Miscellaneous: JUNE LEE VS. 460 FRANCISCO ST H.O.A. ET AL

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                                NO SUMMONS ISSUED

June Lee * LE p
460 Francisco St, #201 Court of Cal

¥ it
San Francisco, CA 94133 a af San Francisco
415-484-9338 a 25 ata
(Pro Se)

Superior Court of the State of California
For the County of San Francisco

June Lee,

Case No. CGC =21 589282

UNLIMITED CIVIL, DEMAND OVER $25,000 :

Plaintiff,

vs.

COMPLAINT FOR DAMAGES FOR BREACH OF
CONTRACT, DEFAMATION, NEGLIGENT
ANDI/OR INTENTIONAL INFLICTION OF
EMOTIONAL DISTRESS

460 Francisco ST H.Q.A., and Waleed Ghnaim

Defendants,

Sy ee eee eS we SS

Plaintiff, June Lee, hereby complains and alleges as follows:

lL Plaintiff, June Lee (hereinafter referred to as Plaintiff) is and at all times mentioned
herein was, an individual, residing in the City of San Francisco, County of San Francisco, State of
California. Plaintiff has always enjoyed a very good reputation in both her personal and professional

life, and is well respected in both her local business community, as well as her local community.

-i-
COMPLAINT FOR DAMAGES FOR Libel2. Defendant 460 Francisco ST H.O.A., (hereinafter referred to as “Defendant
Association”) upon information and belief, is now, and at all times mentioned herein was, an
association, residing in the City of San Francisco, County of San Francisco, State of California.

3. Defendant Waleed Ghnaim, (hereinafter referred to as “Defendant Waleed”) upon
information and belief, is now, and at all times mentioned herein was, an individual, residing in the
City of San Francisco, County of San Francisco, State of California.

4. This court is the proper court for trial in this action in that the actions and omissions of
Defendants as alleged herein were made within this Court’s jurisdictional area.

5. At all times mentioned herein, Defendants, and each of them, were authorized and
empowered by each other to act, and did so act, as agents of each other, and all of the things herein
alleged to have been done by them were done in the capacity of such agency. Upon information and
belief, all Defendants are responsible in some manner for the events described herein and are liable to

Plaintiff for the damages they have incurred.

ST AL
Bre: mitra
6. Plaintiff entered a contract with Defendant Association when she purchased her property
on Feb. 23, 1998. Plaintiff performed all her duties under the contract.
7. Under the contract, Defendant Association agreed to maintain, repair, and insure the

property properly. See CC&R Article V Duties and Powers of The Association. (see Exhibit 1)

-2-
COMPLAINT FOR DAMAGES FOR Libel8. On Dec. 15, 2016, an event occurred, through no fault of her own, which caused severe

damage to plaintiff’s property due to Defendant Association’s failure to properly maintain, repair
and/or insure HOA property.

9. Shortly thereafter, Plaintiff notified Defendant Association of the damage and asked
Defendant Association to perform their duties.

10. Defendant Association failed to perform their obligation and duties. In order to mitigate
any further damage (loss of rental income), Plaintiff repaired the property herself in March, 2016.

11. Plaintiff submitted bills in the amount of $28,333 for the cost of her repairs, Defendant
Association only made a partial payment of $14,576.94 in June, 2016, leaving unpaid balance of the
amount due $13,768.06.

12. Again, on April 26, 2019, an event occurred, through no fault of her own, which caused
severe damage to plaintiff’s property due to Defendant Association’s failure to properly maintain,
repair and/or insure HOA property.

13. Shortly thereafter, Plaintiff notified Defendant Association of the damage and asked
Defendant Association to perform their duties in April, 2019.

14. Defendant Association failed to perform their obligation and duties. In order to mitigate
any further damage (loss of rental income), Plaintiff repaired the property herself in October, 2019.

