NHTSA Complaint #11452878 — 2022 TESLA MODEL 3

I purchased from Tesla Motors, Inc. (“Tesla”) a Tesla Model 3, VIN: [XXX] (the “Defective Vehicle”) and took delivery of the vehicle on December 10, 2021, from the Loveland, Colorado, service center located at 1606 N. Lincoln Ave. (the “Service Center”). Since the day I took delivery of the Defective Vehicle in December 2021, the Defective Vehicle dangerously, suddenly, and repeatedly slams on the emergency brakes while I am driving on the two-lane roads that are my route to commute to work. This defect has existed and the Defective Vehicle has been unsafe and noncompliant with Tesla’ warranty since the day I took delivery of it. The defect substantially impairs the use and market value of the Defective Vehicle, as the Defective Vehicle is a danger to anyone who drives it. My daily commute is approximately 25 miles each way to and from my home, and, on average, the vehicle will slam on the brakes no less than fifteen times per commute. Often, the occurrence is much higher than fifteen times per commute. Vehicles following behind me have had to swerve to avoid the Defective Vehicle and my belongings fly into the dashboard. One morning, the emergency braking caused my vehicle to slip in the snow, and I was fearful I would hit an oncoming vehicle head on because of the unexpected emergency braking. This defect is severe and endangers my life and safety and the life and safety of any passengers. I have attempted several to have the vehicle repaired at the Service Center, but the Service Center has either refused or been unable to bring the Defective Vehicle in conformity with the warranty. I have asked repeatedly when the repairs will be made, but no one at the Service Center responds to me in the app and the Service Center unilaterally cancels and closes service appointments I attempt to make. I have notified Tesla that the vehicle is a Lemon under Colorado law. INFORMATION Redacted PURSUANT TO THE FREEDOM OF INFORMATION ACT (FOIA), 5 U.S.C. 552(B)(6).