Motion for Entry of Default in Geico County Mutual Insurance Company vs. Keanna De Keshia Jefferson,Eugene Chance Jefferson| Trellis.Law

On June 29, 2022 a Motion,Ex Parte was filed involving a dispute between Geico County Mutual Insurance Company, and Jefferson, Eugene Chance, Jefferson, Keanna De Keshia, for Consumer/Commerical Debt - Over $250,000 in the District Court of Montgomery County.

Preview
3110885.001 / EV1

CAUSE NUMBER: 22-06-08342

GEICO County Mutual Insurance )
Company )
)
Plaintiff, ) Montgomery County 457th District Court
)
v. ) Montgomery (TX) (339) County, Texas
)
Keanna De Keshia Jefferson, et al. )
)
Defendants

PLAINTIFF’S MOTION TO ENTER JUDGMENT AS TO DEFENDANT KEANNA DE
KESHIA JEFFERSON ONLY

TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES Plaintiff GEICO County Mutual Insurance Company, Movant
herein, and brings this Motion to Enter Judgment. In support hereof, Movant shows the
following:

A. Plaintiff sued Defendant Keanna De Keshia Jefferson for claims arising
from an automobile accident.
B. Defendant, although duly served with process, has failed to file an answer.
C. Plaintiff filed its Business Records Affidavit and supporting documentation
with the Court and served the same upon Defendant.
D. The Court has been presented with a default judgment in favor of Plaintiff,
GEICO County Mutual Insurance Company which is attached hereto and incorporated
as referenced as if set out in full.
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays this Court will GRANT
this motion and will enter judgment, attached hereto, in favor of Plaintiff, and for such
other and further relief that may be awarded at law or in equity.
Respectfully submitted:

/s/ Jared B. Hall
Jessica R. Lobes / SBN 24083405
Jared B. Hall / SBN: 24055615
Jehaan “Gigi” Mattar / SBN: 24092774
Smaranda Draghia / SBN: 24102962
5930 Royal Lane, Ste E #515
Dallas, TX 75230-3896s
800-870-5521
216-298-4495 [fax]
JLobes@Rathbonegroup.com
JHall@Rathbonegroup.com
GMattar@Rathbonegroup.com
SDraghia@Rathbonegroup.com
TX MDJ Docs Decl.Doc-20220131
3110885.001 / EV1

CAUSE NUMBER: 22-06-08342

GEICO County Mutual Insurance )
Company )
)
Plaintiff, ) Montgomery County 457th District Court
)
v. ) Montgomery (TX) (339) County, Texas
)
Keanna De Keshia Jefferson, et al. )
)
Defendants

CERTIFICATE OF LAST KNOWN MAILING ADDRESS

I certify that the last known mailing address of Defendant Keanna De Keshia
Jefferson against whom judgment is taken in the above-entitled and number cause is:

Keanna De Keshia Jefferson
2720 Montgomery Rd APT #148
Huntsville TX 77340-6016

/s/ Jared B. Hall

Jessica R. Lobes / SBN 24083405
Jared B. Hall / SBN: 24055615
Jehaan “Gigi” Mattar / SBN: 24092774
Smaranda Draghia / SBN: 24102962
5930 Royal Lane, Ste E #515
Dallas, TX 75230-3896
800-870-5521
216-298-4495 [fax]
JLobes@Rathbonegroup.com
JHall@Rathbonegroup.com
GMattar@Rathbonegroup.com
SDraghia@Rathbonegroup.com

TX MDJ Docs Decl.Doc-20220131
3110885.001 / EV1

CAUSE NUMBER: 22-06-08342

GEICO County Mutual Insurance )
Company )
)
Plaintiff, ) Montgomery County 457th District Court
)
v. ) Montgomery (TX) (339) County, Texas
)
Keanna De Keshia Jefferson, et al. )
)
Defendants

