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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 1
CAUSE NO 2015-73882
MARK OBERHOLTZER AND sect IN THE DISTRICT COURT OFMARK-1 PLUMBING INC sect
sect
Plaintiffs sectsect v sect HARRIS COUNTY TEXAS
sectCHARLIE THOMAS FORD LTD sectDBA AUTONATION FORD sectGULF FREEWAY sect
sectDefendant sect 113th JUDICIAL DISTRICT
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT
COME NOW MARK OBERHOLTZER and MARK-1 PLUMBING INC Plaintiffs
in the above-styled cause hereby complaining of CHARLIE THOMAS FORD LTD
DBA AUTONATION FORD GULF FREEWAY Defendant and for this cause of action
would respectfully show the Court as follows
IDISCOVERY CONTROL PLAN
1 Plaintiffs intend to conduct this cause under a Level Two (2) discovery
control plan pursuant to Rule 1903 of the Texas Rules of Civil Procedure
IIPARTIES AND SERVICE
2 Plaintiff MARK OBERHOLTZER (hereinafter referred to as ldquoPlaintiffrdquo or
ldquoMarkrdquo) is an individual residing in Galveston County Texas and may be contacted
through his undersigned attorneys at 2211 Strand Suite 201 Galveston Texas 77550
3 Plaintiff MARK-1 PLUMBING INC (hereinafter referred to as ldquoPlaintiffrdquo
or ldquoCorporationrdquo) is a for-profit corporation incorporated under the laws of the State of
12142015 1045Chris Daniel - District Clerk Harris C
Envelope No 82By SHELLEY B
Filed 12142015 1045
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 2
Texas and may be contacted through its undersigned attorneys at 2211 Strand Suite 201
Galveston Texas 77550
4 Defendant CHARLIE THOMAS FORD LTD DBA AUTONATION
FORD GULF FREEWAY (hereinafter referred to as ldquoDefendantrdquo) is a Texas limited
partnership with its principal office address as 12227 Gulf Freeway Houston Texas
77034 and may be served with process by serving its registered agent Corporation Service
Company dba CSC-Lawyers Incorporating Service Company at 211 E 7th St Ste 620
Austin Texas 78701-3218
IIIJURISDICTION AND VENUE
5 The exercise of this Courtrsquos jurisdiction over the Defendant is proper This
Court has personal jurisdiction over Defendant because it avails itself of the privilege of
doing business in the State of Texas and the subject matter of this action arises under the
common law and statutes of the State of Texas The amount in controversy exceeds the
minimum jurisdictional limits of this Court
6 Venue is proper in Harris County Texas because all or a substantial part of
the events or omissions giving rise to the claim occurred in Harris County Texas TEX
CIV PRAC amp R EM CODE sect 15002(a)(1)
IVBACKGROUND
7 On October 23 2013 Plaintiff Mark-1 Plumbing Inc (ldquoMark-1rdquo) entered
into a transaction with Defendant involving the trade-in of a 2005 Ford F-250 pickup
truck VIN 1FTSX21P15EC91985 in exchange for a 2012 Ford F-250 pickup truck VIN
1FT7W2BT2CEA10391 plus an installment sales contract This was Plaintiffrsquos first and
only transaction with Defendant
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 3
8 The transactional documents between Mark-1 and the Defendant included
a ldquoRetail Purchase Agreementrdquo on its face applicable to a ldquolsquoSellerrsquo or lsquoDealerrsquo Retail
Purchase Agreement for a Motor Vehiclerdquo which contained an ldquoArbitration Agreementrdquo
and a ldquoConditional Delivery Agreementrdquo While such written documents admittedly
applied to the sale of the new vehicle Mark-1 purchased they do not apply to the traded-
in vehicle andor they are wholly and completely silent as to subsequent intervening
superseding torts committed by the Defendant which breached common law duties owed
to Plaintiffs such breaches causing severe permanent injury to Plaintiffs and
consequential and punitive damages Moreover the Arbitration Clause in particular and
the total documents generally give no indication nor do they evidence the exchange of
consideration which would reasonably support any contention that such Clause would
limit claims assertable for the Defendantrsquos subsequent sale lease loan or transfer of the
traded-in vehicle with clearly identifiable markings of Plaintiffs upon it to criminals
terrorists jihadists or others of obviously ill-motive
9 While waiting for the paperwork to be processed Plaintiff began peeling off
the ldquoMark-1 Plumbing Incrdquo decal located on the truckrsquos doors when Defendantrsquos
salesman Edgar Velasquez instructed Plaintiff to stop Mr Velasquez told Plaintiff not
to worry about the decal and that peeling the decal off would blemish the vehicle paint
Consistent with Defendantrsquos advertising to potential customers to ldquolet them handle itrdquo
(see Exhibit A) Mr Velasquez further stated that the dealership had something that
works better for removal and they would use it to remove the decal In relying on Mr
Velasquezrsquos statements Plaintiff ceased peeling off the decal and trusted that the decals
would be removed prior to resale At no time did Velasquez or any other agent servant or
employee of the Defendant tell Plaintiff that Defendant would leave the decals on the
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 4
truck which would be transferred in some fashion to international jihadists conducting
warfare upon innocents in Syria and Plaintiff was not in any conceivable way told
informed or placed on notice that precisely such an incomprehensible and horrific
eventuality would actually occur
10 Over the years Plaintiffs have sold as many as five to ten trucks to different
dealers in Texas Through these transactions Plaintiffs found it to be common practice
for dealerships to remove the decals on vehicles prior to reselling them Onnone of those
occasions have any of those dealers transferred to international jihadists the traded-in
vehicle with Plaintiffsrsquo identifying markings still upon them
11 According to a CARFAX Vehicle History Report (see Exhibit B) the vehicle
was listed as a dealer vehicle sold at a Texas auto auction on November 11 2013 On
December 18 2013 the vehicle was exported from Houston Texas and imported to
Mersin Turkey
12 On December 15 2014
Caleb Weiss of The Long War
Journal tweeted the following
propaganda image of Plaintiffsrsquo Ford
F-250 with an anti-aircraft gun
mounted on it fighting on the front
lines in Syria for Ansar al-Deen a
jihadist group operating near Aleppo
in Syria Plaintiffsrsquo logo and phone
number were still on the vehicle
door
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 5
Within 48 hours the photograph had gone viral via the Internet and multiple news
outlets
13 On December 17 2014 while travelling to Corpus Christi Mark received a
phone call from his secretary Juli Hammonds Ms Hammonds explained to him the
breaking news stories His initial reactions were of utter shock and sheer disbelief
14 By the end of the day Mark-1rsquos office Mark-1rsquos business phone and Markrsquos
personal cell phone had received over 1000 phone calls from around the nation These
phone calls were in large part harassing and contained countless threats of violence
property harm injury and even death These phone calls included but were not limited
to individuals who were
(a) irate and yelling expletives at whomever answered the
phone
(b) degrading to whomever answered the phone regarding
their stupidity
(c) singing in Arabic for the duration of the phone call or voice
message recording
(d) making threats of injury or death against Mark-1rsquos
employees family children and grandchildren in violent
lurid and grossly specific terms and
(e) directing expletive-laced death threats to whomever
answered the phone
Only a precious few of the calls contained support for the Plaintiffs knowing that Plaintiffs
did not support terrorists However that scant number of positive calls in no way
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8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 7
18 On or about December 17 2015 four agents from the United States
Department of Homeland Security arrived at Plaintiffrsquos office in Texas City Texas The
Homeland Security Agents met with Vice President of Mark-1 for approximately one to
two hours During this time period he was not allowed to leave the premises After
concluding their investigation the Homeland Security Agents left him with the sinister
admonition that ldquothere are crazy people out thererdquo and to ldquoprotect himself at all timesrdquo
19 In early January 2015 Mark was met by FBI agents at his office The FBI
Agents conducted a very brief and cordial investigation After concluding their
investigation the FBI Agents once again reiterated that Mark must ldquoprotect himselfrdquo
20 In relying on the advice from both the Homeland Security and FBI Agents
Mark began carrying around a handgun for personal protection Additionally local police
made it routine to include his home and office on its routes But these steps in no way
diminish or mitigate the fear anxiety mental anguish and apprehension Mark feels for
his family or that of his family members
21 Throughout the duration of this situation TV stations and news agencies
both local and national have constantly contacted Plaintiffs for an interview Camera
crews were found videotaping Mark-1rsquos and its employeersquos personal automobiles Camera
crews went to Markrsquos house in an attempt to cover the story One news crew even went as
far as arriving at Mark-1rsquos secretary Juli Hammondrsquos daughterrsquos apartment requesting
an interview
22 Demonstrating the breadth and depth of the dissemination Mark has been
contacted by a vast number of news agencies regarding this situation including but not
limited to USA Today CBS NBC and Inside Edition
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 8
23 On December 18 2014 the final episode of the late-night comedy television
series The Colbert Report began with the segment ldquoTexanrsquos Truck in Syriardquo which was a
news story about a Mark-1 Plumbing truck now being used as an anti-aircraft gun in Syria
This episode was watched by 2481 million viewers making it the most watched episode
ever in the showrsquos history As of December 7 2015 the segment ldquoTexanrsquos Truck in Syriardquo
has an additional 67557 views on Comedy Centralrsquos website The widespread viewing of
the segment increased the volume of the harassing and threatening phone calls and has
immeasurably added to the suffering of Mark his family his employees and their families
24 The harassing and threatening phone calls continued for at least three
weeks from when the news story was officially reported Plaintiffs experienced at least
100-200 phone calls per day over this span of time Since that time Plaintiffs continue to
receive one or two phone calls per week However whenever ISIS commits an atrocity
that is reported nationally which occurs with distressing frequency Plaintiffs receive
more phone calls than normal all over again
25 On September 20 2015 the 67th Primetime Emmy Awards were held The
Colbert Report was nominated for ldquoOutstanding Directing for a Variety Seriesrdquo As part of
its show time nomination The Colbert Report included a bit of ldquoTexanrsquos Truck in Syriardquo
The 67th Primetime Emmy Awards was watched by 119 million viewers As a result
Plaintiffs suffered yet another period of non-stop phone calls averaging 100-200 phone
calls per day Plaintiff continues to receive threatening and harassing phone calls
practically each day Nearly one year has passed since the initial news story broke and
Plaintiffs still receive harassing phone calls and threats to this day
26 Through absolutely no fault of their own Plaintiffs have suffered and
continue to suffer damages directly resulting from Defendantrsquos failure to remove the decal
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 9
prior to resale as promised Plaintiffsrsquo plumbing repair work and all other sources of its
revenues have been substantially impacted and its reputation damaged beyond
rehabilitation As a direct result of the damage to Plaintiffsrsquo reputation Plaintiffs have lost
an excess of $100000000
VCAUSES OF ACTION
A RESPONDEAT SUPERIOR
27 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition At all times material to this Petition Defendantrsquos salesman was an employee
or agent of Defendant The acts of the employee were performed while in the employment
of Defendant and were within the course and scope of that employment or within the
authority delegated to the employee Employee was acting in furtherance of Defendantrsquos
business the accomplishment for which the employee was hired
28 Defendant is liable for the negligent acts and omissions of its employees
under the doctrine of vicarious liability or respondeat superior
29 As a result of Defendantrsquos negligent acts and omissions Plaintiffs have
suffered pecuniary harm and request compensatory and punitive damages in an amount
to be determined at trial
B JOINT AND SEVERAL LIABILITY
30 Additionally Defendant is directly liable for the acts and omissions of its
agents servants and employees in allowing a traded-in vehicle with clearly identifiable
marking of its previous business owner to be placed into the stream of commerce without
first removing said identifying markings such that the truck could fall into the hands of
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 10
criminals terrorists or jihadists and be photographed in circumstances which could and
did bring about Plaintiffrsquos severe injury and their incurring of consequent damages
C LIABILITY FOR NEGLIGENCE GROSS NEGLIGENCE AND COMMONLAW TORTS
31 As hereinafter set out in detail Defendant is liable to Plaintiffs for its
negligence and common law torts and for all economic andor compensatory damages
which have been suffered in the past and which in reasonable probability will be suffered
in the future Moreover Defendantrsquos conduct has been so outrageous malicious and
consciously indifferent to the overwhelmingly likely severe harm of the Plaintiffs as to
