Exhibit,Appendix: GLEN LEIS ET AL VS. AJLOUN ENTERPRISES LLC ET AL

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David W. Evans (Bar No. 79466)
devans@hbblaw.com

Stephen J. Squillario (Bar No. 257781)
ssquillario@hbblaw.com

HAIGHT BROWN & BONESTEEL LLP

Three Embarcadero Center, Suite 200

San Francisco, California 94111

Telephone: 415.546.7500

Facsimile: 415.546.7505

Attorneys for Defendants Zacks & Freedman,
P.C. and Andrew Catterall

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

APR 23 2015

Clerk of the Court
BY: ROMY RISK
Deputy Clerk

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

GLEN LEIS and STEVE MANN,
Plaintiffs,
v.

AJLOUN ENTERPRISES LLC,
MATHEW ZGHOUL, a/k/a MUATH
ZGHOUL, THSAN ZGHOUL, MUSAB
ZGHOUL, MOHAMMED ZGHOUL,
SAM HAMDI a/k/a THSAN HAMDI,
ANDREW CATTERALL and ZACKS &
FREEDMAN, P.C. and DOES 1-20,
inclusive,

Defendants.

1

Case No. CGC 14 541210

EXHIBITS 10 THROUGH 20 OF
DECLARATION OF ANDREW
CATTERALL IN SUPPORT OF
MOTION FOR SANCTIONS BY
DEFENDANTS ZACKS &
FREEDMAN, P.C. AND ANDREW
CATTERALL [CCP § 128.7]

Date: May 15, 2015

Time: 9:30 a.m.

Dept.: 501

Action Filed: August 18, 2014

EXHIBITS 10 THROUGH 20 OF DECLARATION OF ANDREW CATTERALL iN
SUPPORT OF MOTION FOR SANCTIONS BY DEFENDANTS ZACKS &
FREEDMAN, P.C. AND ANDREW CATTERALL [CCP § 128.7]EXHIBIT 10City and County of San Francisco Residential. Rent Stabilization
and Arbitration Board
opin BEC -4 PHS 03

APPEAL. TO THE BOARD sai bt
RESIDENTIAL

Any parly may appeal the Decision of the Administrative Law Judge. Such appeal must Becfila no-latek tit jean
(15) calendar days after the mailing of the Administrative Law Judge's Decislon. if you aretiling fald'yu' must state
tha reason so that the Board can determine if there is good cause for the untimely filing. The filing of a timely appeal will
stay only that portion of any Administrative Law Judge's Decision that permits payment, refund, offsetting or adding rent. If
you are appealing on the basis af financial hardship, you must.use the separate hardship appeal forms.

THIS APPEAL MUST BE ACCOMPANIED BY THE FOLLOWING:

1. 1 SET OF ENVELOPES, LARGE ENOUGH TO ACCOMMODATE ALL OF YOUR APPEAL DOCUMENTS,
PRE-ADDRESSED to the other party(les), with NO return address but with sufficient postage for mailing the
appeal and attached documents. 1

2 2 SETS OF BUSINESS SIZE ENVELOPES, PRE-ADDRESSED fo all parties including the appealing party,
with NO return address but with first class postage affixed for mailing one ounce.

3, COPIES OF THE APPEAL; Including all supporting documents, for each non-appesling party, plus 13 ~
ADDITIONAL COPIES for the Rent Board Commissioners and staff.

4 If you are filing the appsal because you did not receive the notice of hearing, you must attach a completed
Declaration of Non-Receipt of Notice of Hearing form, which is available at the Rent Board's office and on our
website (www.sfgov.org/rentboard),

Orig (yal #- Ih .
AT iuoiaa IN Siqe, _bwichae\ 5. Pero,
‘Casa Number 7 . Name of Administrative Law Judge —
Steve Mann + Gen \a\s Dandi? CO Tenant WAI SOL
Name of Party Filing Appeal (Please Pint) Date Dobision was Mailed
OO ~ AA GS. . A San Francisco, CA
Street Number of the Unit Siret Name Unit Number Zip Code

appeal the Administrative Law Judge’s Decision because ! believe that the Administrative Law Judge erred or abused his
or her discretion in the following respects:

© Beaving officer anibited: bias: which dewied ne denon a Rin heaving,
Aspuaing toieo ar lena piafered CudenCe and ocerpting oidiine.
Stn landistl on Cecto id eauearind uy allowing lavdlovd 40 vourke.
WORE & ean Cane Lirathee ito Se ORiawLion “ny Woldez
ine, ORR Buia nas 0 “ wa “ PS wagutid hous Keane.
” -
TES Se OLAS WL OSAP TT
& aie Murs alleged Puede Mave Leu , (eontinned >
NQTE: THE RENT BOARD WILL MAIL A COPY OF THIS APPEAL TO THI HER PARTY(IES}. HOWEVER, THE PARTII [ST SERVE EACH
OTHER WITH ALL OTHER DOCUMENTS FILED AFTER THE INTIAL FILING OF THIS APPEAL, AND INDICATE YOU HXVE DONESO.

ial [aoi4 Cor <

*Hf representative, print name Nau ut m. Con ep

ADDITIONAL INFORMATION REQUIRED ON BACK SIDE OF THIS FORM
556 Appeal Form 11/8/06

25 Van Ness Avenue #320 Phone 415.252.4602
San Francisco, CA 94102-6033 FAX 415.252.4699Oo Oe NM DH HW PB WN

N ee
BNBRRBBEEB SBD ADEGHE S

NANCY M. CONWAY, ESQ. (SBN 122562)
LAW OFFICES OF NANCY M, CONWAY
345 Franklin Street

San Francisco, CA 94102

(415) 241-1140

(415) 241-1156 fax

Attorney for Appellant Glen Leis

RESIDENTIAL RENT STABILIZATION AND ARBITRATION BOARD
CITY AND COUNTY OF SAN FRANCISCO

In re: 890 47" Avenue, #A. } Case Nos: eToe
ALIOUN ENTERPRISES, LLC } APPEAL FROM DECISION
Landlord Petitioner/Respondent, }
and , }
GLEN LEIS, }
Tenant Respondent/Appellant. ;

Tenants Steve Mann and Glen Leis appeal the decision as it relates to their right to a
garage. The decision holds that the tenants’ rental agreement provided partial non-exclusive use
of 50% of a garage in connection with rental of Unit A, which garage was described as Garage
No. 2. There is no explanation of how the hearing officer arrived at his decision that the tenants.
were entitled to non-exclusive use, other than that there were things in the garage when they took
occupancy. The tenants and their witness credibly testified that they were provided the only key
and sole possession of the garage when they rented the premises, The evidence was that there

was some former tenants property abandoned in there and that no one else had access to the

garage.

