On November 08, 2023 a
Complaint,Petition
was filed
involving a dispute between
Huizar, Laura R.,
and
Does 1 Through 10, Inclusive,
Forest River, Inc.,
Giant Inland Empire Rv Center, Inc,
Lippert Components, Inc.,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
Preview
MFS Legal Inc.
Neal Morrow HI (SEN 295497)
F°
(SEN 289956)
Bulgart
gébgr gIIEEgALIFORNIA
EbIEDETRTgI-ly
$0651261J1
teward HI (SBN 337385) COUNTY 0F SAN BERNARDINO
p '
SAN BERNARDINO DISTRICT
Michael J. Avila (SBN 337521)
53 1 8 East 2nd Street #490 11/8/2023 12:54 pM
Long Beach CA 90803
Tel: (562) 379-2654 By: Gilberto Villegas, DEPUTY
\DOOflQUl-bUJNH
Email: lawclerk@calemonlawteam.com (contact)
eservice@calemonlawteam.com (documents)
Attorneys for Plaintiff
LAURA R. HUIZAR
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
Case N03 CIVSBZ329027
LAURA R. HUIZAR
COMPLAINT FOR DAMAGES AND
Plaintiff, INJUNCTIVE RELIEF
vs. (1) VIOLATION 0F THE SONG-
BEVERLY CONSUMER WARRANTY
FOREST RIVER, INC., a corporation; ACT BREACH 0F EXPRESS WARRANT
(2) VIOLATION OF THE SONG-
NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t
GIANT INLAND EMPIRE RV CENTER, BEVERLY CONSUMER WARRANTY
o o .
ACT BREACH OF IMPLIED WARRANTY
INC, a Callfornla corporatlon; LIPPERT (3) VIOLATION 0F BUSINESS AND
COMPONENTS, INC., a corporation; and aliggléfiggchgpagfinoo
OOQONUI-hUJNi—‘OKDOOQQUI-bUJNHO
DOES 1 through 10’ ‘nduswe’
Unlimited Civil Jurisdiction -
Damages Exceed $25,000
Defendants.
JURY TRIAL DEMANDED
TO THIS HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS OF
RECORD HEREIN:
Plaintiff, LAURA R. HUIZAR (hereinafter “Plaintiff”), an individual alleges as follows:
1. Plaintiffis an individual residing in the City ofBanning, County ofRiverside, and State
0f California.
PLAINTIFF’S COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1
2. Plaintiff is a “buyer” as defined by California Civil Code § 298 1(0) and § 1791(b).
3. Plaintiff is a “buyer” as defined by California Civil Code § 298 1(c) and § 1791(b)
4. Plaintiff believes that Defendant, FOREST RIVER INC., (hereinafter “FOREST”
and 0r “Defendant), is a manufacturer as defined by Civil Code §§ I 791(6) and 0), is and at all
\DOOflQUl-bUJNH
relevant times has been, a business entity, incorporated and organized and existing under the laws
0f the State of Delaware.
5. Defendant FOREST has significant contacts with the State 0f California, and the
activities complained ofherein occurred, in Whole 0r in part in the State of California. FOREST’s agent
for service of process is CSC-Lawyers Incorporating Service located at 710 Gateway Oaks Drive,
Suite 150N, Sacramento CA 95833.
6. Plaintiff believe that Defendant, GIANT INLAND EMPIRE RV CENTER, INC
(hereinafter “GIANT” and 0r “‘Defendant), is a retailer as defined by Civil Code §§ I 791 09 and
(l), is and at all relevant times has been, a business entity, licensed t0 do business, under the laws
NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t
0f the State of California.
7. Defendant GIANT has significant contacts With the State of California, and the
activities complained of herein occurred, in whole or in part in the State 0f California. GIANT’S agent
OOQONUI-hUJNi—‘OKDOOQQUI-bUJNHO
for service ofprocess is Michael F. Klein, located at 225 Broadway Street, Suite 1900, San Diego
CA 92 1 O 1.
8. Plaintiff believes that Defendant LIPPERT COMPONENTS INC. (hereinafter
“LIPPERT” and or “Defendant), is a manufacturer as defined by Civil Code §§ I 791 (e) and 0),
is and at all relevant times has been, a business entity, incorporated and organized and existing
under the laws of the State 0f Indiana and is licensed to d0 business in the State of California.