constitute gross negligence as that term is understood in Texas law for which Plaintiffs
herein seek punitive damages as permitted by common law andor Texas Civil Practice
amp Remedies Code sect 41002
D COMMON-LAW FRAUD
32 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant made a material representation regarding removal of the decals
to Plaintiff to induce him into the transaction Defendant either knew its material
representation regarding removal of the decals was false when stated or Defendant
recklessly stated its material representations as positive assertions without knowledge of
their truth Defendant made these representations with the intent that Plaintiff rely on
them Plaintiff did rely on the representations to his detriment
33 Defendantrsquos false representations directly and proximately caused Plaintiffs
to suffer substantial past damages and in reasonable probability will cause Plaintiffs to
continue to suffer damages into the future
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
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Exhibit A
8202019 Oberholtzer Lawsuit
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-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
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MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
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eserved
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ind a Vehicle
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ease vs Buy
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Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
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Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
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2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 226
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 2
Texas and may be contacted through its undersigned attorneys at 2211 Strand Suite 201
Galveston Texas 77550
4 Defendant CHARLIE THOMAS FORD LTD DBA AUTONATION
FORD GULF FREEWAY (hereinafter referred to as ldquoDefendantrdquo) is a Texas limited
partnership with its principal office address as 12227 Gulf Freeway Houston Texas
77034 and may be served with process by serving its registered agent Corporation Service
Company dba CSC-Lawyers Incorporating Service Company at 211 E 7th St Ste 620
Austin Texas 78701-3218
IIIJURISDICTION AND VENUE
5 The exercise of this Courtrsquos jurisdiction over the Defendant is proper This
Court has personal jurisdiction over Defendant because it avails itself of the privilege of
doing business in the State of Texas and the subject matter of this action arises under the
common law and statutes of the State of Texas The amount in controversy exceeds the
minimum jurisdictional limits of this Court
6 Venue is proper in Harris County Texas because all or a substantial part of
the events or omissions giving rise to the claim occurred in Harris County Texas TEX
CIV PRAC amp R EM CODE sect 15002(a)(1)
IVBACKGROUND
7 On October 23 2013 Plaintiff Mark-1 Plumbing Inc (ldquoMark-1rdquo) entered
into a transaction with Defendant involving the trade-in of a 2005 Ford F-250 pickup
truck VIN 1FTSX21P15EC91985 in exchange for a 2012 Ford F-250 pickup truck VIN
1FT7W2BT2CEA10391 plus an installment sales contract This was Plaintiffrsquos first and
only transaction with Defendant
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 3
8 The transactional documents between Mark-1 and the Defendant included
a ldquoRetail Purchase Agreementrdquo on its face applicable to a ldquolsquoSellerrsquo or lsquoDealerrsquo Retail
Purchase Agreement for a Motor Vehiclerdquo which contained an ldquoArbitration Agreementrdquo
and a ldquoConditional Delivery Agreementrdquo While such written documents admittedly
applied to the sale of the new vehicle Mark-1 purchased they do not apply to the traded-
in vehicle andor they are wholly and completely silent as to subsequent intervening
superseding torts committed by the Defendant which breached common law duties owed
to Plaintiffs such breaches causing severe permanent injury to Plaintiffs and
consequential and punitive damages Moreover the Arbitration Clause in particular and
the total documents generally give no indication nor do they evidence the exchange of
consideration which would reasonably support any contention that such Clause would
limit claims assertable for the Defendantrsquos subsequent sale lease loan or transfer of the
traded-in vehicle with clearly identifiable markings of Plaintiffs upon it to criminals
terrorists jihadists or others of obviously ill-motive
9 While waiting for the paperwork to be processed Plaintiff began peeling off
the ldquoMark-1 Plumbing Incrdquo decal located on the truckrsquos doors when Defendantrsquos
salesman Edgar Velasquez instructed Plaintiff to stop Mr Velasquez told Plaintiff not
to worry about the decal and that peeling the decal off would blemish the vehicle paint
Consistent with Defendantrsquos advertising to potential customers to ldquolet them handle itrdquo
(see Exhibit A) Mr Velasquez further stated that the dealership had something that
works better for removal and they would use it to remove the decal In relying on Mr
Velasquezrsquos statements Plaintiff ceased peeling off the decal and trusted that the decals
would be removed prior to resale At no time did Velasquez or any other agent servant or
employee of the Defendant tell Plaintiff that Defendant would leave the decals on the
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 4
truck which would be transferred in some fashion to international jihadists conducting
warfare upon innocents in Syria and Plaintiff was not in any conceivable way told
informed or placed on notice that precisely such an incomprehensible and horrific
eventuality would actually occur
10 Over the years Plaintiffs have sold as many as five to ten trucks to different
dealers in Texas Through these transactions Plaintiffs found it to be common practice
for dealerships to remove the decals on vehicles prior to reselling them Onnone of those
occasions have any of those dealers transferred to international jihadists the traded-in
vehicle with Plaintiffsrsquo identifying markings still upon them
11 According to a CARFAX Vehicle History Report (see Exhibit B) the vehicle
was listed as a dealer vehicle sold at a Texas auto auction on November 11 2013 On
December 18 2013 the vehicle was exported from Houston Texas and imported to
Mersin Turkey
12 On December 15 2014
Caleb Weiss of The Long War
Journal tweeted the following
propaganda image of Plaintiffsrsquo Ford
F-250 with an anti-aircraft gun
mounted on it fighting on the front
lines in Syria for Ansar al-Deen a
jihadist group operating near Aleppo
in Syria Plaintiffsrsquo logo and phone
number were still on the vehicle
door
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 5
Within 48 hours the photograph had gone viral via the Internet and multiple news
outlets
13 On December 17 2014 while travelling to Corpus Christi Mark received a
phone call from his secretary Juli Hammonds Ms Hammonds explained to him the
breaking news stories His initial reactions were of utter shock and sheer disbelief
14 By the end of the day Mark-1rsquos office Mark-1rsquos business phone and Markrsquos
personal cell phone had received over 1000 phone calls from around the nation These
phone calls were in large part harassing and contained countless threats of violence
property harm injury and even death These phone calls included but were not limited
to individuals who were
(a) irate and yelling expletives at whomever answered the
phone
(b) degrading to whomever answered the phone regarding
their stupidity
(c) singing in Arabic for the duration of the phone call or voice
message recording
(d) making threats of injury or death against Mark-1rsquos
employees family children and grandchildren in violent
lurid and grossly specific terms and
(e) directing expletive-laced death threats to whomever
answered the phone
Only a precious few of the calls contained support for the Plaintiffs knowing that Plaintiffs
did not support terrorists However that scant number of positive calls in no way
8202019 Oberholtzer Lawsuit
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8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 7
18 On or about December 17 2015 four agents from the United States
Department of Homeland Security arrived at Plaintiffrsquos office in Texas City Texas The
Homeland Security Agents met with Vice President of Mark-1 for approximately one to
two hours During this time period he was not allowed to leave the premises After
concluding their investigation the Homeland Security Agents left him with the sinister
admonition that ldquothere are crazy people out thererdquo and to ldquoprotect himself at all timesrdquo
19 In early January 2015 Mark was met by FBI agents at his office The FBI
Agents conducted a very brief and cordial investigation After concluding their
investigation the FBI Agents once again reiterated that Mark must ldquoprotect himselfrdquo
20 In relying on the advice from both the Homeland Security and FBI Agents
Mark began carrying around a handgun for personal protection Additionally local police
made it routine to include his home and office on its routes But these steps in no way
diminish or mitigate the fear anxiety mental anguish and apprehension Mark feels for
his family or that of his family members
21 Throughout the duration of this situation TV stations and news agencies
both local and national have constantly contacted Plaintiffs for an interview Camera
crews were found videotaping Mark-1rsquos and its employeersquos personal automobiles Camera
crews went to Markrsquos house in an attempt to cover the story One news crew even went as
far as arriving at Mark-1rsquos secretary Juli Hammondrsquos daughterrsquos apartment requesting
an interview
22 Demonstrating the breadth and depth of the dissemination Mark has been
contacted by a vast number of news agencies regarding this situation including but not
limited to USA Today CBS NBC and Inside Edition
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 826
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 8
23 On December 18 2014 the final episode of the late-night comedy television
series The Colbert Report began with the segment ldquoTexanrsquos Truck in Syriardquo which was a
news story about a Mark-1 Plumbing truck now being used as an anti-aircraft gun in Syria
This episode was watched by 2481 million viewers making it the most watched episode
ever in the showrsquos history As of December 7 2015 the segment ldquoTexanrsquos Truck in Syriardquo
has an additional 67557 views on Comedy Centralrsquos website The widespread viewing of
the segment increased the volume of the harassing and threatening phone calls and has
immeasurably added to the suffering of Mark his family his employees and their families
24 The harassing and threatening phone calls continued for at least three
weeks from when the news story was officially reported Plaintiffs experienced at least
100-200 phone calls per day over this span of time Since that time Plaintiffs continue to
receive one or two phone calls per week However whenever ISIS commits an atrocity
that is reported nationally which occurs with distressing frequency Plaintiffs receive
more phone calls than normal all over again
25 On September 20 2015 the 67th Primetime Emmy Awards were held The
Colbert Report was nominated for ldquoOutstanding Directing for a Variety Seriesrdquo As part of
its show time nomination The Colbert Report included a bit of ldquoTexanrsquos Truck in Syriardquo
The 67th Primetime Emmy Awards was watched by 119 million viewers As a result
Plaintiffs suffered yet another period of non-stop phone calls averaging 100-200 phone
calls per day Plaintiff continues to receive threatening and harassing phone calls
practically each day Nearly one year has passed since the initial news story broke and
Plaintiffs still receive harassing phone calls and threats to this day
26 Through absolutely no fault of their own Plaintiffs have suffered and
continue to suffer damages directly resulting from Defendantrsquos failure to remove the decal
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 926
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 9
prior to resale as promised Plaintiffsrsquo plumbing repair work and all other sources of its
revenues have been substantially impacted and its reputation damaged beyond
rehabilitation As a direct result of the damage to Plaintiffsrsquo reputation Plaintiffs have lost
an excess of $100000000
VCAUSES OF ACTION
A RESPONDEAT SUPERIOR
27 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition At all times material to this Petition Defendantrsquos salesman was an employee
or agent of Defendant The acts of the employee were performed while in the employment
of Defendant and were within the course and scope of that employment or within the
authority delegated to the employee Employee was acting in furtherance of Defendantrsquos
business the accomplishment for which the employee was hired
28 Defendant is liable for the negligent acts and omissions of its employees
under the doctrine of vicarious liability or respondeat superior
29 As a result of Defendantrsquos negligent acts and omissions Plaintiffs have
suffered pecuniary harm and request compensatory and punitive damages in an amount
to be determined at trial
B JOINT AND SEVERAL LIABILITY
30 Additionally Defendant is directly liable for the acts and omissions of its
agents servants and employees in allowing a traded-in vehicle with clearly identifiable
marking of its previous business owner to be placed into the stream of commerce without
first removing said identifying markings such that the truck could fall into the hands of
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 10
criminals terrorists or jihadists and be photographed in circumstances which could and
