44D01-2303-PL-000007 Filed: 3/27/2023 3:09 PM

Clerk
LaGrange Superior Court LaGrange County, Indiana

STATE OF INDIANA
IN THE LAGRANGE COUNTY SUPERIOR/CIRCUIT COURT

CAUSE NO. ________________________

STATE OF INDIANA,

Plaintiff,
COMPLAINT
v.
FOR INJUNCTION,
FLEXIBLE AUTO SALES LLC RESTITUTION, TREBLE
DAMAGES, CIVIL PENALTIES,
and
AND COSTS
JOHN ALLEN, individually and
doing business as FLEXIBLE AUTO
SALES LLC,

Defendants.

I. INTRODUCTION

1. The State of Indiana, by Attorney General Theodore E. Rokita and Deputy

Attorneys General Mark M. Snodgrass and Steven A. Taterka, commences

this civil action under the Indiana Deceptive Consumer Sales Act, Indiana

Code § 24-5-0.5-1 et seq., the Indiana Odometer Act, Ind. Code § 9-19-9-1 et

seq., the Federal Odometer Act, 49 U.S.C.A. § 32701 et seq., and the Motor

Vehicle Unfair Practices Act, Ind. Code § 9-32-13 et seq., for injunctive relief,

consumer restitution, treble damages, civil penalties, costs, and other relief.

2. The Defendant, Flexible Auto Sales LLC, owned and operated by John Allen,

tampered with and altered the odometers on at least 42 motor vehicles by

rolling back the odometer mileage readings in order to deceive purchasing

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 consumers. Flexible Auto Sales LLC and John Allen purchased the vehicles

mainly from various auto auctions. The auto auctions reported each vehicles’

mileage to vehicle history reporting services and provided Flexible Auto Sales

LLC with odometer disclosure statements and titles for each vehicle.

Between the time Flexible Auto Sales LLC purchased the affected vehicles

from the auctions and the time Flexible Auto Sales LLC sold the vehicles to

Indiana consumers, the mileage reading on each vehicle was significantly

reduced. Flexible Auto Sales altered, or caused to be altered, the vehicles’

odometers to lower the mileage readings on each of the vehicles’ odometers.

Flexible Auto Sales LLC also falsified mileage readings on documents such as

odometer disclosure statements and vehicle titles in an attempt to deceive

purchasing consumers and investigators. In total, Flexible Auto Sales rolled

back odometers by a combined total of over three million miles on the known

vehicles. Flexible Auto Sales LLC and John Allen’s misrepresentations and

actions are unfair, abusive, and deceptive, and constitute violations of

Indiana’s Deceptive Consumer Sales Act, Indiana’s Odometer Act, the

Federal Odometer Act, and the Indiana’s Motor Vehicle Unfair Practices Act

II. PARTIES

3. The plaintiff, the State of Indiana, is authorized to bring this action and to

seek injunctive and other statutory relief under Ind. Code § 24-5-0.5-4(c) and

49 U.S.C. § 32709(d).

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4. Defendant Flexible Auto Sales LLC is an Indiana limited liability company

engaged in the sale of used motor vehicles to Indiana consumers, with a

principal place of business in LaGrange County, located at 0805 North State

Road 5, Shipshewana, Indiana 46565.

5. Defendant John Allen is an individual engaged in the sale of used motor

vehicles to Indiana consumers under the business name Flexible Auto Sales

LLC, with a principal place of business in LaGrange County, located at 0805

North State Road 5, Shipshewana, Indiana 46565.

6. John Allen controlled and directed the affairs of Flexible Auto Sales LLC at

the time of the transactions identified in this Complaint and was active in its

management and operation, including its purchase of inventory at auction,

advertising, sales, and other practices. John Allen used Flexible Auto Sales

LLC to deceive Indiana consumers.

7. Flexible Auto Sales LLC and John Allen will collectively be referred to as

“Flexible Auto Sales” throughout the remainder of this Complaint, unless

otherwise individually referenced.

