- 9 -
their detriment, as follows:
a) Defendants repeatedly represented to
plaintiffs that plaintiffs were receiving and would
continue to receive all of CID's assignments to outside
investigators in Oregon, Washington, Idaho, Montana and
Utah, when plaintiffs were not receiving all such
assignments, defendants had no intention of giving
plaintiffs all such assignments, and CID's policy
expressed to its regional Criminal Investigators was
that assignments would be made on a case-by-case basis.
* * * * * * *
d) Defendants repeatedly represented to
plaintiffs that plaintiffs would be indemnified and
held harmless by defendants when defendants never
intended to indemnify plaintiffs, and never did indem-
nify plaintiffs or reimburse plaintiffs for plaintiffs'
legal fees, costs, and expenses.
* * * * * * *
28. As a result of defendants' fraudulent acts as
described above, plaintiffs were damaged as set out * *
* [in connection with their claim for breaches of
contract]; plaintiffs Peter and Shirley Diamond suf-
fered embarrassment, humiliation, emotional distress
and mental pain and suffering to their damage in the
amount of $500,000 each; plaintiff DCI is entitled to
punitive damages of $25 million; and plaintiffs Peter
and Shirley Diamond are entitled to punitive damages of
$25 million.
* * * * * * *
VII. Contentions of Law
* * * * * * *
1. All of the named defendants are liable to
plaintiffs for the damages described above.
2. All defendants and all plaintiffs were par-
ties to and are bound by the agreement, and are enti-
tled to the benefits thereof.
* * * * * * *
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