FILED

Christina Spurloc
CLERK. SUPERIOR URT
08/09/2022 11:24AM
BY: GHOWEL
DEPUTY

1 Case No.: S8015CV202 00972

Linda Marie Brown, Esq., SBN025382 HON. STEVEN M SS

2
LAW OFFICES OF LINDA MARIE BROWN, PLLC
P.O. Box 21941
3 Bullhead City, Arizona 86439
Telephone: (928) 299-2636
4 E-mail: [email protected]
Attorney for Plaintiff, Paseo El Rio, LLC
5

6 IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

7 IN AND FOR THE COUNTY OF MOHAVE
8 )
PASEO EL RIO, LLC, a Nevada limited )
9
liability company; Richard Lopez, a )
10 single man; and Michael Palacios, a ) Case No.
single man, )
11 Plaintiffs, )
vs. ) COMPLAINT
12 ) (Verified)
D&E MANAGEMENT GROUP, LLC, )
13
an Arizona limited liability company; )
14 ALL ARIZONA RIVER REALTY, )
LLC, an Arizona limited liability ) (Jurv Trial Reguested)
15 company; US SOUTHWEST, L.L.C., an )
Arizona limited liability company; )
16 CLEARY, LLC, an Arizona limited )
liability co; MORAVE VALLEY GOLF, ) Assigned to Honorable
17
LLC, a Delaware limited liability )
18
company; MAAS CONSTRUCTION, )
. INC., an Arizona domestic for-profit )
19 corporation; THOMAS and NANCY )
MAAS, husBand and wife; RANDALL )
20 ~d ANGEL~ MAAS, husband and . )
wife; JERR'1j'" and KATHLEEN )
21 TYRRELL, pusband and wife; DON and )
CATHY DEf1RAFFENREID, husband )
22
and wife; PHILIP CLEARY, a single )
23 man; JOHN lmd JANE DOES I-X; XYZ )
ENTITIES Ilx; ABC PARTNERSHIPS )
24 1-X, CORPORATIONS OR OTHER )
LEGAL ENTITIES I-X; AND )
25 MUNICIPAL ENTITY 1-X, )
)
26
Defendants. )

1
 1 PLAINTIFF, PASEO EL RIO, LLC ("PASEO") hereby submits its complaint against

2 Defendants and alleges as follows:

3 JURISDICTION AND VENUE

4 1. ( This court has subject matter jurisdiction over this case pursuant to A.RS. § 12-

5 123.

6 2. Pursuant to A.R.S. § 12-401, Venue is proper in Mohave County because the

7 .events and actions complained of herein giving rise to the claims herein occurred in Mohave

8 County, state of Arizona.

9 3. The value of the case exceeds $10,000.00.

10 DISCOVERY TIER

11 4. Pursuant to Rule 26.2, Arizona Rules of Civil Procedure, this action qualifies

12 for Tier III discovery assignment.

13 PARTIES

14 5. · Plaintiff, PASEO is a limited liability company formed in the state of Nevada,

15 with its principal place of business in Las Vegas, Nevada.

16 6. Plaintiff, RICHARD LOPEZ ("Mr. Lopez"), a single man, is a resident of Clark

17 County, state ofNevada.

18 7. Plaintiff, MICHAEL PALACIOS ("Mr. Palacios"), a single man, is a resident of

19 Mohave County, state of Arizona..

20 8. Defendant, D&E MANAGEMENT GROUP, LLC ("D&E") is an Arizona

21 limited liability company authorized to do Business in the state of Arizona, and have caused

22 acts, errors, or omissions in Mohave County, Arizona which give rise to Plaintiffs Complaint.

23 9. Defendant, ALL ARIZONA RIVER REALTY, LLC ("River Realty") is an

24 Arizona limited liability company authorized to do Business in the state of Arizona, and have

25 caused acts, errors, or omissions in Mohave County, Arizona which give rise to Plaintiffs

26 Complaint.

2
 1 10. Defendant, US SOUTHWEST, L.L.C. ("US SW") is an Arizona limited liability

2 company authorized to do Business in the state of Arizona, and have caused acts, errors, or

3 omissions in Mohave County, Arizona which give rise to Plaintiffs Complaint.

4 11. Defendant, CLEARY, LLC ("Cleary, LLC") is a limited liability company

5 formed and authorized to do business in the state of Arizona, and have caused acts, errors, or

6 omissions in Mohave County, Arizona which give rise to Plaintiffs Complaint.

