LaSorte vs. Ghassemieh

On 2/21/24, defendant FCA US LLC (FCA) sent Plaintiffs a repurchase offer letter setting forth a total repurchase amount of $56,503.19 and states, “If this offer is acceptable, please sign and return this letter . . .” (Abeel Decl., ¶ 2, Ex. A at p. 1.) The repurchase letter is also accompanied by a release agreement that states Plaintiffs agree to release FCA from liability, other than that arising from personal injuries and medical expenses, related to the vehicle as of the date of this Agreement. (Abeel Decl., ¶ 2, Ex. A at p. 3.)

Plaintiffs did not sign and return the repurchase offer or the release but informed FAC on 9/26/24 that the total buy back number was approximately $86,000 and not the $56,503.19 previously offered. (Abeel Decl., ¶ 3, Ex. B at p. 1.) Counsel further stated, “I need to know we are on the same page as to what the buy back amount is and for what collateral costs.” (Id.) Plaintiffs’ counsel followed up with FCA regarding the repurchase several more times from September 2024 through November 2024 with no response from FCA. (Abeel Decl., ¶ 4, Ex. C.)

On 11/13/24, FCA responded to state it would reimburse Plaintiffs for “payments, interest, and registration” but not for “insurance, maintenance, or fuel.” (Abeel Decl., ¶ 5, Ex. C at p. 2.) Plaintiffs followed up with the current registration and Retail Installment Sales Contract on 11/15/24, at which point FCA no longer responded. (Abeel Decl., ¶ 5, Ex. C.)

On 7/29/26, FCA sent an itemized offer with a release to Plaintiffs’ counsel for final settlement of this matter. (Lemalu Decl. ¶ 8, Ex. E.) FCA’s counsel was informed Plaintiffs’ counsel was out of the country and would not return to the office until 8/10/26. (Lemalu Decl. ¶ 9.) (While the Lemalu Declaration references an email chain reflecting this correspondence as Exhibit F, that exhibit is not attached.)

As stated above, a settlement is enforceable under section 664.6 “only if the parties agreed to all material settlement terms.” Plaintiffs’ declaration and evidence demonstrate the parties did not agree to all material terms, including the repurchase amount, such that a settlement may be enforced under section 664.6. Plaintiffs concede no agreement was made as they state the amount owed to Plaintiffs remains at issue. (Mtn. at 4:11-12.) Defendant also demonstrates the settlement negotiations are ongoing as it sent Plaintiffs’ counsel an offer for final settlement of this matter as recently as 7/29/26 but has not yet received a response.

Accordingly, the Court DENIES Plaintiffs Bradley Consulting Group and Tom Bradley-King’s Motion to Enforce Repurchase Offer and Settlement Agreement. 8 24-01375951 1) Motion for Sanctions 2) Motion for Terminating Sanctions LaSorte vs. Ghassemieh The Court GRANTS the motion of Christina La Sorte for a terminating sanction against defendant Majid Gassemieh dba Ultimate Autoline