Preview
F) ORGINAL =
CIV-130
ATTORNEYORPARTYWITHOUTATTORNEY(Name,State
Barnumber,
and FOR COURTUSEONLY
Steve Mikhov(SBN 224676) / Deepak Devabose( SBN 298890)
Knight Law Group, LLP
10250 Constellation Blvd., Suite 2500
Los Angeles, CA 90067 - I LL Ee
TELEPHONEMO:(310) 552-2250 a ey: ; Superior Court of |
E-MAIL
ADDRESS(Options):
stevem @knightlaw.com/deepakd@knightlaw.com County of Placer
ATTORNEY
FOR (Name):
Plaintiff Anna P. King
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Placer NOV 1 3 2019
STREETADDRESS: ]()820 Justice Center Drive Jake Chatters
MAILINGADDRESS:10820 Justice Center Drive Executive Officer & Clerk
CITYAND ZIPCODE:
Rogeville, CA 95678 By: R. Mcintyre, Deputy
BRANCHNAME: Bil] Santucci Justice Center
PLAINTIFF/PETITIONER: nna
A P. King
DEFENDANT/RESPONDENT: Hyundai Motor America, et al.
NOTICE OF ENTRY OF JUDGMENT GARENUMBER:
OR ORDER SCV0038637
(Check one): [¥] UNLIMITEDCASE [_] LIMITED CASE
(Amount demanded (Amount demanded was
exceeded $25,000) $25,000 or less)
TO ALL PARTIES :
1. A judgment, decree, ororder was entered inthis
action on (date):September 23, 2019
2. Acopy ofthe judgment, decree,or orderisattached tothisnotice.
Date: November 6, 2019 :
Deepak Devabose (SBN 298890) be
(TYPEORPRINT
NAME OF ATTORNEY [ | PARTYWITHOUTATTORNEY) j (SIGNATURE)
Page1 of 2
: www.courtinio.ca.gov
*judela
Counch
CIV-130
Catfomia
of
[New January
1, 2010]
NOTICE OF ENTRY OF JUDGMENT OR ORDER
~ a
CIV-130
PLAINTIFF/PETITIONER: Anna P.King CASENUMBER:
r SCV0038637
DEFENDANT/RESPONDENT: Hyundai Motor America,etal.
PROOF OF SERVICE BY FIRST-CLASS MAIL
NOTICE OF ENTRY OF JUDGMENT OR ORDER
(NOTE: You cannot serve the Notice of Entry ofJudgment or Order if youare a party in theaction. The person who served
the noticemust complete thisproof ofservice.)
1. lam atleast18 years oldand nota party to thisaction. | ama residentofor employed inthe county where the mailingtook
place,and my residence orbusiness address is (specify):
KnightLaw Group,LLP
10250 Constellation Blvd., Suite 2500
Los Angeles, CA 90067
2. | serveda copy ofthe Notice ofEntry ofJudgment or Orderby enclosing itina sealedenvelope withpostage
fully
prepaid and (check one):
a LJ deposited thesealed envelope withthe UnitedStates PostalService.
b. placed thesealed envelope forcollection
and processing formailing,followingthisbusiness's usual practices,
withwhich | amreadilyfamiliar.
On thesame day correspondence isplaced forcollectionand mailing,itis
deposited inthe ordinarycourse ofbusiness with theUnited States PostalService.
3. The Notice ofEntry ofJudgment or Order was mailed:
a. on (date):November 6,2019
b. from (city
and state):LosAngeles, CA
4. The envelope was addressed and mailed asfollows:
a. Name of person served: c. Name of person served:
Streetaddress: Streetaddress:
City: City:
State and zipcode: State and zipcode:
b. Name of person served: d. Name of person served:
Streetaddress: Streetaddress:
City: City:
Stateand zipcode: State and zipcode:
Names and addresses ofadditionalpersons served are attached.(You may use form POS-030(P).)
5. Number ofpages attached 10
| declareunder penaltyofperjury under thelaws ofthe State ofCalifornia
that theforegoing istrueand correct.