7 12. Defendant, MOHAVE VALLEY GOLF, LLC ("MVG") is a limited liability

8 company formed in the state of Delaware, with its principal place of business in Mohave

9 Valley, state of Arizona, and have caused acts, errors, or omissions in Mohave County,

1o Arizona which give rise to Plaintiffs Complaint.

11 13. Defendant, MAAS CONSTRUCTION INC ("Maas Construction") is a

12 domestic for-profit (business) corporation formed in the state of Arizona, with its principal

13 place of business in Fort Mohave, state of Arizona, and have caused acts, errors, or omissions

14 in Mohave County, Arizona which give rise to Plaintiffs Complaint.

15 14. Defendants, THOMAS AND NANCY MAAS ("T&N Maas") are married and

16 own real property in Mohave County in the State of Arizona, and have caused acts, errors, or

17 omissions in Mohave County, Arizona which give rise to Plaintiffs Complaint were for the

1s benefit of the marital community.

19 15. Defendants, RANDALL AND ANGELA MAAS ("R&A Maas") are married

2o and are residents of Mohave County in the State of Arizona, and have caused acts, errors, or ·

21 omissions in Mohave County, Arizona which give rise to Plaintiffs Complaint were for the

22 benefit of the marital community.

23 16. Defendants, JERRY AND KATHLEEN TYRRELL ("J&K Tyrrell") are
24 married and are residents of Mohave County in the state of Arizona, and have caused acts,

2s errors, or omissions in Moha~e County, Arizona which give rise to Plaintiffs Complaint were

26 for the benefit of the marital community.

3
 1 17. .Defendant, DON DEGRAFFENREID ("Mr. DeGraffenreid") is a resident of

2 Mohave County in the state of Arizona, and have caused acts, errors, or omissions in Mohave

.3 County, Arizona which give rise to Plaintiffs Complaint, and at all times material.

4 18. Defendant, PHILIP CLEARY ("Mr. Cleary") is a resident of Mohave County in

5 the state of Arizona, and have caused acts, errors, or omissions in Mohave County, Arizona

6 which give rise to Plaintiffs Complaint, and at all times material.

7 19. John and Jane Does 1-X, XYZ entities 1-X, corporations or other legal entities,

s and Municipal entities 1-X are persons, partnerships, corporations, unincorporated associations,

9 body politics, and public agencies subject to suit in common names whose full names are

1o unknown to Plaintiff and who are, therefore, designated by fictious names pursuant to Ariz. R

11 Civ P lO(f). Upon information of their known identities, leave to amend will be sought to have

12 their true names added.

13 20. Defendants, whether named or unnamed, benefited either directly or indirectly

1~ from the acts, errors, omissions, understandings, representations, agreements and contracts

15 alleged herein. Defendants are jointly and severally liable for the acts, errors, omissions,

16 representations, understandings, agreements and contracts alleged herein as having dei:ived a

17 benefit from such acts, errors, omissions, understandings, representations, agreements and

1s contracts.

19 STATEMENT OF FACTS

20 21. P ASEO is in the business of acquiring real estate holdings and investments for

21 its members. Mr. Lopez is a member of PASEO and Mr. Palacios is PASEO's managing

22 member.

23 22. PASEO, as sole owner, acquired an undivided 88-acre vacant land parcel,

24 Mohave County Assessor Parcel Number: 225-65-010 ("APN 225-65-010' ) on March 30,

25 2021. This undeveloped, vacant land distinctively wraps around and borders El Rio Golf Club

26 ("ERGC").

4
 1 23. MVG operates its partially owned, fifty-percent (50%) interests ofERGC, a

2 famed Matt Dye designed golf course, located in a master planned community known as El Rio

3 Country Club, ("ERCC"). The Owner(s) of the remaining fifty-percent (50%) of ERGC is

4 unknown to PASEO.

5 24. At the time of PASEO's acquisition, it became a 7.65% member and/or

6 shareholder in MVG. This acquisition was obtained by the parties executing an LLC

7 Membership Interest Assignment. The Assignor, CLEARY LLC, assigned its interests to

s Assignee, PASEO, that was approved in accordance with MVG's Operating Agreement.

