4 Randall Greene Accused of Stealing a House

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the material fact to the Plaintiffs to induce the Plaintiffs to provide the funds for the purchase of the Pendio Property

22. At the time Plaintiffs filed the 2012 Lawsuit seeking a constructive trust on the Pendio Property, Alfresco owned the Pendio Prope1iy.
23. On January 8, 2014, Bella Collina POA filed a Motion to Intervene in the 2012 Lawsuit, citing Bella Collina POA’s alleged legal or equitable interest in the Pendio Property.
24. While the 2012 Lawsuit was pending, Bella Collina POA and Alfresco executed the Alfresco Settlement. At that time, counsel for Bella Collina POA and DCS agreed to become counsel for Alfresco to assist Alfresco in defending the Pendio Property from the Plaintiffs’ claims.
25. Defendants had actual knowledge of the 2012 Lawsuit, and Defendants had actual knowledge that Plaintiffs were seeking possession ofthe Pendio Property. Defendants had actual knowledge that Plaintiffs had filed a Lis Pendens on the Pendio Property.
26. In February 2014, Randall Greene contacted Plaintiffs about purchasing Plaintiffs’ interest in the Pendio Property.
27. On March 5, 2014, Randall Greene met with Plaintiffs to discuss Plaintiffs’ interest in the Pendio Property. At that time, Plaintiffs refused to convey Plaintiffs’ interest in the Pendio Property to Greene or DCS.
28. DCS’s counsel at the time of the Alfresco Settlement informed Plaintiffs’ former counsel that, within the Alfresco Settlement, Alfresco agreed to transfer the Pendio Property to Bella Collina POA or DCS by quitclaim deed. Per DCS’s counsel, the agreed transfer of the Pendio Property was explicitly subject to Plaintiffs’ interest in the Pendio Prope1iy.
29. On April 22, 2014, Plaintiffs filed a Motion for Summary Final Judgment in the 2012 Lawsuit. In part, Plaintiffs sought a final judgment on Plaintiffs’ request for a constructive trust in Plaintiffs’ favor on the Pendio Property.
30. On April 28, 2014, after receiving notice of Plaintiffs’ pending Motion for Summary Judgment and with actual knowledge of Plaintiffs’ interest in the Pendio Property, Alfresco executed the DCS Deed, which attempted to convey the Pendio Property to DCS.
31. The DCS Deed was executed because Plaintiffs refused to transfer Plaintiffs’ interest in the Pendio Property to Greene or DCS. The DCS Deed was designed to prevent Plaintiffs from asserting Plaintiffs’ claim to the Pendio Property.
32. On May 5, 2014, Bella Collina POA filed a Notice of Withdrawal of Motion to Intervene in the 2012 lawsuit. In Bella Collina POA’s Notice ofWithdrawal of Motion

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