did bring about Plaintiffrsquos severe injury and their incurring of consequent damages
C LIABILITY FOR NEGLIGENCE GROSS NEGLIGENCE AND COMMONLAW TORTS
31 As hereinafter set out in detail Defendant is liable to Plaintiffs for its
negligence and common law torts and for all economic andor compensatory damages
which have been suffered in the past and which in reasonable probability will be suffered
in the future Moreover Defendantrsquos conduct has been so outrageous malicious and
consciously indifferent to the overwhelmingly likely severe harm of the Plaintiffs as to
constitute gross negligence as that term is understood in Texas law for which Plaintiffs
herein seek punitive damages as permitted by common law andor Texas Civil Practice
amp Remedies Code sect 41002
D COMMON-LAW FRAUD
32 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant made a material representation regarding removal of the decals
to Plaintiff to induce him into the transaction Defendant either knew its material
representation regarding removal of the decals was false when stated or Defendant
recklessly stated its material representations as positive assertions without knowledge of
their truth Defendant made these representations with the intent that Plaintiff rely on
them Plaintiff did rely on the representations to his detriment
33 Defendantrsquos false representations directly and proximately caused Plaintiffs
to suffer substantial past damages and in reasonable probability will cause Plaintiffs to
continue to suffer damages into the future
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
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Exhibit A
8202019 Oberholtzer Lawsuit
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-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
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-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
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eserved
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ease vs Buy
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Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 3
8 The transactional documents between Mark-1 and the Defendant included
a ldquoRetail Purchase Agreementrdquo on its face applicable to a ldquolsquoSellerrsquo or lsquoDealerrsquo Retail
Purchase Agreement for a Motor Vehiclerdquo which contained an ldquoArbitration Agreementrdquo
and a ldquoConditional Delivery Agreementrdquo While such written documents admittedly
applied to the sale of the new vehicle Mark-1 purchased they do not apply to the traded-
in vehicle andor they are wholly and completely silent as to subsequent intervening
superseding torts committed by the Defendant which breached common law duties owed
to Plaintiffs such breaches causing severe permanent injury to Plaintiffs and
consequential and punitive damages Moreover the Arbitration Clause in particular and
the total documents generally give no indication nor do they evidence the exchange of
consideration which would reasonably support any contention that such Clause would
limit claims assertable for the Defendantrsquos subsequent sale lease loan or transfer of the
traded-in vehicle with clearly identifiable markings of Plaintiffs upon it to criminals
terrorists jihadists or others of obviously ill-motive
9 While waiting for the paperwork to be processed Plaintiff began peeling off
the ldquoMark-1 Plumbing Incrdquo decal located on the truckrsquos doors when Defendantrsquos
salesman Edgar Velasquez instructed Plaintiff to stop Mr Velasquez told Plaintiff not
to worry about the decal and that peeling the decal off would blemish the vehicle paint
Consistent with Defendantrsquos advertising to potential customers to ldquolet them handle itrdquo
(see Exhibit A) Mr Velasquez further stated that the dealership had something that
works better for removal and they would use it to remove the decal In relying on Mr
Velasquezrsquos statements Plaintiff ceased peeling off the decal and trusted that the decals
would be removed prior to resale At no time did Velasquez or any other agent servant or
employee of the Defendant tell Plaintiff that Defendant would leave the decals on the
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 4
truck which would be transferred in some fashion to international jihadists conducting
warfare upon innocents in Syria and Plaintiff was not in any conceivable way told
informed or placed on notice that precisely such an incomprehensible and horrific
eventuality would actually occur
10 Over the years Plaintiffs have sold as many as five to ten trucks to different
dealers in Texas Through these transactions Plaintiffs found it to be common practice
for dealerships to remove the decals on vehicles prior to reselling them Onnone of those
occasions have any of those dealers transferred to international jihadists the traded-in
vehicle with Plaintiffsrsquo identifying markings still upon them
11 According to a CARFAX Vehicle History Report (see Exhibit B) the vehicle
was listed as a dealer vehicle sold at a Texas auto auction on November 11 2013 On
December 18 2013 the vehicle was exported from Houston Texas and imported to
Mersin Turkey
12 On December 15 2014
Caleb Weiss of The Long War
Journal tweeted the following
propaganda image of Plaintiffsrsquo Ford
F-250 with an anti-aircraft gun
mounted on it fighting on the front
lines in Syria for Ansar al-Deen a
jihadist group operating near Aleppo
in Syria Plaintiffsrsquo logo and phone
number were still on the vehicle
door
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 5
Within 48 hours the photograph had gone viral via the Internet and multiple news
outlets
13 On December 17 2014 while travelling to Corpus Christi Mark received a
phone call from his secretary Juli Hammonds Ms Hammonds explained to him the
breaking news stories His initial reactions were of utter shock and sheer disbelief
14 By the end of the day Mark-1rsquos office Mark-1rsquos business phone and Markrsquos
personal cell phone had received over 1000 phone calls from around the nation These
phone calls were in large part harassing and contained countless threats of violence
property harm injury and even death These phone calls included but were not limited
to individuals who were
(a) irate and yelling expletives at whomever answered the
phone
(b) degrading to whomever answered the phone regarding
their stupidity
(c) singing in Arabic for the duration of the phone call or voice
message recording
(d) making threats of injury or death against Mark-1rsquos
employees family children and grandchildren in violent
lurid and grossly specific terms and
(e) directing expletive-laced death threats to whomever
answered the phone
Only a precious few of the calls contained support for the Plaintiffs knowing that Plaintiffs
did not support terrorists However that scant number of positive calls in no way
8202019 Oberholtzer Lawsuit
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8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 726
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 7
18 On or about December 17 2015 four agents from the United States
Department of Homeland Security arrived at Plaintiffrsquos office in Texas City Texas The
Homeland Security Agents met with Vice President of Mark-1 for approximately one to
two hours During this time period he was not allowed to leave the premises After
concluding their investigation the Homeland Security Agents left him with the sinister
admonition that ldquothere are crazy people out thererdquo and to ldquoprotect himself at all timesrdquo
19 In early January 2015 Mark was met by FBI agents at his office The FBI
Agents conducted a very brief and cordial investigation After concluding their
investigation the FBI Agents once again reiterated that Mark must ldquoprotect himselfrdquo
20 In relying on the advice from both the Homeland Security and FBI Agents
Mark began carrying around a handgun for personal protection Additionally local police
made it routine to include his home and office on its routes But these steps in no way
diminish or mitigate the fear anxiety mental anguish and apprehension Mark feels for
his family or that of his family members
21 Throughout the duration of this situation TV stations and news agencies
both local and national have constantly contacted Plaintiffs for an interview Camera
crews were found videotaping Mark-1rsquos and its employeersquos personal automobiles Camera
crews went to Markrsquos house in an attempt to cover the story One news crew even went as
far as arriving at Mark-1rsquos secretary Juli Hammondrsquos daughterrsquos apartment requesting
an interview
22 Demonstrating the breadth and depth of the dissemination Mark has been
contacted by a vast number of news agencies regarding this situation including but not
limited to USA Today CBS NBC and Inside Edition
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 826
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 8
23 On December 18 2014 the final episode of the late-night comedy television
series The Colbert Report began with the segment ldquoTexanrsquos Truck in Syriardquo which was a
news story about a Mark-1 Plumbing truck now being used as an anti-aircraft gun in Syria
This episode was watched by 2481 million viewers making it the most watched episode
ever in the showrsquos history As of December 7 2015 the segment ldquoTexanrsquos Truck in Syriardquo
has an additional 67557 views on Comedy Centralrsquos website The widespread viewing of
the segment increased the volume of the harassing and threatening phone calls and has
immeasurably added to the suffering of Mark his family his employees and their families
24 The harassing and threatening phone calls continued for at least three
weeks from when the news story was officially reported Plaintiffs experienced at least
100-200 phone calls per day over this span of time Since that time Plaintiffs continue to
receive one or two phone calls per week However whenever ISIS commits an atrocity
that is reported nationally which occurs with distressing frequency Plaintiffs receive
more phone calls than normal all over again
25 On September 20 2015 the 67th Primetime Emmy Awards were held The
Colbert Report was nominated for ldquoOutstanding Directing for a Variety Seriesrdquo As part of
its show time nomination The Colbert Report included a bit of ldquoTexanrsquos Truck in Syriardquo
The 67th Primetime Emmy Awards was watched by 119 million viewers As a result
Plaintiffs suffered yet another period of non-stop phone calls averaging 100-200 phone
calls per day Plaintiff continues to receive threatening and harassing phone calls
practically each day Nearly one year has passed since the initial news story broke and
Plaintiffs still receive harassing phone calls and threats to this day
26 Through absolutely no fault of their own Plaintiffs have suffered and
continue to suffer damages directly resulting from Defendantrsquos failure to remove the decal
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 926
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 9
prior to resale as promised Plaintiffsrsquo plumbing repair work and all other sources of its
revenues have been substantially impacted and its reputation damaged beyond
rehabilitation As a direct result of the damage to Plaintiffsrsquo reputation Plaintiffs have lost
an excess of $100000000
VCAUSES OF ACTION
A RESPONDEAT SUPERIOR
27 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition At all times material to this Petition Defendantrsquos salesman was an employee
or agent of Defendant The acts of the employee were performed while in the employment
of Defendant and were within the course and scope of that employment or within the
authority delegated to the employee Employee was acting in furtherance of Defendantrsquos
business the accomplishment for which the employee was hired
28 Defendant is liable for the negligent acts and omissions of its employees
under the doctrine of vicarious liability or respondeat superior
29 As a result of Defendantrsquos negligent acts and omissions Plaintiffs have
suffered pecuniary harm and request compensatory and punitive damages in an amount
to be determined at trial
B JOINT AND SEVERAL LIABILITY
30 Additionally Defendant is directly liable for the acts and omissions of its
agents servants and employees in allowing a traded-in vehicle with clearly identifiable
marking of its previous business owner to be placed into the stream of commerce without
first removing said identifying markings such that the truck could fall into the hands of
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 10
criminals terrorists or jihadists and be photographed in circumstances which could and
did bring about Plaintiffrsquos severe injury and their incurring of consequent damages
C LIABILITY FOR NEGLIGENCE GROSS NEGLIGENCE AND COMMONLAW TORTS
31 As hereinafter set out in detail Defendant is liable to Plaintiffs for its
negligence and common law torts and for all economic andor compensatory damages
which have been suffered in the past and which in reasonable probability will be suffered
in the future Moreover Defendantrsquos conduct has been so outrageous malicious and
consciously indifferent to the overwhelmingly likely severe harm of the Plaintiffs as to
constitute gross negligence as that term is understood in Texas law for which Plaintiffs
herein seek punitive damages as permitted by common law andor Texas Civil Practice
amp Remedies Code sect 41002
D COMMON-LAW FRAUD
32 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant made a material representation regarding removal of the decals
to Plaintiff to induce him into the transaction Defendant either knew its material
representation regarding removal of the decals was false when stated or Defendant
recklessly stated its material representations as positive assertions without knowledge of
their truth Defendant made these representations with the intent that Plaintiff rely on
