GM fraudulently induced KK to sell him goods by falsely representing that he was solvent and worth a certain amount, when in fact he was insolvent. KM then transferred the goods to KM without consideration, and KM had notice of GM's fraudulent misrepresentation. KK is suing both GM and KM for delivery of the goods or their value, as well as compensation for detaining the goods. KK affirms that the contents of the complaint are true and correct to the best of his knowledge.