DECLARATION IN SUPPORT OF DEFAULT JUDGMENT

My name is Jared B. Hall. I am capable of making this declaration. I am over the
age of 21 and I am of sound mind. I am the attorney in charge of this case for the
Plaintiff. I have prepared and submitted the attached default judgment. The facts
stated within this declaration filed in support of the default judgment are within my
personal knowledge and are true and correct. The following facts are known to me:

1. Plaintiff, GEICO County Mutual Insurance Company, sued Defendant Keanna
De Keshia Jefferson for damages arising from an automobile accident;
2. Defendant was served on July 7, 2022 with Plaintiff's Petition.
3. Defendant has failed to file an answer in this court.
4. I, and other attorneys employed by Plaintiff's counsel's firm, have spent in
excess of 2.0 hours in preparing and filing the petition and summons,
following for serivce of process, and preparing this motion.
5. I am of the opinion that a fee award of $250.00 per hour, for a total award of
at least $500.00 is entirely reasonable in light of the novelty and difficulty of
the questions of law involved, the skill requisite to properly perform the legal
services called for herein, the fee customarily charged in this locality for
similar services, the amounts involved, and the experience, reputation, and
ability of me and the other attorneys at my firm who have performed the
services referenced above.

My name is Jared Hall, my date of birth is December 2, 1976, and my address is
5930 Royal Lane, Ste E #515 , Dallas, TX 75230-3896, USA. I declare under penalty of
perjury that the foregoing is true and correct.

Executed in Harris County, State of Texas, on the 2nd day of October 2022

/s/ Jared B. Hall
Jared B. Hall

TX MDJ Docs Decl.Doc-20220131
TX MDJ Docs Decl.Doc-20220131
3110885.001 / EV1

CAUSE NUMBER: 22-06-08342

GEICO County Mutual Insurance )
Company )
)
Plaintiff, ) Montgomery County 457th District Court
)
v. ) Montgomery (TX) (339) County, Texas
)
Keanna De Keshia Jefferson, et al. )
)
Defendants

MILITARY SERVICE DECLARATION IN SUPPORT OF DEFAULT JUDGMENT

My name is Jared B. Hall. I am capable of making this declaration. I am over the
age of 21 and I am of sound mind. I am the attorney in charge of this case for the Plaintiff.
I have prepared and submitted the attached default judgment. The facts stated within this
declaration filed in support of the default judgment are within my personal knowledge and
are true and correct. The following facts are known to me:

Defendant Keanna De Keshia Jefferson is not engaged in active military service.
As shown in the attached results of a military verification search of the Department of
Defense Manpower Data Center (DMDC) online database at https://scra.dmdc.osd.mil,
Defendant is not listed on active military service. Said report is incorporated by
reference into this affidavit.

My name is Jared Hall, my date of birth is December 2, 1976 , and my address is
5930 Royal Lane, Ste E #515, Dallas, TX 75230-3896, USA. I declare under penalty of
perjury that the foregoing is true and correct.

Executed in Harris County, State of Texas, on the 2nd day of October 2022

/s/ Jared B. Hall

Jared B. Hall

TX MDJ Docs Decl.Doc-20220131
Received and E-Filed for Record
9/1/2022 12:51 PM
Melisa Miller, District Clerk
Montgomery County, Texas
Deputy Clerk, Carrie Hoke
Police Report

TX Bus Records Decl.Doc-20220608
Payment Records

TX Bus Records Decl.Doc-20220608
Claim Number 0669959330000001
Pay To The Order Of Gwendolyn Elvira Vanhorne

Financials
Gross Amount $1,233.97
Net Amount $1,233.97
Backup Withholding $0.00

Payment Identification
Issued Date 07/07/2021
Mail To Name Gwendolyn Elvira Vanhorne
Mail To Address
Memo ERS - Collision

Payment Type System Check
Check Number 225393934

Related Documents
Document Name

Reserve Line Allocation

Exposure Reserve Line Cost Type Amount

Gwendolyn Elvira Casey - Collision (2017 CHEV) Collision Loss $12,065.16
Property Damage

TX Bus Records Decl.Doc-20220608
COPART AUTO AUCTIONS Date 9/01/21
1655 RANKIN ROAD
HOUSTON, TX 77073 Visit us at www.copart.com
PHONE (281) 214-7800 All Amounts are in USD
TAX ID#