them Plaintiff did rely on the representations to his detriment
33 Defendantrsquos false representations directly and proximately caused Plaintiffs
to suffer substantial past damages and in reasonable probability will cause Plaintiffs to
continue to suffer damages into the future
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
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-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
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eserved
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8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 4
truck which would be transferred in some fashion to international jihadists conducting
warfare upon innocents in Syria and Plaintiff was not in any conceivable way told
informed or placed on notice that precisely such an incomprehensible and horrific
eventuality would actually occur
10 Over the years Plaintiffs have sold as many as five to ten trucks to different
dealers in Texas Through these transactions Plaintiffs found it to be common practice
for dealerships to remove the decals on vehicles prior to reselling them Onnone of those
occasions have any of those dealers transferred to international jihadists the traded-in
vehicle with Plaintiffsrsquo identifying markings still upon them
11 According to a CARFAX Vehicle History Report (see Exhibit B) the vehicle
was listed as a dealer vehicle sold at a Texas auto auction on November 11 2013 On
December 18 2013 the vehicle was exported from Houston Texas and imported to
Mersin Turkey
12 On December 15 2014
Caleb Weiss of The Long War
Journal tweeted the following
propaganda image of Plaintiffsrsquo Ford
F-250 with an anti-aircraft gun
mounted on it fighting on the front
lines in Syria for Ansar al-Deen a
jihadist group operating near Aleppo
in Syria Plaintiffsrsquo logo and phone
number were still on the vehicle
door
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 5
Within 48 hours the photograph had gone viral via the Internet and multiple news
outlets
13 On December 17 2014 while travelling to Corpus Christi Mark received a
phone call from his secretary Juli Hammonds Ms Hammonds explained to him the
breaking news stories His initial reactions were of utter shock and sheer disbelief
14 By the end of the day Mark-1rsquos office Mark-1rsquos business phone and Markrsquos
personal cell phone had received over 1000 phone calls from around the nation These
phone calls were in large part harassing and contained countless threats of violence
property harm injury and even death These phone calls included but were not limited
to individuals who were
(a) irate and yelling expletives at whomever answered the
phone
(b) degrading to whomever answered the phone regarding
their stupidity
(c) singing in Arabic for the duration of the phone call or voice
message recording
(d) making threats of injury or death against Mark-1rsquos
employees family children and grandchildren in violent
lurid and grossly specific terms and
(e) directing expletive-laced death threats to whomever
answered the phone
Only a precious few of the calls contained support for the Plaintiffs knowing that Plaintiffs
did not support terrorists However that scant number of positive calls in no way
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 626
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 7
18 On or about December 17 2015 four agents from the United States
Department of Homeland Security arrived at Plaintiffrsquos office in Texas City Texas The
Homeland Security Agents met with Vice President of Mark-1 for approximately one to
two hours During this time period he was not allowed to leave the premises After
concluding their investigation the Homeland Security Agents left him with the sinister
admonition that ldquothere are crazy people out thererdquo and to ldquoprotect himself at all timesrdquo
19 In early January 2015 Mark was met by FBI agents at his office The FBI
Agents conducted a very brief and cordial investigation After concluding their
investigation the FBI Agents once again reiterated that Mark must ldquoprotect himselfrdquo
20 In relying on the advice from both the Homeland Security and FBI Agents
Mark began carrying around a handgun for personal protection Additionally local police
made it routine to include his home and office on its routes But these steps in no way
diminish or mitigate the fear anxiety mental anguish and apprehension Mark feels for
his family or that of his family members
21 Throughout the duration of this situation TV stations and news agencies
both local and national have constantly contacted Plaintiffs for an interview Camera
crews were found videotaping Mark-1rsquos and its employeersquos personal automobiles Camera
crews went to Markrsquos house in an attempt to cover the story One news crew even went as
far as arriving at Mark-1rsquos secretary Juli Hammondrsquos daughterrsquos apartment requesting
an interview
22 Demonstrating the breadth and depth of the dissemination Mark has been
contacted by a vast number of news agencies regarding this situation including but not
limited to USA Today CBS NBC and Inside Edition
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 8
23 On December 18 2014 the final episode of the late-night comedy television
series The Colbert Report began with the segment ldquoTexanrsquos Truck in Syriardquo which was a
news story about a Mark-1 Plumbing truck now being used as an anti-aircraft gun in Syria
This episode was watched by 2481 million viewers making it the most watched episode
ever in the showrsquos history As of December 7 2015 the segment ldquoTexanrsquos Truck in Syriardquo
has an additional 67557 views on Comedy Centralrsquos website The widespread viewing of
the segment increased the volume of the harassing and threatening phone calls and has
immeasurably added to the suffering of Mark his family his employees and their families
24 The harassing and threatening phone calls continued for at least three
weeks from when the news story was officially reported Plaintiffs experienced at least
100-200 phone calls per day over this span of time Since that time Plaintiffs continue to
receive one or two phone calls per week However whenever ISIS commits an atrocity
that is reported nationally which occurs with distressing frequency Plaintiffs receive
more phone calls than normal all over again
25 On September 20 2015 the 67th Primetime Emmy Awards were held The
Colbert Report was nominated for ldquoOutstanding Directing for a Variety Seriesrdquo As part of
its show time nomination The Colbert Report included a bit of ldquoTexanrsquos Truck in Syriardquo
The 67th Primetime Emmy Awards was watched by 119 million viewers As a result
Plaintiffs suffered yet another period of non-stop phone calls averaging 100-200 phone
calls per day Plaintiff continues to receive threatening and harassing phone calls
practically each day Nearly one year has passed since the initial news story broke and
Plaintiffs still receive harassing phone calls and threats to this day
26 Through absolutely no fault of their own Plaintiffs have suffered and
continue to suffer damages directly resulting from Defendantrsquos failure to remove the decal
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 926
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 9
prior to resale as promised Plaintiffsrsquo plumbing repair work and all other sources of its
revenues have been substantially impacted and its reputation damaged beyond
rehabilitation As a direct result of the damage to Plaintiffsrsquo reputation Plaintiffs have lost
an excess of $100000000
VCAUSES OF ACTION
A RESPONDEAT SUPERIOR
27 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition At all times material to this Petition Defendantrsquos salesman was an employee
or agent of Defendant The acts of the employee were performed while in the employment
of Defendant and were within the course and scope of that employment or within the
authority delegated to the employee Employee was acting in furtherance of Defendantrsquos
business the accomplishment for which the employee was hired
28 Defendant is liable for the negligent acts and omissions of its employees
under the doctrine of vicarious liability or respondeat superior
29 As a result of Defendantrsquos negligent acts and omissions Plaintiffs have
suffered pecuniary harm and request compensatory and punitive damages in an amount
to be determined at trial
B JOINT AND SEVERAL LIABILITY
30 Additionally Defendant is directly liable for the acts and omissions of its
agents servants and employees in allowing a traded-in vehicle with clearly identifiable
marking of its previous business owner to be placed into the stream of commerce without
first removing said identifying markings such that the truck could fall into the hands of
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 10
criminals terrorists or jihadists and be photographed in circumstances which could and
did bring about Plaintiffrsquos severe injury and their incurring of consequent damages
C LIABILITY FOR NEGLIGENCE GROSS NEGLIGENCE AND COMMONLAW TORTS
31 As hereinafter set out in detail Defendant is liable to Plaintiffs for its
negligence and common law torts and for all economic andor compensatory damages
which have been suffered in the past and which in reasonable probability will be suffered
in the future Moreover Defendantrsquos conduct has been so outrageous malicious and
consciously indifferent to the overwhelmingly likely severe harm of the Plaintiffs as to
constitute gross negligence as that term is understood in Texas law for which Plaintiffs
herein seek punitive damages as permitted by common law andor Texas Civil Practice
amp Remedies Code sect 41002
D COMMON-LAW FRAUD
32 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant made a material representation regarding removal of the decals
to Plaintiff to induce him into the transaction Defendant either knew its material
representation regarding removal of the decals was false when stated or Defendant
recklessly stated its material representations as positive assertions without knowledge of
their truth Defendant made these representations with the intent that Plaintiff rely on
them Plaintiff did rely on the representations to his detriment
33 Defendantrsquos false representations directly and proximately caused Plaintiffs
to suffer substantial past damages and in reasonable probability will cause Plaintiffs to
continue to suffer damages into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1126
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1226
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
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PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
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Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
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-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
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8202019 Oberholtzer Lawsuit
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Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 5
Within 48 hours the photograph had gone viral via the Internet and multiple news
outlets
13 On December 17 2014 while travelling to Corpus Christi Mark received a
phone call from his secretary Juli Hammonds Ms Hammonds explained to him the
breaking news stories His initial reactions were of utter shock and sheer disbelief
14 By the end of the day Mark-1rsquos office Mark-1rsquos business phone and Markrsquos
personal cell phone had received over 1000 phone calls from around the nation These
phone calls were in large part harassing and contained countless threats of violence
property harm injury and even death These phone calls included but were not limited
to individuals who were
(a) irate and yelling expletives at whomever answered the
phone
(b) degrading to whomever answered the phone regarding
their stupidity
(c) singing in Arabic for the duration of the phone call or voice
message recording
(d) making threats of injury or death against Mark-1rsquos
employees family children and grandchildren in violent
lurid and grossly specific terms and
(e) directing expletive-laced death threats to whomever
answered the phone
Only a precious few of the calls contained support for the Plaintiffs knowing that Plaintiffs
did not support terrorists However that scant number of positive calls in no way
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 626
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 726
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 7
18 On or about December 17 2015 four agents from the United States
Department of Homeland Security arrived at Plaintiffrsquos office in Texas City Texas The
Homeland Security Agents met with Vice President of Mark-1 for approximately one to
two hours During this time period he was not allowed to leave the premises After
concluding their investigation the Homeland Security Agents left him with the sinister
admonition that ldquothere are crazy people out thererdquo and to ldquoprotect himself at all timesrdquo
19 In early January 2015 Mark was met by FBI agents at his office The FBI
Agents conducted a very brief and cordial investigation After concluding their
investigation the FBI Agents once again reiterated that Mark must ldquoprotect himselfrdquo
20 In relying on the advice from both the Homeland Security and FBI Agents
Mark began carrying around a handgun for personal protection Additionally local police
made it routine to include his home and office on its routes But these steps in no way
diminish or mitigate the fear anxiety mental anguish and apprehension Mark feels for
his family or that of his family members
21 Throughout the duration of this situation TV stations and news agencies
both local and national have constantly contacted Plaintiffs for an interview Camera