-1- Appeal of DecisionOo ON AD A BR WN

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BNR RRRB ESTEE WABDBRE OR HS

The evidence presented by tenants was uncontroverted that they held the only key to the
garage. ‘The evidence was uncontroverted the tenants did not share the garage with any other
tenants or even the landlord. The declaration of the former owner’s son and manager supports
this as well.

The initial petition solely requested a determination of the base rent. At the
commencement of the hearing, the landlord conceded that there was no question that the base
rent was $1200/month, so there was no need for a hearing to establish the base rent. Despite the
fact that Matt Zghoul testified that the amount of rent was known to him prior to his purchase as

being $1200 and despite his knowing that the rent was current, his attorney refused to accept the

‘tenants rent for several months and then before the rent board hearing demanded payment of S

taonths rent on ten days notice,

The evidence presented was that tenant Leis upon moving into the premises was given a
key to the garage associated with his unit. It is undisputed that there were four separate garages
at the subject premises, Matt Zghoul testified that when he purchased the property from the
estate he was not provided any lease or rental agreement for the subject unit “A.” The Petitioner
testified that he had no personal knowledge of the rental of the garage, nor to whom the garages
belonged.

Upoti putchase of the propeity, the Petitioner removed the lock to the tenants” garage
and removed and disposed of the tenant’s property without notice, Further, Petitioner did same
to garages of two other units. The hearing officer would not allow testimony related to these
facts.

____... The tenants presented evidence at the hearing that they were in possession of a specific
garage. He testified that when he first moved in part of the garage had things left from a former
tenant of his unit, who he later learned was deceased and was never coming for those things. The
tenant Steven Mann and guests of Glen Leis used the driveway for parking, which was not ever
discussed in the hearing and which the hearing officer refused to receive testimony on. The

hearing officer made a mistake in his finding that the tenant had non exclusive use of the garage,

-2- Appeal of DecisionOD me IN DH Hh FF BW NH =

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No other tenant had the right to Leis garage number 2 and there was no evidence presented that
any other person had a key to the garage or access to it during the tenancy of the landlord

The hearing officer discounted the declaration of the owner’s son Tony Kirk who lived at
the premises and was involved in managerial duties, on the basis that the declaration, which is
dispositive on the issue of the garage, states that it is one in from the corner and that the one
identified by the tenant is the first garage to the right of the building entry. These are one and
the same garage. The building is facing onto 47" Street and its entrance is in the center of the
building. The first garage to the right of the entryway is the one claimed by the tenants in Unit A
and one in from the garage on the comer is their garage. There are two garages to the right of:

the entry: one is on the comer and the other claimed by the tenants is one in from the corner.

’ The hearing officer was mistaken and his decision rests on this error.

CONCLUSION
The owner already dispossessed all of the tenanis with garages of their possession by
locking them out. The hearing officer’s decision was not based on the evidence presented, was
based on mistake. ‘The conclusion that the tenants were entitled to half the garage and to non-

exclusive use of the garage is not based on any evidence.

DATED: December 4, 2014 LAW OFFICES OF NANCY M. CONWAY

nero

Nancy M. Convyay NY
Attomey for lant Glen Leis
& Steven Mann

-3~ Appeal of DecisionAPPEAL TO THE BOARD (page two)

‘Tenant iiformations: +i there is. more that.one tenant: “attach Addifional-niarnes: ‘and pddresse

Steven _ ve Wainy) €_

First Nar OO VY - Middle Initial
"ORM eg pEtin St__ A PETS cA qual

Mailing Address: Street Number ‘Street Name ‘Unit Number Clty Slate: Zip Codd

Home Phone Number ‘Other Phone Number Email Address.

Nancy Can ws Gas

First Name. { Middle initial Tast Na

Bad ~ Fronklin Gh. Se On Autlog
Mailing Addrass: Street Number Street Name Unit Number hy Slate Zip Code
Home Phone Number. Other Phone Number eal ‘Address
Maat cca Zao +A loaventer-
st Name iddie tni ast Name . bebe ua
Co Zacks « fms ( See \edloxs)') wees
idling Address: Street Number Street Name ‘Onit Number City State Zip Code
and lacaValenniaGl SF cAaM IO)
Home Phone Number ther Phohe Number 7 Email Address:
And row
FirstName ° oe Middle initial “Last Name T-
235 Monicomeru Sr. YOO se CA 2 log
Wailing Address: Stroat Numbar.7 ‘Street Name ‘Unit Number ily Stale
Home Phone Number ‘Other Phone Number Emall Address

FirstName Middle inital LastName
‘Mailing Address: Street Number ‘Street Name Unit Number Clly State Zip Code
Home Phone Number Other Phone Number Email Address

556 Appeal Form 14/8/06

265 Van Ness Avenue #320 Phone 415.252.4602
San Francisco, CA 94102-6033 FAX 415.252.4699EXHIBIT 11Residential Rent Stabilization and Arbitration Board
City & County Of San Francisco

Esta notificacién puede afectar a sus derechos como ARASDHGE OS BERNE SNA. i
propietario o inquilino. Si necesita ayuda para entender este PORTA BOIR T APART, |
aviso, por favor llame al 415-252-4602, S8RUHE 415-252-4602, i

Notice Of Action On Appeal

Appeal Denied
APPEAL NO. AT140200 :
ORIGINAL NO(S). AT140122 :
890 47th Avenue #A

San Francisco, CA 94121

The Appeal regarding the above property was reviewed for consideration on 1/20/2015. The Rent Board Commissioners
voted fe deny the appeal.