15. Plaintiff submitted bills for the amount of $74,567.82 cost of her repairs and damage due
her. Defendant Association refused to pay on March 20, 2020 (see Exhibit 2).

16. Plaintiff requested for the mediation. Defendant Association refused to attend the

mediation on Oct. 28, 2020 (see Exhibit 3).

-3-
COMPLAINT FOR DAMAGES FOR Libel17. Plaintiff is suing Defendant Association for $100,792.63 the unpaid balance due her,

plus, all costs, expenses and fees incurred by Plaintiff.

FACTION
DEFAMATION

(Libel Per Se — Civil Code §45)

18. Plaintiff realleges and incorporates by reference paragraphs 1 through 15, above, as
though fully set forth herein.

19. On or about August 4, 2018, Plaintiff sent an email to Defendant Association’s President
Bill Rose asking about the status of the outstanding amount due that was owed to Plaintiff by
Defendant Association. The President never responded.

20. Suddenly, within 15 minutes of Aug 4, 2018 when the email was sent, for some unknown
reason, Defendant Waleed, who was not an officer of Defendant Association , inexplicably and
uninvited, aggressively, intruded and inserted himself into Plaintiff’s business communication with
Defendant Association’s President Bill Rose, and defamed Plaintiff by accusing her of crimes;
including such as fraud, theft, and robbery, and threatened Plaintiff with further retaliation. These
accusations were false. Upon information and belief, the attorney of Defendant Association had
previously and specifically informed Defendant Association that such allegations were unfounded.

21. These specific email exchanges mentioned above are attached in exhibition 4.

-4-
COMPLAINT FOR DAMAGES FOR Libel22. The mentioned email exchanges were published to every member of Defendant
Association by Defendant Waleed. Defendant Association allowed the defamation to be published,
and never took any corrective action to remedy and/or mitigate the damage of the plaintiff, thereby
increasing the damage to Plaintiff.

23. The aforesaid defamatory statements made by Defendants was and is false and was not

privileged. Defendants made said statements knowing the falsity thereof or without using reasonabie
care to determine the truth or falsity thereof,

24. Defendants made the aforesaid defamatory statements with malice and with the intent

to injure Plaintiff's good name and reputation and to interfere with her peace of mind, and physical
health, in that defendants harbored ill-will toward Plaintiff. Defendants relentless threats have put
Plaintiff in a perpetual state of fear to her person and property.

25. The aforesaid defamatory statements has threatened, humiliated, ridiculed, and

embarrassed Plaintiff, and damaged Plaintiff's Teputation in the community, where Plaintiff has
owned the property of over 20 years.

26. The aforesaid defamatory statements has caused Plaintif? extreme stress, anxiety, and
mental anguish, and all of which resulted in deterioration of Plaintiff's physical health, including but
not limited to depression and degenerative heart condition.

27, The aforesaid defamatory statements has harmed plaintiff’ s reputation; such a
Statement has a tendency to injure and has injured Plaintiff in her occupation, her future business and

employment prospects have been severely harmed.

-5e+
COMPLAINT FOR DAMAGES FOR LibelTHIRD CAUSE OF ACTION
(Negligent and/or Intentional infliction of Emotional Distress)

28. Plaintiff realleges and incorporates by reference paragraphs | through 27, above, as

though fully set forth herein.

29. By the conduct described, Defendants did intentionally inflict emotional distress upon

Plaintiff in that the conduct was and is outrageous and beyond that which should be tolerated in

modern society.

30. That the conduct of Defendants was done in a manner to cause emotional distress and

that as a result of such conduct did cause emotional distress to Plaintiff.

31. Defendants did these acts maliciously and oppressively and with the intent to cause
injury such that Plaintiff is entitled to an award of including exemplary and punitive damages, in an

amount which within the jurisdictional minimum of ‘this Court, and which will be proven at trial.

