Sample Car Dealer Fraud Elder Abuse Complaint California

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If you are a senior citizen over the age of 65 in California, and you were the victim of car dealer fraud or elder financial abuse, including ECOA age discrimination contact our firm for a free evaluation of your case You may be entitled to significant monetary damages We fight elder abuse This is a sample complaint that we might file as consumer advocate in a car fraud case We are a civil litigation, financial elder abuse and consumer protection law firm with offices in California and Arizona This complaint address fraud, ECOA violation, adverse action, predatory auto financing, and abuse high pressure car sales tactics
1 2 3 4 5 6 7 8 9 10 11 THIS DOCUMENT IS PROTECTED BY FEDERAL COPYRIGHT LAW ALL RIGHTS ARE RESERVED IF YOU WANT TO LICENSE A COPY OF THIS CAR DEALER FRAUD ELDER ABUSE LETTER PLEASE CONTACT US AT ATTORNEYSTEVEMEDIACOM OR CALL US AT (877) 276- 5084 ANY UNATHORIZED USE OF THIS DOCUMENT WILL BE DEEMED A VIOLATION OF FEDERAL COPYRIGHT LAW AND PURSUED ACCORDINGLY CONSUMER LAW FIRM lawyerfightelderabusecom Elder Abuse Attorney (SBN 000000) 620 Newport Center Drive, Suite 1100 Newport Beach, CA 92660 Phone: (888) 000-8888 x1234 Fax: (888) 999-8888 x9876 ATTORNEY(S) FOR PLAINTIFF: California Elder Citizen over 65 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF SAN BERNARDINO 13 14 15 16 17 18 19 20 21 22 23 ) Case No: ) ) Plaintiff, ) PLAINTIFF’S COMPLAINT FOR: ) vs ) 1 Financial elder abuse ) 2 Intentional (actual) fraud HIGH PRESSURE CAR DEALERSHIP, a ) 3 Fraudulent inducement to enter into ) business organization, form unknown ELDER ) contract ) 4 Unfair business practices (Cal B&P ABUSE AUTO GROUP, a business ) 17200) ) 5 Intentional infliction of emotional organization, form unknown; and DOES 1 ) distress ) through 25, inclusive, 6 Truth in Lending violation (“TILA”) ) 7 Equal Credit Opportunity Act Defendant(s) (“ECOA”) DEFRAUDED CAR BUYER, an Individual 24 JURY TRIAL REQUESTED 25 26 COMES NOW ELDERLY CAR BUYER (“PLAINTIFF” AND/OR “BUYER”) 27 ALLEGING AS FOLLOWS: Page1 28 ______________________________________________________________________________________ COMPLAINT 2 I GENERAL ALLEGATIONS 1 This is an unfortunate story of greed, fraud, and financial elder abuse committed by 3 sophisticated auto dealers and their agents, at FRAUDULENT CAR DEALERSHIP (“CAR 4 BRAND” and/or “DEFENDANT”) against a Plaintiff, a 74 year-old man (a protected class of 1 5 “elders” / “seniors”) In California Plaintiff was present at Defendant’s car dealership on or 6 7 around 10/3/14 (it being noted that some of the Documents were signed on 10/2/14 and some on 8 10/3/14) Plaintiff had been seeking to a quote to get his vehicle (a 2006 ______) repaired 9 Plaintiff was informed there was no possible way the vehicle could be fixed, even though he was 10 at a __________ approved service station Instead, Plaintiff was informed that he would need to 11 12 buy a new car, and was thereafter lead around the lot by an overly aggressive salesperson (in 13 information and belief “FRAUDULENT SALESPERSON”) and thereafter pressured and 14 coerced into purchasing a new car from the dealership 15 16 2 Based on Plaintiff reasonably believing, based on Defendant’s representations, that there were no other options (ie being under duress, alone and scared), and, and that the vehicle 17 18 could not be fixed, which Plaintiff alleges is false, deceptive, malicious and known to be false 19 when the statement was made (by the sales representative who Plaintiff alleges was authorized to 20 speak on behalf of the dealership), Plaintiff thereinafter was induced, under false pretenses, to 21 enter into a sales contract with Defendant’s automotive Dealership 22 3 This alone, makes Defendant’s conduct unconscionable, intentional, malicious, and 23 fraudulent and warrants punitive damages being imposed 25 4 Attached as Exhibit “A” and incorporated herein by reference is a true and correct 26 copy of an alleged repair review that was allegedly undertaken in regard to the condition of the 27 vehicle The report states that the vehicle “would not start” and there was an issue with the 28 ______________________________________________________________________________________ COMPLAINT Page1 24 1 “alternator” The report states that Defendant’s “perform complimentary multi-point inspection” 2 (allegedly for no charge) and performed a “tire air pressure check” (as if tire pressure was for 