Case 2:19-cv-04006-ER Document 145-2 Filed 03/21/22 Page 1 of 5
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`IN THE UNITED STATES DISTRICT COURT FOR THE
`EASTERN DISTRICT OF PENNSYLVANIA
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`CHIJIOKE- UCHE,
`
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`Plaintiff,
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`v.
`
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`GENERAL MOTORS LLC & CHAPMAN
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`CHEVROLET LLC.
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`Defendants.
`
`Civil Action No. 2:20-cv-00216-ER
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`DEMAND FOR JURY TRIAL
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`MOTION FOR SUMMARY JUDGMENT
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`PROOF OF ONSTAR TURBOCHARGER DEFECT PRE-DIAGNOSTICS
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`VERIFYING OF VEHICLE TUBOCHARGER DEFECT
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`PLAINTIFF’ AFFIDAVIT IN SUPPORT OF HIS MOTION FOR SUMMARY JUDGMENT
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`Affidavit
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`I, Jeffrey Solomon Chijioke-Uche, Plaintiff, being duly sworn, hereby depose and say:
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`1. That I am the Plaintiff in this case.
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`2. That on August 24, 2018, I received from OnStar artificial intelligence system an
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`automated turbocharger pre-diagnostics report.
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`3. That on the diagnostics report showed that my vehicle has a defective turbocharger and
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`that all the powertrain(“engine, and transmission system”) are affected.
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`4. That the OnStar artificial intelligence advised me to schedule a service with the
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`dealership.
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`5. That the OnStar artificial intelligence indicated that the entire Powertrain of the vehicle
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`is affected by the detected defect.
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`6. That the OnStar artificial intelligence indicated that the Engine and transmission system
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`which is part of the Powertrain of the system are seriously affected by the defective
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`turbocharger
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`7. Below is the copy of the OnStar diagnostic report:
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`

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`Case 2:19-cv-04006-ER Document 145-2 Filed 03/21/22 Page 2of5
`Case 2:19-cv-04006-ER Document 145-2 Filed 03/21/22 Page 2 of 5
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` GE@outlook.com
`
`From:
`Sent:
`To:
`Subject:
`
`OnStar Services <vehiclediagnostics@onstar.com>
`Friday, August 24, 2018 8:08 AM
`GE!00k.com
`Your August Diagnostics Report from your Buick Encore AWD
`
`To ensure that you continue to receive emails from OnStar in your inbox, please add vehiclediagnostics@onstar.com to your
`address book. To unsubscr be from Diagnostic Reports,clickhere,
`
`Having trouble viewing this email? Click here.
`
`BUICK
`
`
`
`
`2014 Buick Encore AWD
`
`VN:
`
`PLANS & SERVICES | MY ACCOUNT| RENEW SERVICE
`
`CONNECTED BY
`
`
`
`Diagnostics Report from your
`2014 Buick Encore AWD as of
`08/23/2018
`
`Dear Solomon Jeffrey Chijioke,
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`There is a diagnostic alert for your vehicle this
`month requiring immediate attention. Please see
`the Diagnostic Information for details on your key
`operating systems.It is critical that you take care
`of this issue promptly to maintain the safe
`operation of your vehicle.
`
`| No Issues Found Action Suggested immediate Attention
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`DIAGNOSTIC INFORMATION
`| Engine and Transmission System
`
`e
`
`There is an issue with your turbocharger. Schedule a service visit with your Dealer as soon
`as possible.
`
`Emissions System
`
`Air Bag System
`
`StabiliTrak® Stability Control System
`
`Antilock Braking System
`
`OnStar System
`
`

`

`Case 2:19-cv-04006-ER Document 145-2 Filed 03/21/22 Page 3 of 5
`Case 2:19-cv-04006-ER Document 145-2 Filed 03/21/22 Page 3of5
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`REQUIRED MAINTENANCE
`ime Vehicle Maintenance
`No oil change dueatthis time.
`
`Remaining Oil Life: 46%
`Mileage: 58,061
`
`View maintenance summary
`
`Learn aboutoil life
`
`& Tire Pressure: Normal
`e
`No issues found.
`
`e
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`Recommended tire pressure:
`=
`Front: 35psi
`| Rear: 35psi
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`Left Front:
`38psi
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`Right Front:
`39psi
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`Left Rear: Gi
`39psi
`
`Right Rear:
`41psi
`
`Recalls and Programs
`To check for recalls and
`programs on your GM
`vehicle, click here.
`
`Learn abouttire pressure
`
`Odometer-Based
`Maintenance Items
`
`Based on your current
`mileage, no items on the
`additional maintenancelist
`are dueatthis time.
`
`we Warranty Tracker
`;
`Yourvehicle has one or
`more active warranties.
`
`See warranty coverage
`
`PACKAGES& SERVICES
`FN OnStar" Service Plan
`
`Gy Plan Add-Ons
`You can add individual services to any OnStar
`+ Account+ com
`e
`Basic Plan
`
`Purchase add-ons
`
`You are currently enrolled in OnStar Basic
`Plan. Emergency services including
`Automatic Crash Responseare notactive as
`part ofthis plan.
`
`Upgrade plan
`
`VEHICLE HISTORY
`
`Review charts of your vehicle's history.
`
`bt Oil Life History
`
`Mileage History
`
`
`OTHER INFORMATION
`
`Insurance Benefit
`
`Your mileage makes you eligible for a low mileage discount on auto insurance.
`
`Explore Options
`
`
`TIPS AND EXTRAS
`
`