PRAYER FOR RELIEF

Plaintiff prays for relief as follows:
1) For economic damages, to be proven at trial;
2) For general and compensatory damages, to be proven at trial:

3) For exemplary and punitive damages to be proven at trial;

4) For cosis of suit herein incurred;

5) For interest on all sums awarded at the maximum allowable rate;

-6-
COMPLAINT FOR DAMAGES FOR Libel6) For such other and further relief as the Court may deem just and proper;
7) For reasonable attorney’s fee spent by Plaintiff in order to defend herself and her
reputation from defendants outrageous acts;

8) Plaintiff hereby demands trial by jury.

Dated__ /2~(0 ~202¢2 GP

December 10, 2020 June Lee Plaintiff (Pro Se)

-7-
COMPLAINT FOR DAMAGES FOR LibelExh br |
28% 600 D247 sag
‘In the event ‘Lhat any Lanes
ur the personal property of. the

Section 4.13 Unslle ated Tasen!
are assessed against the Consnan Aria,
Association, rather than aginst’ the Condemininms, such taxes shall be
incinded in the assessments msde under the provisions of Section 4.1,
and if necessary, 2 special assessment may be levied apaini the condo~
minium in an omount equal to such taxes, to be paid in two (2) install-

ments, thirty (30)' days prior to tne ‘due date of each installment.

° . iinet

ARTICLE ¥. . .

DUTIES AND. POKERS
OF THE ASSOCIATION

-_. Section 5.2 Duties. In addition te the ‘dw’

Bo» its. Bylaws, or elsewhere provided in this Declara
limiting the generality thereof,
following duties:

tics enumerated in
tion, and without
the Association shall perform the

: (a) Maintenance. The Association shall maintain, repair,
\ replace, restore, operate and manage all of the Common Area and sll

facilities, improvements, furnishings, equipment and landscaping there-
on, and all property that may be acquired by the Association. Nainte-
nance shall include,. without limitation, paint?-- naiataining, repairs
ing -.d replacing all Common Areas, exterior ,. surfaces, and land-
scaping. The responsibility of the Asgeciation for maintenance and
repair shall. not extend to repairs of replacements arising out of or
caused by the willfsl or negligent act or neglect of an Ovner or his
guests, tenants or invitees, the cost of which is not covered by insur~
ance. Any dispute regarding the liability of an Owner.shall be deter-
mined by a Court of competent jurisdiction. - Repairs .or replacements
resulting from such excluded items shall “be the responsibility of each
Ounez, provided, however, that if an Ouner shall fail to make the ree
pairs ox replacements which are his responsibility as provided herein,
then, upen a vote of 3 majority of the Board of Directors, and after not
less than thirty (30) days notice to the Qvner, and hearing, the Asso-
ciation shall have the right (but not “the obligation} to make such
vepairs or: ceplaocements,

and the cost. thercef shall be added to the
assessments chargeable to such condominium and shall be payable to the
Association by the Ovner of such condominium, . :

(b) Insurance.
policies of insurance:

2.-A policy.or policies of: fire and casualty insurance, with
extended coverage endorsement and coverage against vandalism
and malicious mischief, for the full
units, and the Conewoa Area, payable as provided jin Section 8.9
hereof, -of such other fire aad casually insurance as the Board
shall determine gives substantially cequal oe greater pro~
tection to the Qiners and their mertgagees, as theic res-
peclive interests appear. fach policy shail provide that it

i Loe
The ‘Association- shall maintain the following ~

insurable value of the |

I29> PAT pa,

shall aot be cancelled cithout at least thirty (300 da
written notice to the Assetisbion and te cash of the Caners.
The Board shall revirw the limits of such 1 ance at least
every year and shall anceease or aejust Lae same, Gf feces
sary, to provide such coverape and protectiua as is customari-
ly carried by prudent ovners of similsr prey
in which the Project is lecated. Such pelicy of policies
shall provide for a separate less payable endorsement in favor
of the mortgagee Gr mortgagees of each condominium, if any,

verly im the County

ii. A policy or policies of comprehensive public liability
insurance insuring the A:socistion, Declarant, the Board,
Quners and any appointed manager, against any liability to the
public or toe the Owners incident to the ownership and/or use
of the Project and te protect against any liability to the
public or -to any Ovner incident. to the nse of, or resulting
- from amy accident or intentional: act occurring in