Date: November 6,2019
Marlen Monterroso » VA. ‘
(TYPEORPRINTNAMEOF DECLARANT) (SIGNATURE
OF DECLARANT)
Page2 of 2
CIV-130
[NewJanuary1, 2010] NOTICE OF ENTRY OF JUDGMENT OR ORDER
~ FILED BY FAX
Soheyl Tahsildoost (Bar No. 271294)
Kainoa Aliviado (Bar
ILED
Kw
No. 308382)
~
THETA LAW FIRM, LLP Superior Couri
of
15901 Hawthome Blvd., Suite 270 P Cane ne eeceiitornia
Lawndale, CA 90260
SEP 25 2019
w
Telephone: {424} 297-3103
Facsimile: (424) 286-2244
mB
Jake Chatters
culive Officer & Clerk
Attorneys for defendant Hyundai Motor America
TH
y: O.Lucatuorto, Deputy
DH
SUPERIOR COURT OF THE STATE
BS
OF CALIFORNIA
RP
COUNTY OF PLACER
OS
ANNA P. KING, ) Case No.: SC V0038637
oS
)
Plaintiff, } STIPULATION FOR ENTRY OF
w=
} AMENDED JUDGMENT ON THE
ler
vs. ) VERDICT
)
HYUNDAI MOTOR AMERICA, a )
California Corporation, and DOES } } Complaint Filed: October 28, 2016
through 10, inclusive, } Trial
ae
Date: July 1,2019
&
)
i5 Defendants. )
16 TO THE COURT:
17 By and through their counsel, PlaintiffAnna P.King (“Plaintiff’} and Defendant Hyundai
18 Motor America (“HMA”) hereby stipulateas set forth below:
19 1) Trial inthis matter commenced on July 1, 2019. At the conclusion of the trial,
the jury
20 found in favor of Plaintiffon Plaintiff'sexpress warranty claim under the Song-Beverly
21 Consumer Warranty Act. The verdict awarded Plaintiff with restitution in the amount of
22 $30,412.43.
2) Thereafter, the parties submitted a proposed judgment on the verdict setting forth that
24 Plaintiffwas to receive $30,412.43, Inadvertently, the judgment did not include language
zs requiring Plaintifftosurrender the vehicle, as mandated by the Song-Beverly Consumer
26 Warranty Act which requires the vehicle be repurchased and that itstitlebe branded,
27 3) Prior to correction of thisoversight, the Court signed the proposed judgement on
September 6, 2019.
Bt RING.
ANN APT.E4JTNGSSTIPOr
- AMEND
JUDGMENT.OOCK
l
~~ STIPULATION FOR ENTRY OF AMENDED JUDGMENT ON THE VERDICT
In light of the foregoing, PiaintiffAnna P. King and Defendant Hyundai Motor
America hereby stipulate as follows: The partiesjointly request thatthe Court enter judgment
ON
per the amended proposed judgment attached hereto as Exhibit A and vacate the prior judgment
wm ow&
signed September 6, 2019.
Dated: September {Latis ALTMAN LAW GROUP
oN
—
Allomey for Plaintiff Anna P. King
16
Dated: September 12, 2019 THETA LAW FiRM, LLP
12
13
Me
SOHEYL
3I—
TAHSILDOOST
Attorney for Defendant Hyundai Motor America
14
15
ORDER
16
The parties” stipulation forsubmission of an Amended Propased Judgment on the verdict
17
isgranted. The Court has signed the Amended Proposed Judgment submitted by the parties as
18
Exhibit A with theirstipulation and the priorjudgment on the verdict signed September 6, 2019
isvacated.
20
(OR: IT IS SO ORDERED:
21
22
pre, Ligh 2) 201 The LZ
23
24
25 JuD GE OF THE SUE QR COURT
ee wichael WY.
26
27
28
3OKING,
ANNAPLEADINGSS
TIPO!
