Jens-Peter Gieschen of Harpstedt filed the charges with the Braunschweig prosecuting attorney's office.
"VW knowingly sold vehicles with massive construction faults in engines and has therefore deceived thousands of VW-, Seat- and Skoda-brand buyers," Gieschen told Automobilwoche.
A leaflet titled "Instructions for technical problem-solving" has been circulating internally since August 2000.
Gieschen says the leaflet proves that VW knew of the fault, which causes ice to form in the lubrication system and has caused numerous major engine failures.
"We don't believe that this is enough to take legal action," a Volkswagen spokesman said.
In late January VW promised free service for 10 years for approximately 500,000 customers who have been affected by the engine fault. The company also agreed to refund repair costs --- but has not stuck to its promise.
Gieschen recently obtained a refund for all repair costs for four of his 17 clients. About 5,000 engines have been damaged so far, according to the attorney. Gieschen estimates that "VW will have to expect costs of 15 million euros."