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Fourth Cause of Action - Defamation
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On or about August 1, 1999, and on numerous occasions
thereafter, Defendant made numerous statements concerning
Plaintiff to Toni Arzate (“Arzate”), a close personal friend
of Plaintiff’s. These statements were made to Arzate in the
form of messages left for Arzate by Defendant, which were
recorded and maintained in permanent form on magnetic tape.
The statements that Defendant made to Arzate imputed to
Plaintiff characteristics of infidelity, dishonesty,
criminal behavior, fraud, and other loathsome
characteristics. These statements exposed Plaintiff to
hatred, contempt, and ridicule from Arzate, which has caused
Plaintiff to be shunned and avoided by Arzate. Said
statements were made by Defendant in an attempt to damage
Plaintiff’s personal relationship with Arzate, and did
damage said relationship because Plaintiff is involved in an
intimate personal relationship with Arzate which has been
damaged due to Defendant’s libelous statements to Arzate.
* * * * * * *
Fifth Cause of Action - Specific Performance
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Plaintiff’s request for specific performance is necessary to
ensure Plaintiff has an adequate remedy for Defendant’s
failure to transfer the vehicle per the agreement or June,
1995.
On January 13, 2000, Ms. Wold answered petitioner’s
complaint and filed a cross-complaint against petitioner for
breach of contract, fraud, conversion, and for possession of
personal property related to the sale of an automobile and loans
of money. Ms. Wold’s answer and cross-complaint states, in
pertinent part, as follows:
First Cause of Action - Breach of Contract
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Last modified: May 25, 2011