III. FACTS

8. The table below identifies the vehicles Flexible Auto Sales sold to specific

Indiana consumers, the mileage of each vehicle at the time of acquisition by

Flexible Auto Sales (“Flexible Acquisition Mileage”), the approximate mileage

of each vehicle at the time of Flexible Auto Sales’ sale of the vehicle to each

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 consumer (“Sale to Consumer Mileage”), as well as the date of the sale of the

vehicle to each consumer (“Date of Sale to Consumer”):

Flexible Sale to Date of

Purchasing Consumer Vehicle Year, Make, Acquisition Consumer Sale to
Model, VIN Mileage Mileage Consumer

8.1. Michael Strater 2000 Chevrolet Silverado; 305,275 213,814 6/11/2018

VIN 1GCEK19T8YE394560

8.2. Matthew Wengerd 2004 Dodge Ram 1500; 229,139 146,000 4/15/2019
VIN 1D7HU18D44J263215

8.3. Gary Fry 2005 GMC Yukon; 231,591 131,591 8/15/2019

VIN 1GKEK63U45J104790

8.4. Kari Hiochstetler 2002 Ford Escape; 231,938 131,939 9/26/2019

VIN 1FMYU041X2KB03374

8.5. Manuel Grandos 2004 Chevrolet Avalanche; 217,990 140,980 11/18/2019

VIN 3GNEK12T14G339713

8.6. Anglea Charles 2005 Chevrolet Silverado; 228,270 139,146 2/3/2020

VIN 2GCEK13T751203202

8.7. Tommy Haviland Jr. 2006 Chevrolet Trailblazer; 195,084 150,178 2/22/2020
VIN 1GNET16M466130034

8.8. Ryan Schwartz 2002 Chevrolet Silverado; 329,786 202,690 5/8/2020

VIN 1GCJK39112E143671

8.9. Brian & Erica Branton 2006 Chevrolet Trailblazer; 204,685 143,031 5/18/2020
VIN 1GNDT13S462203344

8.10. Neil Miller 2008 Chevrolet Express; 258,354 178,362 6/4/2020

VIN 1GAGG25K781152825

8.11. Amber Easin 2006 Hummer H2; 182,785 142,785 6/24/2020

VIN 5GRGN22UX6H106007

8.12. Larry Schlabach 2007 GMC Yukon; 227,363 172,554 7/23/2020

VIN 1GKFK63897J389111

8.13. Brittany Thompson 2007 Chevrolet Suburban 229,160 175,910 8/5/2020

VIN 3GNFK16337G320888

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8.14. Caleb Detweiler 2002 Jeep Liberty; 168,340 144,340 12/2/2020
VIN 1J4GL58K32W284436

8.15. Frankie Malerba 2002 Jeep Liberty; 168,340 144,340 Unknown

VIN 1J4GL58K32W284436

8.16. Anthony Yoder 2011 Chevrolet Cruz; 174,652 142,652 12/3/2020

VIN 1G1PG5S92B7192463

8.17. Paul Simpson 2008 Chevrolet Tahoe; 240,732 141,932 1/16/2021

VIN 1GNFK13088R235282

8.18. Jerry Miller 2011 Chevrolet Cruz; 189,089 133,089 2/25/2021

VIN 1G1PH5S9XB7196001

8.19. Audreona Cortes 2011 GMC Acadia; 197,318 144,057 3/16/2021

VIN 1GKKRRED7BJ168220

8.20. Andrew & Tonya Cox 2007 GMC Yukon; 210,290 140,290 3/20/2021
VIN 1GKFK163X7J153795

8.21. Brian Schrock 2008 Ford Focus; 276,459 71,211 3/26/2021

VIN 1FAHP32N68W282328

8.22. Kristina Metheny 2008 Ford Focus; 276,459 71,211 Unknown

VIN 1FAHP32N68W282328

8.23. Daryl Miller 2010 GMC Yukon; 262,582 162,302 3/31/2021

VIN 1GKUKMEF1AR177755

8.24. Michael Clemens 2010 Dodge Ram; 199,848 159,848 4/6/2021

VIN 3D7UT2CL8AG127320

8.25. Chris Shafer 2009 Chevrolet Silverado; 237,336 180,014 4/7/2021

VIN 3GCEK23MX9G249697

8.26. Racheal Mishler 2012 Chevrolet Cruz; 167,318 137,318 5/3/2021

VIN 1G1PF5SCXC7105313

8.27. Matthew Koontz 2008 GMC Sierra; 187,139 162,396 6/7/2021

VIN 3GTEK13JX8G239427

8.28. Lucy Griffith 2009 Mercury Mariner; 218,549 150,541 6/10/2021

VIN 4M2CU97GX9KJ22515
8.29. James Rosen Jr. 2011 GMC Acadia; 186,810 136,810 6/14/2021
VIN 1GKKVRED9BJ280061

