MJB Bixby Construction Co. Lawsuits

[Ayatollahgondola]

Bixby vs Pat Cummings & CB Richard Ellis

At all times herein mentioned, Defendants, and each of them, negligently and
carelessly represented Plaintiffs and negligently and carelessly rendered inappropriate,
inadequate brokerage and management services; negligently and carelessly failed to properly
represent Plaintiffs and to properly protect Plaintiffs' interests by failing to perform numerous
acts, including, but not limited to, failing to properly conduct the appropriate background
investigation of potential tenants, in particular Davi Anthony Rodrigues dba Black Market,
Ayatollah of Gondola; improperly advising Plaintiffs to enter into an industrial real estate lease
with said tenant, in addition to several other inappropriate, inadequate, careless, and negligent
actions or inactions.
11. As a result of the various acts of negligence and carelessness of Defendants, and each
of them, Plaintiffs suffered damages and were deprived of and lost various rights and have
incurred fees and costs related to the prior and continued need to defend/pursue their legal rights
and remedies relating to the above-referenced tenant.