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SIXTH CAUSE OF
ACTION
(Unjust
Enrichment)
94. Plaintiff
repeats and realleges each and every allegation set
forth in Paragraphs 1 through 56 herein, inclusive,
as though fully set forth herein. Through and as a
result of their intentional and willful and
unauthorized use of Mike Hailwood's name, likeness
and identifying characteristics, Defendants have
received substantial monies and other benefits
which rightfully belong to Plaintiff.
Defendants have
failed to properly compensate Plaintiff for said
monies and other benefits received by Defendants
which rightfully belong to Plaintiff and Defendants
have accordingly been unjustly enriched at the
expense of Plaintiff.
As a result of
their actions, Defendants have been unjustly
enriched and have unjustly received monies and
other benefits.
As a result of the
foregoing, Plaintiff has suffered
damages.
WHEREFORE,
Plaintiff demands judgment against Defendants, and
each of them:
(a) For
compensatory damages; and
(b) For such other
and further relief as the Court deems just, proper
and/or appropriate.
JURY
DEMAND
Plaintiff hereby
demands a trial by jury on all issues so
triable.
MONDELLO &
SCHECHTER, P.A.
Attorneys for
Plaintiff,
By:___________________________
Steven C.
Schechter, Esq.
Dated: June 11,
2001. SS2358
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