3 or zbout any
Unit or the Common Arca, The minimum limits of such insurance
shall be determined by the Board and established to provide

such coverage and protection as is customarily carried by
prudent owners of similar Property in the Couty in which the
Project is situated. The Board shall review the limits and
Coverage of such insurence at least every year and shali
Gnerease or adjust the same, if hecessary, to provide adequate
coverage and protectjon to the Assuciation, Declarant, the
Board, Owners, and any appointed manager. Such policy or
policies shall provide cross liabi?<*

~ endorsements or sever-
ability of interest endorsements insuring ev

ach insured against
the liability of each other insnred.

iii. Worker's Compensation Insurance to the exte

“to comply with all applicable Tavs of the State of California

ox the regulations of any goverumentai body or autharity
- - having jurisdiction over the Project.

mo necessary

iv. A fidelity bond in a coamercial blanket fidelity bond
form, obtained at the discretion of the Board naming such
persons as may be designated by the Board as Principals, and

the Ovners as obligees, in an amount tos he determined Ly the
Board in its absolute discretion.

Nothing in this subsection (b) ‘shall restrict or prohibit the Board from
maintaining such additional policies of insurance as it, in its absolute
discretion, shail deem reasonable and necessary. Any AraAnte acm
quired by the Board may be taken in the name of the Board as trastee,
for the use and benefit of the Board and all Quners.

(c) Discharge of Liens. The Association shall discharge by
payment, if necessary, any lirn against the Coaman Area, and the
sest thereof to the wember of members rvs

sponsibte for the existence of
such lien, provided that said member(s) is given notice and the oppor-

Qunity to be heard by the Board hefure the discharge of the lien.

so prior |

7: + —

. e247 ee 87
wax, paper Or otherwise refinish oF devarate th

walls, ceilings, floors, windows, ‘and doors: hounding his Unit. tp the |
tvenb that an Owner fails to maintain the itterior of his Unit ing
manner which the Board deems necessary La preserve the sppearance and
value of the property, the Board may notify the Guaoer ef the work cee
quired and request that it be done withia Sixty (60) days from the
giving ef such notice. In the event the Owner fails to carcy out such
maintenance within the sixty (60) day period, the Board may give notice
and hold’ a hearing and tause such work te be done and may- specially

assess the cost thereof te such Ouner and, if necessary, place a lien on
his condominium for the amount thereof,

thors surfaces of the

Section 8.8 Eatry for Repairs. The Board or its appointed

R Cannection with any main-
£ Association is respon-
sible. Such entry shall be made vith as’ little inconvenience te the
eby shall be repaired

Except in the ease of
any emergenty, forty-eight (48) hour advance notice shall be given to
and any entry shall be at

Section 8.9 Destruction of Condom
Project is damaged by fire or other casualty
ance and the damage is limited to a Single Unit, the insurance proceeds
shall be paid to the Guner of such Unit, of the mortgagee thereof, as,
thsif Yespective interests Sppear, and such Owner or mortgagee shall use
the same to rebuild and repair such Unit. In the event the proceeds are
insufficient to complete such work, the Ovner shall Pay and advance such
additional sums as may be necessary to complete such rebuilding and
repair. .

