Free Motion in Limine - District Court of Arizona - Arizona

EXHIBIT 1

Case 2:04-cv-00161-ROS

Document 189-2

Filed 08/25/2006

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BILL TRH1MELL

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I,
EVALUATION REPORT

INSP.DATE: LOCATION:
ACTIVITY SHEET: # 1 OWNER: LANE SENNETT INSPECTOR: BILL TRIMMELL
N.A.DA. STATED MSRP WAS == $ 125,734.00 , WHOLE SALE VALUE is ~ $ 75,300.00 RETAIL VALUE IS = $ 99,390.00

DA TE: September 4, 2004

CLIENT PAID is:: $ 127,081.05 TOP BOOK RETAIL VALUE is:: $ 100,400.00
SAL V AGE VALUE is = $ 20,080.00

This motor home with no defects would justify top book retail with full adds would a.c.v. At
= $ 100,400.00

NOTE THIS MOTORHOME IN ITS PRESENT DAY CONDITION AND WIll THE FACT THAT IT IS NOT KNOWN WHAT THE CAUSE OF MANY OF THESE ISSUES ARE. I COULD NOT EV ALUA TE IT AT ANY HIGHER V ALDE THAN SEVENTY -FIVE PER-SENT OF WHOLESALE VALUE. $ 100,400.00:: TOP BOOK RETAIL VALUE $ 56,475.00 = ESTIMATED PRESENT DAY VALUE $ 43,925.00 == LOSS OF VALUE

TH OPINIONS, ESTIMA rES, AND EV ALUA TrONS ARE JUST THAT. THESE FINDINGS

ARE BASED ON THE INSPECTION, SERVICE RECORDS, AND INRVIEW WITH THE OWNER. ESTIl\1ATES ARE BASED ON THE LATEST REPAIR METHODS, AND EXCEPTED STANDARDS OF THE INDUSTRY. AMERICAN APPRASIAL, AND OR THE INSPECTOR CAN NOT EXCEPT LIABILITY FOR THE OPINIONS IN THIS REPORT.
By

t5£¡ ~.
Bill Trimmell
Filed 08/25/2006 Page 2 of 6

Case 2:04-cv-00161-ROS

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INSPECTlON LOCATION = INSPECTED BY = BILL TRIMMELL VEHICLE OWNERS = LANE SENNETT VEHCILE INFORMATION ~ 2003 PACE ARROW by FLEETWOOD, MODEL 37A CLASS A MOTOR HOME 38ft. (2) SLIDE OUTS, on 2002 WORK HORSE CHASSIS BONDED WALL CONSTRUCTION VIN. # = 5B4MP67G823351670
LICENSE # == N/ A

MILEAGE = 21,400 apx.
DA TE "" August 22, 2004

Report:

Prior to conducting my interview of Ms, Sen.ieU, I first reviewed the repair orders and purchase documents for this vehicle. After thorough review of the service and repai.r as
well as waranty work orders, my tìrst impression was that the coach's overall quallty

these issues mayor may not have been resoIved in one or more attempts at them, the mere existence of this many defects and problems in.a brand new motor home with the miles registered on this unit. Would indicate a coach not in keeping with Pace Arrow's brand name nor Fleetwood's reputation, and this coach's sellng price. I did note that this motor home was a carryover unit. By that I mean that this is a 2002 chassis with a 2003 coach body built on it. As you have heard me opine in the past about carryover motor homes I can make the
and workmanship was very poor. Even though some of same observations about this one. It would not be unreasonable to relate some of these problems to the fact this chassis was setting around for a much longer period oftime before it was utilized into a full fledged motor home. I would make a couple of other observation before getting into the specific compIaint issues. The first being that this motor home left the assembly plant with some of these problems. This means that the quality was sorely lacking when this coach was manufactued. The second being that it did not receive any better quality control after reaching the sellng dealer and before being sold to this owner as a new supposedly ready to go motor coach. As an example of this the first time the owner hooked up to city water after taking the coach out from the dealer he had massive water leaks and lines that were never connected. This would alone point to the fact that this coach was not water tested by the manufacturer or their representative the selling dealer. When the owner called back to complain about this condition they were told, sorry we must have over looked that. This was just the star of

the problems they would experience with this coach in the next few

months. In fact, iff were looking at the repair history alone, I'd have thought this unit was used with many years and miles on it rather than new.

Compliant issues:

Case 2:04-cv-00161-ROS

Document 189-2

Filed 08/25/2006

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I am not going to address these issues in any particuIar order other, than the way i discussed them with the owners,

one of

The first problem in the coach lies within tht bedroom slide out and is most definitely the issues the motor home left the factory with. This slide out unit was a source of
the elements.

water leaking from day one and was worked on several times before anyone fOW1d the
real issue that was causing this point of entry of

The very first warranty repair order generated on this coach that I have record of .
addresses this leaking of

the bedroom slide and it goes on from there. Hopefully on their last trip in for waranty repairs this issue may have bee? resolved,. at I~ast as t~ how the water was making entry into the motor home structure its stlf. This sttlI remains to be
seen.

