Complaint for Fraud (Over $35,000) June 17, 2024 (2024)

 
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 DocuSign Envelope ID: 93CAA837-7EC44D31-9164-9DOCBEAB493E PLD-C-001 ATTORNEY OR PARTY INITHOUT ATTORNEY STATEBARNUMBER 131663 FOR COURT USE ONLY NAME: Joseph C. Rosenblit FIRM NAME. Law Offices of Joseph C. Rosenblit smEETADDREss 33801 Avenida Calita cnv San Juan Capistrano STATE CA ZIP CODE: 92675 TELEPHQNE No (949) 412-6666 FAx No (949) 312-2090 EMAIL ADDREss rosenbhtlawyer@gmail.corn ATTORNEY FOR (nsmei. WealthCOrp Capital MOrtgage, WealthCOrp TaX & ACCOunting, IGC, ahd fram MartineZ SUPERIOR COURT OF CALIFORNIA, COUNTY OF RIVERSIDE sTREEr AooREss County of Riverside, Historic Courthouse, 4050 Main Street MAILING ADDRESS GITY AND zip coDE Riverside, CA 92501 BRANGH NAME: HISTORIC COURTHOUSE PLAINTIFF: INEALTHCORP CAPITAL MORTGAGE, INEALTHCORP TAX & ACCOUNTING, INC, AND IRAM MARTINEZ DEFENDANT. Ro 000 0, 0 oeo 0 0 s SSAS 0 S, 0 0 s DOES 1 TO 100 VERIFIED CONTRACT & FRAUD COMPLAINT AMENDED COMPLAINT (Number)r CROSS-COMPLAINT ~ AMENDED CROSS-COMPLAINT (Number): ~ Jurisdiction (check all that app/y): ~ ACTION IS A LIMITED CIVIL CASE (does not exceed $ 35,000) CASE NUMBER Amount demanded ~ does not exceed $ 10,000 exceeds $ 10,000 ~~ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $ 35,000) ACTION IS RECLASSIFIED by this amended complaint or cross-complaint 1. ~ from limited to unlimited from unlimited to limited Plaintiff* (name or names): Wealthcorp Capital Mortgage,inc., Wealthcorp Tax 8 Accounting, Inc., and tram Martinez allegea CauSeS OfaCtiOn againat defendant*(name crnameS): R b d G I L S,R b d G I L o d gb Rl b, dRI t .. 2. This pleading, including attachments and exhibits, consists of the following number of pages: 179 3. a. Each plaintiff named above is a competent adult except plaintiff (name)f Wealthcorp Capital Mortgage, Inc. 8 Wealthcorp Tax & Accounting, Inc. ~ (1) ~v a corporation qualified to do business in California. ~~~ (2) an unincorporated entity(descnbe): (3) other(specify): b. Plaintiff (name): (1) has complied with the fictitious business name laws and is doing business under the fictitious name (specify): c. ~~ (2) has complied with all licensing requirements as a licensed (specify): Information about additional plaintiffs who are not competent adults is shown in Attachment 3c. 4. a. Each defendant named above is a natural person ~ except defendant (name): R Innovations ~ ~ except defendant (name)f ~ (1) ~ (2) (3) a business organization, form unknown. a corporation. anunincorporated entity(describe): ~ ~ (1) (2) (3) a business organization, form unknown. a corporation. an unincorporated entity(describe): ~ (4) a public entity (describe): ~ (4) a pubhc entity(descnbe): (5) ~v other (specify)f Sole Proprietorship 'f this form is used as a cross-complaint, ~ (5) other (specify): pla Stiff meaos cross-complainant eod defendant mecca cross-defendant Page 1 of2 Form Approved for Opiooal Use Judicial Couool of Caldoioia COMPLAINT— Contract Code of Civil Procedure, 5 425 12 PLD-C-001 [Rev January I, 2024]DocuSign Envelope ID: 93CAA837-7EC44031-9164-9DOCBEAB493E PLD-C-001 SHORT TITLE: CASE NUMBER Wealthcorp Capital Mortgage, et al vs. Luque, et al 4. b. The true names of defendants sued as Does are unknown to plaintiff. (1) ~v Doe defendants (specify Doe numbers): 1 to 100 were the agents or employees of the named defendants and acted within the scope of that agency or employment. (2) ~v Doe defendants (specify Doe numbers): 1 to 100 are persons whose capacities are unknown to ~ ~ c. d. plaintiff. Information about additional defendants who are not natural persons is contained in Attachment 4c. Defendants who are joined under Code of Civil Procedure section 382 are (names): 5. ~~ Plaintiff is required to comply with a claims statute, and ~ a. b. has complied with applicable claims statutes, or is excused from complying because (specify): 6. ~v This action is subject to ~v Civil Code section 1812.10 ~v Civil Code section 2984.4. 7. This court is the proper court because a. ~v b. c. ~ ~ a defendant entered into the contract here. a defendant lived here when the contract was entered into. a defendant lives here now. d. e. ~ ~v ~ the contract was to be performed here. a defendant is a corporation or unincorporated association and its principal place of business is here. f g. ~ real property that is the subject of this action is located here. other (specify): 8. