Wyatt v. Los Feliz Ford dba Star Ford, and Wells Fargo Dealer Services, Inc.

Los Angeles County Case No. BC 477888

This Complaint seeks relief on behalf of the following three proposed classes:

Class 1: All persons who, in the four years prior to the filing of this complaint, (1) purchased a vehicle from Star Ford for personal use, (2) signed a Retail Installment Sale Contract (“RISC”) that was dated a date prior to the date it was signed, and (3) involved financing at an annual percentage rate greater than 0.00%.

Class 2: All persons who, in the four years prior to the filing of this complaint, (1) purchased a vehicle form Star Ford for personal use pursuant to a RISC (the “New Vehicle”), (2) traded in a vehicle to Star Ford (the “Trade-in Vehicle”) as part of the down payment towards the New Vehicle, and (3) the RISC for the New Vehicle, which was prepared by Star Ford, overstated the prior credit or lease balance due and owing for the Trade-In Vehicle as of the date the RISC was executed.

Class 3: All persons who, in the four years prior to the filing of this complaint, (1) purchased a vehicle in California for personal use (the “New Vehicle”), (2) traded in a vehicle as part of the down payment on the New Vehicle, which vehicle had a balance remaining on its loan or lease (the “Trade-In Vehicle”), (3) the holder of the loan or lease for the Trade-In Vehicle was WFDS, (4) the RISC for the New Vehicle was assigned to WFDS, and (5) the RISC for the New Vehicle overstated the prior credit or lease balance due and owing for the Trade-In Vehicle as of the date the RISC was executed.

Trial has not been set.