NHTSA Complaint #10967666 — 2015 RAM PROMASTER 2500

THE COUPLER BETWEEN THE MOTOR AND THE TRANSMISSION HAS REPEATEDLY FAILED; ALSO, THE AXLE HAS FAILED TWICE, THE LAST AXLE FAILURE THE SHAFT SPLIT IN HALF AND PART OF IT ENDED UP IN THE GEAR BOX. THE A/C CONTINUALLY LEAKS AS THE HIGH PRESSURE HOSE FROM CONDENSOR TO COMPRESSOR IS TOO SHORT. THE ATTACHED IS A LAWSUIT THAT ZENITH FILED IN JUNE 2016 OVER IT'S REPEATED DRIVE TRAIN FAILURES, ALLEGING BORG WARNER AT FAULT. ATTACHED IS A DEPICTION OF THE ZENITH PORTAL THAT WAS ESTABLISHED TO COMMUNICATE AND TRACK SERVICE TICKETS ON REPAIRS; HOWEVER, ON AUGUST 10, 2016 ZENITH DENIED US ANY FURTHER ACCESS TO THE PORTAL. ZENITH HAS REFUSED TO GIVE US SUPPORT. WE ARE A COMMERCIAL OPERATOR WITH COURTESY PASSENGER SHUTTLES FOR MOVEMENT OF PEOPLE TO AND FROM OUR PARKING LOT AND TO THE SAN DIEGO AIRPORT. WE ARE A GROUND TRANSPORTATION OFF AIRPORT PARKING OPERATOR. THE SHUTTLES HAVE BROKEN DOWN TO AND FROM ROUTE DURING OPERATION, THE ROUTE IS 9 MILES ROUND TRIP. WE AVERAGE 150 MILES PER DAY IN A SHUTTLE. WE ARE IN STREET TRAFFIC WITH STOP LIGHTS AND HIGH CONGESTION DUE TO THE ROADS AT THE AIRPORT HAVE HIGH USE. WE OPERATE 24/7 AND HAVE BEEN IN BUSINESS SINCE 1991 AND WE HAVE NEVER HAD BROKEN DRIVETRAINS OR AXLES IN OUR SHUTTLES. WE HAVE VIDEOS OF THE FLOPPY COUPLER THAT DEMONSTRATES THE ONGOING ISSUES OF THIS PART AND THE IMPACT THAT A FLOPPY COUPLER HAS ON THE SPLINES OF THE MOTOR AND GEAR BOX. THIS COMPLAINT WILL BE 1 OF 3 AS WE HAVE 3 SHUTTLES BY ZENITH THAT WERE ALL PURCHASED IN 2015.