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8.30. Oran Miller 2007 Pontiac Torrent; 176,026 129,026 6/19/2021
VIN 2CKDL73F576097059

8.31. Micah Kemp 2007 Chrysler 300; 169,990 130,990 6/28/2021

VIN 2C3KA53G37H851926

8.32. David Miller 2007 Chevrolet Yukon; 246,456 146,256 7/23/2021

VIN 1GKFK66807J280936

8.33. Aaron Miller 2008 Chevrolet Malibu; 193,692 133,692 8/2/2021

VIN 1G1ZK577X8F155111

8.34. Tammy Anteau 2011 Ford Escape; 166,993 136,993 8/16/2021

VIN 1FMCU9D79BKB91823

8.35. Jose Tomas Resinos 2005 Chevrolet Trailblazer; 240,498 140,499 8/20/2021
VIN 1GNDT13SX52268908

8.36. Chloe Bontrager 2011 Chevrolet Cruz; 176,242 125,242 9/2/2021

VIN 1G1PF5S92B7188822

8.37. Ranulfo Mejia 2011 GMC Acadia; 171,189 121,189 9/11/2021

VIN 1GKKRRED3BJ206591

8.38. Jason Yoder 2008 Chevrolet Silverado; 224,954 124,954 9/23/2021

VIN 1GCEK19058Z139931

8.39. Thomas Eichner 2007 Chevrolet Silverado; 244,046 144,258 10/8/2021

VIN 2GCEK13M671694826

8.40. Jamie Penrod 2011 Chevrolet Equinox; 160,688 132,000 10/8/2021

VIN 2CNALFEC4B6261770

8.41. Jason Yoder 2011 Chevrolet Cruz; 212,072 112,072 2/8/2022

VIN 1G1PH5S9XB7300826

8.42. Caleb Yater 2011 Chrysler 200; 211,192 111,192 3/23/2022

VIN 1C3BC8FG0BN600949

9. Flexible Auto Sales acquired its inventory from multiple sources, including

Greater Mishawaka Auto Auction (“GMAA”), Indiana Auto Auction (“IAA”),

and Greater Kalamazoo Auto Auction (“GKAA”).

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10. Prior to selling a vehicle, GMAA, IAA and GKAA visually inspect each

vehicle’s odometer reading, report each vehicle’s odometer reading to

Autocheck (a vehicle history provider), and prepare an odometer disclosure

statement that is provided to the buyer.

11. Flexible Auto Sales received an odometer disclosure statement for each

vehicle identified in Paragraph 8 specifying the vehicle’s odometer reading at

the time of acquisition by Flexible Auto Sales. The mileage of each vehicle at

the time it was purchased by Flexible Auto Sales is referenced in the

“Acquisition Mileage” column in Paragraph 8 above.

12. Flexible Auto Sales altered, or caused to be altered, the odometer of each

vehicle referenced in Paragraph 8 prior to selling each vehicle to the

respective purchasing consumer.

13. As a result, when each vehicle was sold by Flexible Auto Sales, the odometer

on each vehicle referenced in Paragraph 8 listed a significantly lower mileage

than when Flexible Auto Sales acquired the vehicle. The odometers on each

vehicle listed a significantly lower mileage than the vehicle had actually

traveled. The approximate altered mileage of each vehicle at the time it was

sold by Flexible Auto Sales to a consumer is referenced in the “Sale to

Consumer Mileage” column in Paragraph 8 above.

14. Flexible Auto Sales represented or implied in advertisements and to

purchasing consumers referenced in Paragraph 8 that the altered, lower, and

incorrect mileage of each vehicle was the true mileage of the vehicle.

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15. Flexible Auto Sales altered vehicle mileage listings on documents, such as

titles, for vehicles referenced in Paragraph 8 and provided such altered

documents to purchasing consumers.

16. The purchasing consumers referenced in Paragraph 8 were not aware of the

true mileage of each vehicle at the time of the consumers’ respective purchase

dates.

17. The Plaintiff issued Civil Investigative Demands 22-062 and 23-005 to

Flexible Auto Sales LLC to investigate this matter.