3 some reason an important issue)” This was apparently the extent of the INSPECTION before 4 advising Plaintiff that his car could not be fixed, and that he needed to purchase a new car if he 5 wanted to get back home 6 7 5 Again, there was no charge for the alleged tire pressure check, although a 108 charge 8 was noted on the report The report (Page 1 of 1) makes no reference to any need for a new 9 radiator, or fuel pump, timing wheel, new tires, brakes, and other items Defendant’s counsel has 10 subsequently informed Plaintiff’s counsel was checked This is disputed as wholly false and 11 12 13 fraudulent Plaintiff disputes that the brakes, or timing wheel were checked when the car was not alleged to be in running condition 14 6 In short, Defendants are seeking to cover their tracks and Plaintiff alleges they had no 15 intent to inspect, or review the vehicle, and on information and belief alleges the vehicle was not 16 properly inspected, although incurring a 10800 charge Plaintiff alleges this amount was 17 18 demanded in bad faith 19 7 Defendant’s thereafter, knowing Plaintiff was “retired” and on a limited budget, 20 steered Plaintiff to, and pressured him into purchasing a brand new 2015 _________ using high 21 pressure sales tactics aimed at coercing a sale 22 8 Plaintiff was informed that ___________offered “0% financing” programs and that 23 24 25 26 if Plaintiff’s credit was good enough, he could potentially qualify for such programs 9 Based on these representations, which Plaintiff alleges were false when made, and reasonably relied on by Plaintiff, he entered the showroom and was taken to a closing desk Page1 27 28 ______________________________________________________________________________________ COMPLAINT 1 10 Plaintiff alleges his credit was run (although at this stage of the litigation Plaintiff 2 denies signing and agreeing to the pulling of his credit, as all pages of the Credit application have 3 not been provided by Defendant’s counsel) 4 5 11 Plaintiff alleges his credit score was 833 (excellent credit qualifying Plaintiff for the best interest rates including 0% financing alleged to be available) 6 7 12 Despite this near perfect credit, Plaintiff was informed that he did not qualify for 0% 8 financing (his credit scores were not shown to Plaintiff) and instead, he was informed the interest 9 rate would be 489% for 72 months financing (resulting in a finance charge of 5,17277) 10 Plaintiff alleges this amount was taken and appropriated in bad faith 11 12 13 Attached as Exhibit “B” is a true and correct copy of a “Federal Truth in Lending 13 Disclosures” statement indicating Plaintiff’s monthly payment would be 52601 (note that this 14 is in excess of the 52409 set forth in Exhibit “C”) This amount is alleged to be confusing, in 15 violation of TILA, misleading to the ordinary consumer, and predatory as not a financing 16 arrangement made in good faith with a fair conscience toward the ability to repay based on 17 18 Plaintiff’s retired status, and based upon his living on a fixed income 19 14 Plaintiff alleges he was not instructed to or pressured to buy any lesser priced vehicle 20 that perhaps he could afford on his limited fixed income, and instead was steered to as much car 21 as Plaintiff’s could try to hope to get away with 22 15 Plaintiff also alleges that although Defendant’s website indicated prices of 23 24 _________ are in the 22,000 range, the final sales price to Defendant on the TIL statement was 25 indicated to be 24,190 Plaintiff alleges that he is being discriminated against, in regard to 26 pricing and mere 200 trade in value (discussed below), because of his age in violation of the Page1 27 28 ______________________________________________________________________________________ COMPLAINT 1 2 Equal Credit Opportunity Act) See Exhibit “F” which is attached and incorporated herein by reference and represents a true and correct printout of Defendant’s website 3 16 Plaintiff was given a mere 200 for his vehicle (which he was all that it was worth, 4 and falsely informed could not be fixed at any price as set forth above), although Plaintiff is now 5 being informed, through Defense counsel, that the car COULD be fixed, albeit for 2,100 which 6 7 Plaintiff alleges to be false, and part of a cover-up designed to aid, abet, and assist perpetrating 8 financial elder abuse Plaintiff was never provided with any itemized amount to fix his car, and 9 no estimates, and to suggest otherwise is to assist in acts of financial