A Sacramento law firm, Somach, Simmons & Dunn (SSD), on Feb. 4 filed a complaint in Sacramento County Superior Court against Merced County and the Merced County Board of Supervisors concerning unpaid bills arising from the Riverside Motorsports Park (RMP) case.

The complaint alleges that Merced County staff, Assistant Planning Director William Nicholson, committed acts of fraud and intentional misrepresentation, fraud and negligent misrepresentation, violation of state Civil Procedures code for levies and unjust enrichment.

SSD is represented by Donald B. Mooney of Davis CA, who is familiar with the operations of Merced County government.

The background facts alleged in the complaint are:

"On August 19, 2008 , the Sacramento County Superior Court granted SSD's Motion for Summary Judgment against Riverside Motorsports Park, LLC, for recovery of the amount due to SSD under a promissory note executed by Riverside Motorsports Park LLC. (Somach Simmons & Dunn, LLP v. Riverside Motorsports Park , LLC, Sacramento County Superior Court, Case No . 07AS0499 1.) The Judgment Granting Motion for Summary Judgment was entered on August 26, 2008.