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): Breach of Contract Common Counts Other (specify): Misrepresentation and Declaratory Relief 9 ~v Other allegations: See Attachment 1. 10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. ~v damages of $ 1,036,040.00 b. ~v interest on the damages (1) ~v according to proof (2) ~v at the rate of (specify): 30.00 percent per year from (date): May 25, 2024 c. ~v (1) ~ attorney's fees of:$ ~ d. (2) ~v according to proof. other (specify): 11. ~ The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers) FR-1 THROUGH CC-3, inclusive Date: June 12, 2024 Joseph C. Rosenblit (TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY) (lf you wish to verify this pleading, affix a verification.i PLO-0-001 (Re v Jaauaw I, 2024] COMPLAINT— Contract Page 2 of 2DocuSign Envelope ID: 93CAA837-7EC44031-9164-9DOCBEAB493E PLD-C-001(3) CASE NUMBER; SHORT 1 )TEE: Wealthcorp Capital Mortgage, et al vs. Luque, et ai FIRST CAUSE OF ACTION — Fraud (numuer) ATTACHMENT TO Hw Complaint H Cross-Complaint (Use a separate cause of action form for each cause of action.) FR- 1. Plaintiff (name): Wealthcorp Capital Mortgage, Wealthcorp Tax & Accounting, Inco and Iram Martinez alleges that defendant (naf ne: Roberto Gonzalez Luque, individually, and DBA R Innovations, and R Innovations on or about (date): 12/4/23 to 5/31/24 defrauded plaintiff as follows: FR-2 Intentional or Negligent Misrepresentation a. Defendant made representations of material fact H as stated in Attachment FR-2.a Hv as follows: Defendant represented that he had a large book of business that involved the ability to obtain significant discounts if cash was paid upfront to product providers who had contracts to supply things to companies at prices that would provide a large profit. Plaintiffs were in the loan business and checked out the initial book of business presented by defendant. One business was visited and verified. Initially plaintiffs made a small loan and were paid back with the high percentage promised in the contract of 30'/o. In this way, defendant lured plaintiffs in and more monies were lent. Plaintiffs lent Luque $ 1,188,587.00 in principal of which he paid back $ 152,547 which included interest and b. These representations were in fact false. The truth was ~ principal payments up until March 26th (See also exhibits 1-5. ~.v.mr as stated in Attachment FR-2.b ~v as follows: Defendant did not have a business that produced any profit margin. The truth is that defendant falsified documents to make it seem that there was a large volume of business with Universal and others which was a deliberate Iie. The truth is that defendant had no orders from Universal. The truth was that defendants forged orders from Universal and others. The truth is that the drivers license that defendant Luque gave plaintiffs to satisfy them as to the truth of his identity was a forged document. The truth is that Luque kept the money lent to him by plaintiffs such that he converted approximately $ 1,036,040.00 for his own use. (See exhibits 1-5) c. When defendant made the representations, defendant knew they were false, or defendant had no reasonable ground for believing the representations were true. d. Defendant made the representations with the intent to defraud and induce plaintiff to act as described in item FIR-5. At the time plaintiff acted, plaintiff did not know the representations were false and believed they were true. Plaintiff acted in justifiable reliance upon the truth of the representations. FR-3. ~ Concealment a. Defendant concealed or suppressed material facts H as stated in Attachment FR-3.a H as follows: b. Defendant concealed or suppressed material facts defendant was bound to disclose. by telling plaintiff other facts to mislead plaintiff and prevent plaintiff from discovering the concealed or suppressed facts. c. Defendant concealed or suppressed these facts with the intent to defraud and induce plaintiff to act as described in item IFIR-5. At the time plaintiff acted, plaintiff was unaware of the concealed or suppressed facts and would not have taken the action if plaintiff had known the facts. Page 3 Page 1 of 2 Form