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(4) that DCI and the Diamonds periodically invested in new equip-
ment for ETS and hired employees for the purpose of providing
services to FIG; (5) that ETS provided services to FIG during the
years 1982 through 1984; and (6) that FIG breached the agreement
at issue in the Farmers lawsuit.
With respect to the plaintiffs' claims against FIG for
fraudulent misrepresentations, the pretrial order alleged, inter
alia, that FIG repeatedly made false misrepresentations to the
plaintiffs and concealed the true state of affairs from the
plaintiffs with the knowledge and intent that the plaintiffs
would rely on such misrepresentations to their detriment.
With respect to the lost profits damages that the plaintiffs
sought from FIG for breaches of contract and for fraudulent mis-
representations, the pretrial order alleged, inter alia:
(1) That the plaintiffs suffered damages as a result of those
actions of FIG; (2) that the plaintiffs lost profits on the
investigative work that FIG assigned to investigative agencies
other than DCI; and (3) that "Plaintiffs Peter and Shirley
Diamond are entitled to recover their lost income, including loss
of profits from ETS, and increased expenses, arising from defen-
dants' fraud and breach of their agreement with plaintiffs."
With respect to the punitive damages that the plaintiffs
sought from FIG for fraudulent misrepresentations, the pretrial
order alleged that the Diamonds, as well as DCI, were entitled to
punitive damages in the amount of $25 million.
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