Case 3:17-cv-00003-AWT Document 6 Filed 01/07/17 Page 1 of 4

UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
TANISHA COLEY

JURY TRIAL DEMANDED

V.

CASE NO. 3:17 CV 3 (AWT)

GGL, LLC d/b/a KIA OF STAMFORD
FIRST AMENDED COMPLAINT
1. This is an action for actual, statutory, or punitive damages and attorneys fees for
violation of the Truth in Lending Act (“TILA”), 15 U.S.C. § 1601, et seq.; for violation of
the Connecticut Unfair Trade Practices Act, section 42-110a Conn. Gen. Stat. et seq.; Conn.
Gen. Stat. § 52-565 for civil forgery; for breach of the duty of good faith and fair dealing; or for

violation of the common law of misrepresentation.
2. This court has jurisdiction. 15 U.S.C. § 1640(e); 28 U.S.C. § 1331 and §1367.
3. Plaintiff is a citizen of Connecticut.
4. Defendant is a Connecticut corporation doing business as a car dealer at 263
Selleck St., Stamford CT.
5. During the year prior to 12/12/2016, defendant entered into more than 25 Retail
Installment Contracts with individuals which were payable in more than four installments.
6. On December 1, 2016, plaintiff went window-shopping for a car at defendant’s
place of business.
7. On December 1, 2016, Ms. Coley entered information on defendant’s computer to
find out whether she had sufficient credit to buy a car.
8. Ms. Coley did not buy a car or sign or receive any documents concerning a car
purchase from defendant on December 1, 2016, or on any other date.

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9. Ms. Coley was not at defendant’s dealership on December 12, 2016.
10. Some days thereafter, Ms. Coley found a car loan on her credit report, reflecting an
“Opened Date” of Dec. 12, 2016, and a “Balance” of $17,737.
11. The Defendant had electronically booked the car loan for Ms. Coley with Credit
Acceptance Corporation for a 2013 Mazda that she never purchased or took possession of.
12. There is a counterfeited retail installment contract (the “document”) that was never
given to Ms. Coley, with her forged signatures and initials appearing thereon.
13. The document identifies defendant as the “Creditor-Seller.”
14. The document falsely recites that Ms. Coley made a $7,000 down payment.
15. The document includes $674 as a charge for GAP protection that plaintiff did not
request or want.
16. The dealer did not provide any copy of the GAP protection to plaintiff.
17. The document includes $1,301 for an extended warranty or service contract that
plaintiff did not request or want.
18. The dealer did not provide any copy of the warranty or service contract to plaintiff.
19. The document shows a sales price of some $20,000, well over market price for a
2013 Mazda.
20. Plaintiff believes that the excess price was to enable the dealer to recoup the
discount fee charged by the finance company, Credit Acceptance.
21. Because of the excess price, the document included sales taxes that would not have
been changed in a cash transaction.
22. The document shows a finance charge of $10,974.71 and an annual percentage rate

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of 18.99%.
23. Credit Acceptance reassigned the document to the dealer by December 30, 2016.
24. The defendant’s acts complained of herein were done or omitted as a matter of
routine practice and procedure, intentionally and/or in reckless disregard of the rights of the
consumer plaintiff.
DAMAGES
Due to the defendant’s conduct, plaintiff suffered an inaccurate credit report,
inconvenience, expense, and anxiety.
WHEREFORE, it is respectfully prayed that this Court:
1. Award TILA statutory damages of $2,000, plus other statutory, actual, or punitive
damages to the plaintiff under the applicable statutes, or common law.
2. Award costs and a reasonable attorney's fee.
3. Award such other or further relief as the Court deems just or equitable.
THE PLAINTIFF

BY___/s/ Joanne S. Faulkner___
JOANNE S. FAULKNER ct04137
123 Avon Street
New Haven, CT 06511-2422
(203) 772-0395
faulknerlawoffice@snet.net

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Certificate of Service
I hereby certify that on January 7, 2017, a copy of within was filed electronically.
Notice of this filing will be sent by e-mail to all parties by operation of the Court’s
electronic filing system. Parties may access this filing through the Court’s system. A
copy was also mailed, postage prepaid, to defendant’s member and agent for service:
George Fred D’Angelo
263 Selleck St
Stamford CT 06902
____/s/ Joanne S. Faulkner___
JOANNE S. FAULKNER ct04137