Sf the

If such damage extends ‘to twa
any ‘part of the Common Area, the followi
for disposition of insurance

(2) or more Units or extends to
mg procedures shall be employed
proceeds and guidance in reconstruction:
{a} Minor Casualty, Tf the available insucance proceeds

initially offered or paid by the insurer Jo nat exceed] the sum of twenty

= thousand dollars ($20,000), and the Cost' of repairing or rabuilding does
é het exceed the amount of available insurance proceeds by more than five
: thousand dollars (§5,000), such insurance proceeds shall be paid to the

insurance trustee hereinafter

designated. The Board shall thereupon
contract te repair‘and rebuild the damaged portions of all Units and the

Common Area, ia accordance with the conditions existing immediately
i iscretion of the Board to comply with
tandards in effect at the tine of the

the insurance trast find shall be used’

for that purpose. If the insurance proceeds are fasufficient to pay all
rebuilding, of the Units af-
tion of the ncy attiibuted to
rssment on

acy. altributed to the Ciman Area, The
fons ef this Declara-
nents sami shall beARTICLE

DEFINITIONS

Shoat} Wan thar Portion of ;
i 2mproving, 9 ereting any, Managing the Broper
to be Paid by each owner as determined by the Associatio
Section 1.2 “Association” Shall mean and fefer to the 4t
Street Condomi nian Homeowners? Association, the members ¢
‘be owners of condominiums aa the Foject.
Section 1,3 “Board” oy “Board of pj ectors™ Shall mean a
© 8oVerning body of the Association
Section lg Bylaws" hall Mean or tTefer to the Bylaws oL
iation ag amended from time to. ¢ me
Section is.

“Comnon Area™ Sha} 1 mean
of the Property to. which tities
d ©Xcepting the ¢

T owners jy com-
individuay Condomingin units. ie Common Area
Without 1i tation, dana: Slairs; el Vators aad ®levator

Sements ap Storage areas; Satine welts Columns 8irders,

in finisheg floors, oof. and foundations; central heating

wees, flues and chutes and - Fire eS8Capes; conduits, Pipes,

vires an Other utility installments EXCeRE the outlets

Pas theres¢ Jocated within 3 unit), required £0 provide Pover, light, tele-
is Phone, gas, ‘ater, Sewerage, drainage, heat, and levator Servicas-
Sprinklers, SPrinkler Pipes ‘ang SPrinkler heads hich Protrude intg the

air space of a condominium units centraz felevision antenna, i¢ any

oo. Section 16. "Cor
ectual and wet

.
i cao on Expenses"
tstimateg exp o.

able reserve fy

21] sim

Propezty “tn any Feasog-
88 found ang determined by the Bourd and
Ss designateg Connon expenses by OF pit enane @ the Conclesm in j sun
Bocuments, .
. Section’ 1.7: wy
undivided Thy

Peoportiong le
Pant to euch

aC unig
Section 1.8 inm Shall mean aa estate jp real
Feperty ay defined fa ©. a i tion 7g a CONSigting of
te te 5 Uait srg an undiy; commen ares,
Seetion lig ington nie Bai tinge BRAVE een fhe cesi-
tecture Sontaining ium units]

°05-8705-M90

HOME CLMS-FIRECLAIMS

Fri, Mar 20, 2020, 11:10 AM

to 460FRANCISCO201@GMAIL.COM
June Lee,

1 am responding to your email regarding the motion for the claim. | have received direction to not

move forward with the claim as the HOA does not want to move forward with this claim under
is policy. claim will remaii this time.

Best,

Miranda Lilly

Fire Casualty Claim Specialist

Phone: 844-458-4300 Extension: 4806363101

Fax: 1-844-236-3646

Email: statefarmfireclaims@statefarm.com, please place claim number in subject line of email.
Mailing: PO Box 106169, Atlanta, GA 30348

Unit 201 <460francisco201@gmail.com>

Mar 20, 2020, 11:40 AM

to HOME, William, me

Hi Miranda,

1 am sorry to hear that you closed my claim.

Would you please forward me the direction you have received?
Thanks,

June

05-8705-M90

HOME CLMS-FIRECLAIMS

Fri, Mar 20, 4:14 PM

to 460FRANCISCO201@GMAIL.COM

June,

Please contact Mr. Rose for more information.

