SUMMARIZATION

1. On December 15, 1996, our 1994 Chrysler LHS, mechanically failed. The gears would not go into reverse or park, only as far as neutral. The motor kept running even though the key was turned off. The emergency brake did not release - it was too close to the floor board. The plaintiff, David Vaughn, outlined in his first letter to then, president, Robert Eaton of Chrysler Corporation, all the particulars. The mother of the plaintiff, Betty Vaughn Paul, was in the car, she asked her son, the plaintiff, David Vaughn, to stop and let her out of the car. Mrs. Betty Paul is afraid of hills or anything that is steep. (This being as a result of being scared several times over a period of several years.) Mr. Vaughn did stop approximately 20 feet down the driveway and stated he would back up and let his mother out at the top of the driveway. The LHS would not go in to reverse or park. Mr. Vaughn pulled forward a foot or so and again attempted to go into reverse or park. The gear would go only as far as neutral.

2. Mr. Robert Eaton never received the certified letter, Customer service received this letter. Mr. Bennis of customer service sent a letter to David Vaughn.

3. Mr. David Vaughn, Mr. Watkins, an adjuster for Safeco Insurance, asked for a Grindstaff mechanic to check the LHS. Chrysler Corporation denied this request instead they sent a retired representative from Asheville, North Carolina to inspect the LHS. Mr. Goss, the representative, manually shifted the gears back and forth - never driving the LHS. Mr. Goss' report - which was denied to Grindstaff, Inc. or to Mr. Vaughn and the Safeco adjuster. Nor was Mr. Vaughn or Mr. Watkins notified of this inspection. Chrysler Corporation Service, Mr. Bennis, telephoned to say their inspector found nothing wrong with the car. Please note: The motor that kept running, the emergency brake nor the air bag, which did not deploy, has never been addressed.

4. Telephone calls and letter were sent to Chrysler Corporation as to why these mechanical failures occurred and this was a great concern of safety. No, the undercarriage damage was not repaired, why? Because Chrysler Corporation refused to let a Grindstaff mechanic check the LHS. We knew once the repairs were made, the call from Grindstaff dealership would be to inform us that the LHS was "ready."

5. After months of frustration Mrs. Betty Vaughn Paul, P.O.A for the plaintiff, David Vaughn, went to Congressman William "Bill" Jenkins, to his office in Kingsport, Tennessee, and spoke to Mr. Bill Snodgrass, assistant to Congressman Jenkins. He felt I had a legitimate complaint and called the Consumer Affairs in Nashville, Tennessee. I filled out the complaint form. Letter to Mrs. Paul from Mr. Barry Woody, stating that he had heard from Chrysler Corporation informing him that nothing was wrong with the LHS.

6. Letter to the Consumer Affairs, Mr. Barry Woody, written by Betty Vaughn Paul, requesting my letter and documentation be sent to the National Board of Transportation and Safety Administration in Washington, D.C. for a review and investigation.

7. Mrs. Paul did hear from Mr. Scott Shadle of the NHTSA by telephone. Mr. Shadle inquired about the problems and also mentioned that the Chrysler Sebring was under investigation for a
motor that kept running.

8. Letter and a recall notice from Mr. Jimenez of the NHTSA, was sent to Mrs. Betty Paul, concerning electrical wiring of the 1994 LHS, stating that the gears would not go into reverse or park, etc. This was the first time we received this recall notice. The plaintiff or Grindstaff never received a recall notice.

9. Letter to plaintiff and Mrs. Paul from Safeco Insurance, Mr. Craig Torres, stating to get the repairs done that maybe by then we would have heard from Chrysler. This letter was also sent to Grindstaff where it hung on their bulletin board. In the letter, Mr. Torres stated that the car was under full warranty and that a Grindstaff mechanic should check the LHS, again, Chrysler denied a Grindstaff mechanic to check the LHS.

10. The repair to the undercarriage damage was completed and the plaintiff, David Vaughn and Mrs. Paul drove to Elizabethton, Tennessee to get the LHS. We test drove the car, the car hesitated and the gears still not working properly. When the brakes were applied the car shook upon stopping. We drove back to the dealership. It was the rotors. Chrysler refused to pay, yet the car was under warranty.

