Michael Viramontes v. FCA US LLC

I. BACKGROUND

On January 27, 2020, Plaintiffs commenced this action in the Los Angeles County Superior Court. (See Notice of Removal (“NoR”), Ex. A, Complaint (Docket No. 1-3)). Plaintiffs are residents of Los Angeles County, California. (Id. ¶ 2). FCA is a Delaware corporation with its principal place of business is in Michigan. (Id. ¶ 4; NoR ¶ 28). Cerritos is a California corporation conducting business in Los Angeles County. (Compl. ¶ 5). The Complaint alleges as follows: In August 2016, Plaintiffs purchased a 2017 Chrysler Pacifica (the “Vehicle”), which was manufactured and/or distributed by FCA. (Id. ¶ 8). In connection with the purchase, Plaintiffs received an express warranty in which FCA undertook to “preserve or maintain the utility or performance of the Vehicle or to provide compensation if there is a failure in utility or performance for a specified period of time.” (Id. ¶ 9). The warranty provided, in relevant part, that if a defect developed with the Vehicle during the warranty period, Plaintiffs could “deliver the Vehicle for repair services to [FCA’s] representative and the Vehicle would be repaired.” (Id.). During the warranty…