According to the complaint filed by the District Attorney of Orange County, CA
The fines could be:
*Pursuant to Business and Professions Code section 17206, that Defendants, and each
of them, be ordered to pay a civil penalty in the amount of two thousand five
hundred dollars ($2,500.00) for each violation of Business and Professions Code
section 17200 by Defendants, in an amount according to proof.
* That Plaintiff recover it’s costs of suit, including costs of investigation.
* For reasonable attorneys fees pursuant to Code of Civil Procedure section 1021.5,
or other applicable law; and
* For such other equitable relief as is just and proper.
The reasons are:
* The Toyota cars and trucks that are the subject of this Complaint are the vehicles
sold and/or leased by Defendants, during the liability period, with defects that may cause various
makes and models of Toyota-made cars and trucks to experience sudden unexpected and
uncontrollable acceleration of speeds up to 100 miles per hour and more (hereinafter the
* While the models of Toyota cars and trucks at issue are not precisely known at this
time, based on current investigations and admissions of Defendants, the vehicles that are the
subject of this Complaint include: (i) all Toyota and Lexus vehicles referred to in Toyotas October
30, 2009 “Interim Notice,” which according to Toyotas website are: 2007 “ 2010 Camry, 2005 “
2010 Avalon, 2004 “ 2009 Prius, 2005 “ 2010 Tacoma, 2007 “ 2010 Tundra, 2007 “ 2010 ES350,
2006 “ 2010 IS250 and IS350; (ii) all model year 2002 – 2010 Toyota vehicles (this means all
model year 2002 – 2010 vehicles of the Toyota brand, including Prius, and all model year 2002 –
2010 vehicles of the Lexus brand); and (iii) all other Toyota and Lexus cars and trucks sold and/or
leased with the Defects (“Subject Vehicles”).
Toyotas Knowledge Of The Defects And The Risk To Public Safety
* Toyota has known throughout the liability period, and likely earlier, that certain
models of their cars and trucks sold or leased in the State of California were defective because they
tend to accelerate suddenly and uncontrollably, and that consumers and members of the public
could be seriously injured or killed as a direct and proximate result of the Defects.
* Since 2001, and likely earlier, many people have been injured or died in accidents
relating to the Defects. While the exact injury and death toll is unknown, due to Toyotas
campaign of concealment and suppression, as alleged herein, numerous other drivers and
passengers of Toyota vehicles have died or suffered serious injuries and property damage. All
owners and lessees of Toyota-made vehicles have suffered economic damage to their property
due to the Defects. Many are unable to sell or trade their cars, and many are afraid to drive their
* Despite it’s knowledge of the Defects, Toyota continued to sell or lease it’s cars and
trucks with the Defects. As a result, the injury and death toll has continued to increase and, to this
day, Toyota continues to conceal and suppress this information and has failed to disclose to buyers
this life-threatening uncontrolled acceleration peril.
* During this time period, as set forth in detail below, Toyota falsely assured
California consumers in various written statements that their cars were safe and reliable, and
concealed and suppressed the true facts that the Toyota-manufactured vehicles were defective. To