The appeal having been denied, the decision rendered by the Administrative Law Judge is FINAL. [Ordinance Section
37.8(e)(8)} -

Any party aggrieved by this decision must seek judicial review within 90 calendar days of the date of mailing this notice.
{Ordinance Section 37.8(f)(9); Code of Civil Procedure Section 1094.6(f]

|

25 Van Ness Avenue #320 2a-hour information Line 416.252.4600 Phone 418.252.4602
‘San Francisco, CA 94102-6033 Intemet: wow.sttb.ora Fax 416.262.4699Residential Rent Stabilization and Arbitration Board
City & County Of San Francisco

Esta notificacién puede afectar a sus derechos como ARCS ESV S BERR ESHA.
propietario o inquilino. Si necesita ayuda para entender este LORIGB ERT BATARS,
aviso, por favor [lame al 415-252-4602. BAER HE 415-252-4602,

Proof of Service Proof of Service page 1

APPEAL NO, AT140200
ORIGINAL NO(S). AT140122

| am over the age of 18, not a party to this case, and am employed at 25 Van Ness Avenue, #320, San Francisco,
California, 94102. | served a copy of the attached:
Notice Of Action On Appeal

tegarding the property at 890 47th Avenue #A by placing a true copy in a sealed envelope with postage prepaid in the
United States mail at San Francisco, California, on the date shown below, and addressed to the parties as shown below.

Name Property Address Mailing Address.
Landlord - oe be UE eRe pps! Boge Ba Agog
Ajloun Enterprises, LLC Atin: Matt Zghout

1298 Valencia Street

San Francisco, CA 94110

Landlord Attorney; Nae fee : wees
Andrew R. Catterall Zacks & Freedman, P.C.

235 Montgomery Street #400
San Francisco, CA 94104

Tenant"): : aa ! a nets fe ecg.
Glen Leis - 890 47th Avenue #A 890 47th Avenue #A

San Francisco, CA 94121 San Francisco, CA 94121
Steven Mann : 890 47th Avenue #4 890 47th Avenue #A

San Francisco, CA 94121 San Francisco, CA 94121
Tenant Attorney. s a Poe SS : ee
Nancy M. Conway 890 47th Avenue #A Attorney at Law

: San Francisco, CA 94121 346 Franklin Street

San Francisco, CA 94102

| declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this
declaration is executed on the date shown below at San Francisco, California.

Signed: wv Dated: 1/28/2015

28 Van Ness Avenue #820 24-hour Informalion Line 415.252.4809 Phone 416.262.4602
San Francisco, CA 94102-8033 Intemet: wew.sttb.org Fax 416.262.4698EXHIBIT 12a.

a

TD AY NOTICE TO QUIT FOR NUISANCE
(Code of Civil Procedure Section 1161(4))

TO: GLEN LEIS, STEVEN MANN and all occupants in possession of 890 47™ Avenue, Unit
A, San Francisco, California, 94121, including any appurtenant areas {the “Premises”)

NOTICE IS GIVEN THAT, WITHIN THREE (3) DAYS AFTER SERVICE ON YOU OF
THIS NOTICE, YOU ARE REQUIRED TO QUIT POSSESSION OF THE PREMISES.
If you fail to comply with this Notice, your Landlord will institute legal proceedings against you
to: 1) Declate a forfeiture of the Rental Agreement, and 2) Recover possession of the Premises,
plus costs and damages to the extent allowed by law. Delivery of possession may be made by
delivering all keys to the Premises in your possession to Andrew R. Catterall, of Zacks &
Freedman, P.C., 235 Montgomery Street, Suite 400, San Francisco, CA 94104, Telephone: (415)
956-8100, Business Hours: 9:00 a.m. - 5:00 p.m., Monday - Friday, who is authorized to receive
the same, ’

You are required to quit possession of the Premises within the 3-day period, for the reason that
you are in breach of Section 1161(4) of the California Code of Civil Procedure, and Section
37.9(a)(3) of the San Francisco Administrative Code in that you are maintaining, committing or
permitting a nuisance on the Premises, and causing substantial damage to the rental unit and
substantial interference with the comfort safety and enjoyment of the landlord and other tenants
of the building, and are committing illegal acts as follows:

-On or about April 17, 2014, Glen Leis, while appearing to be under the influence of

narcotics, assaulted a neighbor, injuring the neighbor and causing him to go to the
hospital for his injuries; as a result, the police were called to the property and Glen Leis
was arrested; . .

~Based on the amount of foot traffic at the Premises, and the hours during which it takes
place, there is an indication that there is illegal drug activity taking place at the
Premises; as a result of this drug activity, a number of strangers enter the property and
where they sometimes sleep in the common areas, and disposed-of syringes and crack-
pipes often litter the property;

-While appearing to be under the: influence of narcotics, Glen Leis has repeatedly
shouted aggressively at the owner, neighbors, and workers at the property, causing them
to be fearful for their safety;

~Glen Leis has made numerous threats of physical violence to the owner, workers at the
property, and the neighbors;

Residents of the Premises have called the police to the property for no apparent reason,
other than to harass the owner, workers at the property, and the neighbors; on one
occasion in March 2014, a resident of the Premises called the police claiming that their
neighbors—a family who had recently moved in—had broken into the Premises; when the
police arrived, they woke the family up in middle of the night frightening their young
children; Glen Leis appeared to be under the influence of narcotics at the time and would
not let the police into the Premises to investigate; and

-You have broken into the downstairs storage unit of the building; where you steal
electricity from another unit and allow strangers to sleep there,we

© 98

Your Landlord has just cause to recover possession of the Premises under Section 37.9(a)(3) of
the San Francisco Residential Rent Stabilization and Arbitration Ordinance (the “Rent
Ordinance”) because you are committing or permitting to exist a nuisance in, or are causing
substantial damage to, the Premises, and are creating a substantial interference with the comfort,
safety or enjoyment of the Landlord and the other occupants in the building and are committing
illegal acts. .

Advice regarding this notice is available from the San Francisco Residential Rent
Stabilization and Arbitration Board: 25 Van Ness Avenue, Suite 320, San Francisco,
California, 94102; telephone number ts) 252-4602.