AMENDTLEKIMENT
COC £ 2
STIPULATION FOR ENTRY OF AMENDED JUDGMENT ON THE VERDICT
EXHIBIT A
Nant
DH
SUPERIOR COURT OF THE STATE OF CALIFORNIA
sb
COUNTY OF PLACER
OO
DO
ANNA P. KING, ) Case No.: S-CV0038637
)
Piaintiff, ) AMENDED JUDGMENT
)
vB. ) Dept: 3
) Judge: Hon. Michael W. Jones
HYUNDAI MOTOR AMERICA, a }
California Corporation, and DOES | ) Complaint Filed: October 28, 2016
lbrough 10, inclusive, ) Trial Date: July F,2019
)
Defendants. }
)
}
TO THE HONORABLE COURT, PLAINTIFF, AND HER ATTORNEY'S OF RECORD:
This action came on for Trial on July 1, 2019 inDepartment 3 of the Superior Court of
Califomia, County of Placer, Auburn Courthouse located at 101 Maple Street, Auburn Cafifornia
95603, the Honorable Michael W. Jones presiding. Plaintiff was represented attrial!
by Bryan
Altman, Christopher Swanson and Kevin Jacobson. Defendant was represented by Julian Senior
and Sohey] Tahsildoost.
A jury of twelve (12) persons was regularly empaneted and sworn. Witnesses were
sworn and testified. After hearing the evidence and arguments ofcounsel, the jury was duly
instructed by the Court and the cause was submitted to thejury with directions to retum a
verdict, The jury deliberated and thereafterreturned tothe Court itsverdict, as follows, towit:
fit
{ti
MING, AMKASTELAI,
AMENDED[UDGEMENTONTHEVERDICT
DOCK j
womens ee
AMENDED JUDGMENT
Breach af Express Warranty
ty
1.Did Anna King purchase 2010 Hyundai Tucson distributed by !lyundai Motor America?
__X_ Yes No
ww
ff vour answer to question } isyes, then answer question 2. If you answered no,
DA
Stop here, answer no further questions, and have the presiding juror sign and date
thisform.
~S
2. Did ETyundai Motor America give Anna King a written warranty?
©
__%_ Yes No
Co
ff your answer to question 2 isyes, then answer question 3. If yau answered na,
then answer no further questions and sign and date this form.
11
12
3. Did the 2010 Hyundai Tucson have a defect ordefects covered by the warranty that
substantially impaired the vehicle's use, value,or safety to reasonable buyers in Anna King's
situation?
14
__X__ Yes No
15
16
if your answer to question 3is yes,then answer question 4.If you answered no,
17 then answer no further questions and sign and date thisform.
3
19 4. Did Hyundai Motor America or itsauthorized repair facilitiesfailto repair the 2010 Hyundai
Tucson tomatch thewritten warranty aftera reasonable number of opportunities ta do so.
20
2t
22
{f your answer to question 4 isYes, then answer question 5. if you answered No, answer
23 no further questions and sign and date thisform.
24
5. Did Hyundai Motor America failto promptly replace or repurchase the 2010 Hyundai
26 Tucson?
27
28
SKIINGANNAGTRIALAMENDIC
JUDGEMENT
OX THF
Vibe | UX 2
AMENDED JUDGMENT
df your unswer to question 5 isyes, then answer question 6. If you answered no,
then answer nu further questions and sign and date thisform.
WH
6. What are Anna King’s damages? Calculate as follows:
Ww
Add the following amounts:
&
a. The purchase price of the vehicle itself: $ 26,428
we
b. Charges fortransportation and manufacturer-installed options: $0
A
c. Finance charges aciually paid by Anna King: $3.146.83
~~
d, Sales tax. license fees,registration fees,and other officialfees collateral to the purchase
of the vehicle: $2.773.01
¢. Incidental and consequential damages: $0
10
11 SUBTOTAL: $32,347.84
i2 Answer question 7,
13 Vs Calculate the value of the use of thevehicle before itwas brought in for repair as follows:
(a) Add dollar amounts listedin lines6a and 6b above: $26,428
i)
(b} Multiply the resultin line 7a above by the number of miles the vehicle was driven
16 before itwas firstbrought in forrepair of the nonconformity: $232,249,264
17 (c) Divide the dojlacamount in Step (b) by 120,000 and insert resultin VALUE OF
USE below:
18
19 VALUE OF USE: $1,935.41
20 (¢} Subtract the VALUE OF USE from the SUBTOTAL atthe end of question 6 and
insertresult in TOTAL DAMAGES below:
2)
22 TOTAL DAMAGES: $30,412.43
23
Answer guestion 8.