9 Numerous communications were exchanged between several named defendants to ensure that

1o the transfer was properly consummated and incorporated into PASEO' s Escrow Closing

11 Documents when acquiring APN 225-65-010.

12 25. Prior to closing, Mr. Tyrrell, MVG's Managing Member, approved/executed a

13 non-binding Letter of Intent ("LOI") whereby this LOI provided an option for P ASEO to

14 purchase real property and set forth various deal points. The LOI further reflected PASEO's

15 intent to acquire all of MVG real property, known as The El Rio Country Club (also known as

16 El Rio Golf Club) and all of the golf course appurtenances, maintenance facilities and·club

17 house, etc. for a final purchase price of $2,500,000.00 ("Subject Property"). The Agreement

18 contained the following non-binding conditions:

19
"This Letter of Intent represents an expression of the Parties' interest
20
to negotiate only, and each Party reserves the right of final approval
or disapproval, for any reason, of the PURCHASE AGREEMENT,
21 which the Parties acknowledge will contain their full and complete
agreement. This Letter of Intent is not binding on either Party and
22 is intended to merely establish general deal point agreements only.
The Contract (PURCHASE AGREEMENT), when executed by both
23 Parties shall contain their full agreement.".
24 26. Based on the assignment, P ASEO now hol~s 7 .65% membership interest in

25 MVG to include all voting rights. Upon executing the Assignment, Mr. Cleary and Cleary,
26

5
 1 LLC, no longer retained any interest in MVG. The Agreement contained the following

2 conditions:

3 "Assignor hereby represents and warrants and that Assignor has good
title to the membership interest conveyed herein and that Assignor has
4
no limitations on making such assignment, such as any security
5 interest, lien, or encumbrance.

6 Assignor further represents and warrants that it will take any steps to
perfect Assignee's receipt of the membership interest in the LLC as
7 required." (supra)
8
APPLICABLE LAW AND FACTUAL CLAIMS
9
COUNT 1
10 Negligent Misrepresentation/Fraudulent Misrepresentation

11 27. PASEO alleges that Cleary LLC and US SW, the realtor whom represented both

12 PASEO and Cleary LLC in the transaction, intentionally withheld and failed to disclose

13 pertinent property title information regarding clear title in its entirety to ownership of MVG.

14 Without a doubt, Cleary LLC and US SW have unjustly enriched themselves by intentionally

15 withholding key property title information in order to complete the sale of Cleary LLC's

16 interest in MVG to PASEO.

17 28. On April 22, 2021, a meeting was held at Mr. Tyrrell' s residence located in El

18 . Rio Country Club, whereby Mr. Tyrrell was made aware PASEO had discovered MVG could

19 not produce clear title on its purported real property assets. P ASEO explained that during its

20 due diligence for the purchase of Subject Property, P ASEO found MVG only holds a fifty

21 percent (50%) Special Warranty Deed on the golf course parcels and club house

22 structure. PASEO later learned through public records that the golf course parcels and club

23 house structure were purchased by MVG for $40,000.00 by way of a court-appointed

24 bankruptcy receiver obtained through a criminal forfeiture of assets sale (see, United States of

25 America vs. John Keith Hoover (Plea Agreement), CR-14'7554-1-PHX-SB).

26

6
 1 29. PASEO alleges that there was serious misrepresentation of a material facts as to

2 ownership and that Defendants breached their duty to PASEO which caused them to justifiably

3 rely that MV G held 100% clear title to sell MVG to PASEO. It was foreseeable that P ASEO

4 would rely on these misrepresentations to perfect the sale of APN 225-65-010, and as a direct

5 result of relying on this material facts, P ASEO was unable to acquire 100% clear title to MVG

6 as the LOI indicated was PASEO' s intent.

7 30. P ASEO alleges that defendants misrepresented when presenting the operating

8 agreement contradicts the other versions that PASEO relied on when purchasing APN 225-50-

9 010. This is illustrated in the differentials of PASEO's membership interest and whether their

10 membership interest is 7.65% or 7.865%.

11 31. PASEO alleges that Mr. DeGraffenreid, both close and longtime business

12 associates of T&N Maas.and R&A Maas, worked in concert with one another to falsely purport

13 to the bankruptcy court that MVG maintained 50% ownership in the golf course parcels and

14 club house structlrre, and through their deceit and fraudulent representations to the court, the

15 court obliged and sold a 50% stake to MVG at a substantially discounted price of$40,000.00.

16 32. Contrary to River Realty, Mr. DeGraffenreid, T&N Maas and R&A Maas,

17 MVG's false and deceitful representations to the bankruptcy court, MVG never owned a 50%

18 stake in the golf course parcels and club house structure. MVG was established solely to

19 receive the 50% stake in the golf course parcels and clubhouse structure it induced the

2o bankruptcy court to sell them and is a representation of its current holdings.