18. In response to Civil Investigative Demands 22-062 and 23-005, Flexible Auto

Sales provided various documents to the Plaintiff. John Allen, signing on

behalf of Flexible Auto Sales, verified under oath that the documents

provided were true and accurate copies.

19. The documents provided by Flexible Auto Sales had been tampered with and

the mileage numbers on the documents for the vehicles referenced in

Paragraph 8 were lowered to match the rolled back odometers.

20. Flexible Auto Sales provided the Plaintiff with purported copies of the

odometer disclosure statements it received from GMAA, IAA and GKAA for

the vehicles referenced in Paragraph 8. The Plaintiff also obtained odometer

disclosure statements for the same vehicles directly from GMAA, IAA and

GKAA. The mileage readings on the GMAA/IAA/GKAA odometer disclosure

statements provided by Flexible Auto Sales all have significantly lower

vehicle mileage readings than the GMAA/IAA/GKAA odometer disclosure

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 statements obtained by the Plaintiff directly from GMAA, IAA and GKAA.

Vehicle titles provided by Flexible Auto Sales were similarly altered to lower

the mileage references.

21. While all the vehicles referenced in Paragraph 8 share a substantially similar

fact pattern, for illustrative purposes the following is specific example of the

documents and facts for the vehicle referenced in Paragraph 8.33:

21.1. Flexible Auto Sales purchased the 2008 Malibu from GMAA on

7/21/2021. At that time, GMAA provided an odometer disclosure

statement for the 2008 Malibu to Flexible Auto Sales representing

the 2008 Malibu’s mileage as 193,962:

21.2. Flexible Auto Sales provided a copy of the GMAA odometer

disclosure statement for the 2008 Malibu to the Plaintiff in

response to Civil Investigative Demand 22-062. Flexible Auto

Sales’ version of the odometer disclosure statement is identical to

the original provided by GMAA except the mileage has been

changed from 193,962 to 133,962 by altering a “9” to a “3”:

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21.3. Similarly, GMAA provided Flexible Auto Sales with a title to the

2008 Malibu. In two locations on the title, the mileage for the 2008

Malibu was listed as 193,961 and 193,962, respectively:

21.4. Flexible Auto Sales provided a copy of the title for the 2008 Malibu

to the Plaintiff in response to Civil Investigative Demand 22-062.

The title is identical to the original provided by GMAA except, as

with the odometer disclosure statement, the mileage has been

changed in two places from 193,961 to 133,961 and 193,962 to

133,962 by modifying the “9s” to “3s”:

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21.5. The Carfax report for the 2008 Malibu shows GMAA reported a

mileage of 193,962 the day of the acquisition by Flexible Auto

Sales, a mileage which matches both the odometer disclosure

statement and title provided by GMAA:

21.6. The next reported mileage on the Carfax report for the 2008

Malibu comes several months after the sale of the vehicle by

Flexible Auto Sales. The mileage was reported as 139,842,

indicating Flexible rolled back the mileage to 133,962 several

months prior and altered the title and odometer disclosure

statement to reflect its deception:

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22. Flexible Auto Sales’ tampering with odometers and altering documents such

as odometer disclosure statements and titles constitutes fraudulent

concealment under Ind. Code § 34-11-5-1.

23. Flexible Auto Sales knowingly committed the actions described in this

Complaint.

IV. CAUSES OF ACTION

COUNT I:
VIOLATIONS OF THE DECEPTIVE CONSUMER SALES ACT-
MISREPRESENTING THE MILEAGE OF MOTOR VEHICLES

24. The State realleges Paragraphs 1 through 23 this Complaint.

25. Flexible Auto Sales regularly engages in “consumer transactions” under Ind.

Code § 24-5-0.5-2(a)(1).

26. Flexible Auto Sales is a “supplier” under Ind. Code § 24-5-0.5-2(a)(3).

27. Flexible Auto Sales committed unfair and deceptive acts, omissions, and

practices violating Ind. Code § 24-5-0.5-3(a) by misrepresenting the mileage

on motor vehicles to consumers in advertisements, verbally, and on

documents.

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 COUNT II:
VIOLATIONS OF THE FEDERAL ODOMETER ACT- MISREPRESENTING THE
MILEAGE OF MOTOR VEHICLES

28. The State realleges Paragraphs 1 through 27 of this Complaint.

29. Flexible Auto Sales, with intent to defraud, misrepresented the mileage on

motor vehicles to consumers in advertisements, verbally, and on documents,

in violation of 49 U.S.C.A. § 32705(a)(2).