24
25
26
27 8. Did Hyundai Motor America willfully failto repurchase or replace the 2010 Hyundai Tucson?
BAKING.
ANNASTRIAL
AMENDED
[LDGEMENTONTHEVERDICT
DOCK 3
ee “""~KMENDED JUDGMENT
Yes x No
ff your answer to question 8 tspes, then answer question 9. If you answered nv,
then answer nofurther questions and sign and date this form.
9. What amount, if any. do you impose 45 a penalty? You may not exceed two times the Total
Damages listedin Question 7 above.
PENALTY: &
Signed: ist
Presiding Juror
Dated: juty 16, 2019
After this verdict form has been signed, notify the court attendant that you are ready to
present your verdict in the courtroom.
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Hf
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RUNG &NA FRIALLAMENDED
SUDGEMENTOF THE
WERDICT
DOCX 4
erry
AMENDED JUDGMENT
NOW THEREFORE IT [S ORGERED, ADJUDGED, AND DECREED as follows:
Piainff Anna P. King shall recover from Defendant i1yundai Motor America the amount
of $30,412.43. PlaintiffAnna P. King shalireturn the subject 2010 Hyundai Tucson,
KM8jJU3ACXAUG15808 to Hyundai Motor America with clear title.
This Court shall decide allissues involving fees, costs, expenses and interest, ifany, by
post-verdict motion(s) and may order entryof amended judgment as appropriate.
Dated:
Superior Court Judge
AMENDED
ANNACTLIAL
MAIUNG. ON
FUDGEMENT DUK k
THE VERDICT §
AMENDED JUDGMENT
—_
PROOF OF SERVICE
(Code of Civil Procedure §1013a)
NY
I am employed in the County of Los Angeles, State of California. Iam over the age of 18
years and not a party to the within action. My business address is 10250 Constellation Blvd..,
WY
Suite 2500, Los Angeles, CA 90067.
Fe
On November 6, 2019 Iserved the foregoing document described as:
OW
NOTICE OF ENTRY OF JUDGMENT OR ORDER
ND
Said document was served on the interested parties in this action, by placing true copies
thereof enclosed in sealed envelopes, with postage prepaid, addressed as follows:
moO
SEE BELOW MAILING LIST
0
[ro
XX BY MAIL: I am readily familiar with this firm's practice of collection and processing
—
correspondence for mailing with the United States Postal Service. Under that practice, it
ee
NO
would be deposited with the U.S. Postal Service on that same day with postage thereon
fully prepaid at a Postal Service collection box at Los Angeles, California, in the ordinary
WY
course of business. The envelope was sealed and placed for collection that same day
ee
following ordinary business practices, addressed to the above-referenced attorney.
FSF
nO
XX BY E-MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an
agreement of the parties to accept service by e-mail or electronic transmission, Icaused
DBD
the documents to be sent to the persons at the e-mail addresses listed above. I did not
receive, within a reasonable time after the transmission, any electronic message or other
mm
HN
indication that the transmission was unsuccessful.
OD
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
TD
RO
F|Y§
RO
Executed on November 6, 2019 at Los Angeles, Cal}
NY
NO
Ww
KH
MARLEN MONTERROSO
Be
KN
nN
HN
OW
NH NO
CoN
DO
-|-
PROOF OF SERVICE
—
MAILING LIST
King, Anna P. v. Hyundai Motor America, et al.
Case No.: SCV0038637
NO
WY
Soheyl Tahsildoost, Esq.
Ff.
THETA LAW FIRM
15901 Hawthorne Blvd., Suite 270
Oo
Lawndale, CA 90260
Do
Counsel for Defendant,
HYUNDAI MOTOR AMERICA, et al.
N
(via Mail only)
ma
Julian Senior, Esq.
So
SJL LAW, P.C.
841 Apollo St., Suite 300
OC
El Segundo, CA 90245
Counsel for Defendant,
KF
OO
HYUNDAI MOTOR AMERICA, et al.
NYO
(via Mail only)
ES
WY
Rr
Bryan C. Altman, Esq.
