INTERMEDIATE Replevin/Fraud. Client owns a classic 1958 Buick Special. In June 2020, client took the car to an auto shop for repairs and refurbishment. Client’s work order required her to pay $4,000 upfront and $4,000 upon completion. The work order also indicated work would be completed by August 30, 2020. It is now August 2022, and the auto shop has yet to return the car or, likely, perform any of the promised work. Every time client calls, someone tells her it will be another two weeks or months. Every time client visits the auto shop, the car gets moved to another location. The shop also refuses to refund client any money. Volunteer would draft demand letter and prospective complaint for replevin, breach of contract, and consumer fraud against auto shop, and, if threat does not motivate auto shop to return her car and money, file and pursue suit in the Chancery Division.
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