EcoDiesel Bellwether Case Survey

You have been randomly selected as a POTENTIAL California Bellwether Case trial selection. 10 out of 25 of you will be the actual trial cases – but the Court has ORDERED all 25 of you to complete the following survey. Please complete this survey by MARCH 3, 2020.

NOTE: We will provide guidance for some questions below. If you do not understand certain questions, email Mr. Resnick immediately at mresnick@clrattorney.com. THANK YOU!

PLEASE ENTER YOUR UNIQUE 2-DIGIT SURVEY CODE:

1. Are you completing this Fact Sheet in a representative capacity (e.g., on behalf of the estate of a deceased person, or an incapacitated individual, or a minor claiming the damages or injury on which this lawsuit is based)?
[NOTE: If "YES", continue to question no. 2. If "NO", continue to question no. 5.]

Yes No

2. Your Name:

3. Date of Birth:

4. Address:

5. What is your relationship to the represented individual?

6. Were you appointed by a court?
[NOTE: Unless you answered "YES" to question 1, this answer is "NO"]

Yes No

7. Your Name:

8. Your Case Name:
[NOTE: We will complete for you]

My attorney will complete for me

9. Your Northern District of California Case Number:
[NOTE: We will complete for you]

My attorney will complete for me

10(a). Your maiden or other names used or by which you have been known during the last 10 years:
[NOTE: If not applicable, put "NA"]

10(b). Dates during which you were known by such names:
[NOTE: If not applicable, put "NA"]

11(a). Current Address:

11(b). Dates during which you have resided at that address:

12(a). Driver's License Number:

12(b). Driver's License State of Issuance:

12(c). Driver's License Date of Issuance:

12(d). Driver's License Date of Expiration:

13(a). Are you currently married?

Yes No

13(b). If Yes, please provide your spouse's name:
[NOTE: If not applicable, put "NA"]

13(c). If Yes, please state your date of marriage:
[NOTE: If not applicable, put "NA"]

14. Do you have any education (such as college, grad school, etc.) or training (such as trade/tech school or certifications) BEYOND high school?
[NOTE: If "YES", continue below and answer for each such Education. If "NO", continue to question no. 15.]

Yes No

Education #1(a) - Name of School/Training:

Education #1(b) - Dates You Attended or Received Training:

Education #1(c) - State your Major/Degree/Certificate:

Education #1(d) - Date Degree/Certificate Obtained:

Education #2(a) - Name of School/Training:
[NOTE: Complete ONLY if there is a 2nd School/Training. Otherwise, put "NA"]

Education #2(b) - Dates You Attended or Received Training:
[NOTE: Complete ONLY if there is a 2nd School/Training. Otherwise, put "NA"]

Education #2(c) - State your Major/Degree/Certificate:
[NOTE: Complete ONLY if there is a 2nd School/Training. Otherwise, put "NA"]

Education #2(d) - Date Degree/Certificate Obtained:
[NOTE: Complete ONLY if there is a 2nd School/Training. Otherwise, put "NA"]

Education #3(a) - Name of School/Training:
[NOTE: Complete ONLY if there is a 3rd School/Training. Otherwise, put "NA"]

Education #3(b) - Dates You Attended or Received Training:
[NOTE: Complete ONLY if there is a 3rd School/Training. Otherwise, put "NA"]

Education #3(c) - State your Major/Degree/Certificate:
[NOTE: Complete ONLY if there is a 3rd School/Training. Otherwise, put "NA"]

Education #4(a) - Name of School/Training:
[NOTE: Complete ONLY if there is a 4th School/Training. Otherwise, put "NA"]

Education #4(b) - Dates You Attended or Received Training:
[NOTE: Complete ONLY if there is a 4th School/Training. Otherwise, put "NA"]

Education #4(c) - State your Major/Degree/Certificate:
[NOTE: Complete ONLY if there is a 4th School/Training. Otherwise, put "NA"]

Education #4(d) - Date Degree/Certificate Obtained:
[NOTE: Complete ONLY if there is a 4th School/Training. Otherwise, put "NA"]

15(a). Military Service: Have you ever served in any branch of the military?

Yes No

15(b). If "Yes", provide the branch:
[NOTE: If "NO", put "NA"]

15(c). If "Yes", provide the dates of service:
[NOTE: If "NO", put "NA"]

15(d). If "Yes", provide the year of discharge:
[NOTE: If "NO", put "NA"]

15(e). If "Yes", provide the conditions under which you were discharged:
[NOTE: If "NO", put "NA"]

16(a). Employment History: Are you currently employed?

