The Dilly, Dally, Delay & Stall Law Firms representing Route 44 Toyota and Toyota USA just woke up!
The Bullying Rose law firm [whose attorney couldn't make it to court on time] ignored this for months, delayed producing their documents and now insists MY car should be tampered with.
Huh?
I have been asked to contact you directly to
discuss NHTSA's inspection of your client's vehicle (a certain 2012 Toyota
Prius C, VIN: JTDKDTB36C1505559) pursuant to a Defect Petition filed by [your client]. The vehicle is also, the subject of a lawsuit which you have commenced
on behalf of [your client] against Toyota Motor Sales, U.S.A., Inc. in Plymouth
District Court, 1259CV871.
Specifically, NHTSA has requested that the
vehicle be operational in order for NHTSA to conduct NHTSA’s testing and due to
the length of time that the vehicle has been dormant, it is anticipated that
certain work may be necessary in order for the vehicle to be made operational.
This likely would include recharging and/or replacing the vehicle's batteries
and potentially various brake components (for instance, NHTSA may request that
the rotors be changed if inspection finds them rusty from lack of use). In
addition, it is anticipated that NHTSA will want to see any Diagnostic Trouble
Codes (“DTC”) stored in the vehicle and once viewed will want the codes cleared
(erased) for purposes of its inspection. I am writing because I have been asked
to confirm in writing your consent on behalf of [your client] for Toyota to perform
the work requested by NHTSA . Please be aware that at the conclusion of NHTSA’s
inspection, any exchanged components would be removed and the original
components would be reinstalled.
My understanding is that the NHTSA inspection
has been scheduled for April 4, 2013 commencing at 7:00 AM at Route 44 Toyota,
Raynham, Massachusetts. Therefore, your consent to the foregoing is needed
ASAP. In addition, by copy of this email to all counsel in the pending action,
I am placing them on notice of NHTSA’s inspection and the above issues.
Finally, please understand that NHTSA’s
inspection of the vehicle is not Toyota’s legal inspection for the purposes of
the pending litigation and it is our intention to have our expert inspect the
vehicle following receipt of written disclosure responses and the completion of [your client’s] deposition.
Keith B. Rose,
Esq.
The Rose Law
Firm, PLLC
501 New Karner
Road
Albany, New York 12205
***NHTSA had the email addresses of the attorneys involved and could have circulated any necessary request.
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