PLAINTIFF’S COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
2
Document Filed Date
November 08, 2023
Case Filing Date
November 08, 2023
Category
Breach of Contract/Warranty Unlimited
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MFS Legal Inc. Neal Morrow HI (SEN 295497) F° (SEN 289956) Bulgart gébgr gIIEEgALIFORNIA EbIEDETRTgI-ly $0651261J1 teward HI (SBN 337385) COUNTY 0F SAN BERNARDINO p ' SAN BERNARDINO DISTRICT Michael J. Avila (SBN 337521) 53 1 8 East 2nd Street #490 11/8/2023 12:54 pM Long Beach CA 90803 Tel: (562) 379-2654 By: Gilberto Villegas, DEPUTY \DOOflQUl-bUJNH Email: lawclerk@calemonlawteam.com (contact) eservice@calemonlawteam.com (documents) Attorneys for Plaintiff LAURA R. HUIZAR SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO Case N03 CIVSBZ329027 LAURA R. HUIZAR COMPLAINT FOR DAMAGES AND Plaintiff, INJUNCTIVE RELIEF vs. (1) VIOLATION 0F THE SONG- BEVERLY CONSUMER WARRANTY FOREST RIVER, INC., a corporation; ACT BREACH 0F EXPRESS WARRANT (2) VIOLATION OF THE SONG- NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t GIANT INLAND EMPIRE RV CENTER, BEVERLY CONSUMER WARRANTY o o . ACT BREACH OF IMPLIED WARRANTY INC, a Callfornla corporatlon; LIPPERT (3) VIOLATION 0F BUSINESS AND COMPONENTS, INC., a corporation; and aliggléfiggchgpagfinoo OOQONUI-hUJNi—‘OKDOOQQUI-bUJNHO DOES 1 through 10’ ‘nduswe’ Unlimited Civil Jurisdiction - Damages Exceed $25,000 Defendants. JURY TRIAL DEMANDED TO THIS HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: Plaintiff, LAURA R. HUIZAR (hereinafter “Plaintiff”), an individual alleges as follows: 1. Plaintiffis an individual residing in the City ofBanning, County ofRiverside, and State 0f California. PLAINTIFF’S COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF 1 2. Plaintiff is a “buyer” as defined by California Civil Code § 298 1(0) and § 1791(b). 3. Plaintiff is a “buyer” as defined by California Civil Code § 298 1(c) and § 1791(b) 4. Plaintiff believes that Defendant, FOREST RIVER INC., (hereinafter “FOREST” and 0r “Defendant), is a manufacturer as defined by Civil Code §§ I 791(6) and 0), is and at all \DOOflQUl-bUJNH relevant times has been, a business entity, incorporated and organized and existing under the laws 0f the State of Delaware. 5. Defendant FOREST has significant contacts with the State 0f California, and the activities complained ofherein occurred, in Whole 0r in part in the State of California. FOREST’s agent for service of process is CSC-Lawyers Incorporating Service located at 710 Gateway Oaks Drive, Suite 150N, Sacramento CA 95833. 6. Plaintiff believe that Defendant, GIANT INLAND EMPIRE RV CENTER, INC (hereinafter “GIANT” and 0r “‘Defendant), is a retailer as defined by Civil Code §§ I 791 09 and (l), is and at all relevant times has been, a business entity, licensed t0 do business, under the laws NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t 0f the State of California. 7. Defendant GIANT has significant contacts With the State of California, and the activities complained of herein occurred, in whole or in part in the State 0f California. GIANT’S agent OOQONUI-hUJNi—‘OKDOOQQUI-bUJNHO for service ofprocess is Michael F. Klein, located at 225 Broadway Street, Suite 1900, San Diego CA 92 1 O 1. 8. Plaintiff believes that Defendant LIPPERT COMPONENTS INC. (hereinafter “LIPPERT” and or “Defendant), is a manufacturer as defined by Civil Code §§ I 791 (e) and 0), is and at all relevant times has been, a business entity, incorporated and organized and existing under the laws of the State 0f Indiana and is licensed to d0 business in the State of California. PLAINTIFF’S COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF 2