against real property located in the County of Denver at all times relevantto this matter.6.
Plaintiff and Defendant had previously been friends for several years.7.
Plaintiff had met Defendant through business interactions andsubsequently developed a long-lasting friendship.FIRST CAUSE OF ACTION -USURY 8.
Plaintiff would incorporate by reference paragraphs 1 through 7 as setforth above.9.
During the course of that friendship, Defendant lent Plaintiff a sum of money at the interest rate of forty-eight percent (48%) interest.10.
The Colorado usury laws make it illegal and unlawful for any loan toexceed an interest rate of forty-five percent (45%).11.
Defendant secured that loan with an interest rate of forty-eight percent(48%) by filing a lien on a couple of Plaintiff’s parcels of real property between the time of the loan in 2006 and 2012.12.
Defendant only released the lien on one of Plaintiff’s properties secured by the promissory note with the forty-right percent (48%) rate of interestwithin the first few months of 2012.13.
Plaintiff contends that Defendant knew of or should have known of Colorado’s rather liberal usury statute that set the maximum amount of interest that could be charged on any loan at forty-five percent (45%).14.
Prior to the loan at the rate of forty-eight percent (48%), Defendant made aseries of high interest loans to Plaintiff at the interest rate of thirty-two percent (32%).15.
Defendant secured those loans by filing those promissory notes secured bydeeds of trust against Plaintiff’s commercial and residential property in theCity and County of Denver and in Arapahoe County, Colorado.16.
Throughout the course of several years, Defendant was able to obtain payments of interest on a loan that exceeded the usury laws of the State oColorado.17.
As a result of Defendant’s conduct, Plaintiff suffered economic damages.