THE ALTMAN LAW GROUP
FP
Er
10250 Constellation Blvd., Suite 2500
nn
Los Angeles, CA 90067
BE
Email: bryan@altmanlawgroup.net
NHN
KF
Associated Counsel for Plaintiff,
ANNA P. KING
NY
FF
(via E-Mail only)
Fe
OD
Fe
DoD
NO
FY
NO
Ne
NO
Ww
NO
F&F
NO
Un
WN
Dn
NO
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oN
NO
3.
PROOF OF SERVICE
Preview
F) ORGINAL = CIV-130 ATTORNEYORPARTYWITHOUTATTORNEY(Name,State Barnumber, and FOR COURTUSEONLY Steve Mikhov(SBN 224676) / Deepak Devabose( SBN 298890) Knight Law Group, LLP 10250 Constellation Blvd., Suite 2500 Los Angeles, CA 90067 - I LL Ee TELEPHONEMO:(310) 552-2250 a ey: ; Superior Court of | E-MAIL ADDRESS(Options): stevem @knightlaw.com/deepakd@knightlaw.com County of Placer ATTORNEY FOR (Name): Plaintiff Anna P. King SUPERIOR COURT OF CALIFORNIA, COUNTY OF Placer NOV 1 3 2019 STREETADDRESS: ]()820 Justice Center Drive Jake Chatters MAILINGADDRESS:10820 Justice Center Drive Executive Officer & Clerk CITYAND ZIPCODE: Rogeville, CA 95678 By: R. Mcintyre, Deputy BRANCHNAME: Bil] Santucci Justice Center PLAINTIFF/PETITIONER: nna A P. King DEFENDANT/RESPONDENT: Hyundai Motor America, et al. NOTICE OF ENTRY OF JUDGMENT GARENUMBER: OR ORDER SCV0038637 (Check one): [¥] UNLIMITEDCASE [_] LIMITED CASE (Amount demanded (Amount demanded was exceeded $25,000) $25,000 or less) TO ALL PARTIES : 1. A judgment, decree, ororder was entered inthis action on (date):September 23, 2019 2. Acopy ofthe judgment, decree,or orderisattached tothisnotice. Date: November 6, 2019 : Deepak Devabose (SBN 298890) be (TYPEORPRINT NAME OF ATTORNEY [ | PARTYWITHOUTATTORNEY) j (SIGNATURE) Page1 of 2 : www.courtinio.ca.gov *judela Counch CIV-130 Catfomia of [New January 1, 2010] NOTICE OF ENTRY OF JUDGMENT OR ORDER ~ a CIV-130 PLAINTIFF/PETITIONER: Anna P.King CASENUMBER: r SCV0038637 DEFENDANT/RESPONDENT: Hyundai Motor America,etal. PROOF OF SERVICE BY FIRST-CLASS MAIL NOTICE OF ENTRY OF JUDGMENT OR ORDER (NOTE: You cannot serve the Notice of Entry ofJudgment or Order if youare a party in theaction. The person who served the noticemust complete thisproof ofservice.) 1. lam atleast18 years oldand nota party to thisaction. | ama residentofor employed inthe county where the mailingtook place,and my residence orbusiness address is (specify): KnightLaw Group,LLP 10250 Constellation Blvd., Suite 2500 Los Angeles, CA 90067 2. | serveda copy ofthe Notice ofEntry ofJudgment or Orderby enclosing itina sealedenvelope withpostage fully prepaid and (check one): a LJ deposited thesealed envelope withthe UnitedStates PostalService. b. placed thesealed envelope forcollection and processing formailing,followingthisbusiness's usual practices, withwhich | amreadilyfamiliar. On thesame day correspondence isplaced forcollectionand mailing,itis deposited inthe ordinarycourse ofbusiness with theUnited States PostalService. 3. The Notice ofEntry ofJudgment or Order was mailed: a. on (date):November 6,2019 b. from (city and state):LosAngeles, CA 4. The envelope was addressed and mailed asfollows: a. Name of person served: c. Name of person served: Streetaddress: Streetaddress: City: City: State and zipcode: State and zipcode: b. Name of person served: d. Name of person served: Streetaddress: Streetaddress: City: City: Stateand zipcode: State and zipcode: Names and addresses ofadditionalpersons served are attached.(You may use form POS-030(P).) 