Yes No

16(b). If "Yes", state your current employer:
[NOTE: If "NO", put "NA"]

16(c). If "Yes", state your position:
[NOTE: If "NO", put "NA"]

16(d). If "Yes", state the date your employment began:
[NOTE: If "NO", put "NA"]

17(a). Do you belong to any environmental groups?

Yes No

17(b). If "Yes", identify the environmental group(s):
[NOTE: If "NO", put "NA"]

17(c). If "Yes", state the dates of membership:
[NOTE: If "NO", put "NA"]

18(a). Do you donate to any environmental causes?

Yes No

18(b). If "Yes", identify the recipient(s) of the donation(s):
[NOTE: If "NO", put "NA"]

18(c). If "Yes", identify the frequency of the donation(s):
[NOTE: If "NO", put "NA"]

19. Have you been convicted of a felony within the last 10 years?
[NOTE: This is asking if you have been CONVICTED of a felony within the last 10 years, NOT arrested or charged.]
[NOTE: The rules of Federal evidence requires all plaintiffs to answer this question - it is normal. Do not be alarmed!]

Yes No

20(a). If "Yes" to Question 19, identify the charge for which you were convicted:
[NOTE: If "NO", put "NA"]

20(b). If "Yes" to Question 19, identify the court where you were convicted:
[NOTE: If "NO", put "NA"]

20(c). If "Yes" to Question 19, identify the criminal action number assigned to the case:
[NOTE: If "NO", put "NA"]

20(d). If "Yes" to Question 19, identify the sentence imposed:
[NOTE: If "NO", put "NA"]

21. Are any felony criminal charges currently pending against you?
[NOTE: This is asking if there are CURRENTLY any criminal charges PENDING against you.]
[NOTE: The rules of Federal evidence requires all plaintiffs to answer this question - it is normal. Do not be alarmed!]

Yes No

22(a). If "Yes" to Question 21, identify the charges:
[NOTE: If "NO", put "NA"]

22(b). If "Yes" to Question 21, identify the jurisdiction where the matter is pending:
[NOTE: If "NO", put "NA"]

22(c). If "Yes" to Question 21, describe the status of the proceedings:
[NOTE: If "NO", put "NA"]

23(a). Have you ever been a plaintiff in another lawsuit?

Yes No

23(b). If "Yes", identify the court:
[NOTE: If "NO", put "NA"]

23(c). If "Yes", identify the case name:
[NOTE: If "NO", put "NA"]

23(d). If "Yes", identify the names of the adverse parties:
[NOTE: This is asking for the names of the parties ADVERSE/IN CONFLICT to you]
[NOTE: If "NO", put "NA"]

23(e). If "Yes", identify the civil action number, if filed:
[NOTE: If "NO", put "NA"]

23(f). If "Yes", state how the case resolved:
[NOTE: If "NO", put "NA"]

24(a). Have you been compensated in any way, either in whole or in part, either in money or in-kind, for the damages you have alleged in this matter?

Yes No

24(b). If "Yes", identify the type of compensation:
[NOTE: If "NO", put "NA"]

24(c). If "Yes", state the amount of compensation:
[NOTE: If "NO", put "NA"]

24(d). If "Yes", identify the source of compensation:
[NOTE: If "NO", put "NA"]

24(e). If "Yes", state the date of compensation:
[NOTE: If "NO", put "NA"]

25(a). Other than this case, have you been involved with any other claims or cases concerning the Subject Vehicle?

Yes No

25(b). If "Yes", identify the other persons or entities against whom the claims were made or the lawsuits were filed:
[NOTE: If "NO", put "NA"]

25(c). If "Yes", state the date of the claims or lawsuits:
[NOTE: If "NO", put "NA"]

25(d). If "Yes", state where the claims or lawsuits were filed:
[NOTE: If "NO", put "NA"]

25(e). If "Yes", provide the status of the claims or lawsuits:
[NOTE: If "NO", put "NA"]

26. Identify every person or entity with a financial interest in the claims asserted in this lawsuit, including but not limited to co-owners of the Subject Vehicle.
[NOTE: Include the name of any bank or lender on the registration such as Dodge Credit, etc.]

