17 Randall Greene Accused of Stealing a House

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INSTRUMENT# 2014065316 OR BOOK 4489/P AGE 2468 PAGE 2 o f 5

Lake County, Florida.·

F. Purchase price of the Property from Mr. and Mrs. Lye was $925,000.00, of which

the Plaintiffs paid $913;100.29.

G. Upon closing the Property was titled in the name of Defendant, Alfresco

Acquisitions, LLC and the Property has not been titled in the name ofthe Plaintiffs.·

H. Plaintiffs were relying on, and placed. trust .and repose in, Defendant, William Boylan, in his individual capacity and in his capacity as Manager and Owner of Alfresco

Acquisitions, LLC.

I. William Boylan, individually and in his capacity as Manager and Owner of Alfresco

Acquisitions, LLC, held himselfout as acting in the best interests and on behalfofthe Plaintiffs and established a confidential relationship with the Plaintiffs.

J. The Plaintiffs acted upon their reliance of the actions, promises and representations of Defendant, William Boylan, individually and in his capacity of Manager and Owner ofAlfresco Acquisitions, LLC.

K. The Defendants, William Boylan and Alfresco Acquisitions, LLC, knowingly made intentional and material misrepresentations of fact, and the Plaintiffs relied upon these misrepresentations in deciding to provide the money for the purchase ofthe Property.

L. The Plaintiffs have established an equitable right to the Property.

M. The Defendants have been unjustly enriched by their actions and by retaining .ownership and possession ofthe Property purchased with the Plaintiff's money.

N. The Plaintiffs have been damaged, as they did not receive the Property or tlie monetary equivalent ofthe Property, despite paying $913,100.29 to the Defendants for the purchase of the Property. In addition, pre-judgment interest has accrued at the statutory rates: (i) 9/22/2011- 9/30/2011, (6%) in the amount of $1,350.90; (ii) 10/1/2011-3/28/2014, (4.75%) in the amount of $108,016.47; 3/29/2014-6/10/2014, (4.75%) in the amount of $8,793.28. In addition, there may be additional damages due to the Plaintiffs.

0. The Defendants have vacated and abandoned possession of the Property and the Court previously appointed a receiver to manage the Property pending this action.

P. It is· inequitable for the Defendants to retain the benefits of ownership of the Property.

Q. There is no genuine issue of material fact, and Plaintiff is entitled to judgment as a

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