21 33. PASEO presented Mr. Tyrrell with the offiCial Mohave County assessor

22 records, and all of its supporting documentation and in response, Mr. Tyrrell falsely

23 represented MVG legitimately acquired the other 50% stake from an individual named,
24 Howard Norris. Upon repeated request, no one has produced any documents to support who

2s holds ownership to the other 50% of the Subject Property that P ASEO was to acquire upon its

26 purchase of APN 225-50-010.

7
 1 34. As a result of these misrepresentations of material facts, PASEO lost its benefit

2 to purchase the Subject Property in its entirety.

3 35. PASEO explained to Mr. Tyrrell that it believes T &N Maas and R&A Maas,

4 both members of MVG, intentionally manipulated and deceived the bankn~ptcy court in their

5 efforts to acquire the golf course parcels and clubhouse structure for that price by asserting

' 6 false claims to the Court Appointed Receiver.

7 COUNT2
Breach of Covenant of Good Faith and Fair Dealings,
8
Duty of Loyalty and Duty of Care
9 36. PASEO, acting in good faith, was unable to move forward with its intent to
10 purchase the Subject Property in its entirety. Thereafter, PASEO acted in good faith to sell its
11
membership interest back to MVG. However, Mr. Tyrrell stated to Messrs. Lopez and
12 Palacios that he was unable to convince MVG to participate in the required capital call to
13 purchase PASEO' s membership interests, and further stated to PASEO's members that MVG
14
did not hav~ sufficient reserve funds to consummate the deal. Mr. Tyrrell told PASEO that no
15 other MVG member agreed to buy-backPASEO's membership interest, other than himself.
16 . That said, P ASEO continued in its good faith efforts to sell its membership interest to Mr.

17 Tyrrell.
18 37. On April 26, 2021, PASEO emailed Mr. Tyrrell the Transfer of Sale Agreement
19 .
to include an Acceptance Date of April 26, 2021 , and in its comm\lfiication accompanying that
20 transfer, expressly set forth a 3-business day turnaround for the full $140,000.00 to be bank
21 wired to PASEO. PASEO made numerous attempts to complete the transaction but for Mr.
22 Tyrrell's failure to execute the transfer agreement and his inability to obtain financing and/or
23 timely liquidate purported investments to meet the full terms of the transfer.
24 38. PASEO had no other option but to withdrawal its offer to sell. An email was
25 sent to Mr. Tyrrell stating the following:
26

8
 "In light of the delay to execute the proposed Transfer of
1
Shares Agreement, and an apparent inability to obtain adequate funding
2
to complete the acquisition of the Shares, be advised Paseo El Rio, LLC
Shares in Mohave Valley Golf, LLC are no longer available for sale.
3
Accordingly, Paseo El Rio, LLC will validly keep, and remain a
4 Member/Partner/Shareholder in Mohave Valley Golf, LLC. Mr. Jerry
Tyrrell agreed to provide records access, and cooperate in Paseo El Rio,
5 LLC's request to conduct an onsite inspection of Mohave Valley Golf,
LLC's - Book and Records. The onsite inspection is scheduled to take
6
place starting May fl, 2021 at 1:30 PM local time. Mr. Rick Lopez
7 of Paseo El Rio, LLC will be onsite for the duration of this inspection.
Mr. Rick Lopez will provide Mr. Jerry Tyrrell with a list of the books,
8 records, and other corporate documents that need to be made
available for this inspection.".
9
39. On May 01, 2021, Mr. Tyrrell was informed by PASEO' s member via
10
telephone that due to his non-performance, that PASEO has withdrawn its offer to sell its
11
membership interest to MVG. Unrelated to this action, MVG is currently attempting to compel
12
PASEO to sell its' membership interest to MVG under Mohave County Superior Court Case
13
No. S8015CV202100643.
14
40. As a member ofMVG, PASEO alleges that Mr. Tyrrell abandoned his
15
obligations as the Managing Member. The lack of oversight has resulted in what PASEO
16
alleges is a risk factor for its investment as PASEO's members have been made aware of
17
underage drinking taking place at the clubhouse, illegal gambling activity by golf club
18
members, and minors recklessly driving around the golf course in golf carts, to include
19
crossing into and over PASEO acquired undeveloped land.
20
41. In PASEO's attempt to review MVG books and records; PASEO then became
21
aware of allegations being made against MVG then General Manager and its employees of
22
engaging in in illegal "skimming" practices.
23
COUNT3
24 Violation of Inspection Rights-A.R.S. 10-1602, et seq.
25

26

9
 1 42. Because P ASEO retained its membership interest, it then requested an onsite

2 inspection of all book and records inspection in accordance with its Operating Agreement,

3 Section 7.01. An onsite inspection was due to take place on May 11, 2021 at 1:30 PM.

4 43. On May 03, 2021, Mr. Lopez met with MVG's General Manager, J.J. Deleon,

5 and MVG's bookkeeper for an inspection of books and records in exercising its rights under

6 the Operating Agreement.

