3205. Failure to Begin Repairs Within Reasonable Time or to Complete Repairs Within 30 Days--Essential Factual Elements (Civ. Code, § 1793.2(b)) Instruction No 1 Request by Plaintiff Given as Proposed Refused Withdrawn Request by Defendant Given as Modified Requested by Given on Court's Motion Judge Instruction No 1 [Name of plaintiff] claims that [he/she] was harmed because [name of defendant] failed to [begin repairs on the [consumer good/new motor vehicle] in a reasonable time/ [or] repair the [consumer good/new motor vehicle] within 30 days]. To establish this claim, [name of plaintiff] must prove all of the following: 1. That [name of plaintiff] [bought/leased] a[n] [consumer good/new motor vehicle] [from/distributed by/manufactured by] [name of defendant]; That [name of defendant] gave [name of plaintiff] a written warranty that [describe alleged express warranty]; That the [consumer good/new motor vehicle] had [a] defect[s] that [was/were] covered by the warranty; That [name of defendant] or its authorized repair facility failed to [begin repairs within a reasonable time/ [or] complete repairs within 30 days so as to conform to the applicable warranties]. 2. 3. 4. ________________________________________________________________________________ New December 2011; Revised December 2012