North Georgia Title brought suit for breach of contract, negligent title examination, fraud, and punitive damages against David M. Wallace and Southern Land Title, Inc. North Georgia Title also sought to have Southern Land Title, LLC1 declared the successor in interest to Southern Land Title, Inc. and to pierce the corporate veil of both. After a jury trial, a verdict was returned in favor of North Georgia Title in the amount of $64,000 against Wallace and Southern Land Title, Inc. for breach of contract, negligent examination of title, and fraud. North Georgia Title elected to have judgment entered on the fraud count. The jury also found that the corporate veil of Southern Land Title, Inc. and Southern Land Title, LLC had been pierced and that a verdict against one of the defendants would be a verdict against all three. The jury found that North Georgia Title was not entitled to punitive damages. Wallace, Southern Land Title, Inc. and Southern Land Title, LLC appeal from the denial of their motion for judgment notwithstanding the verdict or new trial. Finding no error, we affirm. A contract for the sale of residential property located at 1375 Lorenzo Drive, Atlanta, Fulton County was entered into between Samuel Eudovique, as seller, and Kevin Miller, as purchaser. In order to effectuate the closing of the property, North Georgia Title requested Southern Land Title, Inc. to perform a title examination on the property. Wallace was the sole shareholder and officer of Southern Land Title, Inc., and employed five employees. Wallace initially performed his title examination on November 9, 1998. At such time, the effective date of the records on file in Fulton County was September 15, 1998, and any documents filed after this date would not have shown up of record. In his title report, Wallace showed record title to be vested in Cynthia Matthew-Betts and showed, in addition to several FiFas, two open deeds to secure debt on the property.
As the sales contract showed a different seller, North Georgia Title asked Wallace to recheck the deed records in Fulton County. Wallace rechecked the deed records and issued a second title report showing that record title was vested in Samuel Eudovique and listing the same exceptions to title that was shown in the first report.