Rainer Warner, on and about 1 July 2011 purchased a 300zx 90-96 Nissan Coupe/2+2 Model NV Full Body Kit (260623771109).
8. As documented this item was purchased through ebay, payment through paypal with a potential shipping date through NRG MotorTrend for shipment by R+L Shipping
Exhibit W003, Exhibit W004
9. An e-mail pertaining to shipment of item was received on July 2011. The product was entered into the shipping process. It will be inspected and packed for shipment
with an emphasis on the procedure for delivery of DAMAGED GOODS
Exhibit W004 and W005
10. The product was received on 13 July 2011. The Plaintiff(s) Rainer Warner refused to accept the shipment due to the damages of the freight/kit. Plaintiff will submit to the court pictures as evidence of the subject property damages. Exhibits W006 and W007
11. The Plaintiff(s) per the procedures for claim for damages proceeded with a phone call to the company to rectify the situation.
12. A representative from the company requested for pictures of the damages so that a claim can be expedited. Plaintiff uploaded the photos on 13 July 2011. The representative responded that a claim will be started so that a replacement kit will be sent asap.
see Exhibits W008 and W009
13. Plaintiff, on 23 August 2011inquired about the status of the full body kit; no response from Defendant.
14. Plaintiff, on 13 September 2011inquired about the status of the full body kit; company replied with bogus shipping and tracking information.
see Exhibits W010 and W011
15. Plaintiff, on 14 September 2011responded about the status of the full body kit; the response was sorry for the mix, and we will get back to you.
16. Plaintiff, on 14 October 2011inquired about the status of the full body kit; no response from Defendant. see Exhibits W012 and W013
17. Plaintiff, on 11 December 2011called about the status of the full body kit; spoke with Defendant claim he was waiting for the part to come from China.
18. Plaintiff, on 15 February 2012 called about the status of the full body kit; spoke with Defendant claim he was waiting for the part to come from China.
19. Plaintiff, on 10 April 2012 called about the status of the full body kit; spoke with Defendant claim he was waiting for the part to come from China.
20. Plaintiff, on 4 June 2012 called about the status of the full body kit; spoke with Defendant claim he had the rear and side skirts was waiting for the front end to come from China, and to check with him next month.
21. Plaintiff, on 16 July 2012 called about the status of the full body kit; spoke with Defendant claim he was waiting for the part to come from China.