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intentional infliction of emotional distress, (18) negligent
infliction of emotional distress, (19) breach of fiduciary duty,
and (20) constructive fraud.
Causes of action 1 through 10 and 14 through 20 allege that
as a proximate result of the Bank Defendants' wrongful conduct,
individual MILK PRODUCERS have suffered anxiety,
humiliation, worry, mental anguish and emotional and
physical distress * * * and have been injured in mind
and body all to their general damage * * *.
Other injuries alleged were that plaintiffs incurred medical
expenses, were prevented from pursuing normal employment,
suffered a loss of income and business advantage, and suffered
loss of consortium.
In the prayer for relief, plaintiffs sought damages for
mental suffering, emotional distress, and loss of consortium in
every cause of action except Nos. 11, 12, and 13. They also
sought damages for medical and related expenses and for lost
earnings in every cause of action.
The alleged behavior giving rise to the complaint was that
the Bank Defendants made risky loans to Knudsen for the purchase
of Foremost, knowing that both Knudsen and Foremost were highly
leveraged and vulnerable. As the direct lender, Citicorp took
security interests in all of Knudsen's assets,4 thereby putting
4 The other Bank Defendants were participants in the loan
(i.e., they bought parts of the loan after it was made) and did
not have direct security interests.
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Last modified: May 25, 2011