Best,

Miranda Lilly

Fire Casualty Claim Specialist

Phone: 844-458-4300 Extension: 4806363101

Fax: 1-844-236-3646

Email: statefarmfireclaims@statefarm.com, please place claim number in subject line of email.
Mailing: PO Box 106169, Atlanta, GA 30348Unit 201 <460francisco201@gmail.com>
Mar 20, 2020, 6:58 PM 1
to bill, HOME, bec: me ‘
Miranda, i
We have contacted Mr. Rose numerals times with no response. Please kindly forward us any
emails/directions Mr. Rose sent to you. |

|
Thanks, l

June

05-8705-M90

HOME CLMS-FIRECLAIMS
Mon, Mar 23, 11:47 AM i
to 460FRANCISCO201@GMAIL.COM :
June, '

{ don’t have email correspondence to forward to you. | don’t have approval to move forward with
this claim at this time. If Mr. Rose would like to discuss this further, please have him contact me

directly, he has my direct contact in formation.

Miranda Lilly
Fire Casualty Claim Specialist !
Phone: 844-458-4300 Extension: 4806363101
Fax: 1-844-236-3646
Email: statefarmfireclaims@statefarm.com, please place claim number in subject line of email.
Mailing: PO Box 106169, Atlanta, GA 30348

|

05-8705-M90 '

Unit 201 <460francisco201@gmail.com> |

Mar 23, 2020, 10:37 PM '

to HOME, me, William !

Hi Miranda, '

Please proceed the HOA adopted motion on March 10, 2020 accordingly, See attached motion
made on February 20, 2020, and emails below.

Thank you, \
\
June Lee :
P.S. Please thoroughly review the notes in your system. Bill Rose just like myself, we are
EQUAL home owners/HOA members. He refused to représent HOA on this matter. If you have
|

| 2/3
|

' FMD| 7
| _
|

any other credible and verifiable instruction from HOA, which has to be in writing, please
forward it to me. | deserve to be informed with EQUAL DATA.
|
i
HOME CLMS-FIRECLAIMSTue, Mar 24, 2020, 3:49 PM to me
June, |

Thank you for your response. Mr. Rose is my point of contact for this claim- | have verified the

notes in the file reflect the same. You will have to work with the HOA, as | have not been given

permission to move forward with this claim. If this not the case, please have Mr. Rose contact
me directly. |

Thank you,
Miranda Lilly !
Fire Casualty Claim Specialist
Phone: 844-458-4300 Extension: 4806363101
Fax: 1-844-236-3646 '

Email: statefarmfireclaims@statefarm.com, please place claim number in subject line of email.
Mailing: PO Box 106169, Atlanta, GA 30348

3

Ex. 2exhibit 3

From: Tonya Saheli 

\
Subject: RE: Mediation link for Wednesday at 2:00pm

Hi June, '

!

Unfortunately I will not be going forward with the mediation tomorrow. Bill has never replied
to any of my emails but has continued to request mediation through a different wing of our
program that requires you both to pay for the Services equally. He is still requested mediation
through the ADR program. | realize you don't wont to go this route because you don't want to
pay, but if you don't go the ADR route there will be no mediation. Sorry this did not work out.

Tonya Saheli, JD,MS :

Associate Mediation Counsel

Conflict intervention Service and Special Education
The Bar Association of San Francisco '
415.625.3119 office '
925.216.2115 cell

sibarorg/cis

THIS EMAIL IS CONFIDENTIAL. THE INFORMATION CONTAINED IN IT IS INTENDED
ONLY FOR THE USE OF THE INDIVIDUAL(S) OR ENTITY(IES) TO WHOM IT 1S
ADDRESSED. ANY INADVERTENT DISCLOSURE TO OR USE BY ANY PERSON
OTHER THAN THE INTENDED RECIPIENT(S) SHALL NOT BE DEEMED A WAIVER
OF ANY EXPECTATION OF CONFIDENTIALITY. IF YOU ARE NOT THE INTENDED
RECIPIENT(S) OR THE EMPLOYEE OR AGENT OF THE INTENDED RECIPIENT(S),By hte ZL

New Luck 

. . Aug 4, 2018,
C Ploindeff June Loe) a, 5:58 PM

toWilliamCRose.williamce
1,460francisco,A60FraHA, _
bec: .

