COMPLAINT

I. INTRODUCTION

1. This is an action arising under Pennsylvania’s Uniform Commercial Code, 13 Pa. C.S. §9601, et seq. (“UCC”) and Unfair Trade Practices and Consumer Protection Law, 73 P.S. 201-1, et seq. (“UTPCPL”).
2. The statutorily required Notice of Repossession sent by Defendant failed to provide key information and as such, violates Pennsylvania’s Uniform Commercial Code.
3. Defendant’s deceptions, omissions and misrepresentations in this predatory transaction also violate Pennsylvania’s state anti-deception law, the UTPCPL.

II. PARTIES
4. Plaintiff Leandra Peterson (“Peterson”) is an adult individual residing in Philadelphia, Pennsylvania at the address captioned.
5. Defendant GFC Lending, LLC (“Defendant” or “GFC”) …show more content…
COUNT II
PENNSYLVANIA UNFAIR TRADE PRACTICES AND
CONSUMER PROTECTION LAW

21. The foregoing paragraphs are incorporated herein as if set forth at length.

22. Defendant GFC unfairly, wrongfully and deceptively declared a default and repossessed Plaintiff’s vehicle.
23. Plaintiff relied on defendant’s omissions and misrepresentations.
24. As a direct result of defendant’s conduct, Plaintiff lost amounts paid monthly in improper and inflated finance charges, deprivation of her vehicle, and suffered other ascertainable losses.
25. Defendant engaged in other fraudulent or deceptive conduct which creates a likelihood of confusion or misunderstanding, 73 P.S. 201-2 (xxi). WHEREFORE, Plaintiff, Leandra Peterson, respectfully asks this Court to grant: (a) Actual damages; (b) Treble damages
(c) Reasonable attorney’s fees and costs; and
(d) Such other relief as the Court shall deem just and