FRESNO – A Fresno County individual involved in the placement of workers and temporary workers in the agriculture and field work industries alleges insurance brokers conspired to issue a fraudulent certificate for workers' compensation coverage.

Karey Fidalgo, individually and doing business as Central Cal AG, filed a complaint on May 22 in the Fresno County Superior Court against Brad Machado, Bruno Lometti, DiBuduo and Defendis Insurance Brokers LLC, et al. alleging professional negligence, breach of fiduciary duty, fraudulent misrepresentation and other counts.

According to the complaint, the plaintiff alleges that in 2014, plaintiff contacted the defendants regarding her specific needs for workers' compensation coverage relating to her business. Despite having made payments for the insurance coverage, plaintiff alleges she learned that no workers' compensation coverage was provided when two workers died after an incident on one of the plaintiff's projects in May 2015.

The plaintiff holds the defendants responsible because they allegedly colluded and conspired to enter into a scheme to produce a fraudulent certificate for workers' compensation insurance coverage and took payments and/or commission monies from plaintiff's payment despite knowing the workers’ compensation insurance coverage was not valid and that Certificate of Liability was fraudulently issued.

The plaintiff seeks judgment for all damages incurred, plus costs of suit, attorney's fees and such and further relief as the court deems just and proper. She is represented by Roger S. Bonakdar of Bonakdar Law Firm in Fresno.

Fresno County Superior Court case number 17CECG01752

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