FINAL INVOICE

Copart Lot# 49510361 11 TX - HOUSTON
Loss Date 6/27/21
Called In 7/02/21
P/U Cleared 7/07/21 GC45 PIP679A
Pickup Date 7/07/21 JACKIE DEASON
Original Title 7/09/21 GEICO CASUALTY COMPANY
Trans Title 8/11/21 P.O BOX 13528
Sale Document 8/19/21 MACON, GA 31208
Loss Type COLLISION
Description 17 CHEV CRUZE LT WHITE
Vehicle ID# Claim# 0669959330000001
License#/ST Policy# UNKNOWN
Mileage 131,070 Loss Code C
Pickup From TOMMY'S PAINT & BODY INC Reference#
203 N SANDRA ST Insured GWENDOLYN CASEY
CONROE, TX 77301 Owner GWENDOLYN CASEY
(936) 756-0022

ADVANCE CHARGES PAID BY COPART
TOW SERVICE . . . . . . . . . . . . . . 519.30
YARD/GATE . . . . . . . . . . . . . . . 100.00
STORAGE . . . . . . . . . . . . . . . . 440.00
TAX . . . . . . . . . . . . . . . . . . 36.30
-----------
TOTAL ADVANCE CHARGES . . . . . . . . . 1095.60

COPART SERVICE CHARGES
TITLE PROCESSING. . . . . . . . . . . . 8.00 PROCESSING FEE
PIP PROGRAM CHARGE. . . . . . . . . . . 90.00
-----------
TOTAL COPART SERVICE CHARGES. . . . . . 98.00

TOTAL DUE COPART . . . . . . . . . . . . . . 1193.60
PROCEEDS FROM SALE . . . . . . . . . . . . . 3850.00CR *Bid Raised By Internet*
PREVIOUS PAYMENTS FROM COPART. . . . . . . . 2656.40
------------
NET DUE COPART . . . . . . . . . . . . . . . .00

COPART PAYMENTS DETAIL
COPART CHECK# 15189512 08/31/21 2,656.40
SALE INFORMATION

Lot# 49510361 Sold To 823881 ZACATEX EXPORTS
Sale Date 8/27/21 5506 HARRISBURG BLVD
Sale Amount 3850.00 HOUSTON, TX 77011
ACV 13772.13 (832) 941-9174
Repair Es11147.88
Return 27.9% Item# 10 Invoice Date 8/31/21
Cert# 29730044422250274 Invoice Amount .00 USD
Payment From Buyer 8/30/21 REMIT TO: COPART
Reported To NICB 8/30/21 4610 WESTAMERICA DRIVE
FAIRFIELD, CA 94534
Date July 2, 2021
Accident Date June 27, 2021
Claim Number 066995933 0000 001
Company GEICO County Mutual Insurance Company
Vehicle 2017 CHEV Cruze LT w/1SD Equip Pkg
VIN

Dear: Gwendolyn Casey,

This is a brief explanation of your claim settlement:

Base Value $12,962.00
Condition Adjustment $0.00
Pre Tax Adjustment $0.00
Tax $810.13
_____________________________

Total Value $13,772.13
State and Local Regulatory Fees $28.00
Post Tax Adjustment $0.00
Less Deductible $501.00
Less Percent Negligent 0% $0.00
Less Retention Amount $0.00
_____________________________

Net Settlement Amount $13,299.13
Towing Charges $0.00
Storage Charges $0.00

State law requires that owners of total loss or salvage motor vehicles apply for a salvage certificate within 10
days after a total loss settlement.
Does Apply Does Not Apply

Any state sales tax due the owner through replacement of the vehicle will be considered when notice is given
and purchase invoice presented.
Does Apply Does Not Apply

Adjuster Matthew St Amour Telephone No. 936-714-4393

Customer’s Signature _____________________________________________________

CL-30 (10-13)
GEICO
Houston
Request a supplement at:
PARTNERS.GEICO.COM
21420 Merchants Way
Katy, TX 77449
Phone: (936) 714-4393 Claim #: 0669959330000001-01
Fax: (855) 420-6510 Workfile ID: 4cce0c03

