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DMUND
G. B
ROWN
J
R
.Attorney General of CaliforniaF
RANCES
T. G
RUNDER
Senior Assistant Attorney GeneralB
ENJAMIN
D
IEHL
, State Bar No. 192984Deputy Attorney General300 South Spring Street, Suite 1702
Los Angeles, CA 90013
Attorneys for Plaintiff the People of the State of California
SUPERIOR COURT OF THE STATE OF CALIFORNIACOUNTY OF LOS ANGELES
P
EOPLE OF THE
S
TATE OF
C
ALIFORNIA
,
Plaintiff,
v.U
NITED
F
IRST
, I
NC
., A N
EVADACORPORATION
; MW R
OTH
, PLC;
A
C
ALIFORNIA CORPORATION
; P
AUL
N
OE
,
ANINDIVIDUAL
; M
ITCHELL
R
OTH
,
ANINDIVIDUAL
;
AND
D
OES
1-100,
Defendants.CASE NO.:
COMPLAINT FOR RESTITUTION,CIVIL PENALTIES, AND EQUITABLERELIEF
COMPLAINTPlaintiff, the People of the State of California, by and through Edmund G. Brown Jr.,Attorney General of the State of California, alleges the following, on information and belief:1. This action is brought against Defendants, who regularly violate California lawwhile preying on consumers facing foreclosure and the loss of their homes. In the course of theirelaborate foreclosure rescue fraud scheme, Defendants have unlawfully and unconscionablycharged thousands of dollars in fees to at least 2,000 California consumers, while falsely
1
COMPLAINT FOR RESTITUTION, CIVIL PENALTIES, AND EQUITABLE RELIEF
http://ag.ca.gov/cms_attachments/press/pdfs/n1979_roth_complaint.pdf
12345678910111213141516171819202122232425262728promising to help their victims eliminate mortgages on their homes and improve their credit.Despite taking thousands of dollars in upfront and monthly fees, defendants provided little or noassistance to consumers, often abandoning claims they promised to bring on their behalf.2. In addition to requiring consumers to pay excessive initial and monthly fees,defendants force homeowners to sign unconscionable contracts that purport to obligate victims of their scheme to add defendants as beneficiaries to their property insurance and pay up to 80% of the value of their home to defendants if their legal claims are successful.3. Thousands of California consumers have fallen prey to Defendants’ unlawfulscam, losing thousands of dollars they could have used either to save their homes fromforeclosure or to find new housing. In this action, Plaintiff seeks an order permanently enjoiningDefendants from engaging in their unlawful business practices, granting restitution for affectedconsumers, imposing civil penalties, and granting all other relief provided for under Californialaw.I. DEFENDANTS AND VENUE4. At all relevant times, defendant United First, Inc. (United First), a Nevadacorporation, has transacted and continues to transact business throughout the California, includingin Los Angeles County. United First is not a law corporation and is not licensed as a real estatebroker or as an entity authorized to make loans or extensions of credit.5. At all relevant times, defendant MW Roth PLC (Roth Firm), a Californiacorporation, has transacted and continues to transact business throughout the California, includingin Los Angeles County.6. At all relevant times, defendant Paul Noe (Noe) was president of United First.Defendant Noe took part in, directed, authorized, and ratified the conduct of United Firstdescribed in this Complaint. Defendant Noe is not an attorney, and is not licensed as a real estatebroker or person authorized to make loans or extensions of credit.7. At all relevant times, defendant Mitchell Roth (Roth) was the principal attorney of the Roth Firm. Defendant Roth took part in, directed, authorized, and ratified the conduct of theRoth Firm described in this Complaint.
2
COMPLAINT FOR RESTITUTION, CIVIL PENALTIES, AND EQUITABLE RELIEF
123456789101112131415161718192021222324252627288. Plaintiff is not aware of the true names and capacities of the defendants sued asDoes 1 through 100, inclusive, and therefore sues these defendants by such fictitious names.Each of these fictitiously named defendants is responsible in some manner for the activitiesalleged in this Complaint. Plaintiff will amend this Complaint to add the true names of thefictitiously named defendants once they are discovered.9. The defendants identified in paragraphs 4 through 8, above, shall be referred tocollectively as “Defendants.”10. Whenever reference is made in this Complaint to any act of any defendant(s), thatallegation shall mean that each defendant acted individually and jointly with the other defendants.11. Any allegation about acts of any corporate or other business defendant means thatthe corporation or other business did the acts alleged through its officers, directors, employees,agents and/or representatives while they were acting within the actual or ostensible scope of theirauthority.12. Each defendant committed the acts, caused or directed others to commit the acts,or permitted others to commit the acts alleged in this Complaint. Additionally, some or all of thedefendants acted as the agent of the other defendants, and all of the defendants acted within thescope of their agency if acting as an agent of another.13. Each defendant knew or realized that the other defendants were engaging in orplanned to engage in the violations of law alleged in this Complaint. Knowing or realizing thatother defendants were engaging in or planning to engage in unlawful conduct, each defendantnevertheless facilitated the commission of those unlawful acts. Each defendant intended to anddid encourage, facilitate, or assist in the commission of the unlawful acts, and thereby aided andabetted the other defendants in the unlawful conduct.14. Defendants have engaged in a conspiracy, common enterprise, and commoncourse of conduct, the purpose of which is and was to engage in the violations of law alleged inthis Complaint. This conspiracy, common enterprise, and common course of conduct continuesto the present.15. The violations of law alleged in this Complaint occurred in Los Angeles County
3
COMPLAINT FOR RESTITUTION, CIVIL PENALTIES, AND EQUITABLE RELIEF
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Brown v United First, Roth, Noe et al, CA Superior Ct, Cnty of LA, BC 417194 COMPLAINT Re Mortgage Restitution Scam
Resulted in $1M judgment and permanent injunction
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