Russell

I. FACTUAL AND PROCEDURAL BACKGROUND

24 Wyndham Vacation Resorts, Inc. (“Wyndham Vacation Resorts”) develops, 25 markets and sells membership interests in PTVO Owner’s Association, Inc. (“PTVO”). 26 Ownership in PTVO includes the right to participate in Club Wyndham Access Vacation 27 Ownership Plan and the rights to use accommodations in all the resorts that are a part of 28 the club (collectively, WVR and PTVO will be referred to herein as the “Wyndham Defendants”). These vacation ownership or timeshare interests are measured in points that renew annually and can be redeemed to reserve accommodations. In California, the sale and marketing of timeshare interests is regulated. Plaintiff Dobrina Russell (“Russell” or Plaintiff”), completed a total of six timeshare purchases from Defendants between March 23, 2019 and May 28, 2021. Plaintiff made her first purchase at issue in an agreement for a timeshare interest on March 23, 2019, titled Security Agreement (“March 2019 Agreement”). (Orben Decl., Ex. 1.) The second timeshare purchase was made on February 3, 2020, titled Security Agreement (“February 2020 Agreement”). (Orben Decl., Ex. 2.)…