On November 08, 2023 a
Complaint Filed - COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
was filed
involving a dispute between
Lee, Cheryl L,
Lee, Larry C,
and
Does 1 Through 10, Inclusive,
Ford Motor Company,
Giant Inland Empire Rv Center, Inc.,
Thor Motor Coach, Inc.,
Warren-Anderson Ford,
for Product Liability Unlimited
in the District Court of San Bernardino County.
Preview
MFS Legal Inc.
Neal F. Morrow III (SBN 295497) ELECTRONICALLY FILED
Rene J (SBN 289956)
Dupart SUPERIOR COURT OF CALIFORNIA
53 1 8 East 2nd Street, #490
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Long Beach, CA 90803
Tel: (562)379-2654 11/8/2023 12:49 PM
Email: lawclerk@calemonlawteam.com (contact)
eservice@calemonlawteam.com (documents) By: Elda Ramirez, DEPUTY
\DOOQONUl-bUJNr—
Attorneys for Plaintiffs
LARRY C. LEE and
CHERYL L. LEE
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
Case No; CIVSBZ32905O
LARRY C. LEE and
CHERYL L. LEE COMPLAINT FOR DAMAGES AND
INJUNCTIVE RELIEF
(1) VIOLATION 0F THE SONG-
Plaintiffs, BEVERLY CONSUMER WARRANTY
ACT BREACH 0F EXPRESS
VS.
WARRANTY
(2) VIOLATION 0F THE SONG-
THOR MOTOR COACH, INC., a BEVERLY CONSUMER WARRANTY
FORD MOTOR COMPANY, a
NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t
corporation;
corporation; GIANT INLAND EMPIRE RV
ACT BREACH 0F IMPLIED
CENTER, INC, a California corporation;
WARRANTY
(3) VIOLATION 0F BUSINESS AND
WARREN-ANDERSON FORD d.b.a.
OOQONUl-hUJNi—‘OKDOOQONUl-bUJNi—‘O
PROFESSIONS CODE § 17200
FRITTS FORD, a California corporation;
(4) NEGLIGENT REPAIR
and DOES 1 through 10, inclusive,
Defendants. Unlimited Civil Jurisdiction -
Damages Exceed $25,000
JURY TRIAL DEMANDED
TO THIS HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS
OF RECORD HEREIN:
PLAINTIFFS’ COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
Plaintiffs, LARRY C. LEE and CHERYL L. LEE (hereinafter “Plaintiffs”) are
individuals Who allege as follows:
1. Plaintiffs are individuals residing in the City 0f Moreno Valley, the County 0f
Riverside, and the State 0f California.
\DOOQONUl-bUJNr—
2. Plaintiffs are “buyers” as defined by California Civil Code § 2981(0) and § 1791(b)
3. Plaintiffs believe that Defendant, THOR MOTOR COACH, INC. (hereinafter
“THOR” and or “Defendant), is a manufacturer and distributor as defined by Civil Code §§
I 791 (e) and 0), is and at all relevant times has been, a business entity, and is licensed t0 do
business in the State 0f California.
4. THOR’S agent for process of service is CT Corporation System, located at 330 N
Brand Blvd Suite 700, Glendale CA 91203.
5. Plaintiffs believe that Defendant, FORD MOTOR COMPANY (hereinafter
“FORD” and or “‘Defendant), is a manufacturer and distributor as defined by Civil Code §§
NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t
I 791 (e) and 0), is and at all relevant times has been, a business entity, and is licensed t0 do
business in the State 0f California.
OOQONUl-hUJNi—‘OKDOOQONUl-bUJNi—‘O
6. FORD’S agent for process of service is CT Corporation System, located at 330 N
Brand Blvd Suite 700, Glendale CA 91203.
7. Defendant GIANT INLAND EMPIRE RV CENTER, INC (hereinafter “GIANT”
and 0r “Defendant”) is a retailer as defined by Civil Code §§ I 791 09 and (Z), is and at all relevant
times has been a business entity, authorized t0 do business in the State of California.
8. 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 of California. GIANT’S
PLAINTIFFS’ COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
2
Document Filed Date
November 08, 2023
Case Filing Date
November 08, 2023
Category
Product Liability Unlimited
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MFS Legal Inc. Neal F. Morrow III (SBN 295497) ELECTRONICALLY FILED Rene J (SBN 289956) Dupart SUPERIOR COURT OF CALIFORNIA 53 1 8 East 2nd Street, #490 COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT Long Beach, CA 90803 Tel: (562)379-2654 11/8/2023 12:49 PM Email: lawclerk@calemonlawteam.com (contact) eservice@calemonlawteam.com (documents) By: Elda Ramirez, DEPUTY \DOOQONUl-bUJNr— Attorneys for Plaintiffs LARRY C. LEE and CHERYL L. LEE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO Case No; CIVSBZ32905O LARRY C. LEE and CHERYL L. LEE COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF (1) VIOLATION 0F THE SONG- Plaintiffs, BEVERLY CONSUMER WARRANTY ACT BREACH 0F EXPRESS VS. WARRANTY (2) VIOLATION 0F THE SONG- THOR MOTOR COACH, INC., a BEVERLY CONSUMER WARRANTY FORD MOTOR COMPANY, a NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t corporation; corporation; GIANT INLAND EMPIRE RV ACT BREACH 0F IMPLIED CENTER, INC, a California corporation; WARRANTY (3) VIOLATION 0F BUSINESS AND WARREN-ANDERSON FORD d.b.a. OOQONUl-hUJNi—‘OKDOOQONUl-bUJNi—‘O PROFESSIONS CODE § 17200 FRITTS FORD, a California corporation; (4) NEGLIGENT REPAIR and DOES 1 through 10, inclusive, Defendants. Unlimited Civil Jurisdiction - Damages Exceed $25,000 JURY TRIAL DEMANDED TO THIS HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: PLAINTIFFS’ COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Plaintiffs, LARRY C. LEE and CHERYL L. LEE (hereinafter “Plaintiffs”) are individuals Who allege as follows: 1. Plaintiffs are individuals residing in the City 0f Moreno Valley, the County 0f Riverside, and the State 0f California. \DOOQONUl-bUJNr— 2. Plaintiffs are “buyers” as defined by California Civil Code § 2981(0) and § 1791(b) 3. Plaintiffs believe that Defendant, THOR MOTOR COACH, INC. (hereinafter “THOR” and or “Defendant), is a manufacturer and distributor as defined by Civil Code §§ I 791 (e) and 0), is and at all relevant times has been, a business entity, and is licensed t0 do business in the State 0f California. 4. THOR’S agent for process of service is CT Corporation System, located at 330 N Brand Blvd Suite 700, Glendale CA 91203. 5. Plaintiffs believe that Defendant, FORD MOTOR COMPANY (hereinafter “FORD” and or “‘Defendant), is a manufacturer and distributor as defined by Civil Code §§ NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t I 791 (e) and 0), is and at all relevant times has been, a business entity, and is licensed t0 do business in the State 0f California. OOQONUl-hUJNi—‘OKDOOQONUl-bUJNi—‘O 6. FORD’S agent for process of service is CT Corporation System, located at 330 N Brand Blvd Suite 700, Glendale CA 91203. 7. Defendant GIANT INLAND EMPIRE RV CENTER, INC (hereinafter “GIANT” and 0r “Defendant”) is a retailer as defined by Civil Code §§ I 791 09 and (Z), is and at all relevant times has been a business entity, authorized t0 do business in the State of California. 8. 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 of California. GIANT’S PLAINTIFFS’ COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF 2