crews were found videotaping Mark-1rsquos and its employeersquos personal automobiles Camera
crews went to Markrsquos house in an attempt to cover the story One news crew even went as
far as arriving at Mark-1rsquos secretary Juli Hammondrsquos daughterrsquos apartment requesting
an interview
22 Demonstrating the breadth and depth of the dissemination Mark has been
contacted by a vast number of news agencies regarding this situation including but not
limited to USA Today CBS NBC and Inside Edition
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 826
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 8
23 On December 18 2014 the final episode of the late-night comedy television
series The Colbert Report began with the segment ldquoTexanrsquos Truck in Syriardquo which was a
news story about a Mark-1 Plumbing truck now being used as an anti-aircraft gun in Syria
This episode was watched by 2481 million viewers making it the most watched episode
ever in the showrsquos history As of December 7 2015 the segment ldquoTexanrsquos Truck in Syriardquo
has an additional 67557 views on Comedy Centralrsquos website The widespread viewing of
the segment increased the volume of the harassing and threatening phone calls and has
immeasurably added to the suffering of Mark his family his employees and their families
24 The harassing and threatening phone calls continued for at least three
weeks from when the news story was officially reported Plaintiffs experienced at least
100-200 phone calls per day over this span of time Since that time Plaintiffs continue to
receive one or two phone calls per week However whenever ISIS commits an atrocity
that is reported nationally which occurs with distressing frequency Plaintiffs receive
more phone calls than normal all over again
25 On September 20 2015 the 67th Primetime Emmy Awards were held The
Colbert Report was nominated for ldquoOutstanding Directing for a Variety Seriesrdquo As part of
its show time nomination The Colbert Report included a bit of ldquoTexanrsquos Truck in Syriardquo
The 67th Primetime Emmy Awards was watched by 119 million viewers As a result
Plaintiffs suffered yet another period of non-stop phone calls averaging 100-200 phone
calls per day Plaintiff continues to receive threatening and harassing phone calls
practically each day Nearly one year has passed since the initial news story broke and
Plaintiffs still receive harassing phone calls and threats to this day
26 Through absolutely no fault of their own Plaintiffs have suffered and
continue to suffer damages directly resulting from Defendantrsquos failure to remove the decal
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 926
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 9
prior to resale as promised Plaintiffsrsquo plumbing repair work and all other sources of its
revenues have been substantially impacted and its reputation damaged beyond
rehabilitation As a direct result of the damage to Plaintiffsrsquo reputation Plaintiffs have lost
an excess of $100000000
VCAUSES OF ACTION
A RESPONDEAT SUPERIOR
27 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition At all times material to this Petition Defendantrsquos salesman was an employee
or agent of Defendant The acts of the employee were performed while in the employment
of Defendant and were within the course and scope of that employment or within the
authority delegated to the employee Employee was acting in furtherance of Defendantrsquos
business the accomplishment for which the employee was hired
28 Defendant is liable for the negligent acts and omissions of its employees
under the doctrine of vicarious liability or respondeat superior
29 As a result of Defendantrsquos negligent acts and omissions Plaintiffs have
suffered pecuniary harm and request compensatory and punitive damages in an amount
to be determined at trial
B JOINT AND SEVERAL LIABILITY
30 Additionally Defendant is directly liable for the acts and omissions of its
agents servants and employees in allowing a traded-in vehicle with clearly identifiable
marking of its previous business owner to be placed into the stream of commerce without
first removing said identifying markings such that the truck could fall into the hands of
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1026
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 10
criminals terrorists or jihadists and be photographed in circumstances which could and
did bring about Plaintiffrsquos severe injury and their incurring of consequent damages
C LIABILITY FOR NEGLIGENCE GROSS NEGLIGENCE AND COMMONLAW TORTS
31 As hereinafter set out in detail Defendant is liable to Plaintiffs for its
negligence and common law torts and for all economic andor compensatory damages
which have been suffered in the past and which in reasonable probability will be suffered
in the future Moreover Defendantrsquos conduct has been so outrageous malicious and
consciously indifferent to the overwhelmingly likely severe harm of the Plaintiffs as to
constitute gross negligence as that term is understood in Texas law for which Plaintiffs
herein seek punitive damages as permitted by common law andor Texas Civil Practice
amp Remedies Code sect 41002
D COMMON-LAW FRAUD
32 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant made a material representation regarding removal of the decals
to Plaintiff to induce him into the transaction Defendant either knew its material
representation regarding removal of the decals was false when stated or Defendant
recklessly stated its material representations as positive assertions without knowledge of
their truth Defendant made these representations with the intent that Plaintiff rely on
them Plaintiff did rely on the representations to his detriment
33 Defendantrsquos false representations directly and proximately caused Plaintiffs
to suffer substantial past damages and in reasonable probability will cause Plaintiffs to
continue to suffer damages into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1126
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1226
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
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-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
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copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
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ind a Vehicle
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ease vs Buy
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Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 626
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 726
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 7
18 On or about December 17 2015 four agents from the United States
Department of Homeland Security arrived at Plaintiffrsquos office in Texas City Texas The
Homeland Security Agents met with Vice President of Mark-1 for approximately one to
two hours During this time period he was not allowed to leave the premises After
concluding their investigation the Homeland Security Agents left him with the sinister
admonition that ldquothere are crazy people out thererdquo and to ldquoprotect himself at all timesrdquo
19 In early January 2015 Mark was met by FBI agents at his office The FBI
Agents conducted a very brief and cordial investigation After concluding their
investigation the FBI Agents once again reiterated that Mark must ldquoprotect himselfrdquo
20 In relying on the advice from both the Homeland Security and FBI Agents
Mark began carrying around a handgun for personal protection Additionally local police
made it routine to include his home and office on its routes But these steps in no way
diminish or mitigate the fear anxiety mental anguish and apprehension Mark feels for
his family or that of his family members
21 Throughout the duration of this situation TV stations and news agencies
both local and national have constantly contacted Plaintiffs for an interview Camera
crews were found videotaping Mark-1rsquos and its employeersquos personal automobiles Camera
crews went to Markrsquos house in an attempt to cover the story One news crew even went as
far as arriving at Mark-1rsquos secretary Juli Hammondrsquos daughterrsquos apartment requesting
an interview
22 Demonstrating the breadth and depth of the dissemination Mark has been
contacted by a vast number of news agencies regarding this situation including but not
limited to USA Today CBS NBC and Inside Edition
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 826
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 8
23 On December 18 2014 the final episode of the late-night comedy television
series The Colbert Report began with the segment ldquoTexanrsquos Truck in Syriardquo which was a
news story about a Mark-1 Plumbing truck now being used as an anti-aircraft gun in Syria
This episode was watched by 2481 million viewers making it the most watched episode
ever in the showrsquos history As of December 7 2015 the segment ldquoTexanrsquos Truck in Syriardquo
has an additional 67557 views on Comedy Centralrsquos website The widespread viewing of
the segment increased the volume of the harassing and threatening phone calls and has
immeasurably added to the suffering of Mark his family his employees and their families
24 The harassing and threatening phone calls continued for at least three
weeks from when the news story was officially reported Plaintiffs experienced at least
100-200 phone calls per day over this span of time Since that time Plaintiffs continue to
receive one or two phone calls per week However whenever ISIS commits an atrocity
that is reported nationally which occurs with distressing frequency Plaintiffs receive
more phone calls than normal all over again
25 On September 20 2015 the 67th Primetime Emmy Awards were held The
Colbert Report was nominated for ldquoOutstanding Directing for a Variety Seriesrdquo As part of
its show time nomination The Colbert Report included a bit of ldquoTexanrsquos Truck in Syriardquo
The 67th Primetime Emmy Awards was watched by 119 million viewers As a result
Plaintiffs suffered yet another period of non-stop phone calls averaging 100-200 phone
calls per day Plaintiff continues to receive threatening and harassing phone calls
practically each day Nearly one year has passed since the initial news story broke and
Plaintiffs still receive harassing phone calls and threats to this day
26 Through absolutely no fault of their own Plaintiffs have suffered and
continue to suffer damages directly resulting from Defendantrsquos failure to remove the decal
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 926
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 9
prior to resale as promised Plaintiffsrsquo plumbing repair work and all other sources of its
revenues have been substantially impacted and its reputation damaged beyond
rehabilitation As a direct result of the damage to Plaintiffsrsquo reputation Plaintiffs have lost
an excess of $100000000
VCAUSES OF ACTION
A RESPONDEAT SUPERIOR
27 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition At all times material to this Petition Defendantrsquos salesman was an employee
or agent of Defendant The acts of the employee were performed while in the employment
of Defendant and were within the course and scope of that employment or within the
authority delegated to the employee Employee was acting in furtherance of Defendantrsquos
business the accomplishment for which the employee was hired
28 Defendant is liable for the negligent acts and omissions of its employees
under the doctrine of vicarious liability or respondeat superior
29 As a result of Defendantrsquos negligent acts and omissions Plaintiffs have
suffered pecuniary harm and request compensatory and punitive damages in an amount
to be determined at trial
B JOINT AND SEVERAL LIABILITY
30 Additionally Defendant is directly liable for the acts and omissions of its
agents servants and employees in allowing a traded-in vehicle with clearly identifiable
marking of its previous business owner to be placed into the stream of commerce without
first removing said identifying markings such that the truck could fall into the hands of
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1026
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 10
criminals terrorists or jihadists and be photographed in circumstances which could and
did bring about Plaintiffrsquos severe injury and their incurring of consequent damages
C LIABILITY FOR NEGLIGENCE GROSS NEGLIGENCE AND COMMONLAW TORTS
31 As hereinafter set out in detail Defendant is liable to Plaintiffs for its
negligence and common law torts and for all economic andor compensatory damages
which have been suffered in the past and which in reasonable probability will be suffered
in the future Moreover Defendantrsquos conduct has been so outrageous malicious and
consciously indifferent to the overwhelmingly likely severe harm of the Plaintiffs as to
constitute gross negligence as that term is understood in Texas law for which Plaintiffs
herein seek punitive damages as permitted by common law andor Texas Civil Practice
amp Remedies Code sect 41002
D COMMON-LAW FRAUD
32 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant made a material representation regarding removal of the decals
to Plaintiff to induce him into the transaction Defendant either knew its material
representation regarding removal of the decals was false when stated or Defendant
recklessly stated its material representations as positive assertions without knowledge of
their truth Defendant made these representations with the intent that Plaintiff rely on
them Plaintiff did rely on the representations to his detriment
33 Defendantrsquos false representations directly and proximately caused Plaintiffs
to suffer substantial past damages and in reasonable probability will cause Plaintiffs to
continue to suffer damages into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1126
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1226