27. Provide the Make, Model, and Model Year for the Subject Vehicle.
[NOTE: We will complete for you]

My attorney will complete for me

28. Provide the VIN for the Subject Vehicle:
[NOTE: We will complete for you]

My attorney will complete for me

29. When did you acquire the Subject Vehicle?
[NOTE: We will complete for you]

My attorney will complete for me

30. Did you purchase or lease the Subject Vehicle when first acquired?
[NOTE: We will complete for you]

My attorney will complete for me

31. If you PURCHASED the Subject Vehicle, what was the base purchase price of the vehicle, excluding taxes, registration, and other related purchase costs?
[NOTE: Please consult your purchace agreement and provide the actual, EXACT amount. If you no longer have the agreement or cannot find it, please contact the selling party and try and locate it. This is important for your case.]

32(a). If you LEASED the Subject Vehicle, what was the base purchase price of the vehicle, excluding taxes, registration, and other related purchase costs?
[NOTE: Please consult your purchace agreement and provide the actual, EXACT amount. If you no longer have the agreement or cannot find it, please contact the selling party and try and locate it. This is important for your case.]

32(b). If you LEASED the Subject Vehicle, state your down payment:

32(c). If you LEASED the Subject Vehicle, state any Manufacturer Rebate Offered at the time of lease:

32(d). If you LEASED the Subject Vehicle, state your monthly payment:

32(e). If you LEASED the Subject Vehicle, state how many total months your lease is:

33(a). What is the total amount of additional expenses you incurred at the time you acquired the Subject Vehicle?
[NOTE: This is the total of taxes, registration costs, warranty costs, GAP insurance, clear bra, service/maintenance plan, etc. (anything additional)]

33(b). State the amount of taxes you paid at the time you acquired the Subject Vehicle, if any:

33(c). State the amount of registration costs you paid at the time you acquired the Subject Vehicle, if any:

33(d). State the amount of warranty costs (such as an extended warranty) you paid for at the time you acquired the Subject Vehicle, if any:

33(e). State the amount of GAP insurance you paid at the time you acquired the Subject Vehicle, if any:

33(f). State the amount of accessories (example, clear bra) you paid at the time you acquired the Subject Vehicle, if any:

33(g). State the amount of any service/maintenance plan you paid for at the time you acquired the Subject Vehicle, if any:

33(h). Identify any "extra" item you paid for at the time you acquired the Subject Vehicle AND state the cost, if any:

33(i). Identify any "extra" item you paid for at the time you acquired the Subject Vehicle AND state the cost, if any:

34. If you leased the Subject Vehicle, when does the lease expire?

35(a). If you leased the Subject Vehicle, did you exercise a purchase option during or at the end of your lease?

Yes No

35(b). If you exercised a purchase option at the end of your lease, what were the terms?

36. Identify the name and location where you bought or leased the Subject Vehicle.

37(a). Provide the current license plate number of the Subject Vehicle:

37(b). Provide the current state of registration of the Subject Vehicle.

38. Identify the registered owner(s) of the Subject Vehicle.
[NOTE: Please include yourself and any co-owners]

39(a). If any registered owner of the Subject Vehicle is a business, provide the Business Entity's Legal Name:

39(b). If any registered owner of the Subject Vehicle is a business, provide any "Doing Business" (d/b/a) of the business:

39(c). If any registered owner of the Subject Vehicle is a business, provide the legal structure (Corporation, LLC, Partnership, Sole Proprietorship, etc.):

39(d). If any registered owner of the Subject Vehicle is a business, provide the primary business address:

39(e). If any registered owner of the Subject Vehicle is a business, provide the primary business telephone number:

39(f). If any registered owner of the Subject Vehicle is a business, provide the business website address:

39(g). If any registered owner of the Subject Vehicle is a business, provide the business Tax I.D. Number:

40. Was the Subject Vehicle new or used when you acquired it?

New Used

41. If the Subject Vehicle was used when you acquired it, please state the mileage of the Subject Vehicle when you acquired it:

42(a). Were there other vehicles you considered purchasing or leasing before deciding on the Subject Vehicle?