7 44. Communications with Mr. Tyrrell decreased as he left town for the next six

8 months.

9 COUNT4
Intentional Interference with a Contractual Relationship
10
and/or Business Expectancy
il 45. PASEO was then denied access to MVG's books and records upon presenting
12 its list of documents to inspect. This denial is ·now based on MVG alleging PASEO is not a
13 member and has no rights to inspect books and records as set forth in its operating agreement.
14 46. PASEO alleges that while acting in concert with T. Maas and R. Maas, D&E
15 unscrupulously gained control over El Rio Country Club Homeowners Association
16 ("ERCCHA") affairs, and has since engaged in wrongful and harassing conduct, including but
17
not limited to making ongoing threats to file liens on PASEO' s undeveloped, undivided 88-
18
acre vacant land parcel APN 225-65-010 on unsupported grounds that PASEO is obligated to
19 pay D&E association dues. D&E has failed to produce any evidence that it is legally
20 authorized and entitled to collect dues on behalf of ERCCHA.
21
47. PASEO alleges that T. Maas and R. Maas unilaterally and wrongfully retained
22
D&E to act as a property management firm in their efforts to wrongfully take and collect
23
homeowner association dues, and to enforce the CC&Rs.
24

25 COUNTS
Antitrust Violations
26

10
 1 48. Under A .RS. 44-1408(B) a private action is permitted for antitrust violations.

2 Maas Construction and other defendants engage in anti-competitive business tactics which

3 prevents and stifles competing homebuilders from building within the community.

4 49. T &N Maas and R&A Maas established an architectural committee under D&E

5 and are responsible for reviewing all new plans and designs for home builds in or near the El

6 Rio Community. Wherein, they are homebuilders, have self-interest and are in full control of

7 declaring whether any other projects move forward in or near the El Rio Community.

8 COUNT6
Civil Conspiracy (A.RS.§ 44~1402, et al.)
9
50. P ASEO alleges that Mr. DeGraffenreid and River .Realty abandoned his role as
10
the Bankruptcy Court Appointed Receiver, including but not limited, failing to gain control
11
over ERCCHA, as directed to so by the bankruptcy court. Mr. DeGraffenreid and River
12
Realty neglect the irresponsibility to acquire control over said homeowners' association entity,
13
the golf course, club house and numerous vacant lots previously owned by John K. Hoover and
14
his family members, and has knowingly allowed T &N Maas and R&A Maas to wrongfully
15
conduct all ERCCHA affairs without any regard to all and any applicable laws which govern
16
Homeowners' Associations of the like.
17

18
COUNT7
Trespass to Land; Temporary Restraining Order
19 and Preliminary Injunction

20 51. PASEO acquired the adjacent land surrounding MVG as set forth above.

21 52. PASEO, through legal counsel, on or about February 22, 2022, sent MVG a

22 demand that it execute PASEO's Golf Course Operation Easement Agreement, as a result of

23
PASEO learning that MVG and its employees and customers were wrongfully trespassing onto

24
PASEO's property, and in doing so exposing PASEO to risks and liabilities of unauthorized

25
persons on its land. To date, MVG has been unresponsive and continues to trespass and enter

26
PASEO's land.

11
 COUNTS
1
Property Damage
2 53 . On or around March 20, 2022, PASEO's member observed damage to its
3 property. This damage directly stems from MVG's unauthorized drilling and pumping water
4 from the underground, main water well that passes through PASEO's property in order to
5 irrigate various areas of the golf course. This drilling and pumping of water have caused and
6 continue to cause daniage to APN 225-65-010. Such drilling does not comport with an
7 existing water use agreement between MVG and Mohave Valley Irrigation and Drainage
8 District which specifically prohibits MVG from moving water from one area of the golf course
9 to water another area, and in doing so, further exposes PASEO to liability while MVG
10 continues to do damage in its wrongful conduct.
11 JURY DEMAND
12 Plaintiff hereby demands a trial by jury of any issue triable of right by a jury.
13 PRAYER FOR RELIEF,
14 WHEREFORE, Plaintiff prays for judgment against all Defendants as follows:
15 A. That Defendants be Ordered to disgorge all ill-gotten profits, assets, and provide