Bill Russ President of HOA, ©

As you know, | made claim for reimbursement of water damage ta my unit last year, I have not
received full reimbursement of niy claim. Please respond ASAP.

in addition, please send me a copy of all the board meating minutes of last year, including today.
Thank you for your prompt reply.

Sincerely,

June Les
Owner of unit #204 .wghnaim@yahoo.com ¢ Defence! ont Woelrodl )
[460FranciscoHOA] Aug 4.2018 /
<460FranciscoHOA@yahkeogroups.co :

m> . . .

to 460FranciscaHOA,
WilliamCRose,
williamcrose1,
460francisco

You serious June, you've been over paid and owe the HOA a reimbursement P've been involved

with your fraudulent claim since day one! You stole from ihe HOA and I wil be very involved on
any further actions you are claiming!!!

Trust me, { will be 100% certain you do steal another dime from the HOA, let alone
tupgrade/remodel on our dimell

Move on June, being a fandlord has the responsibility of paying for tenant mishaps! Which | and
the HOA can prove. Be careful what your asking for, { will be relentless to Prove you wrong. O

_Cheers,

Wally GNew Luck  Aug 4, 2018,

C [7 la cette Ti WH Loe) 6:53 PM

to 460FranciscoHOA,
WilliamCRose,
williamcrose1,
460francisco

Listen, your are completely misinformed, and my law suit will include defamation against you
personally! And anybody else who spreads this lies!!

| am forwarding this to my attorney.

Again, respond to my request immediately regarding my claim and the minutes!wghnaim@yahoo.com (Coendant Walood ) :

Aug 4, 2078,
[460FranciscoHOA]

8:36 PM
<460FranciscoHOA@yahoogroups.co
m>

to 460FranciscoHOA,
WilliamCRose,
williamcrose1,
460francisco

Actually you LISTEN! Do NOT ever threaten me, Junell!! You have no idea who you're
threatening?

Let's get a few things straight!

1- the info provided to me, clearly states the flood in your unit was NOT caused by the main
. lateral lines in the building. Which excludes the HOA from any responsibility!

2- you cashed a check that was accidentally issued to you by OM and receiving an additional
check, you cashed from the HOA insurance meaning you double dipped.

That is fraudulent on your part!You have NO proof of additional content showing otherwise, if you do then please provide US
ALL, to clear you from fraud!

Closing note: DO NOT EVER threaten me, as my knowledge and experience with building
Assessment of Structural Performance is well versed...

Just as an FYI!

Cheers,

Wally GNew Luck 

{ ara tiff Tons Lag y Aug 5, 2018,

9-47 AM
Qe

to 460FranciscoHOA,

WilliamCRose,
williamcrose1,
460 francisco

Curiously, why is that when the same thing happened to your unit a few years ago, HOA
insurance paid you $28,000? Please explain.

Again, my requests was addressed to Bill Rose President of HOA, are you President of HOA
now?

Why don’t you answer my requests fo reimburse my outstanding claim of $13,768.06 plus
interest. | have been waiting since last year. Also provide me alll last year’s board: meeting
minutes. You failed to answer what | asked for. Instead you chose to defame me.