11. The LHS was picked up after a lengthy wait in October 1998. We again test drove the LHS. As we came closer to a hill at the red light, black smoke poured from under the hood of the car. The car stalled or hesitated. We returned to Grindstaff and spoke to Mr. Woodard, Manager of the body shop. He raised the hood of the car and a protective covering for the serpentine belt was hanging down. Mr. Woodard had no explanation for the black smoke pouring from under the hood.

12. We picked up the LHS the next day after Mr. Woodard stated we should leave the car. All of the mechanics had left for the day. Mr. David Vaughn accepted the 1994 LHS with great reservations knowing and expressing that the mechanical failures had not been addressed, Mr. Woodard stated to take the car and perhaps it will adjust, since it has been sitting idle at the dealership for so long.

13. The car stalled or hesitated on the thirty miles back to Kingsport. Mrs. Paul drove behind the LHS. Mr. Vaughn left the LHS at Mrs. Paul's home, stating the car hesitated. Mr. Vaughn drove the LHS approximately 50 to 75 miles. As he was leaving Perkins restaurant, coming down the driveway, the car hesitated. He approached a red light to turn on the road to his home. As he depressed the gas pedal, the car accelerated at a high rate of speed almost causing a total collision. Braking as hard as he could, the LHS came to a stop, apparently jarring the serpentine belt loose. Please note, no warning lights ever came on to indicate any problems. Mr. Vaughn pulled into a neighbors level driveway and again, black smoke came from under the hood. This was a week or less after picking the LHS up from Grindstaff.

14. Again, Mrs. Paul notified Chrysler Corporation and other parties, of the latest mechanical failure. This was in October. In February, Mrs. Paul received a letter from Mr. Porterfield stating someone would check the LHS. A retired representative from West Virginia, Mr. Robert Barbary, was sent to check the LHS. With his grandson, they looked under the hood, moved or looked at parts of the LHS, took pictures, and again, the LHS was never driven. In Mr. Barbary's report, which was denied to plaintiff on grounds that it was Chrysler property, Mr. Barbary stated to plaintiff, that he found things to be wrong and he would lite a fire under Chrysler.

15. Mr. Porterfield, telephoned on Monday morning after Mr. Barbary's Saturday afternoon visit to say nothing was found to be wrong with the LHS. I pointed out to Mr. Porterfield that Mr. Barbary used a check list according to him that Chrysler furnished, when I asked how do you determine what is wrong when you don't drive the LHS.

16. A letter from Consumer Affairs, Mr. Barry Woody, stating that he had heard from Chrysler stating we had picked up the LHS and there were not problems. I telephoned Mr. Barry Woody and wrote a letter stating that the LHS had malfunctioned for the second time.

17. The LHS was parked from October until July on the neighbors driveway. When it was returned to Grindstaff, Mr. Bill Snodgrass, assistant to Bill Jenkins, called Mr. Scott Shadle on our behalf telling him of this second mechanical failure and Chrysler ignoring the failures and safety of the LHS.

18. Mr. Scott Shadle gave me the address of Ms. Susan Cishke, director of Safety and 011" Compliance and suggested I write to her. A certified letter to Ms. Cishke, with letters and documentation, was written with no written response. I again went to the Congressman to state I was afraid the letter had gone to customer service. Mr. Snodgrass called Ms. Cishke's office and spoke to a secretary, which she stated my letter and documentation were being reviewed.

19. Mr. Ronnie Davis, service manager of Grindstaff, received a telephone call from Mr. Tony DeBenders, assistant to Ms. Cishke, asking that a monitor be part of the LHS. Mr. Davis reported to Mr. DeBenders that the LHS did hesitate and he had trouble shifting the gears. Mr. Davis revealed this information when I called on Friday, after he had spoken to Mr. DeBenders.