`

`Case 2:19-cv-04006-ER Document 145-2 Filed 03/21/22 Page 4 of 5
`Case 2:19-cv-04006-ER Document 145-2 Filed 03/21/22 Page 4of5
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`DEALER INFORMATION
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`Youare enrolled in Dealer MaintenanceNotification, and your dealerwill be notified when your vehicle
`is due for service.
`
`Review Dealer Information
`
`Preferred Dealer
`
`CHAPMAN CHEVROLET, LLC
`6925 ESSINGTON AVENUE
`PHILADELPHIA, PA19153
`
`Schedule Service
`
`Dealer Website
`
`Dealer Pricing and Offers
`
`
`
`Privacy Statement
`
`‘ Visit OnStar.com for coverage maps, details and system limitations. Subject to terms and conditions.
`
`2 SirilusXM services require a subscription after trial period. If you decide to continue your service at the
`endof yourtrial subscription, the plan you choose will automatically renew andbill at then-current rates
`until you call 1-866-635-2349 to cancel. See SiriusXM Customer Agreement for complete termsat
`www.sirlusxm.com. NavtTraffic available only in certain vehicles and in select markets. Current information
`and features may not be available in all locations, or on all receivers. SiriusXM is not responsible for any
`errors or inaccuracies in the NavTraffic service orits use in the vehicle. See www.siriusxm.com for more
`details.
`
`If you are deaf, hard of hearing, or speech impaired, you may now use the dedicated TTY connection to
`call ustoll free at 1.877.248.2080 or email us at TTY@onstar.com for assistance or with questions
`regarding your OnStar account.
`
`To unsubscribe from Diagnostics Report service, pleasevisit the Settings page at your vehicle’s Owner
`Center.
`
`Would youlike to update your email address?
`
`This is an automated email - please do not respond.
`
`Basic Plan includes select Vehicle Diagnostics and select mobile app features that require factory-
`installed remote start, power locks, Tire Pressure Monitoring System and active OnStar service. Basic
`Plan does not include Emergency, Security or Navigation services; these and other services, such as the
`vehicle locate feature, require a paid plan. Visit onstar.com for details and service availability. Services
`are subject to user terms and limitations, and vary by vehicle model. Visit onstar.com for more details.
`Availability and additional features subject to change.
`
`As always,if you have any questions about this report, please call 1.888.4-ONSTAR (1.888.466.7827)for
`details.
`
`You can contact OnStarat the following address:
`OnStar MemberServices, P.O. Box 1027, Warren, MI 48090-1027.
`
`©2018 OnStar LLC.All rights reserved.
`
`

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`Case 2:19-cv-04006-ER Document 145-2 Filed 03/21/22 Page 5 of 5
`BEFORE ME
`COMMISSIONER FOR OATHS
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`Under penalty of perjury, I declare that the foregoing in support of Plaintiff’s opposition to the
`Defendant’s summary judgement is true and correct.
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` By: ____________________________________________________
`Signature of Person Swearing Affidavit
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`STATE OF
`COUNTY OF
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`Jeffrey Solomon Chijioke-Uche
`Printed Name:___________________________________
`Title:
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`The foregoing instrument was acknowledged, sworn
`to (or affirmed) and subscribed before me this
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`day of
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`, by
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`oath COMMISSIONER’s SEAL/STAMP
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` Name of Person Swearing Affidavit
`Notary Public – State of
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`Jeffrey Solomon Chijioke-Uche
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`Name of Oath Commissioner printed AND Signature appended
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`.
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`My Commission Expires:
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`□ Personally Known
`□ Produced Identification Type of Identification Produced:
`ID No.: 29 667 919
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`PA Driver's License
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` Date of Issuance: ___________________________________
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`Florida
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`Palm Beach
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`N/A
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`3rd
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`February
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`2022
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`Darien Hernandez
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`Florida
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`Darien Hernandez
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`Notarized online using audio-video communication
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`10/14/2025
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`12/07/2019
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