COUNT III:
VIOLATIONS OF THE INDIANA ODOMETER ACT- MISREPRESENTING THE
MILEAGE OF MOTOR VEHICLES

30. The State realleges Paragraphs 1 through 29 of this Complaint.

31. Flexible Auto Sales committed unfair and deceptive acts, omissions, and

practices violating Ind. Code § 9-19-9-7 by misrepresenting the mileage on

motor vehicles to consumers in advertisements, verbally, and on documents

in violation of 49 U.S.C.A. § 32705(a)(2).

COUNT IV:
VIOLATIONS OF THE DECEPTIVE CONSUMER SALES ACT- ALTERING
ODOMETERS

32. The State realleges Paragraphs 1 through 31 of this Complaint.

33. Flexible Auto Sales committed unfair and deceptive acts, omissions, and

practices violating Ind. Code § 24-5-0.5-3(a) by altering, or causing to be

altered, the odometers of motor vehicles.

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 COUNT V:
VIOLATIONS OF THE FEDERAL ODOMETER ACT- ALTERING ODOMETERS

34. The State realleges Paragraphs 1 through 33 of this Complaint.

35. Flexible Auto Sales, with intent to defraud, altered odometers on motor

vehicles with the intent to change the mileages thereon, in violation of 49

U.S.C.A. § 32703(2).

COUNT VI:
VIOLATIONS OF THE INDIANA ODOMETER ACT- ALTERING ODOMETERS

36. The State realleges Paragraphs 1 through 35 of this Complaint.

37. Flexible Auto Sales committed unfair and deceptive acts, omissions, and

practices violating Ind. Code § 9-19-9-7 by altering, or causing to be altered,

odometers on motor vehicles with intent to change the mileages thereon, in

violation of 49 U.S.C.A. § 32703(2).

COUNT VII:
VIOLATIONS OF THE DECEPTIVE CONSUMER SALES ACT- ALTERING
DOCUMENTS RELATED TO THE PURCHASE AND SALE OF A MOTOR
VEHICLE

38. The State realleges Paragraphs 1 through 37 of this Complaint.

39. Flexible Auto Sales committed unfair and deceptive acts, omissions, and

practices violating Ind. Code § 24-5-0.5-3(a) by falsifying the mileages on

documents related to the purchase and sale of a motor vehicles, including

auction receipts, odometer disclosure statements and titles.

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 COUNT VIII:
VIOLATIONS OF THE FEDERAL ODOMETER ACT- ALTERING DOCUMENTS
RELATED TO THE PURCHASE AND SALE OF A MOTOR VEHICLE

40. The State realleges Paragraphs 1 through 39 of this Complaint.

41. Flexible Auto Sales committed unfair and deceptive acts, omissions, and

practices violating 49 U.S.C.A. § 32705(a)(2) by falsifying the mileages on

documents related to the purchase and sale of motor vehicles, including

auction receipts, odometer disclosure statements and titles.

COUNT IX:
VIOLATIONS OF THE INDIANA ODOMETER ACT- ALTERING DOCUMENTS
RELATED TO THE PURCHASE AND SALE OF A MOTOR VEHICLE

42. The State realleges Paragraphs 1 through 41 of this Complaint.

43. Flexible Auto Sales committed unfair and deceptive acts, omissions, and

practices violating Ind. Code § 9-19-9-7 by falsifying the mileages on

documents related to the purchase and sale of motor vehicles, including

auction receipts, odometer disclosure statements and titles, in violation of by

violating 49 U.S.C.A. § 32705(a)(2).

COUNT X:
KNOWING VIOLATIONS OF THE DECEPTIVE CONSUMER SALES ACT

44. The State realleges Paragraphs 1 through 43 of this Complaint.

45. Flexible Auto Sales committed the unfair and deceptive acts asserted in this

Complaint with knowledge of their unfair and deceptive acts, subjecting

Flexible Auto Sales to penalties under Ind. Code § 24-5-0.5-4(g).