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
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copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
Site Map
Fleet Sales
ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 726
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 7
18 On or about December 17 2015 four agents from the United States
Department of Homeland Security arrived at Plaintiffrsquos office in Texas City Texas The
Homeland Security Agents met with Vice President of Mark-1 for approximately one to
two hours During this time period he was not allowed to leave the premises After
concluding their investigation the Homeland Security Agents left him with the sinister
admonition that ldquothere are crazy people out thererdquo and to ldquoprotect himself at all timesrdquo
19 In early January 2015 Mark was met by FBI agents at his office The FBI
Agents conducted a very brief and cordial investigation After concluding their
investigation the FBI Agents once again reiterated that Mark must ldquoprotect himselfrdquo
20 In relying on the advice from both the Homeland Security and FBI Agents
Mark began carrying around a handgun for personal protection Additionally local police
made it routine to include his home and office on its routes But these steps in no way
diminish or mitigate the fear anxiety mental anguish and apprehension Mark feels for
his family or that of his family members
21 Throughout the duration of this situation TV stations and news agencies
both local and national have constantly contacted Plaintiffs for an interview Camera
crews were found videotaping Mark-1rsquos and its employeersquos personal automobiles Camera
crews went to Markrsquos house in an attempt to cover the story One news crew even went as
far as arriving at Mark-1rsquos secretary Juli Hammondrsquos daughterrsquos apartment requesting
an interview
22 Demonstrating the breadth and depth of the dissemination Mark has been
contacted by a vast number of news agencies regarding this situation including but not
limited to USA Today CBS NBC and Inside Edition
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 826
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 8
23 On December 18 2014 the final episode of the late-night comedy television
series The Colbert Report began with the segment ldquoTexanrsquos Truck in Syriardquo which was a
news story about a Mark-1 Plumbing truck now being used as an anti-aircraft gun in Syria
This episode was watched by 2481 million viewers making it the most watched episode
ever in the showrsquos history As of December 7 2015 the segment ldquoTexanrsquos Truck in Syriardquo
has an additional 67557 views on Comedy Centralrsquos website The widespread viewing of
the segment increased the volume of the harassing and threatening phone calls and has
immeasurably added to the suffering of Mark his family his employees and their families
24 The harassing and threatening phone calls continued for at least three
weeks from when the news story was officially reported Plaintiffs experienced at least
100-200 phone calls per day over this span of time Since that time Plaintiffs continue to
receive one or two phone calls per week However whenever ISIS commits an atrocity
that is reported nationally which occurs with distressing frequency Plaintiffs receive
more phone calls than normal all over again
25 On September 20 2015 the 67th Primetime Emmy Awards were held The
Colbert Report was nominated for ldquoOutstanding Directing for a Variety Seriesrdquo As part of
its show time nomination The Colbert Report included a bit of ldquoTexanrsquos Truck in Syriardquo
The 67th Primetime Emmy Awards was watched by 119 million viewers As a result
Plaintiffs suffered yet another period of non-stop phone calls averaging 100-200 phone
calls per day Plaintiff continues to receive threatening and harassing phone calls
practically each day Nearly one year has passed since the initial news story broke and
Plaintiffs still receive harassing phone calls and threats to this day
26 Through absolutely no fault of their own Plaintiffs have suffered and
continue to suffer damages directly resulting from Defendantrsquos failure to remove the decal
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 926
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 9
prior to resale as promised Plaintiffsrsquo plumbing repair work and all other sources of its
revenues have been substantially impacted and its reputation damaged beyond
rehabilitation As a direct result of the damage to Plaintiffsrsquo reputation Plaintiffs have lost
an excess of $100000000
VCAUSES OF ACTION
A RESPONDEAT SUPERIOR
27 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition At all times material to this Petition Defendantrsquos salesman was an employee
or agent of Defendant The acts of the employee were performed while in the employment
of Defendant and were within the course and scope of that employment or within the
authority delegated to the employee Employee was acting in furtherance of Defendantrsquos
business the accomplishment for which the employee was hired
28 Defendant is liable for the negligent acts and omissions of its employees
under the doctrine of vicarious liability or respondeat superior
29 As a result of Defendantrsquos negligent acts and omissions Plaintiffs have
suffered pecuniary harm and request compensatory and punitive damages in an amount
to be determined at trial
B JOINT AND SEVERAL LIABILITY
30 Additionally Defendant is directly liable for the acts and omissions of its
agents servants and employees in allowing a traded-in vehicle with clearly identifiable
marking of its previous business owner to be placed into the stream of commerce without
first removing said identifying markings such that the truck could fall into the hands of
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1026
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 10
criminals terrorists or jihadists and be photographed in circumstances which could and
did bring about Plaintiffrsquos severe injury and their incurring of consequent damages
C LIABILITY FOR NEGLIGENCE GROSS NEGLIGENCE AND COMMONLAW TORTS
31 As hereinafter set out in detail Defendant is liable to Plaintiffs for its
negligence and common law torts and for all economic andor compensatory damages
which have been suffered in the past and which in reasonable probability will be suffered
in the future Moreover Defendantrsquos conduct has been so outrageous malicious and
consciously indifferent to the overwhelmingly likely severe harm of the Plaintiffs as to
constitute gross negligence as that term is understood in Texas law for which Plaintiffs
herein seek punitive damages as permitted by common law andor Texas Civil Practice
amp Remedies Code sect 41002
D COMMON-LAW FRAUD
32 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant made a material representation regarding removal of the decals
to Plaintiff to induce him into the transaction Defendant either knew its material
representation regarding removal of the decals was false when stated or Defendant
recklessly stated its material representations as positive assertions without knowledge of
their truth Defendant made these representations with the intent that Plaintiff rely on
them Plaintiff did rely on the representations to his detriment
33 Defendantrsquos false representations directly and proximately caused Plaintiffs
to suffer substantial past damages and in reasonable probability will cause Plaintiffs to
continue to suffer damages into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1126
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1226
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
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eserved
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Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 826
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 8
23 On December 18 2014 the final episode of the late-night comedy television
series The Colbert Report began with the segment ldquoTexanrsquos Truck in Syriardquo which was a
news story about a Mark-1 Plumbing truck now being used as an anti-aircraft gun in Syria
This episode was watched by 2481 million viewers making it the most watched episode
ever in the showrsquos history As of December 7 2015 the segment ldquoTexanrsquos Truck in Syriardquo
has an additional 67557 views on Comedy Centralrsquos website The widespread viewing of
the segment increased the volume of the harassing and threatening phone calls and has
immeasurably added to the suffering of Mark his family his employees and their families
24 The harassing and threatening phone calls continued for at least three
weeks from when the news story was officially reported Plaintiffs experienced at least
100-200 phone calls per day over this span of time Since that time Plaintiffs continue to
receive one or two phone calls per week However whenever ISIS commits an atrocity
that is reported nationally which occurs with distressing frequency Plaintiffs receive
more phone calls than normal all over again
25 On September 20 2015 the 67th Primetime Emmy Awards were held The
Colbert Report was nominated for ldquoOutstanding Directing for a Variety Seriesrdquo As part of
its show time nomination The Colbert Report included a bit of ldquoTexanrsquos Truck in Syriardquo
The 67th Primetime Emmy Awards was watched by 119 million viewers As a result
Plaintiffs suffered yet another period of non-stop phone calls averaging 100-200 phone
calls per day Plaintiff continues to receive threatening and harassing phone calls
practically each day Nearly one year has passed since the initial news story broke and
Plaintiffs still receive harassing phone calls and threats to this day
26 Through absolutely no fault of their own Plaintiffs have suffered and
continue to suffer damages directly resulting from Defendantrsquos failure to remove the decal
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 926
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 9
prior to resale as promised Plaintiffsrsquo plumbing repair work and all other sources of its
revenues have been substantially impacted and its reputation damaged beyond
rehabilitation As a direct result of the damage to Plaintiffsrsquo reputation Plaintiffs have lost
an excess of $100000000
VCAUSES OF ACTION
A RESPONDEAT SUPERIOR
27 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition At all times material to this Petition Defendantrsquos salesman was an employee
or agent of Defendant The acts of the employee were performed while in the employment
of Defendant and were within the course and scope of that employment or within the
authority delegated to the employee Employee was acting in furtherance of Defendantrsquos
business the accomplishment for which the employee was hired
28 Defendant is liable for the negligent acts and omissions of its employees
under the doctrine of vicarious liability or respondeat superior
29 As a result of Defendantrsquos negligent acts and omissions Plaintiffs have
suffered pecuniary harm and request compensatory and punitive damages in an amount
to be determined at trial
B JOINT AND SEVERAL LIABILITY
30 Additionally Defendant is directly liable for the acts and omissions of its
agents servants and employees in allowing a traded-in vehicle with clearly identifiable
marking of its previous business owner to be placed into the stream of commerce without
first removing said identifying markings such that the truck could fall into the hands of
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1026
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 10
criminals terrorists or jihadists and be photographed in circumstances which could and
did bring about Plaintiffrsquos severe injury and their incurring of consequent damages
C LIABILITY FOR NEGLIGENCE GROSS NEGLIGENCE AND COMMONLAW TORTS
31 As hereinafter set out in detail Defendant is liable to Plaintiffs for its
negligence and common law torts and for all economic andor compensatory damages
which have been suffered in the past and which in reasonable probability will be suffered
in the future Moreover Defendantrsquos conduct has been so outrageous malicious and
consciously indifferent to the overwhelmingly likely severe harm of the Plaintiffs as to
constitute gross negligence as that term is understood in Texas law for which Plaintiffs
herein seek punitive damages as permitted by common law andor Texas Civil Practice
amp Remedies Code sect 41002
D COMMON-LAW FRAUD
32 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant made a material representation regarding removal of the decals
to Plaintiff to induce him into the transaction Defendant either knew its material
representation regarding removal of the decals was false when stated or Defendant
recklessly stated its material representations as positive assertions without knowledge of
their truth Defendant made these representations with the intent that Plaintiff rely on
them Plaintiff did rely on the representations to his detriment
33 Defendantrsquos false representations directly and proximately caused Plaintiffs
to suffer substantial past damages and in reasonable probability will cause Plaintiffs to
continue to suffer damages into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1126
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1226
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
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CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
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Investor Relations BlogFOLLOW US
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eserved
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ind a Vehicle
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ease vs Buy
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Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 926
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 9
