Interpretation ID: nht92-8.46

DATE: February 24, 1992

FROM: Neil Friedkin -- Attorney at Law

TO: Erica Z. Jones -- Chief Counsel, NHTSA

TITLE: Re: Fred Levinson Productions v. Sports Imports Inc. and Coachbuilders Ltd.

ATTACHMT: Attached to letter dated 4/13/92 from Paul J. Rice to Neil Friedkin (A39; S 108 (a)(1)(A); S 108 (a)(2)(A); S 108 (b)(1); Part 567)

TEXT:

I am the attorney for Fred Levinson Productions Inc. ("FLP"). In August of 1986, FLP leased a 1986 Mercedes 560 LEC from Sports Leasing. As part of the lease, Coachbuilders Ltd converted the vehicle from hardtop to convertible. The vehicle identification Number is WDBCA45D3GA270730.

Mr. Levinson is in litigation concerning the vehicle. In part, he alleges Coachbuilders did not RECERTIFY the vehicle after conversion and that the conversion did not conform with the standards of the Safety Act.

In the past, I have written to your office concerning what rules would be applicable to the conversion and whether Coachbuilders would have been required to recertify the vehicle. I also asked if any complaints had been made against Coachbuilders.

In response, you were kind enough to provide me with certain rules and regulations and with opinion letters you had issued in the past (copies of which are enclosed) on similar inquiries.

I am writing to you now to see if you can provide a similar opinion letter addressed to my client and the conversion of this Mercedes hardtop to convertible. If this is possible, or if you require further information, please contact me.