elder abuse 10 17 Plaintiff estimates the value of his vehicle to be approximately no less than 3,072 at 11 12 the time the dealership took possession of the vehicle under false pretenses (Exhibit “E”) 13 18 In addition, Plaintiff was pressured, using high-pressure car salesman tactics, to 14 purchase additional unnecessary items (on information and belief, because the dealership had 15 “legs” built into the transaction so that forcing products upon Plaintiff became a required act 16 from a financing perspective) 17 18 19 Such items are referenced in the attached Exhibit “C” which is incorporated herein 19 by reference and represents a true and correct copy of a “Optional Products and Services 20 Disclosure” which indicates the items Plaintiff was informed “he needed” in order to purchase 21 the vehicle from the dealership 22 20 Plaintiff alleges he was pressured and coerced, under duress to purchase these items 23 25 26 27 one of which being a 1,49500 “exterior paint” product, which product, like all the other products, were not properly explained to Plaintiff and which he was pressured into accepting 21 Plaintiff alleges it is unconscionable to charge 7,76300 for these additional products (which appear to add up to 6,86800 on the TILA statement) making this document 28 ______________________________________________________________________________________ COMPLAINT Page1 24 1 false and misleading to the ordinary consumer The final TIL statement indicates an absence of 2 the “Tire and Wheel” product (which covered only 60 months, although the terms of the 3 financing were 72 months), which Exhibit “C” claims Plaintiff was to receive 4 5 21 The “Due Bill” (Exhibit “D”) indicates that Defendants were to “Apply _______ Paint and Fab PR”, Plaintiff alleges he was never informed of what this product is, nor has he 6 7 8 9 10 ever received such a product 22 Plaintiff alleges that the foregoing is malicious and oppressive and intended to, and is in fact causing severe mental and emotional distress 23 Plaintiff alleges that the conduct of Defendants, as alleged herein, is shocking, 11 12 13 extreme, outrageous and unconscionable resulting in a VOID transaction 24 WHERFORE, Plaintiff prays as follows: II THE PARTIES 25 Plaintiff CALIFORNIA ELDER ABUSE CITIZEN OVER 65 YEARS OF AGE 14 15 16 (“Plaintiff” and/or “BUYER”) is an elder California citizen, over the age of 65 at the time of the 17 transaction in question 19 26 Defendant RV DEALERSHIP, is a California business organization, form unknown 20 27 21 22 23 24 Defendant BOAT, CAR AND TRUCK AUTO GROUP, is a California business organization, form unknown 28 Collectively the above named parties may be referred to herein as “Defendant” and/or “Defendants” 25 29 Plaintiffs are ignorant of the true names and capacities of Defendants sued herein as 26 Does 1-25, inclusive and therefore sue these Defendants by such fictitious names Plaintiff will 27 amend this complaint to allege their true names and capacities when they have been ascertained 28 ______________________________________________________________________________________ COMPLAINT Page1 18 1 Plaintiffs are informed and believe that each of said fictitiously named Defendants are 2 responsible in some manner for the occurrences herein alleged, and that Plaintiffs’ injuries as 3 herein alleged were proximately caused by the acts and/or omissions of each 4 5 30 Plaintiff is informed and believes and thereon alleges on information and belief that Defendants, and each of them, were the agents, servants, employees, co-conspirators, joint 6 7 venture partners, contractors and alter egos of each of the other Defendants, and at all times 8 mentioned herein, each were acting within the knowledge and direction of each other and within 9 the purpose, scope and course of their agency, service, employment, joint venture and with the 10 express and/or implied knowledge, permission, consent and ratification of the remaining 11 12 13 Defendants and each thereby has conspired, approved, aided, abetted, encouraged, incentivized and ratified the acts of the other Defendants III JURISDICTION 14 15 16 17 18 19 31 Jurisdiction over this action and its claims is provided by Cal Code of Civil Proc § 88 The violations of law set forth herein occurred in this County 32 Venue is proper pursuant to Cal Code of Civ Proc § 392(a)(1) 33 Plaintiff hereby asserts their demand for a jury trial and an expedited trial under 20 California elder abuse statutes IV CAUSES OF ACTION 22 23 FIRST CAUSE