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9. That the one ar~d only ~urpose for the aforesaid conveyanceg,
~ as more fully appears Fram copies of the annexed Warranty Deeds, ~n~as to ~
enable the said defendant, MARTiN LEIBOWITZ, to so obtain financing '
through Florida banks and for no other reason . : ~
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. l0. Said defendant, ~.~ARTIN LEiBOWITZ, further represented
~ to the plaintiffs that the aforesa~d transfer was made sde[y for the aforesaid
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purpose , and for no other reason . ~
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ll. That the said defendant, MARTIN LEIBOW[TZ, knew that '
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his aforesaid representations to the plaintiffs were fatse and made with the ;
intent to deceive and defraud the plaintiffs , and to obtain for himself the ~
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: possession of the aforesaid property. ;
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12. That by reason of the aforesaid and believing said re- ;
t
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presentateons to be true and by furtE~er reason of the fact that plaintiffs were ~
unable to understartd the full significance of their said actions, as aforestated;
and by further reason that they were subjected to severe mental pressure, '
ptaintiffs reiied upon the said defenctant's representation, and signed the ~
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aforesaid Deeds , as aforesaid . ,
l3. That prior to the commencement of this action due demand
was made upon the deFendants for the return of said property and for the
setting aside and cancellation of said Deeds and the same was refused. ;
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AS ~ND FOR A SECOND CAUSE OF ACT[ON,
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~ ~ ' PLAINTIFFS FURTHER ALLEGE; ~
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