DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO 1437 Bannock Street Denver, Colorado 80202 STATE OF COLORADO, ex rel. John W. Suthers, Attorney General, Plaintiff, v. AMERICAN MORTGAGE CONSULTANTS-AMC, a sole proprietorship; OLIVER PAUL MALDONADO, an individual; and SANTIAGO FABIAN PINEDA, an individual, Defendants. COURT USE ONLY JOHN W. SUTHERS, Attorney General Case No.: JENNIFER MINER DETHMERS, Assistant Attorney General, Reg. No. 32519* ERIK R. NEUSCH, Assistant Attorney General, Reg. No. 33146* Courtroom: 1525 Sherman Street Denver, Colorado 80203 Phone: 303-866-4500 E-mail:
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[email protected] *Counsel of Record COMPLAINT Plaintiff, the State of Colorado, upon relation of John W. Suthers, Attorney General for the State of Colorado, by and through the undersigned counsel, states and alleges against Defendants American Mortgage Consultants-AMC, Oliver Paul Maldonado and Santiago Fabian Pineda (“Defendants”) as follows: INTRODUCTION 1. This matter is a civil law enforcement action by the State of Colorado, ex rel. John W. Suthers, under the Colorado Consumer Protection Act, §§ 6-1-101 – 6-1-1120, C.R.S. (2009), to preliminarily and permanently enjoin Defendants from engaging in deceptive trade practices, to recover statutory civil penalties, to obtain restitution, to disgorge unjust proceeds, 1 and to recover attorney fees and costs. PARTIES 2. John W. Suthers is the duly elected Attorney General for the State of Colorado and has express authority under § 6-1-103, C.R.S. (2009) to enforce and prosecute violations of the Colorado Consumer Protection Act. 3. Defendant American Mortgage Consultants-AMC (“American Mortgage Consultants”) is a sole proprietorship owned and controlled by Defendant Maldonado.