Burns v. Cassatt

The complaint alleges two causes of action for fraud based on “ false and fraudulent misrepresentations.” Paragraph III of the complaint, which is realleged by reference in the second cause of action, reads as follows: “ III. That the defendants now are and during all of the times hereinafter mentioned were investment brokers and maintained an investment brokerage office at the City of Elmira, New York; and upon information and belief alleges that the defendants failed and neglected to comply with the statutes of the State of New York in that they failed and neglected to file in the office of…