16 to Plaintiffs all equitable remedies available for damages resulting as a direct cause of

' 17 the named Defendants misrepresentations;

18 B. A detailed accounting of all income and other benefits derived or received,

19 directly or indirectly, by Defendants as a result of having engaged in, or having any

2o interest in, any business as a direct cause of the named Defendants misrepresentations;
21 c. The Court enter an Order appointing a Receiver of Defendant MVG assets and

22 directing the Receiver to take possession of Defendant MVG property and business and

23 to rehabilitate and otherwise deal with its property and business either in the name of

24 the Receiver, or name of Defendant MVG as may be most convenient under the

25 circumstances, and.further authorizing Receiver to appoint one or more Special Deputy

26

12
 1 Receivers to act for him/her, and to engage such counsel and assistants as he/she deems

2 necessary to carry out the orderly rehabilitation of Defendant MVG;

\.
3 D. For issuances of a temporary restraining order and preliminary and permanent

4· injunction against Defendants according to proof as it pertains to trespass to land;

5 . E. For appropriate injunctive or other equitable relief~ damages sustained and, as

6 determined by the court, taxable costs and reitSonable attorney's fees. If the trier of fact

7 finds that the violation isflagrant, it shall increase recovery to an amom1t not .in excess
8 of three times the damages sustained pursuant to A.RS. § 44-1408(8).

F. For Plaintiffs' damages for compensatory, expectancy, incidental,

1o consequential, treble, and punitive damages as set forth in any and all applicable laws,

11 including but not limited to A.RS. § 33-420 to be proven at trial;

12 G. For Plaintiffs' reasonable attorneys' fees and costs incurred in bringing this

13 action pursuant to A.R.S. § 12-341, § 12-1103, § 33-420, and all and any other

14 applicable laws;

15 H. For pre- and post-judgment interest at the rate of'10% per annum; and

16 I. For such other relief as the court deems just and proper.
17 RESPECTFULLY submitted this 81h day of August, 2022.

Lin~ k
18

19

20
LAW OFFICES OF LINDA MARIE BROWN, PLLC
P.O. Box 21941
21 Bullhead City, Arizona 86439

22

23

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13
 1
VERIFICATION

2
STATE OF ARIZONA )
3 )
County of Mohave )
4
Michael Palacios, being first duly sworn upon his oath, deposes and states as.follows:
5
I am the managing member of the named Plaintiff in the above--captioned lawsuit, and
6
as such I am authorized to make this Verification. I have read the foregoing Verified ·
7
Complaint and know the contents thereof, that the statements are true and of my own personal
8
knowledge, except as to those matters therein stated upon infonnation and belief; and, as to
9
those matters, I believe them to be true.
10

%.~
11

12

13 Michael Palacios, as managing member

for PASEO EL RIO, LLC
14

15
SUBSCRIBED TO AND SWORN before me this 0~ day of August,
16
2022, by Michael Palacios, in his capacity as managing member for PASEO EL RIO, LLC.
17

18 ~Cuv
Notary Public
19
My Commission Expires: l?4f l<o{ 20z5
20

21

22

23

24

25

26

14
 1
.VERIFICATION
2

S·..i. Richard.' Lopez:, being firstduly swom upon his oathi.depose$ and s4\tes as follows:
l run a~m:em.b~r of th~ '!_lamed PlainJ.lff in the :above;.captfoned lawsuit, and as·such I am
7 · · authorlzedto.· make this Verificatiot.t ) have read the foregoing Verified Complaint ap.dknow
8 . :the:contents thereof,,th~tthe statements.:are true and efmy own personal k.nowkdge, eJCc;ept as
9 to-tho~.maite.~ the~ein stated upQ~ jnfonnation and belief; and, as to those. matters~t belie"e

io· them to he .true~

1.2

lJ:
Richard.-Lopez, as a m~mbe.t of .
PASEO EL RIO, LLC
'•

S~BSCRlBED:TO ~D ~\VQRNbeforeme thi~ ·g· d~r of August,

15

16.'
•·.·.

n 2022~ by Richard·LQJ>ez, in·hls·cap~ity &s a member of.PASEO :EL RIO, LLC.

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