On April 22, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Campos, Haydee Cruz,
and
American Honda Motor Co., Inc.,
Does 1-10,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
Preview
KNIGHT LAW GROUP, LLP
Roger Kimos (SBN 283 1 63)
rogerk@knightlaw.com ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
Timothy Lupinek (SBN 334876) COUNTY OF SAN BERNARDINO
timothyl@knightlaw.com SAN BERNARDINO DISTRICT
10250 Constellation B1Vd., Suite 2500
11/8/2023 5:03 PM
KOOONONUl-hUJNr—A
Los Angeles, CA 90067
Telephone: (310) 552-2250 By: Amaris Morales Eumana, DEPUTY
Fax: (310) 552-7973
Attorneys for Plaintiff,
HAYDEE CRUZ CAMPOS
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
HAYDEE CRUZ CAMPOS Case No.: CIVSB2208274
’
Plaintiff,
Unlimited Jurisdiction
PLAINTIFF’S NOTICE OF MOTION
vs.
AND MOTION FOR LEAVE TO FILE
AMERICAN HONDA MOTOR CO., INC., AN AMENDED COMPLAINT;
a California Corporation, and DOES 1 MEMORANDUM OF POINTS AND
through 10, inclusive, AUTHORITIES
NNNNNNNNNHh—kr—Ar—AHh—kh—r—Ar—AH
[Submitted concurrently with the
Defendants. Declaration of Timothy Lupinek,
[Proposed] First Amended Complaint;
OONONMLUJNF—‘OKOOONONMLUJNF—‘O
[Proposed] Order.]
Hearing Date: March 5, 2024
Hearing Time: 8:30 am.
Department: S-27
Filed: April 22, 2022
Trial Date: November 27, 2023
PLAINTIFF’S MOTION FOR LEAVE TO AMEND
TO ALL PARTIES AND HIS ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that 0n March 5, 2024 at 8:30 am. in Department 827 of the
San Bernardino Superior Court, Historic Courthouse, located at the San Bernardino Justice
Center 247 West Third Street, San Bernardino, CA 92415, Plaintiff Haydee Cruz Campos
\OOOQONUI-RUJNr—t
(“Plaintiff’) will and hereby does move this Court for an order granting leave to file an amended
complaint, pursuant to Code of Civil Procedure, section 473, subdivision (a) and Code 0f Civil
Procedure, section 576 t0 add a cause of action for Violation of the Song-Beverly Act — Breach
of Express warranty because 0f newly discovered evidence obtained in the deposition of
Defendant’s person most qualified Witness, Which confirmed that the Subject Vehicle was
presented for sufficient repair presentations such to support a cause 0f action for breach 0f
express warranty.
This motion is based upon the Memorandum 0f Points and Authorities attached hereto, the
Declaration 0f Timothy Lupinek in Support 0f the Motion, the records on file in this action, and
upon such evidence, oral and documentary, Which may be presented at the hearing on this matter.
NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—K
Dated: November 8, 2023 KNIGHT LAW GROUP, LLP
’Wfiiw
OOQGUIAUJNHOKOOOQONMAUJNHO
Roger Kimos (SBN 283 1 63)
Timothy Lupinek (SBN 334876)
Attorneys for Plaintiff,
HAYDEE CRUZ CAMPOS
-1-
PLAINTIFF’S MOTION FOR LEAVE TO AMEND
Document Filed Date
November 08, 2023
Case Filing Date
April 22, 2022
Category
Breach of Contract/Warranty Unlimited
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KNIGHT LAW GROUP, LLP Roger Kimos (SBN 283 1 63) rogerk@knightlaw.com ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA Timothy Lupinek (SBN 334876) COUNTY OF SAN BERNARDINO timothyl@knightlaw.com SAN BERNARDINO DISTRICT 10250 Constellation B1Vd., Suite 2500 11/8/2023 5:03 PM KOOONONUl-hUJNr—A Los Angeles, CA 90067 Telephone: (310) 552-2250 By: Amaris Morales Eumana, DEPUTY Fax: (310) 552-7973 Attorneys for Plaintiff, HAYDEE CRUZ CAMPOS SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO HAYDEE CRUZ CAMPOS Case No.: CIVSB2208274 ’ Plaintiff, Unlimited Jurisdiction PLAINTIFF’S NOTICE OF MOTION vs. AND MOTION FOR LEAVE TO FILE AMERICAN HONDA MOTOR CO., INC., AN AMENDED COMPLAINT; a California Corporation, and DOES 1 MEMORANDUM OF POINTS AND through 10, inclusive, AUTHORITIES NNNNNNNNNHh—kr—Ar—AHh—kh—r—Ar—AH [Submitted concurrently with the Defendants. Declaration of Timothy Lupinek, [Proposed] First Amended Complaint; OONONMLUJNF—‘OKOOONONMLUJNF—‘O [Proposed] Order.] Hearing Date: March 5, 2024 Hearing Time: 8:30 am. Department: S-27 Filed: April 22, 2022 Trial Date: November 27, 2023 PLAINTIFF’S MOTION FOR LEAVE TO AMEND TO ALL PARTIES AND HIS ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that 0n March 5, 2024 at 8:30 am. in Department 827 of the San Bernardino Superior Court, Historic Courthouse, located at the San Bernardino Justice Center 247 West Third Street, San Bernardino, CA 92415, Plaintiff Haydee Cruz Campos \OOOQONUI-RUJNr—t (“Plaintiff’) will and hereby does move this Court for an order granting leave to file an amended complaint, pursuant to Code of Civil Procedure, section 473, subdivision (a) and Code 0f Civil Procedure, section 576 t0 add a cause of action for Violation of the Song-Beverly Act — Breach of Express warranty because 0f newly discovered evidence obtained in the deposition of Defendant’s person most qualified Witness, Which confirmed that the Subject Vehicle was presented for sufficient repair presentations such to support a cause 0f action for breach 0f express warranty. This motion is based upon the Memorandum 0f Points and Authorities attached hereto, the Declaration 0f Timothy Lupinek in Support 0f the Motion, the records on file in this action, and upon such evidence, oral and documentary, Which may be presented at the hearing on this matter. NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—K Dated: November 8, 2023 KNIGHT LAW GROUP, LLP ’Wfiiw OOQGUIAUJNHOKOOOQONMAUJNHO Roger Kimos (SBN 283 1 63) Timothy Lupinek (SBN 334876) Attorneys for Plaintiff, HAYDEE CRUZ CAMPOS -1- PLAINTIFF’S MOTION FOR LEAVE TO AMEND