1. Repair History and Days Out of Service The vehicle has been at CMA Colonial Kia dealership since [insert drop-off date], totaling 49 days (and counting) out of service as of 05/13/2025. The sole but critical issue is a failed high-voltage battery, which the dealership and Kia confirmed must be fully replaced. This is the first repair attempt, but the car has remained unusable for over a month. 2. Substantial Impairment to Use, Value, and Safety The failure of the high-voltage battery in an electric vehicle renders it completely inoperable, with no capability to drive, charge, or function. This significantly impairs the use, safety, and value of the vehicle: Use: The car cannot be driven at all. Safety: Battery failure in an EV represents a major system defect with fire and high-voltage risks. Value: A brand-new EV with major battery failure has diminished resale value and buyer confidence. 3. Eligibility Under Virginia Lemon Law Under the Virginia Motor Vehicle Warranty Enforcement Act (Lemon Law): A vehicle qualifies if it is out of service for 30 or more calendar days for warranty repairs within the first 18 months or 18,000 miles. My EV9 has been out of service for 49+ days, meets mileage and time limits, and involves a major system failure. Therefore, my vehicle qualifies for relief under the statute. 4. Issues for the Arbitrator to Address The vehicle meets Virginia Lemon Law criteria due to prolonged inoperability for a substantial defect. Kia has not provided a comparable loaner or timely resolution. The vehicle poses safety concerns due to failed propulsion battery. 5. Desired Resolution I am requesting a full repurchase (buyback) of the vehicle, including: Full reimbursement of the purchase price (down payment, monthly payments made, taxes, fees). Any towing or rental expenses incurred. Cancellation of the finance agreement if applicable.