Yes No

42(b). If yes, please identify the makes and models of the other vehicles you considered purchasing or leasing:
[NOTE: Please list all vehicles you were considering]

43. Do you still possess the Subject Vehicle?

Yes No

44(a). If you no longer possess the Subject Vehicle, select how you relinquished it:

Sold Traded-In Totaled in Accident Gave Away/Charity

44(b). If you no longer possess the Subject Vehicle, provide the state and location where you relinquished it:

44(c). If you no longer possess the Subject Vehicle, provide the price or other compensation received, if applicable:

44(d). If you no longer possess the Subject Vehicle, provide the name and location of any person or business to which you sold, traded-in or otherwise relinquished the vehicle:

45(a). If you still possess the Subject Vehicle, where do you keep it when it is not being driven?

45(b). If you still possess the Subject Vehicle, state the date it was last driven:

45(c). If you still possess the Subject Vehicle, what is the current mileage?

46(a). Has the Subject Vehicle been used for any business or work purposes?

Yes No

46(b). If "Yes", describe how the Subject Vehicle was used for business or work purposes. For example, how was the vehicle used for these purposes, by whom, and how frequently?

46(c). If "Yes", have you or others claimed reimbursements or other tax benefits for the business or work use of the Subject Vehicle?

Yes No

47(a). Did you receive a written warranty with the Subject Vehicle?

[NOTE: Please email a scan/or cameraphone pictures of all warranty documentation (such as a front and back of the warranty guide/booklet) to Mr. Resnick at mresnick@clrattorney.com]

Yes No

47(b). If "Yes", please list the warranty(ies):

48(a). At the time you purchased the Subject Vehicle or at any time thereafter, did you purchase an optional extended warranty or vehicle service agreement for the Subject Vehicle?

[NOTE: Please email a scan/or cameraphone pictures of all extended warranty or vehicle service agreement documentation (such as a front and back of the extended warranty/service contract) to Mr. Resnick at mresnick@clrattorney.com]

Yes No

48(b). If "Yes", identify the warranty provider:

48(c). If "Yes", state the cost you paid:

49. Have you ever purchased or leased a vehicle other than the Subject Vehicle?
[NOTE: Assuming "Yes", please complete the information below for the last 3 vehicles you had]

Yes No

Vehicle #1 - Make:

Vehicle #1 - Model:

Vehicle #1 - Year:

Vehicle #1 - Engine Type:

Vehicle #1 - Purchased or Leased:

Purchased Leased

Vehicle #1 - Name of the dealership or person that you purchased or leased Vehicle 1 from:

Vehicle #1 - Date of purchase or lease:

Vehicle #1 - New or Used?

New Used

Vehicle #1 - If you no longer own Vehicle 1, state the date you sold the vehicle or the date the lease was terminated:

Vehicle #2 - Make:

Vehicle #2 - Model:

Vehicle #2 - Year:

Vehicle #2 - Engine Type:

Vehicle #2 - Purchased or Leased:

Purchased Leased

Vehicle #2 - Name of the dealership or person that you purchased or leased Vehicle 2 from:

Vehicle #2 - Date of purchase or lease:

Vehicle #2 - New or Used?

New Used

Vehicle #2 - If you no longer own Vehicle 2, state the date you sold the vehicle or the date the lease was terminated:

Vehicle #3 - Make:

Vehicle #3 - Model:

Vehicle #3 - Year:

Vehicle #3 - Engine Type:

Vehicle #3 - Purchased or Leased:

Purchased Leased

Vehicle #3 - Name of the dealership or person that you purchased or leased Vehicle 3 from:

Vehicle #3 - Date of purchase or lease:

Vehicle #3 - New or Used?

New Used

Vehicle #3 - If you no longer own Vehicle 3, state the date you sold the vehicle or the date the lease was terminated:

50(a). Identify which of the following, if any, you relied on or considered in purchasing or leasing the Subject Vehicle (check all that apply):
[NOTE: Your case will be MUCH stronger if you make sure to include "The EcoDiesel badge on the vehicle" as part of your selection(s) below]

50(b). If "Other" was also selected, please explain here:

51. Do you still have copies of any of the material(s) referenced in question 50?

[NOTE: If you answered "Yes", please email a scan/or cameraphone pictures of any such materials to Mr. Resnick at mresnick@clrattorney.com]

Yes No

52(a). Has the Subject Vehicle, or any of its components or parts, ever been repaired or replaced outside of an official recall performed by an authorized Jeep or Ram dealership, including by you, by someone else at your direction, or by a previous owner or lessee (to the best of your knowledge)?