Dated: April 18, 2014

ZACKS & FREEDMAN, P.C.
235 Montgomery Street, Ste. 400
San Francisco, CA 94104

(415 810

WC
Attomeys for Landlord

ect San Francisco Residential Rent'Stabilization and Arbitration Board‘Ketorney Or Party Without. Attorney (Name and Address)

ANDREW CATTERALL, ESQ. (2 9)

ZACKS & FREEDMAN, PC

235 Montgomery Street, Suite 400

San Francisco, California
Attorneys fe: = LANDLORD

94104

Telephone: FOR COURT USE ONLY
(415) 956-8'

[insert niame of court, judicial district and branch court, If any:

Plaintiff: LANDLORD
Defendant: GLEN LEIS, et al.

Ref. No. Or File No.

W2628600

PROOF OF SERVICE | >t:
ccp § 1162

Time:

Depo: Case Number:

4. At the time of service I was at least 18 years of age and not a party to this action, and X served {specify documents):

THREE DAY NOTICE TO QUIT FOR

NUISANCE

2. a. Party served: GLEN LEIS; STEVEN MANN; ALL OTHER OCCUPANTS

tb Person served: By POSTING and MAILING true and correct copies.

3. By delivery at: 890 47th Avenue, Unit A,San Francisco, California 94121

a. ON, the date of: April 18, 2014

b. AT, the time of: 5:51 p.
4. I served the party named in item

[1 PeRsonat SERVICE

[[) susstrrrutep servic

POSTING + MAILING

5. Person serving:
Stephen Sabol
Wheels of Justice, Inc.
657 Mission Street, Suite 502
San Francisco, California 94105
Phone: (415) 546-6000

.m. (Posting)

2 by:

(Mailing)

By personally delivering a copy of the notice to the named tenant(s).

E If he or she is absent from his or her place of residence, and from his or her usual place of
business, by leaving a copy with some person of suitable age and discretion at either place,
and sending a copy through the mail addressed to the tenant at his or her place of residence

If such place of residence and business can not be ascertained, or a person of suitable age or
discretion there can not be found, then by affixing a copy in a conspicuous place on the
property, and also delivering a copy to a person there residing, if such person can be found;
and by placing a true copy in a sealed envelope with postage fully prepaid for first dass in the
United States mail. Service upon a subtenant may be made in the same manner.

@. Fee for service:
d. Registered California Process Server
{1) Employee or independent contractor
. (2) Registration No.: 1267
(3) County: ,San Francisco
(4) Expires: 1/7/2015

6. I declare under penalty of perjury under the laws of the State of California that the foregoing Is true and correct

am CI Tam a California sheriff, marshal, or constable and I certify that the foregoing is true and

Date: Aprii 21, 2014wo eNO A FW NY

ZACKS & FREEDMAN, P.C,
Ss = 5

235 MONTGOMERY STREET, SUITE 400
SAN FRANCISCO, CALIFORNIA 94104

© °o

PROOF OF SERVICE
Superior Court of California, County of San Francisco
Case No.: CUD-14-648300

I, Betzy Lesser, declare that:

Iam employed in the County of San Francisco, State of California. Iam over the age of 18, and
am not a party to this action. My business address is 235 Montgomery Street, Suite 400, San
Francisco, California 94104.

On April 22, 2014, I served:

CIVIL CASE COVER SHEET
SUMMONS - UD- EVICTION
PREJUDGMENT F RIGHT TO POSS.
COMPLAINT

in said cause addressed as follows:
Glen Leis

890 47" Ave., Unit #A

San Francisco, CA 94121

Steven Mann
890 47% Ave., Unit #A.
San Francisco, CA 94121

/XX/(BY PROFESSIONAL MESSENGER SERVICE) By placing and true copy thereof in a
sealed envelope, and causing said envelope to be delivered by professional messenger service to | -
the addressee(s) listed above.

Tdeclare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed on April 22, 2014 at San Francisco, California.

aS Lesser

ORIGINAL

PROOF OF SERVICE- © °

NOTICE: EVERYONE WHO LIVES IN THIS RENTAL UNIT MAY BE EVICTED BY COURT ORDER. READ THIS FORM IF YOU
LIVE HERE AND IF YOUR NAME !S NOT ON THE ATTACHED SUMMONS AND COMPLAINT.
4. If you live here and you do not complete and submit this form within 10 days of the date of service shown on this form,
you will be. evicted without further hearing by the court along with the persons named in the Summons and Complaint.
2. If you file this form, your claim will be determined in the eviction action against the persons named in the Complaint.
3. i you de not file this form, you will be evicted without further hearing.

‘CLAIMANT OR CLAIMANT'S ATTORNEY (Name and Across) "TELEPHONE NO, FOR COURT USE ONLY

ATTORNEY FOR (Name).
NAME OF COURT:SAN FRANCISCO SUPERIOR COURT
streeranpress: 400 MCALLISTER STREET
MAILING ADDRESS:
orrvannzie cos: SAN FRANCISCO, CA 94102
BRANCH NAME: LIMITED CIVIL JURISDICTION

PLAINTIFF: AJLOUN ENTERPRISES, LLC

DEFENDANT: GLEN LEIS, STEVEN MANN and DOES 1-10

PREJUDGMENT CLAIM OF RIGHT TO POSSESSION UDOT 648536

: {10.08 comploneo ay une enone on OF
Complete this form only if ALL of these statements are true: DATE OF SERVICE:

1. You are NOT named in the accompanying Summons and Complaint.
2. You occupied the premises on or before the date the unlawful detainer (evic- (Date that this form Is served or delivered,

tion) Complaint was filed. and posted, and malied by the officer or
3. You still occupy the premises. process server)

I DECLARE THE FOLLOWING UNDER PENALTY OF PERJURY:

1. My name is (specify):

2. Ireside at (street address, unit No., city and Z/P code):

3. The address of “the premises” subject to this claim is (address): 890 47TH AVE., UNIT 4 A, SAN FRANCISCO,
CA 94121

4. Oh (insert date}: CT), the. landlord or the landlord's authorized agent filed a complaint to recover
possession of the premises. (This date is the court filing date on the accompanying Summans and Complaint. }

5. loccupied the premises on the date the complaint was filed (the date in item 4), | have continued to occupy the premises ever since.
6. | was at least 18 years of age on the date the complaint was filed (the date in item 4),
7. 1 claim a right to possession of the premises because | occupied the premises on the date the complaint was filed (the date
in tem 4).
8. {was not named in the Summons and Complaint.
9. understand that if! make this claim of right to possession, | wilf be added as a defendant to the unlawful detainer (eviction) action.
10. (Filing fee) | understand that | must go to the court and pay a filing of $ or file with the court the form.

