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also filed a complaint against the Bank Defendants, in the action
entitled In re Milk Producers v. Citicorp Industrial Credit, Inc.
(milk producers action) in the Superior Court of the State of
California, Los Angeles County. By stipulation re amendment of
exhibit A to the complaint, filed July 2, 1990, all petitioners
herein were named as plaintiffs in their individual capacities;
the entities with which they were affiliated were also named.
The complaint alleged 12 causes of action sounding in tort based
upon the Bank Defendants' direct liability: (1)
Fraud/misrepresentation, (2) negligent misrepresentation, (3)
intentional interference with contractual relationship, (4)
negligent interference with contractual relationship, (5)
intentional interference with prospective economic advantage, (6)
negligent interference with prospective economic advantage, (7)
intentional infliction of emotional distress, (8) negligent
infliction of emotional distress, (9) breach of fiduciary duty,
(10) constructive fraud, (11) unjust enrichment, and (12) unjust
enrichment as a result of good faith belief induced by the Bank
Defendants' behavior.
Plaintiffs alleged eight additional causes of action (the
indirect causes of action) based upon a theory of the Bank
Defendants' alleged derivative liability through Knudsen: (13)
Breach of contract, (14) breach of implied covenant, (15)
fraud/misrepresentation, (16) negligent misrepresentation, (17)
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