Estimate of Record

Written By: MATTHEW ST. AMOUR, 7/2/2021 12:58:27 PM
Adjuster: CBG2

Insured: Gwendolyn Casey Owner Policy #: Claim #: 0669959330000001-01
Type of Loss: Collision Date of Loss: 06/27/2021 12:06 PM Days to Repair: 5
Point of Impact: 08 Left Qtr Post Deductible: 501.00
(Left Side)

Owner (Insured): Inspection Location: Appraiser Information: Repair Facility:
Gwendolyn Casey Tommy's paint and body Mstamour@geico.com TOTAL LOSS
Tommy's paint and body (936) 714-4393
203 N Sandra St
Conroe, TX 77301
Field

VEHICLE

2017 CHEV Cruze LT w/1SD Equip Pkg 4D SED 4-1.4L Turbocharged Gasoline Direct Injection Summit White

VIN: Production Date: 11/2016 Interior Color: Jet Black
License: Odometer: 131070 Exterior Color: Summit White
State: TX Condition:

TRANSMISSION TELESCOPIC WHEEL SEARCH/SEEK ANTI-LOCK BRAKES (4)
AUTOMATIC TRANSMISSION STEERING WHEEL TOUCH AUXILIARY AUDIO CONNECTION GLASS & MIRRORS
CONTROLS
DRIVER CONVENIENCE CONSOLE/STORAGE SATELLITE RADIO DUAL MIRRORS
KEYLESS ENTRY INSTRUMENT PANEL SAFETY SEATS
REMOTE STARTER TRACTION CONTROL DRIVERS SIDE AIR BAG CLOTH SEATS
MESSAGE CENTER STABILITY CONTROL PASSENGER AIR BAG BUCKET SEATS
POWER DRIVER SEAT ALARM FRONT SIDE IMPACT AIR BAGS RECLINING/LOUNGE SEATS
POWER WINDOWS AIR CONDITIONING HEAD/CURTAIN AIR BAGS HEATED SEATS
POWER LOCKS REAR DEFOGGER REAR SIDE IMPACT AIR BAGS REAR END
POWER MIRRORS HANDS FREE DEVICE PAINT BACKUP CAMERA
HEATED MIRRORS COMMUNICATION SYSTEM CLEARCOAT PAINT WHEELS
POWER TRUNK/LIFTGATE RADIO FRONT END 4-WHEEL DISC BRAKES
CRUISE CONTROL AM RADIO XENON OR L.E.D. HEADLAMPS ALUMINUM/ALLOY WHEELS
INTERMITTENT WIPERS FM RADIO POWER STEERING
TILT WHEEL STEREO POWER BRAKES

7/2/2021 12:58:29 PM 117200 | 1.8.04.03050 Page 1
Claim #: 0669959330000001-01
Workfile ID: 4cce0c03
Estimate of Record

