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`files its Response in Opposition to Defendant’s Motion to Dismiss and states the following:
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`Plaintiff’s Complaint sets forth three causes of action: Count I –
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`PLAINTIFF’S RESPONSE
`DEFENDANT’S MOTION TO DISMISS
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`NOT A CERTIFIED COPY
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`Enrichment. These claims arise out of Plaintiff’s employment of Defendant, Wesley Richards
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`(“Richards”), a pilot for CBI.
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`FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 05/18/2023 12:01:59 PM
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`Defendant’s Motion to Dismiss
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`NOT A CERTIFIED COPY
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`4th DCA 2006) (“[T]rial courts must generally afford a litigant an opportunity to cure a defect
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`the pleading before dismissing it with prejudice.”);
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`(Fla. 4th DCA 1999) (“A claim should not be dismissed with prejudice without giving the
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`cannot be amended to state a cause of action.” (citation and quotation marks omitted)).
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`“To state a cause of action for fraud in the inducement, the Plaintiff must allege (a) a
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`in justifiable reliance on the representation.”
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`So.2d 489, 497 (Fla. 4th DCA 2001). Furthermore, “[i]n order for a claim of fraud in the
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`which the statement was made.”
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`NOT A CERTIFIED COPY
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`CBI justifiably relied on Richard’s false statements to its detriment. Compl.
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`Accordingly, Defendant’s Motion to Dismiss Count I must be denied as Plaintiff’s
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`whether “all
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`pilots” were
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`case law cited by Defendant. Plaintiff’s Complaint clearly states that Richards received valuable
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`NOT A CERTIFIED COPY
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`As noted previously, Defendant’s attempt to draw a distinction as to Richards vs. “all of the
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`pilots” is without merit and unsupported in his Motion.
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`f’s Complaint clearly states that CBI provided Richards with
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`Complaint and requests this honorable Court to deny Defendant’s Motion to Dismiss.
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`NOT A CERTIFIED COPY
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