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`NOT A CERTIFIED COPY
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`If Plaintiff’s Amended Complaint survives this Motion to Dismiss, Defendant will be contesting certain allegations
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`FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 06/12/2023 02:10:46 PM
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`and certified. See Plaintiff's Amended Complaint, paragraph 14. These additional allegations, as
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`discussed morefully under the respective Counts, still
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`NOT A CERTIFIED COPY
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`Defendant’s
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`Plaintiff’s
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`“premised
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`Plaintiff’s
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`Plaintiff’s
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`contract.”
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`Plaintiff’s
`Here, there is no contract. Additionally, Plaintiff's own allegations are that the purchase
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`of the new aircraft required Defendant, as well as the other CBIpilots, to complete
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`Plaintiff’s
`comprehensivetraining andcertification in order to have the ability to operate it. See Plaintiff's
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`Amended Complaint, paragraph 9. Therefore, the alleged omissions made by Defendant did not
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`induce Plaintiff to send him to training,as all its pilots were required to complete the training and
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`obtain certification.
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`Plaintiff failed to meet the first element to state a cause of action for-Fraud,in the
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`element, Plaintiff cannot show that it was relied on since Plaintiffasent allthe pilots it employed
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`for the training andcertification. Since Plaintiff has already had ‘anopportunity to Amend the
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`Complaint to state a cause ofaction, this Count should bewdismissed with prejudice.
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`Defendant’s
`Inducement. Evenif the Court were to find that Defendant’s omission’was sufficient to meet that
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`Plaintiff’s Amended Complaint still contains the factual allegations that the purchase of
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`Complaint, paragraph 9. Notably, Plaintiff’s Amended Complaint does not allege that the other
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`ate it. See Plaintiff’s Amended
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`As in the original Complaint, Plaintiff’s Amended Complaint is a
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`Enrichment in Plaintiff’s Amended Complaint is identical to the original Complaint. As such it is
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`NOT A CERTIFIED COPY
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