Approved for Opeonal Uve Code of Civil Procedure, 2 425 12 Judicial Council of California CAUSE OF ACTION — Fraud www courtrnfo.ca gov PLC-C-001I3) IRev Januanf 1, 2007)DocuSign Envelope ID: 93CAA837-7EC44031-9184-9DOCBEAB493E PLD-C-001(3) CASE NUMBER SHORT TITLE: Wealthcorp Capital Mortgage, et al vs. Luque, et al FIRST CAUSE OF ACTION — Fraud (number) FR-4. ~& Promise Without Intent to Perform a. Defendant made a promise about a material matter without any intention of performing it in Attachment FR-4.a ~P as follows: ~ as stated See Exhibits 1-5 Defendant represented that he had a large book of business that involved the ability to obtain significant discounts if cash was paid upfront to product providers who had contracts to supply things to companies at prices that would provide a large profit. Plaintiffs were in the loan business and checked out the initial book of business presented by defendant. One business was visited and verified. Initially plaintiffs made a small loan and were paid back with the high percentage promised in the contract of 30%. In this way, defendant lured plaintiffs in and more monies were lent. Plaintiffs lent Luque $ 1,188,587.00 in principal of which he paid back $ 152,547 which included interest and principal payments up until March 26th b. Defendant's promise without any intention of performance was made with the intent to defraud and induce plaintiff to rely upon it and to act as described in item FR-5. At the time plaintiff acted, plaintiff was unaware of defendant's intention not to perform the promise. Plaintiff acted in justifiable reliance upon the promise. FR-5. In justifiable rehance upon defendant's conduct, plaintiff was induced to act as follows: ~ as stated in Attachment FR-5 Plaintiffs lent defendant sums of $ 1,036,040.00 which was not repaid. FR-6. Because of plaintiffs reliance upon defendant's conduct, plaintiff has been damaged Attachment FR- 6 ~& as follows: ~ as stated in The loss of $ 1,036,040.00 plus interest. FIR-7. Other: The attached contracts that the parties entered into were a result of the fraud in the inducement created by defendant Luque in his false fabrication of commercial orders, in his statements regarding his book of business and in the drivers hcense he presented as his identification which is a false document unregistered with the DMV. Defendants'raud voids the contracts as a matter of law. (Rosenthal v. Great Western fin. Securities Corp., 58 CaLRptr.2d 875, 14 Ca).4th 394, 926) P.2d 1061 (Cal 1996 Page 4 Ptn-C-oot(3)(Reu January t, 2007 Page 2 of2 CAUSE OF ACTION — FraudDocuSign Envelope ID: 93CAA837-7EC44031-9164-9DOCBEAB493E PLD-C-001(1) SHORT TITLE: CASE NUMBER: Wealthccrp Capital Mortgage, et al vs. Luque, et al SECOND CAUSE OF ACTION —Breach of Contract (number) ATTACHMENT TO K Complaint H Cross - Complaint (Use a separate cause of action form for each cause of action.) BC-1. Plaintiff (name): Wealthcorp Capital Mortgage, Wealthcorp Tax & Accounting, Iucn and Iram Martinez 12/4/23 to 5/31/24 a ~v written ~ alleges that on or about (date)i oral ~ other (specify): agreement was made between (name parties to agreement): Wealthcorp Capital Mortgage, Wealthccrp Tax & Accounting, Inca and Iram Martinez ~v A copy of the The essential terms of the agreement ~ agreement is attached as Exhibit A, or Exhibits 1 - 5 are stated in Attachment BC-1 ~ are as follows (specify)r BC-2. On or about (dates) 5/25/2024 defendant breached the agreement by (speci fy): ~v the acts specified in Attachment BC-2 ~ the following acts BC-3. Plaintiff has performed all obligations to defendant except those obligations plaintiff was prevented or excused from performing. BC-4. Plaintiff suffered damages legally (proximately) caused by defendant's breach of the agreement as stated in Attachment BC-4 Mv as follows (specify): The loss of $ 1,036,040.00 plus interest according to proof. BC-5. ~ Plaintiff is entitled to attorney fees by an agreement or a statute BC-6. ~ ~ Other: of $ according to proof. Page 5 Page 1 of 1 Form Approved for Optional Uae Judiaal Counal of California CAUSE OF ACTION — Breach of Contract Code of Civil Procedure, I 425 12 www coudinfo ca gov Ptccu)ef(f) [Rev Januarv 1, 2007]DocuSign Envelope ID: 93CAA837-7EC44D31-9164-9DOCBEAB493E PLD-C-001(2) SHORT TITLE: CASE NUMBER. Wealthcorp