Kiko Khounvichith vs Ti Sila et al.

4. Plaintiff further alleges mental and emotional distress arising from Defendants' fraudulent and wrongful conduct.

FIRST CAUSE OF ACTION - FRAUD (Against All Defendants)

5. Defendants knowingly made false representations and concealed material facts with intent to induce reliance by Plaintiff, who reasonably relied on said misrepresentations to his detriment.

SECOND CAUSE OF ACTION - BREACH OF CONTRACT (Against All Defendants)

6. Plaintiff and Defendants entered into agreements regarding the Tenaya proterty. Defendants breached by failing to honor terms relating to Plaintiff's equity and rights.

THIRD CAUSE OF ACTION - CONVERSION

(Against All Defendants)

7. Defendants wrongfully exercised control over Plaintiff's property interests, depriving Plaintiff of use and enjoyment.

FOURTH CAUSE OF ACTION - CONSTRUCTIVE FRAUD

8. By virtue of the relationship of trust and reliance, Defendants owed fiduciary duties to Plaintiff and breached those duties, causing damages.

WHEREFORE, Plaintiff prays for judgment against Defendants as follows:

A. For damages in the amount of $201,489.75, plus lost rent and interest;

B. For punitive and exemplary damages according to proof;

C. For costs of suit incurred herein;

D. For such other and further relief as the Court deems just and proper.

DEMAND FOR JURY TRIAL Plaintiff demands trial by jury on all issues so triable. Dated: October 1, 2025 Kelo Kend Kiko Khounvichith, Plaintiff In Pro Per

Plaintiff, Kiko Khounvichith, hereby demands trial by jury on all issues so triable pursuant to Article 1, Section 16 of the California Constitution and Code of Civil Procedure 631.

Dated: October 1, 2025 Kee but Kiko Khounvichith, Plaintiff In Pro Per