This case filed by the insurance company for one of Bixby's Contracting business customers, alleged Fraud, misrepresentation, Violation of unfair competition law, negligence, and breach of contract.
25. Plaintiffs are informed and believe that BIXBY and DOES 1 through 50. by
6 way of further example and not by way of limitation. agreed to undertake specific work
7 in the INSURED HOMES, represented to the INSUREDS and FIRST AMERICAN that
8 they had in fact performed specific tasks, and thereafter submitted invoices to the
9 INSUREDS and FIRST AMERICAN for the costs and labor associated with this work,
10 when in fact BIXBY and DOES 1 through 50 knew that each of these representations
11 were false, that they had not, nor had the ever intended to, perform all or some of these
12 specific tasks, and that their invoices were fraudulent.