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 COUNT XI:
INCURABLE DECEPTIVE ACTS

46. The State realleges Paragraphs 1 through 45 of this Complaint.

47. The unfair and deceptive acts asserted in this Complaint are incurable

deceptive acts and were committed by Flexible Auto Sales as part of a

scheme, artifice, or device with intent to defraud or mislead, subjecting

Flexible Auto Sales to penalties under Ind. Code § 24-5-0.5-8.

COUNT XII:
VIOLATIONS OF THE MOTOR VEHICLE UNFAIR PRACTICES ACT

48. The State realleges Paragraphs 1 through 47 of this Complaint.

49. Flexible Auto Sales committed deceptive and unfair acts and practices

violating Ind. Code § 9-32-13-20 by misrepresenting the mileage on motor

vehicles to consumers in advertisements, verbally, and on documents, by

tampering with and/or altering the odometers on motor vehicles, and by

altering the mileage on documents related to the purchase and sale of motor

vehicles.

V. RELIEF

50. The State requests the Court enter judgment against the Defendants,

Flexible Auto Sales LLC and John Allen, for the relief described in

Paragraphs 51 through 58 of this Complaint.

51. The State seeks a permanent injunction, under Ind. Code § 24-5-0.5-4(c)(1)

and 49 U.S.C. § 32709(d)(1)(A), enjoining Flexible Auto Sales LLC and John

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 Allen, and the agents, representatives, employees, successors, and assigns of

each, from:

51.1. Tampering, altering, or causing to be altered, the odometer of a motor

vehicle;

51.2. falsifying the stated mileage of a motor vehicle on any documents

referencing the vehicle’s mileage;

51.3. making any misrepresentations regarding the mileage on a vehicle;

and

51.4. committing an unfair, abusive, or deceptive act, omission, or practice

in connection with a consumer transaction, in violation of Ind. Code §

24-5-0.5-3(a).

52. The State seeks consumer restitution, under Ind. Code § 24-5-0.5-4(c)(2) and

Ind. Code § 9-32-16-13(b)(2)(C), payable to the Office of the Attorney General,

for the benefit of the consumers referenced in Paragraph 8 in the amounts

each respective consumer paid for their vehicle.

53. The State seeks treble damages, under 49 U.S.C.A. § 32709(d)(1)(B) and 49

U.S.C.A. § 32710(a), in the amount of three (3) times the actual damages or

ten thousand dollars ($10,000), whichever is greater, for the benefit of each

consumer referenced in Paragraph 8 above, payable to the Office of the

Attorney General.

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54. The State seeks costs, under Ind. Code § 24-5-0.5-4(c)(4), awarding the Office

of the Attorney General its reasonable expenses incurred in the investigation

and prosecution of this action.

55. The State seeks civil penalties, under Ind. Code § 9-19-9-7, on Counts III, VI

and IX of this Complaint, for Flexible Auto Sales’ violations of the Indiana

Odometer Act, payable to the State of Indiana, in the amount of one

thousand, five hundred dollars ($1,500.00) per violation.

56. The State seeks civil penalties, under Ind. Code § 24-5-0.5-4(g), on Count X of

this Complaint, for Flexible Auto Sales’ knowing violations of Ind. Code § 24-

5-0.5-3(a), payable to the State of Indiana, in the amount of five thousand

dollars ($5,000.00) per violation.

57. The State seeks civil penalties, under Ind. Code § 24-5-0.5-8, on Count XI of

this Complaint, for Flexible Auto Sales’ incurable deceptive acts, payable to

the State of Indiana, in the amount of five hundred dollars ($500.00) per

violation.

58. The State seeks all other just and proper relief.

Respectfully submitted,

THEODORE E. ROKITA
Indiana Attorney General
Attorney No. 18857-49

By: /s/ Mark M. Snodgrass

Mark M. Snodgrass
Deputy Attorney General
Attorney No. 29495-49

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 Office of Attorney General
Indiana Government Center South
302 West Washington St., 5th Floor
Indianapolis, IN 46204
Telephone: (317) 234-6784
Fax: (317) 233-4393
[email protected]

By: /s/ Steven Taterka

Steven Taterka
Deputy Attorney General
Deputy Director,
Consumer Protection Division
Attorney Number 14160-49

Office of Attorney General

Indiana Government Center South
302 West Washington St., 5th Floor
Indianapolis, IN 46204
Telephone: (317) 232-0167
Fax: (317) 233-4393
[email protected]

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