prior to resale as promised Plaintiffsrsquo plumbing repair work and all other sources of its
revenues have been substantially impacted and its reputation damaged beyond
rehabilitation As a direct result of the damage to Plaintiffsrsquo reputation Plaintiffs have lost
an excess of $100000000
VCAUSES OF ACTION
A RESPONDEAT SUPERIOR
27 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition At all times material to this Petition Defendantrsquos salesman was an employee
or agent of Defendant The acts of the employee were performed while in the employment
of Defendant and were within the course and scope of that employment or within the
authority delegated to the employee Employee was acting in furtherance of Defendantrsquos
business the accomplishment for which the employee was hired
28 Defendant is liable for the negligent acts and omissions of its employees
under the doctrine of vicarious liability or respondeat superior
29 As a result of Defendantrsquos negligent acts and omissions Plaintiffs have
suffered pecuniary harm and request compensatory and punitive damages in an amount
to be determined at trial
B JOINT AND SEVERAL LIABILITY
30 Additionally Defendant is directly liable for the acts and omissions of its
agents servants and employees in allowing a traded-in vehicle with clearly identifiable
marking of its previous business owner to be placed into the stream of commerce without
first removing said identifying markings such that the truck could fall into the hands of
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1026
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 10
criminals terrorists or jihadists and be photographed in circumstances which could and
did bring about Plaintiffrsquos severe injury and their incurring of consequent damages
C LIABILITY FOR NEGLIGENCE GROSS NEGLIGENCE AND COMMONLAW TORTS
31 As hereinafter set out in detail Defendant is liable to Plaintiffs for its
negligence and common law torts and for all economic andor compensatory damages
which have been suffered in the past and which in reasonable probability will be suffered
in the future Moreover Defendantrsquos conduct has been so outrageous malicious and
consciously indifferent to the overwhelmingly likely severe harm of the Plaintiffs as to
constitute gross negligence as that term is understood in Texas law for which Plaintiffs
herein seek punitive damages as permitted by common law andor Texas Civil Practice
amp Remedies Code sect 41002
D COMMON-LAW FRAUD
32 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant made a material representation regarding removal of the decals
to Plaintiff to induce him into the transaction Defendant either knew its material
representation regarding removal of the decals was false when stated or Defendant
recklessly stated its material representations as positive assertions without knowledge of
their truth Defendant made these representations with the intent that Plaintiff rely on
them Plaintiff did rely on the representations to his detriment
33 Defendantrsquos false representations directly and proximately caused Plaintiffs
to suffer substantial past damages and in reasonable probability will cause Plaintiffs to
continue to suffer damages into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1126
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1226
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
Americas Largest Automotive Retailer
copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
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ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1026
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 10
criminals terrorists or jihadists and be photographed in circumstances which could and
did bring about Plaintiffrsquos severe injury and their incurring of consequent damages
C LIABILITY FOR NEGLIGENCE GROSS NEGLIGENCE AND COMMONLAW TORTS
31 As hereinafter set out in detail Defendant is liable to Plaintiffs for its
negligence and common law torts and for all economic andor compensatory damages
which have been suffered in the past and which in reasonable probability will be suffered
in the future Moreover Defendantrsquos conduct has been so outrageous malicious and
consciously indifferent to the overwhelmingly likely severe harm of the Plaintiffs as to
constitute gross negligence as that term is understood in Texas law for which Plaintiffs
herein seek punitive damages as permitted by common law andor Texas Civil Practice
amp Remedies Code sect 41002
D COMMON-LAW FRAUD
32 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant made a material representation regarding removal of the decals
to Plaintiff to induce him into the transaction Defendant either knew its material
representation regarding removal of the decals was false when stated or Defendant
recklessly stated its material representations as positive assertions without knowledge of
their truth Defendant made these representations with the intent that Plaintiff rely on
them Plaintiff did rely on the representations to his detriment
33 Defendantrsquos false representations directly and proximately caused Plaintiffs
to suffer substantial past damages and in reasonable probability will cause Plaintiffs to
continue to suffer damages into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1126
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1226
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
Americas Largest Automotive Retailer
copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
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Fleet Sales
ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1126
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 11
34 Defendantrsquos actions were fraudulent malicious andor grossly negligent
and subject it to exemplary damages in an amount to be determined by the jury
E NEGLIGENT MISREPRESENTATION
35 In the alternative or in supplement thereto Defendant committed
negligent misrepresentation In the course of Defendantrsquos business and in transactions
involving its own pecuniary interest Defendants made representations to Plaintiffs that
the Defendants would remove Plaintiffsrsquo decals from Plaintiffsrsquo truck prior to resale
Defendants had an interest in Plaintiffs selling their truck to Defendant Plaintiffs
released their truck to Defendant under the pretense that the decals would be removed
prior to resale Defendant negligently supplied false misleading and deceptive
information to Plaintiffs regarding the transaction to induce that very transaction
Defendant wholly failed to exercise that reasonable care and competence of a vehicle
dealership in same or similar circumstances in ensuring the decals were removed prior to
resale Plaintiffs justifiably relied on the representations made by Defendant during the
transaction to their enormous and continuing injury and damage
36 Defendantrsquos misrepresentations proximately caused Plaintiffs to suffer
substantial damages in the past and will in reasonable probability continue to do so into
the future
37 Defendantrsquos actions were negligent malicious andor grossly negligent and
subject it to exemplary damages in an amount to be determined by the jury
F LIBEL PER SE
38 Plaintiffs incorporate as if set forth verbatim the preceding paragraphs of
this Petition Defendantrsquos failure to remove the decals from Plaintiffrsquos truck amounted to
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1226
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
Americas Largest Automotive Retailer
copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
Site Map
Fleet Sales
ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1226
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 12
Defendant implicitly accepting Mark-1 Plumbing Incrsquos decals as its own statement which
was subsequently published nationally Defendantrsquos failure the remove the decal makes
the statement defamatory per se under the common law because when taken as a whole
and as would have been perceived by a reasonable viewer Defendant imputed terroristic
andor jihadist ties and support to the Plaintiffs As a result Plaintiffs were injured in
their profession and occupation and in reasonable probability will continue to be so
injured into the future Such tortious conduct makes the Defendant strictly liable to
Plaintiff under Texas law because it is libelous per se
39 Defendantrsquos statement severely and irretrievably injured Plaintiffsrsquo
reputation and exposed Plaintiffs to national public hatred contempt ridicule and
financial injury and in reasonable probability will continue to do so into the future
40 Plaintiffs have suffered substantial injury as a result of Defendantrsquos
defamatory statements including but not limited to injury to character and reputation
mental anguish loss of past and future income and loss of earning capacity and in
reasonable probability will continue to do so into the future
G INVASION OF PRIVACY BY APPROPRIATION OF NAME
41 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant appropriated Plaintiffsrsquo name when it failed to remove the
traded-in truckrsquos decals prior to resale Plaintiff can be identified from the publication
through the plethora of news articles that include the propaganda photograph Defendant
received advantage in cutting costs by not removing the decals prior to resale
42 As a result of Defendantrsquos appropriation Plaintiff suffered injury to its
reputation prestige social or commercial standing and public interest and in reasonable
probability will continue to do so into the future
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
Americas Largest Automotive Retailer
copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
Site Map
Fleet Sales
ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1326
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 13
43 Plaintiff has suffered substantial injury as a result of Defendantrsquos invasion
of privacy by appropriation of Plaintiffrsquos name including but not limited to injury to
character and reputation mental anguish loss of past and future income and loss of
earning capacity
H VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES ACTBUSINESS amp COMMERCE CODE sect 1746
44 Plaintiffs incorporate as set forth verbatim the preceding paragraphs of
this Petition Defendant violated Texas Business amp Commerce Code sect 1746 in the
following particulars (2) causing confusion or misunderstanding as to the source
sponsorship approval or certification of goods (3) causing confusion or
misunderstanding as to the affiliation connection or association with or certification by
another (4) using deceptive representations or designations of geographic origin in
connection with goods (5) representing that goods have sponsorship approval which
they do not have for all of which violations Defendant is liable per se
45 Regarding such violations Plaintiffs herein seek damages for past and future
mental anguish all past and future proximately caused economic damages taxable costs
of court and reasonable attorneyrsquos fees together with interest as provided by law all in
conformity with Texas Business amp Commerce Code sect 1750
VIREQUEST FOR DISCLOSURE
46 Pursuant to Rule 194 of the Texas Rules of Civil Procedure Plaintiffs request
that Defendant disclose within the time provided by the Rules the information or
material described in Rule 1942
VIISTATEMENT OF RELIEF
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
Americas Largest Automotive Retailer
copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
Site Map
Fleet Sales
ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1426
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 14
47 Pursuant to Rule 47(c) of the Texas Rules of Civil Procedure Plaintiffs seek
monetary relief over $100000000
48 Plaintiffs seek damages that are within the jurisdictional limits of this Court
VIIIJURY DEMAND
49 Plaintiffs demand a jury trial and tender the appropriate fee with this
Petition
IXRESERVATION OF RIGHTS
50 Plaintiffs reserve the right to amend their complaint to assert such
additional causes of action as may be revealed during discovery
XPRAYER
WHEREFORE PREMISES CONSIDERED Plaintiffs MARK OBERHOLTZER
and MARK-1 PLUMBING INC pray that Defendant be cited to appear and answer
herein and upon final hearing that Plaintiffs be awarded a judgment and all relief sought
herein against Defendant as follows
a all economic and compensatory damages proved by a
preponderance of evidence
b punitive damages as proved by clear and convincing evidence
c reasonable and necessary attorneysrsquo fees
d pre-judgment and post-judgment interest as provided by law
e court costs and
f all other relief at law or in equity to which Plaintiff is justly
entitled
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
Americas Largest Automotive Retailer
copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
Site Map
Fleet Sales
ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1526
PLAINTIFFSrsquo FIRST AMENDED ORIGINAL PETITION PAGE 15
Respectfully submitted
L AW OFFICES OF A CRAIG EILAND
By ________________________
A Craig EilandState Bar No 06502380 Austin MartinState Bar No 24090245Old Galveston Square2211 The Strand Suite 201Galveston Texas 77550Telephone (409) 763-3260Facsimile (409) 763-8154ceilandeilandlawcomamartineilandlawcom
ATTORNEYS FOR PLAINTIFFS
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
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MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
Americas Largest Automotive Retailer
copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
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ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1626
Exhibit A
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
Americas Largest Automotive Retailer
copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
Site Map
Fleet Sales
ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1726
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Looking to sell your vehicle Before you place that classified ad read below to find out why it makes more sense to sell your vehicle
o us instead
SAVE
MONEY
n many states you only pay sales tax on the ldquoPrice Differencerdquo as opposed to the full selling price when you buy without trading For
example if you buy a new car for $25000 and trade-in your old car for $8000 you will only pay $1200 in taxes vs $1500 if you did
not trade-in your car
MAKE IT EASY ON
YOURSELF
Selling your car requires significant effort on your part In order to sell your used car youll have to do things like running classified
ads field phone calls and have strangers come to your house to go on test drives Then of course youll have to negotiate
AVOID CAR
REPAIR
f you sell your car you will need to ensure it is maintained and all parts are working This is extra worry and expense on your part
ncluding fixing brakes tires and other pricey items If you trade-in with a dealership they cover all of the reconditioning expenses
PROTECT
YOURSELF
Selling your car can be very dangerous If you do choose to sell your vehicle yourself be extremely careful and take the proper
precautions to insure your personal and financial saftey When setting up appointments with potential buyers that you dont know only
schedule meetings when a friend or family member can be there with you
WALK AWAY
FREELY
When you trade-in your car youll prevent any issues with a dissatisfied customer later on What happens if the engine burns up or
he transmission goes out If you sell your car the new owner knows where you live and may contact or harass you When you trade-
n your vehicle the dealership assumes all of the responsibility and you can walk away carefree
Home Value My Trade-In Trade-In vs Selling It Myself
Trade-In vs Selling It Myself
VALUE YOUR VEHICLE USING KELLEY BLUE BOOKreg
SHOULD I LEASE
OR BUYFind out which makes
the most sense
LEASE VS BUY
FIND A VEHICLE FINANCING VALUE MY TRADE-IN SPECIAL OFFERS SERVICE REPAIRS
Find a Store
Click to Chat Sign InRegister My AccouChange NOV DEC FEB
6 2012 2013 2015
11 captures
6 Dec 13 - 30 May 15
Cl
H
Keyword Search
httpwwwautonationcomhoustonvalue-trade-intrade-in-vs-selling-it-myself Go
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
Americas Largest Automotive Retailer
copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
Site Map
Fleet Sales
ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1826
-in Vs Selling it Myself | AutoNation | How to Trade-In a Car
-in Vs Selling it Myself _ AutoNation _ How to Trade-In a Car December 6 2013htm[11302015 115846 AM]
Simply follow three easy steps and youll receive a free Kelley Blue Bookreg Value on your current car Its just
that easy
AutoNationcom copy 2013 All rights reserved Privacy Policy | Terms of Use | Careers
ACURAAut oNati on A cur a Gulf Freeway
BMWMW of Houston
BMWMINIMW of The Woodlands
CHEVROLETAut oNati on Chevro let Highway 6Aut oNati on Chevro let Gu lf Fr eeway
CHRYSLERDODGEJEEPRAM Aut oNati on Chr ysl er Dodg e Jeep Ram Sprin g
FORD Aut oNation Ford Katy Aut oNati on Fo rd Gu lf Fr eeway
MERCEDES-BENZMercedes-Benz of Houston NorthMercedes-Benz of Greenway
MITSUBISHI Aut oNati on Mi tsu bis hi Gu lf Fr eeway
NISSAN Aut oNati on Nissan Katy
TOYOTASCION Aut oNati on Toyot a Gulf Freeway
BLOGS Aut oNati on B log
Investor Relations BlogFOLLOW US
Americas Largest Automotive Retailer
copy 2013 AutoNationcom All rights
eserved
About AutoNation
Locate a Store in Your Area
Investor Relations
Site Map
Fleet Sales
ind a Vehicle
More Search Optionsinancing
Start The Finance Process
ease vs Buy
Vehicle Protection Videos
Get an Extended Warranty
Value My Trade-In
Trade-In Appraisal
Trade-In vs Sellin It M self
Value My Trade
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 1926
Exhibit B
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2026
For Personal Use Only
Vehicle Information2005 FORD F250 SUPER DUTY
VIN 1FTSX21P15EC91985
4 DOOR EXTENDED CAB PICKUP
60L V8 DIR4 WHEEL DRIVE
Standard Equipment | Safety Options
This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 12715 at 52342 PM (EST)
Other information about this vehicle including problems may not have been reported to CARFAX Use this report as one important toolalong with a vehicle inspection and test drive to make a better decision about your next used car
Price Calculator trade
Adjust the value of this 2005 Ford F250 Super Dut y based on the information available in this report
Ownership HistoryThe number of owners is estimated
Owner 1
Year purchased 2005
Type of owner Corporate
Estimated length of ownership 8 yrs 3 mo
Owned in the following statesprovinces Texas
Estimated miles driven per year 20780yr
Last reported odometer reading 172446
Title HistoryCARFAX guarantees the information in this section
Owner 1
Salvage | Junk | Rebuilt | Fire | Flood | Hail | LemonGuaranteedNo Problem
Not Actual Mileage | Exceeds Mechanical Limi tsGuaranteed
No Problem
172446
Minor damage reported
CARFAX 1-Owner vehicle
2 Service records available
Corporate vehicle
Last reported odometer reading
Worth $10 more thanretail book value
1) Retail Book Value 2) CARFAX Price Adjustmenttrade 3) Adjusted Retail Value
$ 0
Enter retail book value here Above retail book value
Begin by entering
the retail book value
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2126
Glossary
Of course not every car in this area was affectedby the flood but Id stillget it inspected beforebuying Cant be toocareful
GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles
(DMV) If you find that any of these title problems were reported by a DMV and not included in this report
CARFAX will buy this vehicle back Register | View Terms | View Certificate
Addi tional HistoryNot all accidents issues are reported to CARFAX
Owner 1
Total Loss
No total loss reported to CARFAX
No Issues
Reported
Structural Damage
No structural damage reported to CARFAX
No IssuesReported
Ai rbag Deploym ent
No airbag deployment reported to CARFAX
No IssuesReported
Odometer Check
No indication of an odometer rollback
No IssuesIndicated
Acc iden t Damage
Accident reported on 12122009
Minor Damage
Manufacturer Recall
A current list of recalls is available at Ford Motor Company
No Recalls
Reported
Basic Warranty
Original warranty estimated to have expired Interested in an extended warranty
Warranty
Expired
Tell us what you know about this vehicle
View other FORD F250 SUPER DUTY vehicles with FREE CARFAX Reports
View vehicles with free CARFAX Reports
Detailed History
Owner 1
Purchased 2005
Type Corporate
Where Texas
Est milesyear 20780yr
Est length owned 72705 -
111113
(8 yrs 3 mo)
Date Mileage Source Comments
04052005 NICB Vehicle manufactured
and shipped to original dealer
07182005 McRee FordDickinson TX
281-337-1529mcreefordcom
Pre-delivery inspection completed
07272005 14 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Title issued or updatedFirst owner reported
Titled or registered ascorporate vehicle
09262005 CARFAX This vehicle was registered in a countydeclared a flood disaster area by the Federal
Emergency Management Agency ( FEMA )
07012006 TexasMotor Vehicle Dept
La Marque TXTitle
08420238546090751
Registration issued or renewedPassed safety inspection
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2226
Minor damage is usuallycosmetic includingdents or scratches to thevehicle body
View Full Glossary
07012007 Texas
Motor Vehicle DeptLa Marque TXTitle
08420238546090751
Registration issued or renewed
Passed safety inspection
09222007 66530 Texas
Inspection StationTexas City TX
Emissions inspection performed
Passed safety inspection
07012008 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012009 TexasMotor Vehicle DeptLa Marque TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
12122009 Damage Report Accident reportedMinor damage reported
07012010 Texas
Motor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewed
Passed safety inspection
07012011 TexasMotor Vehicle Dept
La Marque TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
07012012 TexasMotor Vehicle DeptTexas City TX
Title
08420238546090751
Registration issued or renewedPassed safety inspection
07012013 TexasMotor Vehicle Dept
Texas City TXTitle08420238546090751
Registration issued or renewedPassed safety inspection
10252013 172303 AutoNation Ford Gulf
FreewayHouston TX713-489-2089
autonationcom
Vehicle serviced
11112013 172446 Auto Auction
Texas
Listed as a dealer vehicle
Vehicle sold at auction
11142013 Dealer Inventory Vehicle offered for sale
12182013 Vehicle Exporter Vehicle exported fromHouston TX
and imported toMersin Turkey
Print thi s CARFAX Report and take it t o your pre-purchase inspection
Have Questions Please visit our Help Center at wwwcarfaxcom
Glossary
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2326
Acc ident Damage Ind icator CARFAX receives information about accidents in all 50 states the District of Columbia and Canada Different information in avehicles history can indicate an accident or damage such as salvage auction fire damage police-reported accident crash test
vehicle damage disclosure collision repair facility and automotive recycler records Not every accident or damage event is reported
and not all reported are provided to CARFAX Details about the accident or damage event when reported to CARFAX (eg severityimpact location airbag deployment) are included on the Vehicle History Report CARFAX recommends you obtain a vehicleinspection from your dealer or an independent mechanic
According to the National Safety Council Injury Facts 2007 edition 7 of the 245 million registered vehicles in the
US were involved in an accident in 2005 Over 75 of these were considered minor or moderate
CARFAX depends on many sources for its accident damage data CARFAX can only report what is in our database
on 12715 at 52342 PM (EST) New data wi ll result in a change to this report
CARFAX Price Adjustmenttrade
Accidents service records number of owners and many other history factors can affect a vehicles value The CARFAX Price Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported toCARFAX affects the value of a particular vehicle The vehicles retail book value plus the CARFAX Price Adjustment will give you a
more accurate measure of the vehicles value Use this tool along with a vehicle inspection and test drive to make a better decisionabout your next used car
First Owner When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership
Ford or Lin coln Mercury RecallThe Ford Motor Company provides Carfax with recall information regarding safety compliance and emissions programs announced
since 2000 for a specific vehicle For complete information regarding programs or concerns about this vehicle please contact a localFord or Lincoln Mercury Dealer
Ownership HistoryCARFAX defines an owner as an individual or business that possesses and uses a vehicle Not all title transactions representchanges in ownership To provide estimated number of owners CARFAX proprietary technology analyzes all the events in a vehiclehistory Estimated ownership is available for vehicles manufactured after 1991 and titled solely in the US including Puerto Rico
Dealers sometimes opt to take ownership of a vehicle and are required to in the following states Maine Massachusetts New JerseyOhio Oklahoma Pennsylvania and South Dakota Please consider this as you review a vehicles estimated ownership history
Title Issued A state issues a title to provide a vehicle owner with proof of ownership Each title has a unique number Each title or registrationrecord on a CARFAX report does not necessarily indicate a change in ownership In Canada a registration and bill of sale are used
as proof of ownership
Follow Us facebookcomCARFAX CarfaxReports CARFAX on Google+
CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION THEREFORE NO
RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAXFURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED INCLUDING ANY IMPLIED WARRANTIES OFMERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE CARFAXregcopy 2015 CARFAX Inc a unit of IHS Inc All rights reserved
Covered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2426
2005 FORD F250 SUPER DUTYVIN 1FTSX21P15EC91985Body Style 4 DOOR EXTENDED CAB
PICKUPEngine Size 60L V8 DIRDrivetrain 4 WHEEL DRIVE
Original Manufacturers Warranty
Basic Warranty Expired
Please confirm remaining factory warranty andextended warranty options with your dealer
The original manufacturers warranty includes
36 months or 36000 miles
Information excerpted from the CARFAX VehicleHistory Report andor Safety amp Reliability Ratingssee full reports for additional information glossary
of terms source attributionsdisclaimers amplimitations Go to carfaxcom for complete Buyback
Guarantee terms and conditions
Number of Owners
Last owned in the following
stateprovinceTexas
None of these major title problems
were reported by a state Departmentof Motor Vehicles
Salvage Junk Rebuilt Fire
Flood Hail Lemon
GuaranteedNo Problem
Not Actual Mileage Exceeds
Mechanical Limit s
Guaranteed
No Problem
No issues reported to CARFAX on the following
Total Los sNo IssuesReported
Structural DamageNo Issues
Reported
Ai rbag DeploymentNo IssuesReported
Odometer RollbackNo IssuesReported
Minor damage reported on this vehicle Please see the
full CARFAX Vehicle History Report for more details
copy 2015 CARFAX Inc a unit of IHS Inc All rights reservedCovered by United States Patent Nos 7113853 7778841 7596512 8600823 8595079 8606648 750583812715 52342 PM (EST)
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2526
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
1272015
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
8202019 Oberholtzer Lawsuit
httpslidepdfcomreaderfulloberholtzer-lawsuit 2626
FAX Vehicle History Report for this 2005 FORD F250 SUPER D httpswwwcarfaxcomshowroomreport1FTSX21P15
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