Capital Mortgage, et al vs. Luque, et al THIRD CAUSE OF ACTION —Common Counts (number) ATTACHMENT TO V Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) CC I plaintiff (name) WealthcorP CaPital Mortgage, WealthcorP Tax & Accounting, Icc., and Iram Martinez es that defendant (name) Roberto Gonzalez Luque, Roberto Gonzalez Luque doing business as R Innovations, acd R . Innovations became indebted to V plaintiff other (name): a. V within the last four years (1) on an open book account for money due. (2) because an account was stated in writing by and between plaintiff and defendant in which it was agreed that defendant was indebted to plaintiff. b. V within the last V two years four years (1) for money had and received by defendant for the use and benefit of plaintiff. (2) for work, labor, services and materials rendered at the special instance and request of defendant and for which defendant promised to pay plaintiff. the sum of $ $ 1,036,040.00 the reasonable value. (3) for goods, wares, and merchandise sold and delivered to defendant and for which defendant promised to pay plaintiff the sum of $ the reasonable value. (4) for money lent by plaintiff to defendant at defendant's request. (6) for money paid, laid out, and expended to or for defendant at defendant's special instance and request. (6) V other (specify): See Exhibits I — 5. CC-2. $ $ 1,036,040.00 which is the reasonable value, is due and unpaid despite plaintiffs demand, ~ , plus prejudgment interest V according to proof at the rate of percent per year from (date) t May 26, 2024 CC-3. V Plaintiff is entitled to attorney fees by an agreement or a statute of $ according to proof. CC-4. Other: Page 6 Paae 1 of 1 Form Approved for Opional uae Judinal Counml of California CAUSE OF ACTION — Common Counts Code of Civil Procedure, 5 425 12 nnn.couninfo.ca.gov PLCC001(2) [Rev Januae1,2009]DocuSign Envelope ID: 93CAA837-7EC44031-9164-9DOCBEAB493E PLD-PI-001(6) SHORT TITLE: Weslthcofp Capital Mortgage, et sl vs. Luque, et ai Exemplary Damages Attachment Page 7 ATTACHMENT TO HP Complaint W Cross - Complaint EX-1. As additional damages against defendant (name): Roberto Gonzalez Luque, Roberto Gonzalez Luque doing business as R Innovations, and R Innovations Plaintiff alleges defendant was guilty of malice fraud oppression as definedin Civil Code section 3294, and plaintiff should recover, in addition to actual damages, damages to make an example of and to punish defendant. EX-2. The facts supporting plaintiffs claim are as follows: Defendant Luque deliberately fabricated documents in order to scam plaintiffs out of $ 1,036,040.00. EX-3. The amount of exemplary damages sought is a. ~v not shown, pursuant to Code of Civil Procedure section 425.10. b.H $ Page1of1 Form Approved for Opaonal Uae Code of Civil Procedure, 9 425 12 Judioal Counol of California Exemplary Damages Attachment nnmcourtrnfo ca gov PLC-Pfurgffd)IRev Januarp 1,2007IDocuSign Envelope ID: 93CAA837-7EC44031-9164-9DOCBEAB493E PLD-C-001(3) CASE NUMBER; SHORT 1 )TEE: Wealthcorp Capital Mortgage, et al vs. Luque, et ai FIRST CAUSE OF ACTION — Fraud (numuer) ATTACHMENT TO Hw Complaint H Cross-Complaint (Use a separate cause of action form for each cause of action.) FR- 1. Plaintiff (name): Wealthcorp Capital Mortgage, Wealthcorp Tax & Accounting, Inco and Iram Martinez alleges that defendant (naf ne: Roberto Gonzalez Luque, individually, and DBA R Innovations, and R Innovations on or about (date): 12/4/23 to 5/31/24 defrauded plaintiff as follows: FR-2 Intentional or Negligent Misrepresentation a. Defendant made representations of material fact H as stated in Attachment FR-2.a Hv as follows: Defendant represented that he had a large book of business that involved the ability to obtain significant discounts if cash was paid upfront to product providers who had contracts to supply things to companies at prices that would provide a large profit. Plaintiffs were in the loan business and checked out the initial book of business presented by defendant. One business was visited and verified. Initially plaintiffs made a small loan and were paid back with the high percentage promised in the contract of 30%. In this way, defendant lured plaintiffs in and more monies were lent. Plaintiffs lent Luque $ 1,188,587.00 in principal of which he paid back $ 