RICHARD LUCERO,
On behalf of himself and
All others similarly situated, Case No. :D-202-CV-2017-05833
Plaintiff,
vs.
CENTURYLINK, INC.
Defendant.
COMES NOW, Plaintiff, RICHARD LUCERO, on behalf of himself and all others
similarly situated, by and through the undersigned counsel, and files this Class Action Complaint
for Damages for Violation of the Unfair Practices Act against Defendant, CENTURYLINK,
INC., and in support shows the following:
I. INTRODUCTION
1. This is an action for actual and statutory damages brought by Plaintiff, Richard Lucero,
an individual consumer, on behalf of himself and all others similarly situated, against Defendant,
CenturyLink, Inc., for violation of the Unfair Practices Act ("UPA"), 57-12-1, et seq. which
prohibits businesses from engaging in deceptive or unfair practices.
2. Defendant conducts business in New Mexico.
II. PARTIES
2.
21. Excluded from the Class are (1) any judges or judicial officer assigned to this matter
and his or her immediate family and (2) the legal representatives, successors or assigns of any
3.
(b ). A class action is superior to other available methods for the fair and efficient
adjudication of the controversy.
34. Certification of a class under N.M.R.A. 1-023(B)(2) is also appropriate because
Defendant has acted on grounds generally applicable to the Class thereby making appropriate
declaratory relief with respect to the classes as a whole.
(2) Treble statutory damages pursuant to the UPA plus pre-judgment interest at 15%
thereon;
(6) For such other and further relief as the Court may deem just and proper.
"Electronically Filed"
4.