398. Plaintiffs repeat and reallege the allegations contained in COUNT I of this complaint as fully as if set forth here.
399. Count V of this complaint is brought by all plaintiffs as a class action against defendant FIRST EASTERN BANK, MLA, CBG, FRANK CEDRONE, VALLEY UTILITIES CO., INC., and ONEIDA WATER CO. for common law fraud and deceit.
400. The court has jurisdiction of this state claim under the doctrine of pendent jurisdiction.
401. Defendant's acts, schemes, misrepresentation, etc., constitute common law fraud under the law of the State of New Jersey.
402. Defendant's acted intentionally, willfully, wantonly, maliciously, for profit, and without just cause or excuse.
403. Plaintiffs suffered damages as a result of defendants wrongful actions.