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COUNT X <br />54. All introductory paragraphs are realleged and incorporated herein by this <br />reference. <br />55. Defendants acted jointly and in concert to misrepresent the material <br />extracted from the Plaintiffs property in order to avoid paying royalties to the Plaintiff. <br />56. As a result the Plaintiff has lost income and incurred unnecessary expense <br />to recover the unpaid royalties and has suffered punitive damages. <br />PRAYER FOR RELIEF <br />WHEREFORE Plaintiffs requests Relief as follows: <br />1. Award compensatory and punitive damages in favor of Zellitti Properties <br />against Hocker Construction, L.L.P. for trespass on Plaintiff's property, plus pre and <br />post judgment interest and costs of this action; and <br />2. Award compensatory and punitive damages in favor of Zellitti Properties, plus <br />pre and post judgment interest and costs of this action against Defendants Anthony <br />Zellitti and Marilyn Zellitti; and <br />3. Award compensatory and punitive damages in favor of Wilma Zellitti against <br />Hocker Construction, L.L.P. for intentional infliction of emotional distress, plus pre and <br />post judgment interest and costs of this action; and, <br />4. Award compensatory and punitive damages in favor of Wilma Zellitti, plus pre <br />and post judgment interest and costs of this action against Defendants Anthony Zellitti <br />and Marilyn Zellitti; and <br />5. Award attorney fees and costs of this litigation and prejudgment and post <br />judgment interest; and, <br />Plaintiffs demand trial by jury on all issues triable as of right. <br />Dated this 28th day of April, 2009 <br />s/s Charles C. Powers <br />original duly signed and on file at the office of Charles C. Powers