Yes No

52(b). If "Yes", describe the repair or replacement:

52(c). If "Yes", state the date on which the repair or replacement occurred:

52(d). If "Yes", state who performed the repair or replacement:

52(e). If "Yes", state how much the repair or replacement cost:

53(a). Have you obtained the EPA- and CARB-approved emissions modification (AEM) for the Subject Vehicle?

Yes No

53(b). If "Yes", where did you get the AEM software installed?

53(c). If "Yes", when did you get the AEM software installed?

54(a). Have there been any modifications or alterations to the Subject Vehicle, the effect or purpose of which was to modify, alter, bypass, or replace the emissions, exhaust, transmission, or engine control software, systems, devices or elements of design on your Subject Vehicle, other than as part of an official recall or repair performed by an authorized Jeep or Ram dealership, including by you, by someone else at your direction, or by a previous owner or lessee (to the best of your knowledge)? For example, this includes, but is not limited to, installation of any aftermarket tuning device, diesel tuner or tuner kit, diesel programmer, chip, delete or delete pipe, or other modifications to the Subject Vehicle’s software, calibration, or hardware. This also includes any software, hardware or calibration that affects, removes, inhibits or modifies the Subject Vehicle’s exhaust gas recirculation (EGR), selective catalytic reduction (SCR), diesel particulate filter (DPF), or other systems?

[NOTE: You should include any modification to the Subject Vehicle, even if the modification was subsequently removed (for example, if you installed an aftermarket tuning device or software that was subsequently overwritten at an authorized dealership, you should describe that device or software here)

Yes No

54(b). If "Yes", identify the part, component, or software:

54(c). If "Yes", identify the manufacturer:

54(d). If "Yes", state when you acquired it:

54(e). If "Yes", state the price paid for it:

54(f). If "Yes", state the reason for acquiring it:

55. Identify all losses or out of pocket expenses that you believe you have incurred after learning of the allegations that the Subject Vehicle was equipped with an emissions defeat device (e.g., expenses for repairs, alternative transportation, towing, etc.).

56(a). Did you change your driving habits with respect to the Subject Vehicle at any time because of the facts and circumstances alleged in this lawsuit?

Yes No

56(b). If "Yes", please describe such a change in driving habits, including any period of time when you stopped driving the Subject Vehicle.

56(c). If "Yes", if you used alternative transportation because of the facts and circumstances alleged in this lawsuit, describe what alternative transportation you used and the cost of such alternative transportation, if any:

57. Have you attempted to sell, trade in, or otherwise dispose of the Subject Vehicle after January 12, 2017?

Yes No

58(a). If you attempted to sell, trade in, or otherwise relinquish the Subject Vehicle, please identify any efforts you undertook to sell or otherwise relinquish the Subject Vehicle, including all online, mobile, print, or other advertising:

58(b). If you attempted to sell, trade in, or otherwise relinquish the Subject Vehicle, please identify any offers made on the Subject Vehicle, including the date, amount, and party making the offer:

58(c). If you attempted to sell, trade in, or otherwise relinquish the Subject Vehicle, please identify any dealership you communicated with about a trade-in, and the trade-in value offered by any dealership:

59(a). If you sold or traded-in the Subject Vehicle, please identify the date of sale or trade-in:

59(b). If you sold or traded-in the Subject Vehicle, please identify how it was sold or traded in:

59(c). If you sold or traded-in the Subject Vehicle, please identify any counterparty to the sale or trade-in:

59(d). If you sold or traded-in the Subject Vehicle, please identify any money or other consideration received in exchange for the Subject Vehicle:

59(e). If you sold or traded-in the Subject Vehicle, please identify the mileage on the date of sale or disposal:

59(f). If you sold or traded-in the Subject Vehicle, please identify the condition of the vehicle at the time of sale or disposal:

60. Would you be willing and able to have your case tried in federal court in the Northern District of California?

[NOTE: You want to answer "Yes"]

Yes No

61(a). Have you or someone on your behalf blogged, uploaded, or posted any information, descriptions, videos or other material to web pages, social networking sites, blog sites, online forums, or the Internet regarding: (i) the Subject Vehicle; (ii) the allegations made in this matter; or (iii) your injuries and damages?

Yes No

61(b). If "Yes", please identify the blog, web page, online forum, Internet site or social networking site:

61(c). If "Yes", state the date of the post or upload;

61(d). If "Yes", state the username or handle used: