DEMAND FOR DOCUMENTS
1. Entire deal jacket 2. Any letters received from anyone acting on the plaintiff’s behalf 3. Invoice 4. All repair orders for this car 5. All insurance estimates and damage reports for this car 6. Deal Recap 7. Expert reports 8. Documents to be used at trial 9. Entire service history 10. All documents used in the certification process 11. Communication with the MFGR regarding the final certification and transmittal any proceeds sent to the MFGR.
12. VINS of all of the certified used cars that were sold by the dealership in the one year before the plaintiff’s transaction that either had 1) an accident/damage reported in CARFAX or 2) known damage to the car before the sale to the customer.
13. VINS of all of the certified used cars that were sold by the dealership in the one year before the plaintiffs transaction 14. If you are going to assert that the damage (alleged) done to the plaintiffs vehicle has no effect on the value or the selling price of the car please bring all records for any vehicle that was sold by the dealership with ANY damage disclosed and/or accident on CARFAX.
15. Any advertisement for the plaintiff’s vehicle 16. Book out sheet for the plaintiff’s vehicle to the financing source 17. Copies of any and all GALVES , NADA or any manuals used by the used car manager or any dealer employee to value used cars 18. Copy of the certification manual applicable to the plaintiffs car 19. Website material pertaining to the quality of certified used cars 20. Dealer license 21. Dealer bond
Cherry Hill Tri Plex