5. Number ofpages attached 10 | declareunder penaltyofperjury under thelaws ofthe State ofCalifornia that theforegoing istrueand correct. Date: November 6,2019 Marlen Monterroso » VA. ‘ (TYPEORPRINTNAMEOF DECLARANT) (SIGNATURE OF DECLARANT) Page2 of 2 CIV-130 [NewJanuary1, 2010] NOTICE OF ENTRY OF JUDGMENT OR ORDER ~ FILED BY FAX Soheyl Tahsildoost (Bar No. 271294) Kainoa Aliviado (Bar ILED Kw No. 308382) ~ THETA LAW FIRM, LLP Superior Couri of 15901 Hawthome Blvd., Suite 270 P Cane ne eeceiitornia Lawndale, CA 90260 SEP 25 2019 w Telephone: {424} 297-3103 Facsimile: (424) 286-2244 mB Jake Chatters culive Officer & Clerk Attorneys for defendant Hyundai Motor America TH y: O.Lucatuorto, Deputy DH SUPERIOR COURT OF THE STATE BS OF CALIFORNIA RP COUNTY OF PLACER OS ANNA P. KING, ) Case No.: SC V0038637 oS ) Plaintiff, } STIPULATION FOR ENTRY OF w= } AMENDED JUDGMENT ON THE ler vs. ) VERDICT ) HYUNDAI MOTOR AMERICA, a ) California Corporation, and DOES } } Complaint Filed: October 28, 2016 through 10, inclusive, } Trial ae Date: July 1,2019 & ) i5 Defendants. ) 16 TO THE COURT: 17 By and through their counsel, PlaintiffAnna P.King (“Plaintiff’} and Defendant Hyundai 18 Motor America (“HMA”) hereby stipulateas set forth below: 19 1) Trial inthis matter commenced on July 1, 2019. At the conclusion of the trial, the jury 20 found in favor of Plaintiffon Plaintiff'sexpress warranty claim under the Song-Beverly 21 Consumer Warranty Act. The verdict awarded Plaintiff with restitution in the amount of 22 $30,412.43. 2) Thereafter, the parties submitted a proposed judgment on the verdict setting forth that 24 Plaintiffwas to receive $30,412.43, Inadvertently, the judgment did not include language zs requiring Plaintifftosurrender the vehicle, as mandated by the Song-Beverly Consumer 26 Warranty Act which requires the vehicle be repurchased and that itstitlebe branded, 27 3) Prior to correction of thisoversight, the Court signed the proposed judgement on September 6, 2019. Bt RING. ANN APT.E4JTNGSSTIPOr - AMEND JUDGMENT.OOCK l ~~ STIPULATION FOR ENTRY OF AMENDED JUDGMENT ON THE VERDICT In light of the foregoing, PiaintiffAnna P. King and Defendant Hyundai Motor America hereby stipulate as follows: The partiesjointly request thatthe Court enter judgment ON per the amended proposed judgment attached hereto as Exhibit A and vacate the prior judgment wm ow& signed September 6, 2019. Dated: September {Latis ALTMAN LAW GROUP oN — Allomey for Plaintiff Anna P. King 16 Dated: September 12, 2019 THETA LAW FiRM, LLP 12 13 Me SOHEYL 3I— TAHSILDOOST Attorney for Defendant Hyundai Motor America 14 15 ORDER 16 The parties” stipulation forsubmission of an Amended Propased Judgment on the verdict 17 isgranted. The Court has signed the Amended Proposed Judgment submitted by the parties as 18 Exhibit A with theirstipulation and the priorjudgment on the verdict signed September 6, 2019 isvacated. 20 (OR: IT IS SO ORDERED: 21 22 pre, Ligh 2) 201 The LZ 23 24 25 JuD GE OF THE SUE QR COURT ee wichael WY. 26 27 28 3OKING, ANNAPLEADINGSS TIPO! AMENDTLEKIMENT COC £ 2 STIPULATION FOR ENTRY OF AMENDED JUDGMENT ON THE VERDICT EXHIBIT A Nant DH SUPERIOR COURT OF THE STATE OF CALIFORNIA sb COUNTY OF PLACER OO DO ANNA P. KING, ) Case No.: S-CV0038637 ) Piaintiff, ) AMENDED JUDGMENT ) vB. ) Dept: 3 ) Judge: Hon. Michael W. Jones HYUNDAI MOTOR AMERICA, a } California Corporation, and DOES | ) Complaint Filed: October 28, 2016 lbrough 10, inclusive, ) Trial Date: July F,2019 ) Defendants. } ) } TO THE HONORABLE COURT, PLAINTIFF, AND HER ATTORNEY'S OF RECORD: This action came on for Trial on July 1, 2019 inDepartment 3 of the Superior Court of