Nadia Sheibani v. Ford Motor Company

I. Introduction

On April 11, 2019, Plaintiff Nadia Sheibani filed the present lawsuit in state court alleging: (1) breach of warranty in violation of California Civil Code Section 1793.2(d), (2) failure to repair in violation of California Civil Code Section 1793.2(b), (3) failure to make available authorized service and repairs in violation of California Civil Code Section 1793.2(A)(3), (4) breach of express written warranty in violation of California Civil Code Sections 1791.2(a) and 1794, and (5) breach of implied warranty of merchantability in violation of California Civil Code Sections 1791.1 and1794, against Ford Motor Company (“Ford”), Towne Ford, and Does 1 through 100 inclusive (collectively referred to as “Defendants”). See Complaint, attached as Exhibit B to Notice of Removal, Docket No. 1-2. In the Complaint, Plaintiff asserted various deficiencies in their newly purchased 2013 Ford C-Max (“Vehicle”) (id. at ¶ 9); and also that “Defendant and its representatives in this state have been unable to service or repair the Vehicle to conform to the applicable express warranties after a reasonable number of opportunities.” Id. ¶ 10.1 Defendants filed a notice of removal…