Alina Sokiazian v. BMW Financial Services NA, LLC

I. Background

Plaintiff alleges that, on October 23, 2020, she entered into a lease agreement with for a 2020 MINI Hardtop (“the Subject Vehicle”). See Notice of Removal, Dkt. # 1, Ex. A (“Compl.”), ¶¶ 15–20. The terms of the lease were devised and drafted by Defendant. Id. ¶ 23. On December 14, 2021, the Subject Vehicle was declared a total loss by Plaintiff’s insurance company. Id. ¶ 26. The insurance company subsequently determined that the total loss amount was $30,788.18, which was $10,409.43 more than the adjusted lease balance of $20,028.75. Id. ¶¶ 27–32. Plaintiff alleges that Defendant collected the full sum of $30,788.18 and refused to remit Plaintiff’s entitled equity sum under the terms of the lease agreement. Id. ¶¶ 28, 31–32. On February 26, 2023, Plaintiff, a California resident, filed this action in Los Angeles County Superior Court against Defendant, Stephen Joseph Quinn (“Quinn”), and Mini of Santa Monica (“Mini SM”). See generally id. Defendant is a Delaware Corporation with its principal place of business in New Jersey. See id. ¶ 2. Plaintiff alleged five causes of action: (1) fraud and deceit; (2) breach of implied covenant of good faith and…