As to the motion of Catherine Louise Gentile aka Katia Louise and Wild For Life Foundation, denied. Plaintiff has met its burden of establishing that there exist triable material issues of fact. Fraud: The elements of fraud are: (1) misrepresentation or concealment, (2) knowledge of falsity, (3) intent to defraud, (4) justifiable reliance, and (5) resulting damage. (Engalla v. Permanente Medical Group (1997) 15 Cal. 4th 951.) (Lovejoy v. AT&T Corp. (2004) 119 Cal. App. 4th 151, 157-158.) Plaintiffs allege that Louise told Autry that WFLF was looking for a new ranch for the horses because the owner of their previous home had stolen from WFLF and poisoned some of the horses. (Complaint (Compl.)), ¶18.) Louise this statement was allegedly false and intended to conceal an eviction in order to defraud Plaintiffs and obtain donations for a new ranch. (Ibid.) Plaintiffs also allege that Louise misrepresented that she used funds provided Plaintiffs for renovations to the Anza Ranch. (Compl., ¶