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1 Fourth, Plaintiffs have not otherwise alleged a claim under state consumer
2 protections laws for any unlawful or unfair conduct.
3 Fifth, Plaintiffs equitable claims fail because Plaintiffs have alleged that
4 there is an inadequate remedy at law. Further, unjust enrichment is not an
5 independent claim under prevailing California law.
6 Sixth, Plaintiffs do not have standing to pursue claims regarding vehicles they
7 did not purchase.
8 This motion is made following the conference of counsel pursuant to
9 L.R. 7-3 that took place on February 24, 2017. This motion is based on this Notice
10 of Motion and Motion to Dismiss, the accompanying Memorandum of Points and
11 Authorities, Toyotas Request for Judicial Notice, the Declaration of Barry M.
12 Hare, the Declaration of David L. Schrader, and all other matters that may be
13 judicially noticed, as well as the files and records in this case, and any oral or
14 documentary evidence that may be adduced at the hearing on this matter.
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16 Dated: March 3, 2017 MORGAN, LEWIS & BOCKIUS LLP
David L. Schrader
17
Esther K. Ro
18 Jahmy S. Graham
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20 By /s/ David L. Schrader
21 David L. Schrader
Attorneys for Defendant
22 Toyota Motor Sales, U.S.A., Inc.
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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW NOTICE OF MOTION AND MOTION TO
LOS ANGELES 2 DISMISS PLAINTIFFS COMPLAINT
DB1/ 90809060.1