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88. The Plaintiff knowingly, intentionally and willfully advanced sums to the Defendants
which it was aware could not be repaid.
89. The Plaintiff knowingly, intentionally and willfully advanced such sums to the
Defendants upon oppressive, usurious, improper, unlawful and unfair terms.
90. The Plaintiff knowingly, intentionally and willfully advanced such sums to the
Defendants with the understanding that they were under extreme economic duress and would