Preview
. '
’
QUILL & ARROW, LLP
Kevin Y. Jacobson, Esq. (SBN 320532)
kiacobson@quillamowlaw.com
Aaron Cohen, Esq. (SBN 333008) F l L D
acohen@quillarrowlaw.com supemon couaT%F CALIFORNIA
COUNTY 0F SAN BERNARDINO
10900 Wilshire Boulevard, Suite 300 SAN BERNARDINQ DISTRICT
Los Angeles, CA, 90024
Telephone: (3 10) 933-4271
MAR 15 2022
Facsimile: (3 10) 889—0645
E-mail: e-sewice@quillarrowlaw.com BY
JACQUELINE AH as ;DEPUTY
\OOOQON Attorneys for Plaintiff,
VERONICA MACHUCA
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 COUNTY OF SAN BERNARDINO
12
VERONICA MACHUCA, CaseNo.:
CIV SB 2205 8 78
l\\AAA
13 an individual,
Unlimited Jurisdiction
\1
14 Plaintiff,
QL'ILLBARRUWWLLP
COMPLAINT
ir\1»x
15
vs.
\Hw
1. VIOLATION OF SONG—BEVERLY
16 ACT - BREACH OF EXPRESS
FORD MOTOR COMPANY, a Delaware WARRANTY
17 Corporation, and DOES through 10,
1
2. VIOLATION OF SONG-BEVERLY
inclusive, ACT - BREACH OF IMPLIED
18
WARRANTY
19 3. VIOLATION OF THE SONG-
Defendants. BEVERLY ACT SECTION 1793.2
20
21
22
23
§fi€§3§l
24
25
26
27
28
COMPLAINT
I J
1
.
CIVSB 2205878
Plaintiff, VERONICA MACHUCA, 5n individual, alleges as follows against Defendant,
FORD MOTOR COMPANY, a Delaware Corporation (“FORD MOTOR COMPANY”), and
DOES 1 through 10 inclusive, on information and belief, formed after a reasonable inquiry under
the circumstances:
DEMAND FOR JURY TRIAL
QON
1. Plaintiff, VERONICA MACHUCA, hereby demands trial by jury in this action.
GENERAL ALLEGATIONS
2. Plaintiff, VERONICA MACHUCA, is an individual residing in the City of San
Jacinto, State of California.
10 3. Defendant, FORD MOTOR COMPANY, is and was a Delaware Corporation
11 operating and doing business in the State of California.
é
12 4. These causes 0f causes of action arise out 0f warranty and repair obligations 0f
?
13 FORD MOTOR COMPANY in connection with a vehicle Plaintiffpurchased and for which FORD
QL'ILLEARROW'OLLP
i. 14 MOTOR COMPANY issued a written warranty. The warranty was not issued by the selling
"-'
15 dealership.
‘
16 5. Plaintiff does not know the true names and capacities, whether corporate,
17 partnership, associate, individual, or otherwise 0f Defendant issued herein as Does 1 through 10,
18 inclusive, under the provisions 0f section 474 ofthe California Code of Civil Procedure. Defendant
19 Does 1 through 10, inclusive, are in some manner responsible for the acts, occurrences, and
20 transactions set forth herein, and are legally liable t0 Plaintiff. Plaintiff will seek leave to amend
21 this Complaint to set forth the true names and capacities of the fictitiously named Defendant,
22 together With appropriate charging allegations, when ascertained.
23 6. A11 acts 0f corporate employees as alleged were authorized or ratified by an officer,
24 director, or managing agent 0f the corporate employer.
25 7. Each Defendant, whether actually or fictitiously named herein, was the principal,
26 agent (actual or ostensible), 0r employee 0f each other Defendant, and in acting as such principal
27 or within the course and scope 0f such employment or agency, took some part in the acts and
28 omissions hereinafter set forth by reason of which each Defendant is liable to Plaintiff for the relief
COMPLAINT
Preview
. ' ’ QUILL & ARROW, LLP Kevin Y. Jacobson, Esq. (SBN 320532) kiacobson@quillamowlaw.com Aaron Cohen, Esq. (SBN 333008) F l L D acohen@quillarrowlaw.com supemon couaT%F CALIFORNIA COUNTY 0F SAN BERNARDINO 10900 Wilshire Boulevard, Suite 300 SAN BERNARDINQ DISTRICT Los Angeles, CA, 90024 Telephone: (3 10) 933-4271 MAR 15 2022 Facsimile: (3 10) 889—0645 E-mail: e-sewice@quillarrowlaw.com BY JACQUELINE AH as ;DEPUTY \OOOQON Attorneys for Plaintiff, VERONICA MACHUCA 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF SAN BERNARDINO 12 VERONICA MACHUCA, CaseNo.: CIV SB 2205 8 78 l\\AAA 13 an individual, Unlimited Jurisdiction \1 14 Plaintiff, QL'ILLBARRUWWLLP COMPLAINT ir\1»x 15 vs. \Hw 1. VIOLATION OF SONG—BEVERLY 16 ACT - BREACH OF EXPRESS FORD MOTOR COMPANY, a Delaware WARRANTY 17 Corporation, and DOES through 10, 1 2. VIOLATION OF SONG-BEVERLY inclusive, ACT - BREACH OF IMPLIED 18 WARRANTY 19 3. VIOLATION OF THE SONG- Defendants. BEVERLY ACT SECTION 1793.2 20 21 22 23 §fi€§3§l 24 25 26 27 28 COMPLAINT I J 1 . CIVSB 2205878 Plaintiff, VERONICA MACHUCA, 5n individual, alleges as follows against Defendant, FORD MOTOR COMPANY, a Delaware Corporation (“FORD MOTOR COMPANY”), and DOES 1 through 10 inclusive, on information and belief, formed after a reasonable inquiry under the circumstances: DEMAND FOR JURY TRIAL QON 1. Plaintiff, VERONICA MACHUCA, hereby demands trial by jury in this action. GENERAL ALLEGATIONS 2. Plaintiff, VERONICA MACHUCA, is an individual residing in the City of San Jacinto, State of California. 10 3. Defendant, FORD MOTOR COMPANY, is and was a Delaware Corporation 11 operating and doing business in the State of California. é 12 4. These causes 0f causes of action arise out 0f warranty and repair obligations 0f ? 13 FORD MOTOR COMPANY in connection with a vehicle Plaintiffpurchased and for which FORD QL'ILLEARROW'OLLP i. 14 MOTOR COMPANY issued a written warranty. The warranty was not issued by the selling "-' 15 dealership. ‘ 16 5. Plaintiff does not know the true names and capacities, whether corporate, 17 partnership, associate, individual, or otherwise 0f Defendant issued herein as Does 1 through 10, 18 inclusive, under the provisions 0f section 474 ofthe California Code of Civil Procedure. Defendant 19 Does 1 through 10, inclusive, are in some manner responsible for the acts, occurrences, and 20 transactions set forth herein, and are legally liable t0 Plaintiff. Plaintiff will seek leave to amend 21 this Complaint to set forth the true names and capacities of the fictitiously named Defendant, 22 together With appropriate charging allegations, when ascertained. 23 6. A11 acts 0f corporate employees as alleged were authorized or ratified by an officer, 24 director, or managing agent 0f the corporate employer. 25 7. Each Defendant, whether actually or fictitiously named herein, was the principal, 26 agent (actual or ostensible), 0r employee 0f each other Defendant, and in acting as such principal 27 or within the course and scope 0f such employment or agency, took some part in the acts and 28 omissions hereinafter set forth by reason of which each Defendant is liable to Plaintiff for the relief COMPLAINT