Califomia, County of Placer, Auburn Courthouse located at 101 Maple Street, Auburn Cafifornia 95603, the Honorable Michael W. Jones presiding. Plaintiff was represented attrial! by Bryan Altman, Christopher Swanson and Kevin Jacobson. Defendant was represented by Julian Senior and Sohey] Tahsildoost. A jury of twelve (12) persons was regularly empaneted and sworn. Witnesses were sworn and testified. After hearing the evidence and arguments ofcounsel, the jury was duly instructed by the Court and the cause was submitted to thejury with directions to retum a verdict, The jury deliberated and thereafterreturned tothe Court itsverdict, as follows, towit: fit {ti MING, AMKASTELAI, AMENDED[UDGEMENTONTHEVERDICT DOCK j womens ee AMENDED JUDGMENT Breach af Express Warranty ty 1.Did Anna King purchase 2010 Hyundai Tucson distributed by !lyundai Motor America? __X_ Yes No ww ff vour answer to question } isyes, then answer question 2. If you answered no, DA Stop here, answer no further questions, and have the presiding juror sign and date thisform. ~S 2. Did ETyundai Motor America give Anna King a written warranty? © __%_ Yes No Co ff your answer to question 2 isyes, then answer question 3. If yau answered na, then answer no further questions and sign and date this form. 11 12 3. Did the 2010 Hyundai Tucson have a defect ordefects covered by the warranty that substantially impaired the vehicle's use, value,or safety to reasonable buyers in Anna King's situation? 14 __X__ Yes No 15 16 if your answer to question 3is yes,then answer question 4.If you answered no, 17 then answer no further questions and sign and date thisform. 3 19 4. Did Hyundai Motor America or itsauthorized repair facilitiesfailto repair the 2010 Hyundai Tucson tomatch thewritten warranty aftera reasonable number of opportunities ta do so. 20 2t 22 {f your answer to question 4 isYes, then answer question 5. if you answered No, answer 23 no further questions and sign and date thisform. 24 5. Did Hyundai Motor America failto promptly replace or repurchase the 2010 Hyundai 26 Tucson? 27 28 SKIINGANNAGTRIALAMENDIC JUDGEMENT OX THF Vibe | UX 2 AMENDED JUDGMENT df your unswer to question 5 isyes, then answer question 6. If you answered no, then answer nu further questions and sign and date thisform. WH 6. What are Anna King’s damages? Calculate as follows: Ww Add the following amounts: & a. The purchase price of the vehicle itself: $ 26,428 we b. Charges fortransportation and manufacturer-installed options: $0 A c. Finance charges aciually paid by Anna King: $3.146.83 ~~ d, Sales tax. license fees,registration fees,and other officialfees collateral to the purchase of the vehicle: $2.773.01 ¢. Incidental and consequential damages: $0 10 11 SUBTOTAL: $32,347.84 i2 Answer question 7, 13 Vs Calculate the value of the use of thevehicle before itwas brought in for repair as follows: (a) Add dollar amounts listedin lines6a and 6b above: $26,428 i) (b} Multiply the resultin line 7a above by the number of miles the vehicle was driven 16 before itwas firstbrought in forrepair of the nonconformity: $232,249,264 17 (c) Divide the dojlacamount in Step (b) by 120,000 and insert resultin VALUE OF USE below: 18 19 VALUE OF USE: $1,935.41 20 (¢} Subtract the VALUE OF USE from the SUBTOTAL atthe end of question 6 and insertresult in TOTAL DAMAGES below: 2) 22 TOTAL DAMAGES: $30,412.43 23 Answer guestion 8. 