2017 CHEV Cruze LT w/1SD Equip Pkg 4D SED 4-1.4L Turbocharged Gasoline Direct Injection Summit White

Line Oper Description Part Number Qty Extended Labor Paint
Price $
TOW BILL FOR 219.30 & 300.00
PAID SEPERATE
Refn Car Cover 0.2
Subl Flex Additive 5.00
Restore Corrosion Protection 10.00 X 0.2
RESTRAINT SYSTEMS
Repl Driver air bag black 39090515 799.50 m 0.7 M
Air bag system diagnosis 0.5 M
Repl RT Head air bag sedan 39058599 831.48 m 0.9 M
Repl LT Head air bag sedan 39058600 831.48 m 0.9 M
10 Repl LT Ft seat air bag 13369904 831.48 m 0.3 M
11 Repl LT Knee air bag 39066823 831.48 m 0.4 M
12 Repl Air bag module 13520995 573.25 m 0.6 M
13 Repl RT Ft impact sensor 13504470 241.49 m 0.3 M
14 Repl LT Ft impact sensor 13504470 241.49 m 0.3 M
15 Repl LT Side impact sens front door 13576422 241.49 m 0.2 M
16 Repl LT Side impact sens lock pillar 13504470 241.49 m 0.2 M
17 Repl LT Seat belt assy black 19352254 171.52 0.5
18 SEATS & TRACKS
19 Repl Seat back cover w/o leather black 84193218 134.78 1.6
20 Repl Seat back pad 84136745 84.82
21 PILLARS, ROCKER & FLOOR
22 Sect LT Uniside assy w/o RS pkg 42673292 1,337.30 s 17.0 3.4
quarter panel
23 Add for Clear Coat 1.4
24 Deduct for Rear Bumper R&I -1.4
25 Blnd LT Roof Rail 1.0
26 SETUP & PULL 2.5
27 REAR DOOR
28 Blnd LT Outer panel 23279155 1.0
29 R&I LT Belt molding bright finish 84180439 0.2
30 R&I LT Handle, outside w/o passive 13506795 0.4
entry
31 R&I LT R&I trim panel 84178598 0.5
32 TRUNK LID
33 Blnd Trunk lid w/o spoiler 84209473 1.2
34 R&I Emblem w/o RS package 23401134 0.2
35 R&I Nameplate "CRUZE" w/o code 23368275 0.2
CG6
36 REAR BUMPER
37 O/H rear bumper 1.9
38 Repl Bumper cover w/o obstacle 19354103 475.95 Incl. 3.0
detection

7/2/2021 12:58:29 PM 117200 | 1.8.04.03050 Page 2
Claim #: 0669959330000001-01
Workfile ID: 4cce0c03
Estimate of Record

2017 CHEV Cruze LT w/1SD Equip Pkg 4D SED 4-1.4L Turbocharged Gasoline Direct Injection Summit White

39 Add for Clear Coat 1.2
40 Repl LT Side support 84142839 22.18 0.2
41 Repl LT Lower bracket 23422559 11.80 0.2
42 Repl Center support 84077172 46.70 0.3
43 OTHER CHARGES
44 E.P.C. 2.50
SUBTOTALS 7,967.18 29.8 12.4

NOTES

Prior Damage Notes:
rock chips on bumper/hood

ESTIMATE TOTALS
Category Basis Rate Cost $
Parts 7,954.68
Body Labor 24.5 hrs @ $ 46.00 /hr 1,127.00
Paint Labor 12.4 hrs @ $ 46.00 /hr 570.40
Mechanical Labor 5.3 hrs @ $ 75.00 /hr 397.50
Paint Supplies 12.4 hrs @ $ 32.00 /hr 396.80
Miscellaneous 10.00
Other Charges 2.50
Subtotal 10,458.88
Sales Tax $ 8,351.48 8.2500 % 689.00
Total Cost of Repairs 11,147.88
Deductible 501.00
Total Adjustments 501.00
Net Cost of Repairs 10,646.88

MyPriceLink Estimate ID / Quote ID:
840270259012247552 / 88771312

7/2/2021 12:58:29 PM 117200 | 1.8.04.03050 Page 3
Claim #: 0669959330000001-01
Workfile ID: 4cce0c03
Estimate of Record

2017 CHEV Cruze LT w/1SD Equip Pkg 4D SED 4-1.4L Turbocharged Gasoline Direct Injection Summit White

This is not an authorization to repair.

All GEICO customers have the right to have their vehicle repaired in the shop of their choice.

No Supplement will be honored unless authorized by GEICO.

