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FORMAL NOTICE AND DEMAND FOR RIGHT TO CURE
Date: September 10, 2026
VIA EMAIL AND TEXT MESSAGE
TO:
KINEMA TRAILER DEPOT II
Attn: Daniel Andrade, Sales Representative
1680 Hwy. 158 West
Douglas, Georgia 31535
FROM:
Pablo Szundryk
Purchaser
RE: UTILITY TRAILER -- FORMAL NOTICE OF DEFECTS, NONCONFORMITY, IDENTIFICATION DISCREPANCY, AND DEMAND FOR RIGHT TO CURE
Dear Mr. Andrade and Kinema Trailer Depot II:
This correspondence constitutes formal written notice of defects, material nonconformities, and discrepancies concerning the utility trailer sold to Pablo Szundryk, together with a formal demand that Kinema Trailer Depot II be afforded a limited opportunity to cure the matter by providing an appropriate replacement trailer and arranging the return of the trailer delivered to the purchaser.
1. SALES TRANSACTION
On Thursday, September 3, 2026, at approximately 10:13 a.m., Mr. Daniel Andrade, a sales representative of Kinema Trailer Depot II, located at 1680 Hwy. 158 West, Douglas, Georgia 31535, contacted prospective purchaser Pablo Szundryk by text message and provided photographs depicting a utility trailer being offered for sale.
The trailer was represented as a utility trailer identified by the following information:
VIN: 1P9BF1618TN949757
Stock Number: 9757
Price: $4,740
Mr. Szundryk relied upon the photographs, identifying information, price, and representations provided by the seller in evaluating the trailer and determining whether to proceed with the transaction.
On Friday, September 4, 2026, Mr. Szundryk received approval for financing. The purchase transaction was thereafter finalized by telephone, and the applicable purchase and financing documents were executed electronically through email.
2. DELIVERY
The trailer was delivered on Tuesday, September 8, 2026, at approximately 8:00 a.m., to the following location:
Hi Tech Gas Station
58387 U.S. 231
Oneonta, Alabama 35121
After the trailer was unhitched from the delivery driver's vehicle and connected to the purchaser's vehicle, the delivery driver moved the trailer approximately one block from the gas station.
Once the trailer was in the purchaser's possession and available for closer inspection, Mr. Szundryk immediately discovered numerous visible defects, deficiencies, and imperfections that raised substantial concerns regarding the condition and identity of the trailer delivered.
3. DEFECTS AND CONDITIONS DISCOVERED
The purchaser promptly observed, among other conditions, the following:
1. Dry-rotted and deteriorated deck boards.
2. Loose decking boards that were not adequately secured.
3. Missing, inadequate, or improperly installed fasteners in multiple locations.
4. Bent and/or damaged portions of the trailer structure, including an affected area near the left wheel and light-frame assembly.
5. Visible deterioration and deficiencies in multiple areas of the trailer.
6. Conditions inconsistent with the condition reasonably expected from the trailer depicted and represented during the sales process.
7. Additional defects and workmanship concerns discovered during the purchaser's inspection.
These conditions were discovered immediately following delivery. The purchaser therefore promptly notified Kinema Trailer Depot II and the financing company and began documenting the trailer's condition through photographs, written communications, text messages, and other available records.
4. MANUFACTURER NOTIFICATION
Following notification of the defects, Kinema Trailer Depot II communicated the reported issues to the trailer manufacturer.
The purchaser provided the available documentation concerning the condition of the trailer, including photographs and communications, through email and text message.
The manufacturer subsequently requested additional photographs and identifying information for the purpose of verifying the trailer involved in the transaction.
During this verification process, an additional and significant discrepancy was discovered.
5. TRAILER IDENTIFICATION DISCREPANCY
The large identifying number visible in the photographs originally provided by the Kinema Trailer Depot II sales representative did not match the identifying number or VIN associated with the trailer ultimately delivered to and sold to Mr. Szundryk.
The photographs and records provided by the sales representative at Kinema Trailer Depot II showed identifying numbers ending in 01070. Those numbers did not match the VIN associated with the trailer represented and sold to the purchaser, which was identified as:
VIN: 1P9BF1618TN949757
The trailer was also identified in the sales transaction by stock number 9757 and a purchase price of $4,740.
The discrepancy is material because the photographs and identifying information provided by the seller were part of the purchaser's decision to enter into the transaction. The identifying numbers shown in the photographs and records from the sales representative do
