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As alleged in the First Amended Complaint (“FAC”) filed June 29, 2020, on February 3, 2016, plaintiffs Erin Parisi and Mosby Simmons (collectively, “Plaintiffs”) entered into a new construction residential purchase agreement (“Purchase Agreement”) with defendants Almaden Project LLC (“AP”), Ridgecrest Group Inc. (“RG”), Mike Masoumi aka Masud Masumi (“Masoumi”), and RE/MAX Properties West Inc. (“Remax”) (collectively, “Defendants”) for the purchase of property at 1082 Valentine Court in San Jose for $1.6 million. (See FAC, ¶ 8.) When escrow closed on March 30, 2016, construction was still unfinished and Masoumi and AP agreed to complete the construction in a workmanlike manner, incorporating a punch list into the Purchase Agreement. (See FAC, ¶ 9.) AP and Masoumi represented that construction would be finished and any necessary items fixed. (See FAC, ¶ 10.) Upon moving in, Plaintiffs discovered a number of construction defects. (See FAC, ¶ 11.) Plaintiffs requested that AP