152,547 which included interest and b. These representations were in fact false. The truth was ~ principal payments up until March 26th (See also exhibits 1-5. ~.v.me as stated in Attachment FR-2.b ~v as follows: Defendant did not have a business that produced any profit margin. The truth is that defendant falsified documents to make it seem that there was a large volume of business with Universal and others which was a deliberate Iie. The truth is that defendant had no orders from Universal. The truth was that defendants forged orders from Universal and others. The truth is that the drivers license that defendant Luque gave plaintiffs to satisfy them as to the truth of his identity was a forged document. The truth is that Luque kept the money lent to him by plaintiffs such that he converted approximately $ 1,036,040.00 for his own use. (See exhibits 1-5) c. When defendant made the representations, defendant knew they were false, or defendant had no reasonable ground for believing the representations were true. d. Defendant made the representations with the intent to defraud and induce plaintiff to act as described in item FIR-5. At the time plaintiff acted, plaintiff did not know the representations were false and believed they were true. Plaintiff acted in justifiable reliance upon the truth of the representations. FR-3. ~ Concealment a. Defendant concealed or suppressed material facts H as stated in Attachment FR-3.a H as follows: b. Defendant concealed or suppressed material facts defendant was bound to disclose. by telling plaintiff other facts to mislead plaintiff and prevent plaintiff from discovering the concealed or suppressed facts. c. Defendant concealed or suppressed these facts with the intent to defraud and induce plaintiff to act as described in item IFIR-5. At the time plaintiff acted, plaintiff was unaware of the concealed or suppressed facts and would not have taken the action if plaintiff had known the facts. Page 3 Page 1 of 2 Form Approved for Opeonal Uve Code of Civil Procedure, 2 425 12 Judicial Council of California CAUSE OF ACTION — Fraud www courtrnfo.ca pov PLC-C-001I3) IRev Januanf 1, 2007)DocuSign Envelope ID: 93CAA837-7EC44031-9184-9DOCBEAB493E PLD-C-001(3) CASE NUMBER SHORT TITLE: Wealthcorp Capital Mortgage, et al vs. Luque, et al FIRST CAUSE OF ACTION — Fraud (number) FR-4. ~& Promise Without Intent to Perform a. Defendant made a promise about a material matter without any intention of performing it in Attachment FR-4.a ~P as follows: ~ as stated See Exhibits 1-5 Defendant represented that he had a large book of business that involved the ability to obtain significant discounts if cash was paid upfront to product providers who had contracts to supply things to companies at prices that would provide a large profit. Plaintiffs were in the loan business and checked out the initial book of business presented by defendant. One business was visited and verified. Initially plaintiffs made a small loan and were paid back with the high percentage promised in the contract of 30%. In this way, defendant lured plaintiffs in and more monies were lent. Plaintiffs lent Luque $ 1,188,587.00 in principal of which he paid back $ 152,547 which included interest and principal payments up until March 26th b. Defendant's promise without any intention of performance was made with the intent to defraud and induce plaintiff to rely upon it and to act as described in item FR-5. At the time plaintiff acted, plaintiff was unaware of defendant's intention not to perform the promise. Plaintiff acted in justifiable reliance upon the promise. FR-5. In justifiable rehance upon defendant's conduct, plaintiff was induced to act as follows: ~ as stated in Attachment FR-5 Plaintiffs lent defendant sums of $ 1,036,040.00 which was not repaid. FR-6. Because of plaintiffs reliance upon defendant's conduct, plaintiff has been damaged Attachment FR- 6 ~& as follows: ~ as stated in The loss of $ 1,036,040.00 plus interest. FIR-7. Other: The attached contracts that the parties entered into were a result of the fraud in the inducement created by defendant Luque in his false fabrication of commercial orders, in his statements regarding his book of business and in the drivers hcense he presented as his identification which is a false document unregistered with the