NOTICE: Vehicles constructed of special metals may require the use of specialized welding and bonding equipment.
Proper measuring and structural repair systems are required on today's vehicle to accurately accomplish vehicle
repairs. Make sure your shop has the proper equipment to repair your vehicle.
ALTERNATE PARTS DISCLAIMER:
IF A QUALITY REPLACEMENT PART (A/M, LKQ, RECOND OR OPT OEM) APPEARS ON THIS ESTIMATE, IT INDICATES
THAT THIS ESTIMATE HAS BEEN PREPARED BASED ON THE USE OF ONE OR MORE CRASH PARTS SUPPLIED BY A
SOURCE OTHER THAN THE MANUFACTURER OF YOUR MOTOR VEHICLE. GUARANTEES, IF ANY, APPLICABLE TO
THESE REPLACEMENT CRASH PARTS ARE PROVIDED BY THE PART MANUFACTURER OR DISTRIBUTOR RATHER
THAN BY THE MANUFACTURER OF YOUR VEHICLE.

***IN ADDITION TO ANY SUCH GUARANTEES, GEICO PROVIDES THE FOLLOWING:
****OWNER LIMITED GUARANTEE**** WE GUARANTEE THAT ALL QUALITY REPLACEMENT BODY PARTS (PARTS
NOT MANUFACTURED BY THE MANUFACTURER) IDENTIFIED ON YOUR ESTIMATE, ARE FREE OF DEFECTS IN
MATERIAL AND WORKMANSHIP AND MEET GENERALLY ACCEPTED INDUSTRY STANDARDS. THIS PARTS AND
LABOR GUARANTEE WILL BE IN EFFECT FOR AS LONG AS YOU OWN THE VEHICLE DESCRIBED IN THE ESTIMATE.
THIS GUARANTEE COVERS THE COST OF THE PART, LABOR TO INSTALL, AND INCIDENTALS SUCH AS PAINT AND
MATERIALS AND IS SPECIFICALLY LIMITED TO THOSE ITEMS. THIS GUARANTEE DOES NOT COVER LOSS OR
DAMAGE THAT IS UNRELATED TO DEFECTS IN THE QUALITY REPLACEMENT PARTS. THIS IS NOT TRANSFERABLE.
IF ANY QUALITY REPLACEMENT PARTS ARE DEFECTIVE IN EITHER MATERIAL OR WORKMANSHIP, CONTACT YOUR
LOCAL GEICO REPRESENTATIVE.

7/2/2021 12:58:29 PM 117200 | 1.8.04.03050 Page 4
Claim #: 0669959330000001-01
Workfile ID: 4cce0c03
Estimate of Record

2017 CHEV Cruze LT w/1SD Equip Pkg 4D SED 4-1.4L Turbocharged Gasoline Direct Injection Summit White

Estimate based on MOTOR CRASH ESTIMATING GUIDE and potentially other third party sources of data. Unless
otherwise noted, (a) all items are derived from the Guide DR1CC16, CCC Data Date 06/16/2021, and potentially other
third party sources of data; and (b) the parts presented are OEM-parts. OEM parts are manufactured by or for the
vehicle's Original Equipment Manufacturer (OEM) according to OEM's specifications for U.S. distribution. OEM parts
are available at OE/Vehicle dealerships or the specified supplier. OPT OEM (Optional OEM) or ALT OEM (Alternative
OEM) parts are OEM parts that may be provided by or through alternate sources other than the OEM vehicle
dealerships with discounted pricing. Asterisk (*) or Double Asterisk (**) indicates that the parts and/or labor data
provided by third party sources of data may have been modified or may have come from an alternate data source.
Tilde sign (~) items indicate MOTOR Not-Included Labor operations. The symbol (<>) indicates the refinish
operation WILL NOT be performed as a separate procedure from the other panels in the estimate. Non-Original
Equipment Manufacturer aftermarket parts are described as Non OEM, A/M or NAGS. Used parts are described as
LKQ, RCY, or USED. Reconditioned parts are described as Recond. Recored parts are described as Recore. NAGS
Part Numbers and Benchmark Prices are provided by National Auto Glass Specifications. Labor operation times listed
on the line with the NAGS information are MOTOR suggested labor operation times. NAGS labor operation times are
not included. Pound sign (#) items indicate manual entries.

Some 2022 vehicles contain minor changes from the previous year. For those vehicles, prior to receiving updated
data from the vehicle manufacturer, labor and parts data from the previous year may be used. The CCC ONE
estimator has a list of applicable vehicles. Parts numbers and prices should be confirmed with the local dealership.

