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COUNT IX <br />48. All preceding paragraphs 1-44 are realleged and incorporated herein by this <br />reference. <br />49. Wilma Zellitti is managing partner of Zellitti Properties. <br />50. Wilma Zellitti is an elderly widow and lives in wheat Ridge, Colorado far <br />removed for the actual location of the property which is the subject of this action. <br />51. Defendants have recklessly and intentionally and in bad faith disregarded <br />the rights of the Plaintiff Wilma Zellitti and intentionally inflicted emotional distress upon <br />her and have used her property and entered agreements regarding Plaintiff Zellitti <br />Properties' property without notice or consent, and in furtherance thereof have: <br />a. Exclusively utilized Plaintiffs' property without Plaintiffs consent; <br />b. Refused to produce documents regarding the use of Plaintiffs property <br />in a reasonable time; <br />c. Altered the alleged written exclusive lease of Plaintiffs' property; <br />d. Filed malicious prosecution and abuse of process and interference <br />claims against the Plaintiff without reasonable basis therefore and in violation of prior <br />agreements; <br />e. Refused to pay royalties and use fees while using Plaintiffs' property to <br />their advantage; <br />f. Forced the Plaintiff Zellitti Properties to expend excessive funds on <br />attorney fees to gain access to documents that should have been made readily <br />available; <br />g. failed to disclose Zellitti Properties interest in the property on official <br />documents to gain advantage without Zellitti Properties consent; <br />52. The actions of the Defendants have been in bad faith with intent to create <br />mental and emotional distress, anxiety and undue pressure on the Plaintiff to force <br />Wilma Zellitti as general partner to abandon and relinquish valuable rights of Zellitti <br />properties. <br />53. As a direct and proximate result, Wilma Zellitti has suffered mental and <br />emotional distress and lost enjoyment of life and she has been forced to contribute <br />money to ZP to pay for otherwise unnecessary expense.