Counterclaimants DARRICK ANGELONE; AONE CREATIVE, LLC; and ON CHAIN INNOVATIONS, LLC (collectively “Counterclaimants”) allege against HIDDEN EMPIRE HOLDINGS, LLC; HYPER ENGINE, LLC; and DEON TAYLOR (collectively “Cross-Defendants”) as follows:
(1) BREACH OF EXPRESS PARTNERSHIP AGREEMENT
(2) BREACH OF IMPLIED PARTNERSHIP AGREEMENT
(3) BREACH OF FIDUCIARY DUTY
(4) CONSTRUCTIVE FRAUD
(5) PROMISSORY FRAUD
(6) NEGLIGENT MISREPRESENTATION
(7) CONSPIRACY TO COMMIT FRAUD
(8) UNJUST ENRICHMENT
(9) UNLAWFUL BUSINESS PRACTICES (VIOLATION OF BUS. & PROF. CODE §17200)
(10) DECLARATORY RELIEF
(11) SPECIFIC PERFORMANCE
(12) QUANTUM MERUIT
(13) NEGLIGENCE
