevard <br />Lakewood, Colorado 80228 <br />GORSUCH, KIRGIS, CAMPBELL, <br />WA ER AND GROVER <br />BY~ <br />Roger W. Noonan, No. 6085 <br />Paul F. Kennebeck, No. 7939 <br />Randy D. Funk, No. 9732 <br />1401 Seventeenth Street, Suite 1100 <br />Denver, Colorado 80202 <br />(303) 534-1200 <br />Attorneys for Plaintiff <br />-8- <br />