The owners were told that the screws that hold this slide out together were never sealed from the time they were installed during its manufacturer at the factory. This m~ans that any time it was exposed to rain or any other outside elements, such as water testing for
leaks, this slide out structure was indeed leaking. Lets examine the last Fleetwood repair order numbered # t 7532. This is the hand

written repair order claim number stamped 90300. This is hand written not by the owner's or me but by Fleetwood's representative Dick Gore's RV World that actually preformed these repairs for Fleetwood. It starts 'out "removed window and bottom extrusion, placed shims under skin and drained water". They are talking about a slide out wall assembly here this is not a bathtub, this is not a holding tank. A bonded wall structure was never designed nor meant to hold water, not in anybody's wildest imagination was it ever built for that purose. For it to be holding water ever is a manufacturer's defect of massive proportions, and in my opinion it has destroyed this
assembly for al1 intents and purposes. This slide out assembly should be removed and

completely replaced at the very least. For anyone who bothers to read this technician's this work he stil winds up with more of the same Ieaking. Now after finding he stil has leaks, does he go back disassemble this wall strcture again dry it out once more, reassemble it and then completely reseal the bottom extrusion? No he doesn't, it clearly states he "resealed, let set, leak test again, had no leaks this time". Well what about the water that entered when he Ieak tested the time before, that was left trapped inside the wall structure, and now its sealed in there with no way for it to escape. If he is right about truly having it waterproof this last attempt, this trapped water is left there to do its damage with no way to escape from this wall structure. Now lets look at what the o\Ver's were complaining about, they had wet carpet on both sides of the bed from this very water leak that was happening in the slide out wall, What about the floor decking that this carpet and pad was setting on. As it turns out the
hand wrtten job expIanation it is quite clear that after performing all of

~aret a11d pad only served to hold and trap this water next to the floor decking allowing

it to do more da.mage than ifit were to run out on the bare floor. Was this floor decking ever addressed, was it checked for water damage, I think n.ot. I certainly don't find any record of it and I am sure no One did it for free. This only reflects the shoddy quality of

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this coach and also indica.tes the OVver's can reasonably expect continuing problems as a result of these water-Ieaking issues. You have heard me express my opinion on water leaking issues in the past and nothing has changed to cause me to change my mind on them. Water is the number one damage causing factor a RV has facing it. RV exteriors are designed to be as waterproof as possible rubber and fiberglass and metal are all used on the outsides to keep water out and as long as they are kept properly sealed they do an admirable job. The interiors however is a totally different story they are not designed to be waterproof. The materials used and even the way they are put together by no means insure any degree of water resistance, in fact it is just the opposite. The materials used in constructing the interior ofRV's are mostly wood or wood products. The ceilng panels and substrates, the wall panels, studs and framing, the floor decking and inlayed wood floor coverings are the most commonly used materials in RV interiors. These things are raw wood or made of raw wood byproducts they are not pressure treated, sealed, painted or in any way waterproofed. The reason for this is probably because they are not designed
to be gotten wet, water is not suppose to get to ìhese things, and in a perfect world they

don't gei wet, soaked, or exposed to great amountS of moisture. What happens to these things when they are exposed to water, nothing good can come of it believe me. The things that do happen are things Iike warping, delaminating, soft spotting, rotting, decay, and mold to mention a few. In fact, the owner has expressed a great deal of concern over the coach's safety and reliability based OD this issue of water leaking into this coach body the various water leaks and exposures it has been subject too. from all of In reviewing these waranty repair orders I see other instances of water leaks from other sources than just this slide out. The roof and its sealant seem to be an issue on a couple of write-ups. There are toilet leaks, pIW11bing leaks, and leaks in several of the
compartent bays noted as welL. All of these only serve to contribute to the exposure of

water to the interior of this motor home. One lust point about these various leaking issue I would like to make and addressing
the roofleaks in particular. This pace anow motor home has a rubber roof

the factory. How the sealant could be failing in the first couple of months of its life would make one think there either had to be contamination of some sort on this roof before it was sealed at the factory or faulty sealant was used at the time it was installed. Rubber roof sealant, which is an EPDM rubber based sealant just. does not deteriorate that quickly. For it to either open up or loose its adhesion is just not a normal occurrence. So
unle~s.this ro~f.'ì seaI~r1t was completely removed and re-applied I would be very

installed from

suspicious ofits quahty and durability. I can totally understand the concern the owner's have expressed to me that this as well as other issues have truly been resolved. When one loo~s at (he service history of this coach it would make me have the same concerns. This again retlects the shoddy quality of this coach and also indicates the owner can reasonably expect continuing problems and repair issues in the future.
The next complaint issue is related to several of

the chassis issues the owners have

experi~~ced with this coach. There have been fuel-related problems with the main as well as auxiliary generator en~ines. Again these are well documented and dearly manufacturer defects having to do with a kink in the fuel line to bad and faulty fuel pumps. They have as well had problems with the leveling jacks, belt tensioner, dash air

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conditioner, and windshield wipers, and various other trim and fit problems that are as well documented. The service history of this motor home basically runs from May through September, which is when the Sennett's for all intents and purposes parked this coach and stopped using it. When you look at the service record of this unit it is no wonder they have lost alJ confidence in using it. For this amount of problems to have cropped up in this short amount of time I can honestly say I do not blame them. In fact, the owner has expressed a
great deal of concern over the coach's safety and reliability based on all of

these warranty

repair issues.

Conclusion:

This RV does not indicate a level of quality or workmanship consistent with its brand name of Pace Arrow and Fleetwoods reputation and certainly with its price. I am not sure it is possible to cure this R V's many defects and problems and expect that this unit ""ill be subject to multiple and repeaied repairs for a lot of these same issues and
problems. The O\\ller is fully justified in having a total

1055 of confidence in the motor

coach and can reasonably expeci a diminished ~biJity to use the R V because of its defects and problems. In fact, the owner would probably have been off buying a five year old coach and applied the savings towards repairs and maintenance rather than buying this pat1icular new vehicle. To this end. my assessment of this coach's diminished value is (see attached evaluation report.) I declare under penalty of perjury that the foregoing constitutes my expert opinion after
a review of

the coach's service history and an interview with the 0\111er.

6$7

By BILL TRIMMELL

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Case 2:04-cv-00161-ROS

Document 189-2

Filed 08/25/2006

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