DMV. Defendants'raud voids the contracts as a matter of law. (Rosenthal v. Great Western fin. Securities Corp., 58 CaLRptr.2d 875, 14 Ca).4th 394, 926) P.2d 1061 (Cal 1996 Page 4 Ptn-C-oot(3)(Reu January t, 2007 Page 2 of2 CAUSE OF ACTION — FraudDocuSign Envelope ID: 93CAA837-7EC44031-9164-9DOCBEAB493E PLD-C-001(1) SHORT TITLE: CASE NUMBER: Wealthccrp Capital Mortgage, et al vs. Luque, et al SECOND CAUSE OF ACTION —Breach of Contract (number) ATTACHMENT TO K Complaint H Cross - Complaint (Use a separate cause of action form for each cause of action.) BC-1. Plaintiff (name): Wealthcorp Capital Mortgage, Wealthcorp Tax & Accounting, Iucn and Iram Martinez 12/4/23 to 5/31/24 a ~v written ~ alleges that on or about (date)i oral ~ other (specify): agreement was made between (name parties to agreement): Wealthcorp Capital Mortgage, Wealthccrp Tax & Accounting, Inca and Iram Martinez ~v A copy of the The essential terms of the agreement ~ agreement is attached as Exhibit A, or Exhibits 1 - 5 are stated in Attachment BC-1 ~ are as follows (specify)r BC-2. On or about (dates) 5/25/2024 defendant breached the agreement by (speci fy): ~v the acts specified in Attachment BC-2 ~ the following acts BC-3. Plaintiff has performed all obligations to defendant except those obligations plaintiff was prevented or excused from performing. BC-4. Plaintiff suffered damages legally (proximately) caused by defendant's breach of the agreement as stated in Attachment BC-4 Mv as follows (specify): The loss of $ 1,036,040.00 plus interest according to proof. BC-5. ~ Plaintiff is entitled to attorney fees by an agreement or a statute BC-6. ~ ~ Other: of $ according to proof. Page 5 Page 1 of 1 Form Approved for Optional Uae Judiaal Counal of California CAUSE OF ACTION — Breach of Contract Code of Civil Procedure, I 425 12 www coudinfo ca gov Ptccu)ef(f) [Rev Januarv 1, 2007]DocuSign Envelope ID: 93CAA837-7EC44D31-9164-9DOCBEAB493E PLD-C-001(2) SHORT TITLE: CASE NUMBER. Wealthcorp Capital Mortgage, et al vs. Luque, et al THIRD CAUSE OF ACTION —Common Counts (number) ATTACHMENT TO V Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) CC I plaintiff (name) WealthcorP CaPital Mortgage, WealthcorP Tax & Accounting, Icc., and Iram Martinez es that defendant (name) Roberto Gonzalez Luque, Roberto Gonzalez Luque doing business as R Innovations, acd R . Innovations became indebted to V plaintiff other (name): a. V within the last four years (1) on an open book account for money due. (2) because an account was stated in writing by and between plaintiff and defendant in which it was agreed that defendant was indebted to plaintiff. b. V within the last V two years four years (1) for money had and received by defendant for the use and benefit of plaintiff. (2) for work, labor, services and materials rendered at the special instance and request of defendant and for which defendant promised to pay plaintiff. the sum of $ $ 1,036,040.00 the reasonable value. (3) for goods, wares, and merchandise sold and delivered to defendant and for which defendant promised to pay plaintiff the sum of $ the reasonable value. (4) for money lent by plaintiff to defendant at defendant's request. (6) for money paid, laid out, and expended to or for defendant at defendant's special instance and request. (6) V other (specify): See Exhibits I — 5. CC-2. $ $ 1,036,040.00 which is the reasonable value, is due and unpaid despite plaintiffs demand, ~ , plus prejudgment interest V according to proof at the rate of percent per year from (date) t May 26, 2024 CC-3. V Plaintiff is entitled to attorney fees by an agreement or a statute of $ according to proof. CC-4. Other: Page 6 Paae 1 of 1 Form Approved for Opional uae Judinal Counml of California CAUSE OF ACTION — Common Counts Code of Civil Procedure, 5 425 12 nnn.couninfo.ca.gov PLCC001(2) [Rev Januae1,2009]DocuSign Envelope ID: 93CAA837-7EC44031-9164-9DOCBEAB493E PLD-PI-001(6) SHORT TITLE: Weslthcofp Capital Mortgage, et sl vs. Luque, et ai Exemplary Damages Attachment Page 7 ATTACHMENT TO HP Complaint W Cross - Complaint EX-1. As additional damages against defendant (name): Roberto Gonzalez Luque, Roberto Gonzalez Luque doing business as R Innovations, and R Innovations Plaintiff alleges defendant was guilty of malice 

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