Case 5:00-at-99999 Document 3 Filed 05/28/20 Page 1 of 60 George F. Farah (NY Bar No. GF3472) Rebecca P. Chang (NY Bar No. RC5493) HANDLEY FARAH & ANDERSON PLLC 81 Prospect Street Brooklyn, NY 11201 Tel: (212) 477-8090 Facsimile: (844) 300-1952
[email protected] [email protected] Attorneys for Plaintiffs and the putative Class [Additional Counsel on Signature Page] IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF NEW YORK MARILYN DICKINSON and KATE CONROY, Civ. No.: _________ individually and on behalf of others similarly situated, CLASS ACTION COMPLAINT Plaintiffs, vs. DEMAND FOR JURY TRIAL VOLKSWAGEN GROUP OF AMERICA, INC. and VOLKSWAGEN AG, Defendants. Plaintiffs Marilyn Dickinson and Kate Conroy bring this action against Defendant Volkswagen Group of America, Inc. and Volkswagen AG (collectively, “Defendants” or “Volkswagen”), by and through their attorneys, individually and behalf of all others similarly situated, and allege as follows: INTRODUCTION 1. This is a class action lawsuit brought by Plaintiffs on behalf of themselves and a class of current and former owners and lessees of model years (“MY”) 2018 and 2019 CLASS ACTION COMPLAINT 1 Case 5:00-at-99999 Document 3 Filed 05/28/20 Page 2 of 60 Volkswagen GTI, Golf, Jetta, Passat and Tiguan vehicles equipped with 2.0L TSI engines (the “Class Vehicles” or “Vehicles”). 1 2. This action arises from Volkswagen’s failure, despite its longstanding knowledge, to disclose to Plaintiffs and other consumers that the engines in the Class Vehicles are predisposed to a manufacturing defect which causes them to suddenly and unexpectedly stall and stop while being operated.