“Application for Waiver of Court Fees and Costs.“ | understand that if | don't pay the filing fee or fie with the court the form

for waiver of court fees within 10 days from the date of service on this form (excluding court holidays), | will not be entitled
to make a claim of right to possession.

{Continued on reverse)
P10. {New January 1, $981) PREJUDGMENT CLAIM OF RIGHT TO POSSESSION scl Code ot Civil Procedure, §§ 415.48,
oe

lutions” 715.010, 715.020, 1174.25
Ss.: © °o

PLAINTIFF (Name): AJLOUN ENTERPRISES, LLC ‘CASE NUMBER:

| DEFENDANT (Name): GLEN LEIS, STEVEN MANN and DOES 1-10 CUD-14~648300

i NOTICE: If you fail to file this claim, you will be evicted without further hearing.

11. (Response required within five days after you file this form) | understand that | will have five days (excluding court holidays)
to file a response to the Summons and Complaint after | file this Prejudgment Claim of Right to Possession form.

12. Rental agreement. | have (check aif that apply to you):
a.[_] an oral rental agreement with the landlord.
b. [|__| a written rental agreement with the landiord.
c. [| an oral rental agreement with a person other than the landlord.
da. Co a written rental agreement with a person other than the !andlord.
e.[_] other fexplain).

| declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
| WARNING: Perjury is a felony punishable by imprisonment in the state prison.

Date:

(TYPE OR PRINT NAME) (SIGNATURE OF CLAIMANT)

NOTICE: If you file this claim of right to possession, the unlawlul detainer (eviction) action against
you will be determined at trial. At trial, you may be found liable for rent, costs, and, in some
cases. treble damages.

- NOTICE TO OCCUPANTS -

YOU MUST ACT AT ONCE if all the following are true:
1. You are NOT named in the accompanying Summons and Complaint.
2. You occupied the premises on or before the date the unlawful detainer (eviction) complaint was filed. (The date is
the court filing date on the accompanying Summons and Complaint.)
3. You still occupy the premises.

{Where fo file this form) You can complete and SUBMIT THIS CLAIM FORM WITHIN 10 DAYS from the date of service (on
the reverse of this form) at the court where the unlawful detainer (eviction) complaint was filed.

(What will happen if you do not file this form) if you do not complete and submit this form (and pay a filing fee or file the
form for proceeding in forma pauperis if you cannot pay the fee), YOU WILL BE EVICTED.

After this form is properly filed, you will be added as a defendant in the unlawful detainer (eviction) action and your right
to occupy the premises will be decided by the court. If you do not file this claim, you will be evicted without a hearing.

P10 5 {New January 4, 1994] PREJUDGMENT CLAIM OF RIGHT TO POSSESSION Page taEXHIBIT 13oe NW DR Hh FW NY

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ZAURS Of FICLIUIVLAN, FU.
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235 MONTGOMERY STREET, SUITE 400
SAN FRANCISCO, CALIFORNIA 94104

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SESE sue 0
ANDREW M. ZACKS (147794) Cony SH Cour
ANDREW CATTERALL (221089) FRANCISCO
ZACKS & FREEDMAN, P.C. a A Pi
235 Montgomery Street, Suite 400 R22 PM 3: 55
San Francisco, CA 94104 CLERK of
Tel: (415) 956-8100 om THE Cougy
Attomeys for Plaintiff, 5 : OEPOTY of
OUN ENTERPRISE: .
nebot reppe
SUPERIOR COURT - STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO — LIMITED JURISDICTION
AJLOUN ENTERPRISES, a California cASENa. UD 14 648556
limited liability company,
COMPLAINT FOR UNLAWFUL
Plaintiff, DETAINER
ve Amount Does Not Exceed $10,000
GLEN LEIS, STEVEN MANN, and DOES 1
through 10 inclusive,
Defendants.

Plaintiff Ajloun Enterprises (“Plaintiff”) complains against Defendants Glen Leis and
Steven Mann (“Defendants”) as follows:

L Plaintiff is a California limited liability company with its principal place of
business in San Francisco, California. On or about October 14, 2013, Plaintiff purchased the real
property, possession of which is sought in this action, commonly known as and situated at 890
47" Avenue, Unit A, San Francisco, California, 94121 (the “Premises”). Plaintiff is the owner of
the Premises.

2. Plaintiff is informed and believes and on that basis alleges that Defendants Glen
Leis and Steven Mann (“Defendants”) are individuals who currently claim some right of

possession to the Premises pursuant to an agreement with Plaintiff's predecessor in interest.

-d-
COMPLAINTom TA NW RF WN

Ss

Plaintiff does not possess a copy of any written rental agreement governing Defendants’
possession of the Premises.

3. Plaintiff sues DOES 1 through 10 under the provisions of Code of Civil Procedure
section 474, Plaintiff will amend this complaint to insert their true. names and capacities when
ascertained, together with appropriate charging allegations.

4, On April 18, 2014, Plaintiff served Defendants with a THREE DAY NOTICE TO
QUIT (the “Notice”). The Notice specifically states the nature and the substance of the nuisance
in and damage to the Premises caused by Defendant, and the substantial interference to the
comfort, safety and enjoyment of the landlord and tenants in the building caused by Defendant.
The Notice requires that Defendants quit the Premises within three days service of the Notice.
The Notice specifically states that advice regarding the Notice is available from the San Francisco
Residential Rent Stabilization and Arbitration Board. Attached hereto as Exhibit A is a true and
correct copy of the Notice.

5, On April 18, 2014, a registered process server served Defendants Glen Leis and
Steven Mann with the Notice by posting and mailing the notice at the Premises pursuant to Code
of Civil Procedure Section 1162(a)(3). Attached hereto as Exhibit B is a true and correct copy of
the proof of service of the Notice.

