NHTSA Complaint #11266565 — 2014 TESLA MODEL S

SHORTLY AFTER UPDATING THE VEHICLE WITH TESLA'S SOFTWARE UPDATES 2019.16.1 AND 2019.16.2, IT WAS DISCOVERED FOR THE FIRST TIME THAT THE VEHICLE HAD SUFFERED FROM A SUDDEN AND IMMEDIATE LOSS OF APPROXIMATELY 26 MILES OF RANGE AS A RESULT OF THE PAIR OF SOFTWARE UPDATES. THE UPDATES IN QUESTION ALSO SEVERELY DECREASED THE SUPERCHARGING SPEEDS FOR THE VEHICLE. IN ADDITION, THE SOFTWARE UPDATES ISSUED BY TESLA DID NOT DISCLOSE ANYTHING WITH REGARDS TO THE RANGE LOSS OR DECREASED CHARGING SPEEDS. TESLA HAS RELEASED UPDATES SINCE INITIAL RANGE-REDUCING AND CHARGE-SPEED LIMITING UPDATES WHICH WERE SUPPOSED TO AND PURPORTEDLY WERE ISSUED TO CORRECT THE PROBLEMS, HOWEVER, THERE IS NO SIGNIFICANT CHANGE OR INCREASE IN RANGE OR CHARGING FOR THE VEHICLE TO DATE. NOTE - THIS COMPLAINT HAS BEEN SUBMITTED BY LEGAL COUNSEL WHO CURRENTLY REPRESENTS THE AFFECTED OWNER FOR THIS SPECIFIC VEHICLE. LEGAL COUNSEL HERE ALSO SERVES AS COUNSEL TO THE PUTATIVE CLASS MEMBERS AND NAMED CLASS PLAINTIFF IN THE LITIGATION CURRENTLY PENDING IN THE U.S. DISTRICT COURT, NORTHERN DISTRICT OF CA, CASE NO. 5:19-CV-01422-VKD.