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1.1.2.4 Additional Pleadings, Primary Sources, and Practice Tools

The online version of this treatise also includes various pleadings and discovery material, practice tools, and primary sources. They are listed at the bottom of the table of contents found in the left pane on the website and are fully searchable. Search filters allow users to search only for pleadings, only for primary sources, or only for practice tools. It is recommended to search for pleadings using the Advanced Pleadings Search tool, found above the Search box.

Pleadings, generally available in Microsoft Word format, include:

  • • Complaints regarding odometer violations, wreck, salvage and flood abuses, yo-yo sales, prior use, lemon laundering, gray market sales, and other topics, including class complaints;
  • • Discovery including document requests, interrogatories, requests for admissions, discovery enforcement, deposition notices, and deposition transcripts;
  • • Responses to motions to dismiss and summary judgment motions;
  • • Trial documents including trial briefs, voir dire, opening statements, expert reports and exhibits, closing statements, and jury instructions;
  • • Class action documents including class certification motions, class notices, and class settlements;
  • • Attorney fee documents, settlements, and appellate briefs.

Additional primary sources include the text of the federal odometer act prior to recodification, National Motor Vehicle Title Information System (NMVTIS) regulations, National Highway Traffic Safety Administration (NHTSA) odometer interpretations, and various state agency interpretations and letters. Practice tools include sample title transfer documents, alternative weblinks to locate DMV websites, title search forms from each state, sample reports for NMVTIS, Carfax, and Autocheck, the NHTSA odometer study, and various manufacturers’ policy and procedure manuals.