6. More than three days have elapsed since service of the Notice, but Defendants
have failed to quit as required by the Notice; therefore, Plaintiff is entitled to possession of the
Premises.

7. Defendants continue in possession of the Premises without Plaintiffs consent.

8. Plaintiff has complied with the San Francisco Residential Rent Stabilization and
Arbitration Ordinance (the “Rent Ordinance”). Plaintiff has just cause to recover possession of

the Premises under Section 37.9(a)(3) of the Rent Ordinance of because Defendants are

-2-
COMPLAINTOo wor nA WNW FF WN

commiting or permitting to exist a nuisance in and are causing substantial damage to the
Premises, and is creating a substantial interference with the comfort, safety and enjoyment of the
landlord and the other occupants in the building.

9. The daily rental value of the Premises is $40.

WHEREFORE, Plaintiff prays for judgment against Defendants, for:

1. Restitution of the Premises;

2. Forfeiture of the any rental agreement;

3. Consequential damages according to proof at trial including damages for the
reasonable rental value of the Premises after termination of the tenancy;

4. Costs of suit; and

5. Such other and further relief as the Court deems just and proper.

Dated: April 22, 2014

Andrew R. Catterall
Attorneys for Plaintiff

COMPLAINTApr.22.2014 01:00 “oO Around Seniior Servic ee PAGE.

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VERIFICATION

I, Matthew Zghoul, declare:

1 am the managing member of Ajloun Enterprises, Plaintiff in the within action, and I am
authorized to take this verificetion on its behalf. I-have read the foregoing Complaint for
Unlawful Detainer and know its contents. I am informed and believe and on that ground allege
that the matters stated in the foregoing Complaint for Unlawful Detainer are true,

I declare, under penalty of perjury under the laws of the State of California, that the

foregoing is tme and correct and that this Verification was executed at

Sus Hedy __, Califomia.

Dated: April gt, 2014 Mbp L

FAX SIGNATURE

COMPLAINTEXHIBIT(A]a.

et

oS. °o

THRE CE TO QUIT FOR NUIS,
(Code of Civil Procedure Section 1161(4))

TO: GLEN LEIS, STEVEN MANN and all occupants in possession of 890 4T™ Avenue, Unit
A, San Francisco, California, 94124, including any appurtenant areas (the “Premises”)

NOTICE IS GIVEN THAT, WITHIN THREE (3) DAYS AFTER SERVICE ON YOU OF
THIS NOTICE, YOU ARE REQUIRED TO QUIT POSSESSION OF THE PREMISES.
If you fail to comply with this Notice, your Landlord will institute legal proceedings against you
to: 1) Declare a forfeiture of the Rental Agreement; and 2) Recover possession of the Premises,
ples costs and damages to the extent allowed by law. Delivery of possession may be made by
delivering all keys to the Premises in your possession to Andrew R, Catterall, of Zacks &
Freedman, P.C., 235 Montgomery Street, Suite 400, San Francisco, CA 94104, Telephone: (415)
956-8100, Business Hours: 9:00 a.m. - 5:00 p.m., Monday - Friday, who is authorized to receive
the same.

You are required to quit possession of the Premises within the 3-day period, for the reason that
you are in breach of Section 1161(4) of the California Code of Civil Procedure, and Section
37.9(a)(3) of the San Francisco Administrative Code in that you are maintaining, committing or
permitting a nuisance on the Premises, and causing substantial damage to the rental unit and

substantial interference with the comfort safety and enjoyment of the landlord and other tenants

of the building, and are committing illegal acts as follows:

-On or about April 17, 2014, Glen Leis, while appearing to be under the influence of .

narcotics, assaulted a neighbor, injuring the neighbor and causing him to go to the
hospital for his injuries; as a result, the police were called to the property and Glen Leis
was arrested;

-Based on the amount of foot traffic at the Premises, and the hours during which it takes
Place, there is an indication that there is illegal drug activity taking place at the
Premises; as a result of this drug activity, a number of strangers enter the property and
where they sometimes sleep in the common areas, and disposed-of syringes and crack-
pipes often litter the property;

-While appearing to be under the: influence of narcotics, Glen Leis has repeatedly
shouted aggressively at the owner, neighbors, and workers at the property, causing them
to be fearful for their safety;

-Glen Leis has thade numerous threats of physical violence to the owner, workers at the
property, and the neighbors, .

-Residents of the Premises have called the police to the property for no apparent reason,
other than to harass the owner, workers at the property, and the neighbors; on one
occasion in March 2014, a resident of the Premises called the police claiming that their
neighbors—a family who had recently moved in~-had broken into the Premises; when the
police arrived, they woke the family up in middle of the night frightening their young
children; Glen Leis appeared to be under the influence of narcotics at the time and would
not let the police into the Premises to investigate; and

-You have broken into the downstairs storage unit of the building; where you steal
electricity from another unit and allow strangers to sleep there,° 8

Your Landlord has just cause to recover possession of the Premises under Section 37.9(a)(3) of
the San Francisco Residential Rent Stabilization and Arbitration Ordinance (the “Rent
Ordinance”) because you are committing or permitting to exist a nuisance in, or are causing
substantial damage to, the Premises, and are creating a substantial interference with the comfort,
safety or enjoyment of the Landlord and the other occupants in the building and are committing
iNegal acts, ~

Advice regarding this notice is available from the San Francisco Residential Rent
Stabilization and Arbitration Board: 25 Van Ness Avenue, Suite 320, San Francisco,
California, 94102; telephone number (415) 252-4602.

