Sampson-Et-Al-V-Subaru-Of-America
Case 1:21-cv-10284-RMB-KMW Document 1 Filed 04/27/21 Page 1 of 187 PageID: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY LAURA AND JAMES SAMPSON, ANTHONY VENTURA AND JOANNE FULGIERI VENTURA, ELIZABETH WHEATLEY, and SHIRLEY REINHARD ON HER OWN BEHALF AND ON Civil Action No. BEHALF OF THE ESTATE OF KENNETH REINHARD, individually and on behalf of all others similarly CLASS ACTION COMPLAINT situated, Plaintiffs, JURY TRIAL DEMANDED v. SUBARU OF AMERICA, INC. and SUBARU CORPORATION f/k/a FUJI HEAVY INDUSTRIES, LTD. Defendants. INTRODUCTION 1. Plaintiffs Laura and James Sampson, Anthony Ventura and Joanne Fulgieri Ventura, Elizabeth Wheatley, and Shirley Reinhard, on her own behalf and on behalf of the Estate of Kenneth Reinhard, (“Plaintiffs”) bring this action for themselves and on behalf of all persons in the United States who purchased or leased any 2013-2021 Subaru equipped with an autonomous emergency braking (“AEB”) system that includes “Pre-Collision Braking” and “Reverse Automatic Braking” (“AEB Class Vehicles”) and on behalf of all persons in the United States who purchased or leased any 2013-2021 Subaru equipped with Lane Keep Assist (“LKA 1 Case 1:21-cv-10284-RMB-KMW Document 1 Filed 04/27/21 Page 2 of 187 PageID: 2 Class Vehicles”), against Subaru of America, Inc. (“SOA”) and Subaru Corporation, formerly known as Fuji Heavy Industries, Ltd., (“Subaru Corp.”) (together with SOA, “Subaru” or “Defendants”). The allegations herein are based on personal knowledge as to Plaintiffs’ own experiences and are made as to other matters based on an investigation by counsel, including analysis of publicly available information.
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