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Tilo’s European Autohaus, that Defendant would transfer
title to the Vehicle to Plaintiff.
At the time Defendant made this agreement with Plaintiff,
Defendant intended [sic] keep the title to the Vehicle in
the name of Defendant and not transfer title to the Vehicle
to Plaintiff as was required per the terms of the agreement
between Plaintiff and Defendant. Defendant has previously
represented to Plaintiff that Plaintiff is the owner of the
Vehicle, yet Defendant continues to refuse to execute any
necessary documents to transfer title to the Vehicle to
Plaintiff. Defendant never intended to transfer the Vehicle
to Plaintiff per Defendant’s earlier representations,
instead Defendant has subsequently represented that
Defendant always intended to demand the return of the
Plaintiff’s Vehicle upon payment in full of the liability
for the Vehicle.
* * * * * * *
As a result of Defendant’s fraudulent statements and acts
and failure to transfer title per the agreement, plaintiff
has suffered damages in the form of monies expended for the
purchase, maintenance, and repair of the Vehicle which
Defendant refuses to transfer to the Plaintiff.
Third Cause of Action - Conversion
* * * * * * *
On June 30, 1998, Defendant wrongfully took possession of
said Vehicle and numerous items of Plaintiff’s personal
property contained inside said Vehicle, against Plaintiff’s
wishes and despite Plaintiff’s objections. Defendant
maintained exclusive possession and control of said vehicle
and items of personal property, and refused to return same
to Plaintiff until July 11, 1999.
* * * * * * *
Defendant’s actions have caused Plaintiff to suffer damages,
including lost work time, transportation costs, and other
damages as a result of Defendant’s deprivation of
Plaintiff’s ownership interest in said vehicle.
Additionally, pursuant to California Civil Code Section 3336
Plaintiff is presumptively entitled to damages for the value
of the converted property in the amount of $40,000.
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