Dated: April 18, 2014

ZACKS & FREEDMAN, P.C.
235 Montgomery Street, Ste. 400
San Francisco, CA 94104

{4S 8101
An Cc
Attomeys for Landlord

ee: San Francisco Residential Rent Stabilization and Arbitration BoardEXHIBIT([P |‘Kitorney Or Party Without Attorney (Name and Address) Telephones FOR COURT USE ONLY

ANDREW CATTERALL, ESQ. (2 89) (415) 956-8:
ZACKS & FREEDMAN, PC
235 Montgomery Street, Suite 400 -

San Francisco, California 94104
Attomeys fo: LANDLORD

Insert name of court, judicial district and branch court, if any:

Plaintiff: LANDLORD Ref. No. Or File No.
befendant: GLEN LEIS, et al. W2628600
PROOF OF SERVICE | ot: Time: DepyDw: Case Number:
CCP § 1162

4. At the time of service I was at feast 18 years of age and not a party to this action, and I served (specify documents):
THREE DAY NOTICE TO QUIT FOR NUISANCE

2. a, Partyserved: GLEN LEIS; STEVEN.MANN; ALL OTHER OCCUPANTS

b. Person served: By POSTING and MAILING true and correct copies.
3. By delivery at: 890 47th Avenue, Unit A, San Francisco, California 94121

a. ON, the date of} April 18, 2014
b. AT, the time of: 5:51 p.m. (Posting) 8:12 p.m. (Mailing)

4, I served the party named in item 2 by:

Ol PERSONAL SERVICE _ By personally delivering a copy of the notice to the named tenant(s).

oO SUBSTITUTED SERVICE If he or she is absent from his or her place of residence, and from his or her usual place of
business, by leaving a copy with some person of suitable age and discretion at either place,
and sending a copy through the mail addressed to the tenant at his or her piace of residence

POSTING + MAILING If such piace of residence and business can not be ascertained, or a person of sultable age or
discretion there can not be found, then by affixing a copy In a conspicuous place on the
property, and also delivering a copy to @ person there residing, If such person can be found;
and by placing a true copy in a sealed envelope with postage fully prepaid for first class in the
United States mail. Service upon a subtenant may be made in the same manner,

5. Person serving: a. Fee for service:
Stephen Sabol d. Registered California Process Server
Wheels of Justice, Inc. (1) Employee or independent contractor
657 Mission Street, Suite 502 . (2) Registration No.: 1267
San Francisco, California 94105 (3) County: |San Francisco
Phone: (415) 546-6000 {4) Expires: 1/7/2015

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct
m oO 1am a California sheriff, marshal, or constable and 1 certify that the foregoing is true and

eS

Date: April 21, 2014 Signatur¢Co we NA Hw WN =

wet nee eet
A BF BN = Oo

ZACKS & FREEDMAN, P.C.
a

235 MONTGOMERY STREET, SUITE 400
SAN FRANCISCO, CALIFORNIA 94104

RNR NN DY Be ee
RPNRRE BRRSSSeNA

© °

PROOF OF SERVICE
Superior Court of California, County of San Francisco
Case No.: CUD-14-648300

I, Betzy Lesser, declare that:

Lam employed in the County of San Francisco, State of California. 1 am over the age of 18, and
am not a party to this action. My business address is 235 Montgomery Street, Suite 400, San
Francisco, California 94104.

On April 22, 2014, I served:

CIVIL CASE COVER SHEET

PREJUDGMENT OF HT TO POSS
COMPLAINT

in said cause addressed as follows:
Glen Leis

890 47" Ave., Unit #A

San Francisco, CA 94121

Steven Mann
890 47" Ave., Unit #A
San Francisco, CA 94121

/XX/(BY PROFESSIONAL MESSENGER SERVICE) By placing and true copy thereof in a
sealed envelope, and causing said envelope to be delivered by professional messenger service to
the addressee(s) listed above.

I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed on April 22, 2014 at San Francisco, California.

6 A Lesser

ORIGINAL

PROOF OF SERVICEno © °

NOTICE: EVERYONE WHO LIVES IN THIS RENTAL UNIT MAY BE EVICTED BY COURT ORDER. READ THIS FORM IF YOU
LIVE HERE AND IF YOUR NAME IS NOT ON THE ATTACHED SUMMONS AND COMPLAINT.
1. If you live here and you do not complete and submit this form within 10 days of the date of service shown on this form,
you will be evicted without further hearing by the court along with the persons named in the Summons and Complaint.
2. If you file this form, your claim will be determined in the eviction action against the persons named in the Complaint.
3. If you do not file this form, you will be evicted without further hearing.

CLAIMANT OR CLAIMANT'S ATTORNEY (Name and Access): TELEPHONE NO. FOR GOURT USE ONLY

ATTORNEY FOR (hiamel:
NAME OF COURT: SAN FRANCISCO SUPERIOR COURT
streerappress: 400 MCALLISTER STREET
MAILING ADDRESS:
ciryanozipcooe: SAN FRANCISCO, CA 94102
brancuName: LIMITED CIVIL JURISDICTION

PLAINTIFF: AJLOUN ENTERPRISES, LLC

DEFENDANT: GLEN LEIS, STEVEN MANN and DOES 1-10

eazy
PREJUDGMENT CLAIM OF RIGHT TO POSSESSION ¢ . 4 oF 6 4 8 5 3 6
~ (10 09 compioree vy tite nate m8)
Compiete this form only if ALL of these statements are true: DATE OF SERVICE:
1, You are NOT named in the accompanying Summons and Complaint.
2. You occupied the premises on or before the date the unlawful detainer (evic- {Date that this form is served or delivered,
tion) Complaint was filed. and posted, and mailed by the officer or
3. You still occupy the premises. Process server}

| DECLARE THE FOLLOWING UNDER PENALTY OF PERJURY:
1. My name is (specify):

2. \reside at (street address, unit No., city and ZIP code):

3. The address of “the premises’ subject to this claim is (address): 890 47TH AVE., UNIT # A, SAN FRANCISCO,
CA 94121

4. Onfinsertdate:[ the landlord or the landlord's authorized agent filed a complaint to recover
possession of the premises. (This date is the court filing date on the accompanying Summons and Complaint. )

5. | occupied the premises on the date the complaint was filed (the date in item 4). | have continued to occupy the premises ever since.
8. | was at least 18 years of age on the date the complaint was filed (the dafe in item 4).

7. | claim a right to possession of the premises because i occupied the premises on the date the complaint was filed (the date
In item 4),

8. [was not named in the Summons and Complaint.
9. lunderstand that if | make this claim of right to possession, | wilt be added as a defendant to the unlawful detainer (eviction) action.

10. (Filing fee) i understand that | must go to the court and pay a filing of $ ar file with the court the form
“Application for Waiver of Court Fees and Costs.” | understand that if | don't pay the filing fee or file with the court the form
for waiver of court fees within 10 days from the date of service on this form (excluding court holidays), | will not be entitled
to make a claim of right to possession.