24 25 26 27 8. Did Hyundai Motor America willfully failto repurchase or replace the 2010 Hyundai Tucson? BAKING. ANNASTRIAL AMENDED [LDGEMENTONTHEVERDICT DOCK 3 ee “""~KMENDED JUDGMENT Yes x No ff your answer to question 8 tspes, then answer question 9. If you answered nv, then answer nofurther questions and sign and date this form. 9. What amount, if any. do you impose 45 a penalty? You may not exceed two times the Total Damages listedin Question 7 above. PENALTY: & Signed: ist Presiding Juror Dated: juty 16, 2019 After this verdict form has been signed, notify the court attendant that you are ready to present your verdict in the courtroom. ff Hf if iif iif il tif Hit fff ff iff He if ii fil it RUNG &NA FRIALLAMENDED SUDGEMENTOF THE WERDICT DOCX 4 erry AMENDED JUDGMENT NOW THEREFORE IT [S ORGERED, ADJUDGED, AND DECREED as follows: Piainff Anna P. King shall recover from Defendant i1yundai Motor America the amount of $30,412.43. PlaintiffAnna P. King shalireturn the subject 2010 Hyundai Tucson, KM8jJU3ACXAUG15808 to Hyundai Motor America with clear title. This Court shall decide allissues involving fees, costs, expenses and interest, ifany, by post-verdict motion(s) and may order entryof amended judgment as appropriate. Dated: Superior Court Judge AMENDED ANNACTLIAL MAIUNG. ON FUDGEMENT DUK k THE VERDICT § AMENDED JUDGMENT —_ PROOF OF SERVICE (Code of Civil Procedure §1013a) NY I am employed in the County of Los Angeles, State of California. Iam over the age of 18 years and not a party to the within action. My business address is 10250 Constellation Blvd.., WY Suite 2500, Los Angeles, CA 90067. Fe On November 6, 2019 Iserved the foregoing document described as: OW NOTICE OF ENTRY OF JUDGMENT OR ORDER ND Said document was served on the interested parties in this action, by placing true copies thereof enclosed in sealed envelopes, with postage prepaid, addressed as follows: moO SEE BELOW MAILING LIST 0 [ro XX BY MAIL: I am readily familiar with this firm's practice of collection and processing — correspondence for mailing with the United States Postal Service. Under that practice, it ee NO would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at a Postal Service collection box at Los Angeles, California, in the ordinary WY course of business. The envelope was sealed and placed for collection that same day ee following ordinary business practices, addressed to the above-referenced attorney. FSF nO XX BY E-MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, Icaused DBD the documents to be sent to the persons at the e-mail addresses listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other mm HN indication that the transmission was unsuccessful. OD I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. TD RO F|Y§ RO Executed on November 6, 2019 at Los Angeles, Cal} NY NO Ww KH MARLEN MONTERROSO Be KN nN HN OW NH NO CoN DO -|- PROOF OF SERVICE — MAILING LIST King, Anna P. v. Hyundai Motor America, et al. Case No.: SCV0038637 NO WY Soheyl Tahsildoost, Esq. Ff. THETA LAW FIRM 15901 Hawthorne Blvd., Suite 270 Oo Lawndale, CA 90260 Do Counsel for Defendant, HYUNDAI MOTOR AMERICA, et al. N (via Mail only) ma Julian Senior, Esq. So SJL LAW, P.C. 841 Apollo St., Suite 300 OC El Segundo, CA 90245 Counsel for Defendant, KF OO HYUNDAI MOTOR AMERICA, et al. NYO (via Mail only) ES WY Rr Bryan C. Altman, Esq. THE ALTMAN LAW GROUP FP Er 10250 Constellation Blvd., Suite 2500 nn Los Angeles, CA 90067 BE Email: bryan@altmanlawgroup.net NHN KF Associated Counsel for Plaintiff, ANNA P. KING NY FF (via E-Mail only) Fe OD Fe DoD NO FY NO Ne NO Ww NO F&F NO Un WN Dn NO wo oN NO 3. PROOF OF SERVICE