OF ACTION 24 Financial Elder Abuse 25 (Against all Defendants) 26 27 28 34 Plaintiff incorporates the allegations of Paragraphs 1 through 33 of this Complaint as though fully set forth herein ______________________________________________________________________________________ COMPLAINT Page1 21 1 2 3 4 5 35 Plaintiff is an “elder” under California law (Welfare & Institutions Code) and was over 65 years of age during all acts, events, and omissions giving rise to this lawsuit 36 Plaintiff alleges that each of the Defendant conspired and aided, abetted and assisted each other in the various acts that constitute financial elder abuse under California law 37 Plaintiff alleges Defendants wrongfully took, secreted, appropriated, retained and 6 7 converted Plaintiff’s property (money and his car) in bad faith (and each assisted the 8 other defendants in doing the same) by committing the following intentional acts and 9 omissions: 10 38 Representing a charge of 10800 was owed for an inspection Plaintiff alleges never 11 12 happened; 13 39 By representing that if Plaintiff’s credit was good enough he might qualify for 0% 14 financing (and despite a 833 FICO score, obtained a 72 month loan at 4895 interest 15 resulting in wrongfully taking 5,17277 in bad faith) 16 40 By violating the ECOA and taking more from Plaintiff, and engaging in price 17 18 discrimination (in regard to the sales price of the vehicle) charging Plaintiff more than 19 advertised on their website for the subject vehicle, and based on Plaintiff’s age and 20 vulnerabilities 21 22 41 By giving Plaintiff 200 for his trade-in (making false representations of material fact that his car was not fixable), and that it was worth no more than 200, when Plaintiff 23 alleges the vehicle was worth no less than 3,072 (a 2,87200 difference) As such, 25 Plaintiff was required to make a 1,700 down payment in order to purchase the vehicle, 26 such down payment, including a required 500 from Plaintiff was money (personal 27 property) taken in bad faith and converted to a wrongful use 28 ______________________________________________________________________________________ COMPLAINT Page1 24 1 42 As a result of these intentional acts and material omissions, which Plaintiff alleges were 2 each   part   of   an   intentional   plan,   design,   and   scheme   with   other   Defendants   to  take, 3 secret,   appropriate,   obtain,   and   retain  Plaintiff’s   property   in   bad   faith   Plaintiff   has 4 suffered and Defendants have placed Plaintiff in serious risk of financial harm and caused 5 6 financial losses to Defendant in the amounts stated above, but not limited to amounts 7 provable at trial 8 9 10 43 Defendants have also caused other serious mental, emotional, trauma, pain, suffering, humiliation, embarrassment and depression 11 44 WHEREFORE, given the above, Plaintiff seeks against each Defendant actual damages 12 in an amount no less than the jurisdictional limits of this Court and including punitive 13 damages, costs, attorney fees, disgorgement of fees wrongfully obtained, rescission of the 14 15 transaction (declaring such VOID), pain and suffering and other just and equitable relief SECOND CAUSE OF ACTION 16 17 Intentional Fraud 18 (Against Defendants) 19 20 21 45 Plaintiff incorporates the allegations of Paragraphs 1 through 44 of this Complaint as though fully set forth herein 22 46 Plaintiff alleges that Defendants, and each of them, on the date referenced above, made 23 false statements of material fact, which were known to be false when made (particularly 24 of the salesman “GREEDY AND UNETHICAL SALESMAN”) who stated if Plaintiff 25 27 28 had excellent credit he would qualify for a 0% financing 47 Such false statements were relied upon Plaintiff to his detriment, causing the herein referenced damages, and other damages to be proven at trial ______________________________________________________________________________________ COMPLAINT Page1 26 1 48 Additional fraudulent false statements of fact were made by unknown management 2 members (names of same within the exclusive control of Defendants), regarding 3 Plaintiff’s vehicle being beyond repair, and that he would need to purchase a new 2015 4 vehicle if Plaintiff 5 49 These false statements of fact, and fraudulent inducements to enter into a sales contract, 6 7 8 9 10 were reasonably relied upon by the Elder Plaintiff and his reasonable reliance resulted in causing Plaintiff severe and significant financial, mental, and emotional damages 