Jacqueline Perry v. Ford Motor Company

I. BACKGROUND

23 On May 25, 2019, Perry purchased a 2016 Ford Explorer (the “Subject Vehicle”) 24 for $45,649.20 and entered into a warranty agreement with Defendant Ford Motor 25 Company (“Ford”). (Notice of Removal, Ex. A (“Compl.”), Docket No. 1-2 ¶¶ 7, 15). 26 Perry alleges that “[d]efects and nonconformities to warranty manifested themselves 27 within the applicable express warranty period” that “substantially impaired the use, 28 value and/or safety of the Subject Vehicle.” (Id. ¶ 16). Perry alleges that she brought the Subject Vehicle to one of Ford’s authorized repair facilities, but that Ford “was unable to conform the Subject Vehicle to the applicable express warranty after a reasonable number of repair attempts.” (Id. ¶¶ 17–18). On May 16, 2023, Perry filed this action in Los Angeles Superior Court, asserting two claims against Ford for violations of the Song-Beverly Act. (See generally id.). Perry asserts in the Complaint that the purchase price of the Subject Vehicle was $45,649.20 and that she seeks “a civil penalty up to two times the amount of actual damages” for Ford’s alleged violations. (Id. ¶¶ 15, 25, 37). Perry served,…