Please answer the questions asked.CM-01

| ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):

rt FOR COURT USE ONLY
RAL |
4bo Erenciso st. 4201,
Sam Fromcigur, cA 44133 Fe E y
TELEPHONENO: S41 5 = peep - 33S FAXNO: Superior Court of California
AUIORNEY FOR (Nome): JW PRO PER =Gounty of San Francisco
|SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sain Frey ctSeo =
STREET ADRESS: Lhpo We Alli shep sk poud mi JAN 25 202%
vasune AooRESS a :
cmvawzrcone Stm Franciseo, CA THe? bz THE COU
BRANCHNAME: ctu L . a
CASE NAME: .
s Abo Frncisie stH. 0A. gad Waleoe Ghnaim
CIVIL CASE cover SHEET Complex Case Designation CASE NUMBER:
Unlimited Limited ; :
(Amount (Amount [J counter [—] Joinder Ee 668 =e 59
demanded demanded is Filed with first appearance by defendant ~ ~ gy 2 g 2
exceeds $25,000) _ $25,000 or less) (Cal. Rules of Court, rule 3.402) DEPT:

items 1-6 below must be completed (see instructions on page 2).
1. Check one box below for the case type that best describes this case:

Auto Tort Contract Provisionally Complex Civil Litigation
_] auto (22) Breach of contractwarranty (06) (Cal. Rules of Court, rules 3.400-3.403)
[J Uninsured motorist (46) Rule 3.740 collections (09) [| Antitrust/Trade regulation (03)
Other PUPDIWD (Personal Injury/Property  [__] Other collections (09) LJ construction defect (10)
Damage/Wrongful Death) Tort [J insurance coverage (18) [7] ass tort (40)
Asbestos (04) [[1 other contract (37) Securities litigation (28)
LJ Product iapitty (24) Real Property {J Environmental/Toxic tort (30)
[1 Medicat malpractice (45) Eminent domain/inverse [JF insurance coverage claims arising from the
[J other pvepwp (23) condemnation (14) above listed provisionally complex case
Non-PYPDAWD (Other) Tort [] wrongful eviction (33) types (41)
L_] Business tortuntair business practice (07) Other real property (26) Enforcement of Judgment
[_] ivi rights (08) Unlawful Detainer [1 Enforcement of judgment (20)
[__] Defamation (13) Commercial (31) Miscellaneous Civil Complaint
[J Fraud (16) Residential (32) [_] rico 7)
L intellectual property (19) LI Drugs (38) Other complaint (not specified above) (42)
Professional negligence (25) Judicial Review Miscellaneous Civil Petition
Other non-PUPD/WD tort (35) Asset forfeiture (05) Partnership and corporate governance (21)
Employment Petition re: arbitration award (14) Other petition (not specified above) (43)
[__] Wrongful termination (36) Writ of mandate (02)
Other employment (15) Other judicial review (39)

2. This case CI is ~ BE] isnot complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
factors requiring exceptional judicial management:

a. [4 Large number of separately represented parties d. Large number of witnesses

b. Extensive motion practice raising difficult or novel e. [4 Coordination with related actions pending in one or more courts
issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court

c Substantial amount of documentary evidence f. |__] Substantial postjudgment judicial supervision

3. Remedies sought (check ail that apply):
4. Number of causes of action (specify): 2

5. This case is [2Slisnot actass action suit.

6. If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.)

Date: 12-/0-2020 ip—
Tune Lee >
{TYPE OR PRINT NAME) . {SIGNAT IF PARTY OR ATTORNEY FOR PARTY)

NOTICE
© Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed

under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.

® File this cover sheet in addition to any cover sheet required by local court rule.

© If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
other parties to the action or proceeding.

° Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only.
ag

LX] monetary b. nonmonetary; declaratory or injunctive relief c. PS] punitive

e 4 of 2}
Form Adopted for Mandatory Use . Cal. Rules of Court, rules 2.30, 3.220, 3.400-3.403, 3.740;

‘ude Counc of Calforia CIVIL CASE COVER SHEET Gal. Standards of Judcial Administration, std 310
‘CM-010 [Rev. July 1, 2007] ‘wvew.courtinio.ca.gov