50 WHEREFORE,   given  the   above,  and   given  the  abusive  process  undertaken,   Plaintiff seeks against each Defendant actual damages in an amount no less than the jurisdictional 11 12 13 limits of this Court, and punitive damages, designed to punish and deter Defendants from engaging in future conduct of this nature and other just and equitable relief 14 15 THIRD CAUSE OF ACTION 16 Fraudulent Inducement to Enter into Contract 17 (Against Defendants) 18 51 Plaintiff incorporates the allegations of Paragraphs 1 through 50 of this Complaint as 19 20 though fully set forth herein 21 52 Plaintiff’s alleges Defendant’s used lies, trickery, deceit, and false pretenses as set forth 22 above, in an effort to force Plaintiff into a position where he was forced to purchase a 23 brand new vehicle from Defendants 24 25 26 53 Plaintiff, an elder, was under Duress, and coerced through high-pressure sales tactics to purchase the vehicle Page1 27 28 ______________________________________________________________________________________ COMPLAINT 1 54 Under the guise of these false promises, coercion, and distress, Defendant’s fraudulently 2 induced Plaintiff to enter into a 72-month sales contract, forcing Plaintiff into a situation 3 where his good credit score is now at risk 4 5 55 As such, Plaintiff alleges all transactions with Defendants are VOID as against public policy, and given it is a product of fraud and the “fruit of the poisonous tree” to borrower 6 7 a legal term 8 56 As such, each Defendant is liable to Plaintiff for actual damages in an amount no less 9 than the jurisdictional limits of this Court, punitive damages in an amount sufficient to 10 punish and deter, and to have the contract declared VOID and unenforceable due to the 11 12 extreme   and   outrageous,   unconscionable   conduct   of   Defendants,   and   other   just   and 13 equitable relief 14 15 FOURTH CAUSE OF ACTION Unfair and Deceptive Business Practices – Cal B&P 17200 16 (Against Defendants) 17 18 19 20 57 Plaintiff incorporates the allegations of Paragraphs 1 through 56 of this Complaint as though fully set forth herein 21 58 Plaintiff alleges the above acts and omissions and false statements to Plaintiff were 22 designed to induce Plaintiff to enter into a purchase and sales agreement and to thereby 23 seek to obtain additional costs, fees, commissions, bonuses and secret profits to the 24 detriment of Plaintiff 26 59 Plaintiff alleges Defendants had no belief in the truth of their statements to Plaintiff and 27 third parties when made and that Plaintiff justifiably relied on Defendants affirmative 28 representations and relied on their position of trust and authority ______________________________________________________________________________________ COMPLAINT Page1 25 1 2 60 Plaintiffs have suffered damages as a result of this intentional fraud by Defendants, which is deemed a “fraudulent” act under B&P 17200 3 61 Plaintiff asserts that the above acts and omissions were also “unfair” as set forth under 4 B&P 17200 as serving no legitimate business purpose and to beyond the bounds of 5 conduct elders in the State of California should be expected to endure when they visit a 6 7 8 9 10 car dealership 62 Plaintiff further alleges violations of statute, which support a B&P 17200 claim (ex Federal Truth in Lending Law, and Equal Credit Opportunity Act) as alleged below 63 As such, each Defendants are liable to Plaintiff to return all sums collected, return 11 12 13 Plaintiff’s vehicle, to provide full restitution to Plaintiff, and for other just and equitable relief 14 15 FIFTH CAUSE OF ACTION Intentional Infliction of Emotional Distress 16 (Against Defendants) 17 18 19 20 21 64 Plaintiff incorporates the allegations of Paragraphs 1 through 63 of this Complaint as though fully set forth herein 65 Socking an elder away in a bad car deal is not good business, and is harmful to elders and their families who must try to console them 22 66 Plaintiff alleges Defendants have engaged in extreme and outrageous conduct in 24 committing the above referenced acts and omissions, and must be held liable for all 25 mental and emotional damages caused 26 27 67 Plaintiff alleges he has suffered severe mental and emotional distress as a result of the facts set forth and alleged in this Complaint 28 ______________________________________________________________________________________ COMPLAINT Page1 23 1 68 As such, each Defendants are liable to Plaintiff for all actual damages suffered, and in