DAVID KHATIB v. TOYOTA MOTOR NORTH AMERICA, INC.

I. BACKGROUND

The following contentions are taken from the parties’ briefings and Khatib’s complaint. Khatib operates a taxi service in the Washington D.C. area. (Remand Mot. at 3.) In 2020, Khatib purchased a 2016 Toyota Sienna from a Virginia dealership, Toyota of Woodbridge to use for his taxi service. On August 8, 2021, Khatib picked up a family in the Sienna and, during the trip, his car suddenly and unexpectedly accelerated, causing the car to crash into a concrete median and flip onto its roof. (Comp’l, Dkt. No. 1-2, Ex. 1 ¶ 16.)

CENTRAL DISTRICT OF CALIFORNIA

CIVIL MINUTES - GENERAL

Case No. 8:23-cv-00943-JVS (Ex) Date August 11, 2023 Title David Khatib v. Toyota Motor North America, Inc. et al dealership, Anakin, LLC dba Ourisman CDJR of Woodbridge. Khatib asserts he mistakenly believed that Anakin was the dealership from which he purchased his Sienna. However, he claims he now knows the correct dealership is NGD, LLC dba Toyota of Woodbridge (NGD, LLC was converted in 2023 from LTD, Inc. dba Lustine Toyota Scion). Believing Anakin to have been improperly and fraudulently named because it did not exist at the time Khatib purchased his Sienna,…