CACI No. 3241

Code, §§ 1793.2(d)(2), 1794(b))

If you decide that [name of defendant] or its authorized repair facility

failed to repair the defect(s) after a reasonable number of opportunities,

then [name of plaintiff] is entitled to recover the amounts

[he/she/nonbinary pronoun] proves [he/she/ nonbinary pronoun] paid for the

car, including:

1. The amount paid to date for the vehicle, including finance

charges [and any amount still owed by [name of plaintiff]];

2. Charges for transportation and manufacturer-installed options;

and

3. Sales tax, use tax, license fees, registration fees, and other official

fees.

In determining the purchase price, do not include any charges for items

supplied by someone other than [name of defendant].

[[Name of plaintiff]’s recovery must be reduced by the value of the use of

the vehicle before it was [brought in/submitted] for repair. [Name of

defendant] must prove how many miles the vehicle was driven between

the time when [name of plaintiff] took possession of the vehicle and the

time when [name of plaintiff] first delivered it to [name of defendant] or its

authorized repair facility to fix the defect. [Insert one of the following:]

[Using this mileage number, I will reduce [name of plaintiff]’s

recovery based on a formula.]

[Multiply this mileage number by the purchase price, including any

charges for transportation and manufacturer-installed options, and

divide that amount by 120,000. Deduct the resulting amount from

[name of plaintiff]’s recovery.]]

New September 2003; Revised February 2005, June 2005, December 2011, June