The following is a list of additional abbreviations or symbols that may be used to describe work to be done or parts to
be repaired or replaced:

SYMBOLS FOLLOWING PART PRICE:
m=MOTOR Mechanical component. s=MOTOR Structural component. T=Miscellaneous Taxed charge category.
X=Miscellaneous Non-Taxed charge category.

SYMBOLS FOLLOWING LABOR:
D=Diagnostic labor category. E=Electrical labor category. F=Frame labor category. G=Glass labor category.
M=Mechanical labor category. S=Structural labor category. (numbers) 1 through 4=User Defined Labor Categories.

OTHER SYMBOLS AND ABBREVIATIONS:
Adj.=Adjacent. Algn.=Align. ALU=Aluminum. A/M=Aftermarket part. Blnd=Blend. BOR=Boron steel.
CAPA=Certified Automotive Parts Association. D&R=Disconnect and Reconnect. HSS=High Strength Steel.
HYD=Hydroformed Steel. Incl.=Included. LKQ=Like Kind and Quality. LT=Left. MAG=Magnesium. Non-Adj.=Non
Adjacent. NSF=NSF International Certified Part. O/H=Overhaul. Qty=Quantity. Refn=Refinish. Repl=Replace.
R&I=Remove and Install. R&R=Remove and Replace. Rpr=Repair. RT=Right. SAS=Sandwiched Steel.
Sect=Section. Subl=Sublet. UHS=Ultra High Strength Steel. N=Note(s) associated with the estimate line.

CCC ONE Estimating - A product of CCC Intelligent Services Inc.

The following is a list of abbreviations that may be used in CCC ONE Estimating that are not part of the MOTOR
CRASH ESTIMATING GUIDE:
BAR=Bureau of Automotive Repair. EPA=Environmental Protection Agency. NHTSA= National Highway
Transportation and Safety Administration. PDR=Paintless Dent Repair. VIN=Vehicle Identification Number.

7/2/2021 12:58:29 PM 117200 | 1.8.04.03050 Page 5
Claim #: 0669959330000001-01
Workfile ID: 4cce0c03
Estimate of Record

2017 CHEV Cruze LT w/1SD Equip Pkg 4D SED 4-1.4L Turbocharged Gasoline Direct Injection Summit White

RECALL INFO

2017 CHEV Cruze LT w/1SD Equip Pkg 4D SED 4-1.4L Turbocharged Gasoline Direct Injection Summit White

VIN: Production Date: 11/2016 Interior Color: Jet Black
License: Odometer: 131070 Exterior Color: Summit White
State: TX Condition:

The National Highway Transportation and Safety Administration (NHTSA) has issued 1 safety-related recall notice(s) that may apply to the selected
vehicle.

NHTSA ID: 17V057000 Issued: Jan 1, 17 Number of Vehicles: 00017197

SEATS General Motors LLC (GM) is recalling certain 2016-2017 Chevrolet Cruze vehicles. A bracket used in the driver or front passenger seat-back
recliner mechanism may have been incorrectly welded to the seat-back frame, as a result, in the event of a crash, the head-restraints may not
function properly. As such, these vehicles fail to comply with the requirements of Federal Motor Vehicle Safety Standard (FMVSS) number 202a,
"Head Restraints." In a crash, the seat-backs for the front seats may break, increasing the risk of injury to the occupants. GM will notify owners,
and dealers will inspect the front passenger seats, replacing any with seat-back frames that are incorrectly welded, free of charge. The
manufacturer has not yet provided a notification schedule. Owners may contact Chevrolet customer service at 1-800-222-1020. GM''s number for
this recall is 17035.

7/2/2021 12:58:29 PM 117200 | 1.8.04.03050 Page 6

Case Info

Judge

Santini, Vincenzo J Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

October 03, 2022

Case Filing Date

June 29, 2022

County

Parties

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Motion,Ex Parte: Geico County Mutual Insurance Company vs. Keanna De Keshia Jefferson,Eugene Chance Jefferson

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Case Info

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