20. Mr. DeBender telephoned me, stating nothing is wrong with the LHS. As well as calling the Congressman's office, telling Mr. Snodgrass that nothing was wrong with the LHS. Mr. Snodgrass called Mrs. Paul relaying the conversation he had with Mr. DeBenders. Mrs. Paul referred Mr. Snodgrass to speak to Ronnie Davis of Grindstaff, that the information from Mr. DeBenders was not true. Mr. Davis stated to Mr. DeBenders that he did have problems with the LHS. Mr. Davis asked Mr. DeBenders, why don't you settle with the plaintiff.? David Vaughn and his mother, Mrs. Paul, they are afraid of this LHS. Ronnie Davis offered to test drive the LHS. A letter to Ronnie Davis, from Mrs. Paul, for David Vaughn, giving permissions to drive the LHS.

21. A letter to Mr. John Harman, with documentation and letter for his review. Mr. Harman's letter and his recommendations.

22. A letter to Mr. Robert Eaton, CEO of Chrysler, stating the problems.

23. A letter to Mr. Schrempp, CEO, Germany Daimler Chrysler, with letters
and documentation.

24. A letter of reply from Mr. Salton, Daimler- Chrysler, Germany, sending
letter to Chrysler in Michigan.

25. A letter from Chrysler Corporation, reply by Mr. Abbot, in reference to our letter to Mr. Schrempp.

26. A letter to NHSTA, Mr. Jiminez with documentation as well as telephone calls.

27. A letter to Consumer Affairs, Nashville, to Mr. Barry Woody.

28. A letter to Bill Snodgrass.

29. An application for a neutral arbitration by the National Center for Dispute Settlements. Four letter of denial by a single Chrysler panel member, Mr. Robert Prophet

30. A letter to the Attorney General of Michigan.

31. Telephone call to Mr. Leigh, Consumer Protection of Atlanta, GA, with advise to take legal action. Ms. Leigh called the Federal Trade Commission, they sent a letter and the Maugen-Moss Act. Meetings with Mr. Steve Grindstaff, owner of Grindstaff, Inc. and Ronnie Davis, to discuss the history of the LHS and the corrected erroneous statements. Mr. Grindstaff stated he had read
the letters I had gave to Mr. Davis with the documentation. Could not understand why Chrysler sponsored National Center for Dispute Settlements, had denied neutral arbitration.

33.A letter from Mr. Barry Woody of Consumer Affairs, Nashville, Tennessee, stating out best course would be to take legal action. Legal action was taken at the eleventh hour, giving Chrysler every chance to act in good faith, to honor the warranty and tell us why the mechanical failures occurred.

34. Three years went by, with car payment of $505.00 a month, full insurance coverage, proof of payments and insurance. Loss of use, car sitting idle on Grindstaff Dealership's lot.

35. Three years, six days, Chrysler had a retired inspector and their attorney come to Elizabethton, Tennessee, where a computer read out was performed, a test drive and a check under the hood was performed. A Chrysler inspector, attorney David Hatfield, and the plaintiff's attorney Lon V. Boyd, were present. A video expert taped the inspection. A report of the inspection.

36. Mrs. Betty Vaughn Paul, had Ron's Transmission, as an expert to check the LHS. This amounted to an eight mile test drive by a hand held computer. The Chrysler Corporation, their attorney and inspector, violated our rights to be present for this inspection. Mrs. Paul showed up during the inspection, unexpected. The hand-held computer inspection, is a complete and total rejection of the plaintiff and Mrs. Paul. The Chrysler's attorneys enclosed a copy of the report from Ron's Transmission Service, which the plaintiff's attorney, Lon V. Boyd, has never received a copy of. The question is, what right did the attorney David Hatfield, and Mr. Thayer, have in securing our report?

37. Telephone call in September 2000 from the NHSTA in Washington, DC, from Ms. Judy
Taylor, inquiring if Chrysler had complied or done anything. She also informed me that many people had never received the recall notice of electrical wiring - harness. A letter to Ms. Judy Taylor with letters and documentation's.

38. Mrs. Betty Vaughn Paul has sent other letters to various people and signs have been made, video tapes outlining the problems and the action which has been taken to try and correct the problems.