an 2 amount no less than the jurisdictional limits of this Court, pain and suffering, punitive 3 damages, cancellation and voiding of the contract, and other just and equitable relief 4 5 SIXTH CAUSE OF ACTION 6 Violation of Truth in Lending (“TILA”) 7 (Against all Defendants) 8 9 10 11 12 69 Plaintiff incorporates the allegations of Paragraphs 1 through 168 of this Complaint as though fully set forth herein 70 Plaintiff was an “elder,” as defined under the California Welfare & Institutions Code, as was over the age of 65 when entering into the sham purchase and sale agreement 13 14 referenced above Plaintiff is 74 years of age and retired 15 71 As such, each Defendant had a duty to treat Plaintiff with care, and to deal with him in 16 good faith and to ensure all TILA disclosures were clear and conspicuous and accurate 17 72 Plaintiff alleges that he signed one document (Exhibit “C”), which indicated his monthly 18 payment would be 52409, (Exhibit “B”) but the TILA disclosure represents a 19 20 21 22 23 24 HIGHER monthly payment figure of 52601 This is false and deceptive, and misleading and confusing to the average elderly consumer 73 Plaintiff alleges this also indicates illegal “payment packing” and predatory lending activity 74 Plaintiff alleges these are material TILA violation, permitting rescission of the loan 25 27 28 agreement 75 Plaintiff further argues a violation of “Reg Z” in regard to failure to take into account the ability to repay the car loan and for unfair, abusive, deceptive lending practices ______________________________________________________________________________________ COMPLAINT Page1 26 76 As such, each Defendants are liable to for statutory damages, attorney fees, and to 1 rescind the loan at issue, and is entitled to other just and equitable relief 2 3 SEVENTH CAUSE OF ACTION 4 Violation of Equal Credit Opportunity Act – “ECOA” 5 (Against Defendants) 6 77 Plaintiff incorporates the allegations of Paragraphs 1 through 76 of this Complaint as 7 though fully set forth herein 8 9 78 Plaintiff alleges that given the foregoing, he has been discriminated against in regard to 10 being charged excessive amounts for the 2015 car, and excessive financing charges for 11 same, in excess of amounts charged to other Clients, based upon Plaintiff’s age 12 13 79 Plaintiff alleges he was false induced to enter into a consumer credit transaction and that 14 Defendants are “Creditors” as they regularly extend credit and the loan was primarily for 15 family and household purposes 16 80 Further, Plaintiff alleges that he was switched, intentionally and in reckless disregard of 17 his credit score, from a 0% loan, to a loan at 489% without receiving an “adverse action 18 letter” in violation of the ECOA 19 20 81 Wherefore Plaintiff seeks actual and punitive damages, statutory damages, attorney fees,  21 and other just and equitable relief 22 23 V PRAYER FOR RELIEF 24 25 26 WHEREFORE, given the foregoing, Plaintiff’s pray for relief as set forth above and as follows: 1 That the Court assume jurisdiction in this case and grant a jury trial and expedited trial 27 under California elder abuse statutes; Page1 28 ______________________________________________________________________________________ COMPLAINT 1 2 That the Court award actual and compensatory damages in an amount to be proven at 2 trial, (but no less than the jurisdictional minimum of this Court); 3 3 4 Elder abuse statute, TILA, ECOA, and California Civil Code 10215; 5 4 That the Court award reasonable costs and attorney fees to Plaintiff under California’s That the Court allow punitive damages designed to punish and deter Defendants from 6 7 engaging in similar future conduct; 8 5 9 Defendant; 10 6 That the Court award treble damages and that monetary penalties be assessed to each That the Court order the sales transaction VOID and unenforceable and Order that all 11 12 13 secret profits and ill-gotten gains be disgorged; 7 That the Court award such other and further relief as the Court deems just and proper 14 15 16 17 18 RESPECTFULLY SUBMITTED Dated: January 24, 2015 AUTO FRAUD CONSUMER LAW CENTER CALIFORNIA 19 20 21 By ________________________________________________________________ INJURED AUTO BUYER 22 23 24 25 26 Page1 27 28 ______________________________________________________________________________________ COMPLAINT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page1 27 28 ______________________________________________________________________________________ COMPLAINT