(Continued on reverse)
OPIC.S [New January 1, 1991} PREJUDGMENT CLAIM OF RIGHT TO POSSESSION Code of Civil Procedure, §§ 415.46,
lutions 716.010, 718.020, 1474.25

8.PLAINTIFF (Name): AJLOUN ENTERPRISES, LLC CASE NUMBER:
r DEFENDANT (Name): GLEN LEIS, STEVEN MANN and DOES 1~i0 CUD-14-648300
[ NOTICE: if you fail to file this claim, you will be evicted without further hearing. |

41. (Response required within five days after you file this form) | understand that | will have five days (excluding court holidays)
to file a response to the Summons and Complaint after | file this Prejudgment Claim of Right to Possession form.

12. Rental agreement. | have (check aif that apply to you):
a.[__] an oral rental agreement with the landlord.
b.{_] a written rental agreement with the fandlord.
¢.{__] an oral rentat agreement with a person other than the landlord.
d.(_] a written rentat agreement with a person other than the tandlord.
el] other (explain):

| declare under penaity of perjury under the laws of the State of California that the foregoing is true and correct.
| WARNING: Perjury is a felony punishable by imprisonment in the state prison. ]

(TYPE OR PRINT NAME) {SIGNATURE OF CLAIMANT)

INOTICE: If you file this claim of right to possession, the unlawful detainer (eviction) action against
you will be determined at trial. At trial, you may be found liable for rent, costs, and, in some
cases, treble damages.

- NOTICE TO OCCUPANTS -

YOU MUST ACT AT ONCE if all the following are true:
1, You are NOT named in the accompanying Summons and Complaint.
2. You occupied the premises on or before the date the unlawful detainer (eviction) complaint was filed. (The date is
the court filing date on the accompanying Summons and Complaint}
3. You still occupy the premises.

{Where fo file this form) You can complete and SUBMIT THIS CLAIM FORM WITHIN 10 DAYS fram the date of service (on
the reverse of this form) at the court where the unlawful detainer (eviction) complaint was filed.

{What will happen if you do not file this form) if you do not complete and submit this form (and pay a filing fee or file the
form for proceeding in forma pauperis if you cannot pay the fee), YOU WILL BE EVICTED.

After this form is properly filed, you will be added as a defendant in the unlawful detainer (eviction) action and your right
to occupy the premises will be decided by the court. /f you do not file this claim, you will be evicted without @ hearing.

GPO iNew January 1, 1894] PREJUDGMENT CLAIM OF RIGHT TO POSSESSION

Page toEXHIBIT 14UD-405
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Siste Bar number, and address}, FOR COURT USE ONLY
Nancy M. Conway 122562
345 Franklin Street I
San Francisco, CA 94102 Supatior C
: 415-241-411 : 415-241-1156 F Court of Cal
cere “ rmsno ATS County of San Fanon
ATTORNEY FOR iNere: Glen Leis and Steve Mann
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco JUN 76 2014
street aporess: 400 Me Allister Street CLE F THE COU;
MAILING ADORESS: IBY: RT
ciyanoze cove: San Francisco, CA 94102 Deans
srancH name: Lid Bown, IAN uty Clerk
Piaint#, Ajloun Enterprises, LLC Llu
Defendant: Glen Leis
| CASE NUMBER:
ANSWER - UNLAWFUL DETAINER CUD-14-648536

4. Defendant (each defendant for whom this answer is fled must be named and must sign this answer unless his or her attomey
signs): Glen Leis

answers the compiaint as follows:
2. Check ONLY ONE of the next two boxes:
a. [X} Defendant generally denies each statement of the complaint. (Oo not check this box if the complaint demands more than
$1,000.)
b. [2] Defendant admits that all of the statements of the complaint are true EXCEPT:
(1) Defendant claims the following statements of the complaint are false (stafe paragraph numbers from the complaint
or explain below or an form MC-025): (2) Explanation is on MC-025, titled as Attachment 2b(1).

{2) Defendant has no information or belief that the following statements of the complaint are true, so defendant denies
them (state paragraph numbers from the complaint or explain below or on form MC-025):
(J expianation is on MC-025, tiled as Attachment 2b(2). ‘

eo

AFFIRMATIVE DEFENSES (NOTE: For each box checked, you must state brief facts to support it in item 3k (top of page 2).)

a. oO {nonpayment of rent only) Plaintiff has breached the warranty to provide habitable premises.

b. () (nonpayment of rent only) Defendant made needed repairs and properly deducted the cost from the rent, and plaintiff did
not give proper credit.

c. (2) (aonpayment of rent only) On (date): before the notice to pay or quit expired, defendant offered
the rent due but plaintiff would not accept it.

d. QQ] Plaintiff waived, changed, or canceled the notice to quit.

e. (Q} Plaintiff served defendant with the notice to quit or filed the complaint to retaliate against defendant.

f. CQ) By serving defendant with the notice to quil or filing the complaint, plaintiff is arbitrarily discriminating against the
defendant in violation of the Constitution or the faws of the United States or California.

g. CQ) Plaintiff's demand for possession violates the local rent control or eviction control ordinance of (city or county, title of
ordinance, and date of passage}: San Francisco Rent Stabilization and Arbitration Ordinance, June 12, 1979 an

as amended
{Also, briefly state in item 3k the facts showing violation of the ordinance.)

h. (2) Plaintiff accepted rent from defendant to cover a period of time after the date the notice to quit expired.

i. (2) Plaintiff seeks to evict defendant based on acts against defendant or a member of defendant's household thal constitute
domestic violence, sexual assault, stalking, human trafficking, or abuse of an elder or a dependent adult. (A temporary
restraining order, protective order, or police report not more than 180 days old is required naming you or your household
member as the protected party or a victim of these crimes.)

j. (2) Other affirmative defenses are stated in item 3k. Paget of2
Form, for Optional Use ANSWER - UNLAWFUL DETAINER oa Gage, § 1860 309;
Feel Bocnct of Gator Coste of Civil Procedure, § 425.12, § 1181 et 09
UD-106 (Rev. January 2.2014) Leis, Glen ‘wuew courts 02. govUD-105

‘CASE NUMBER:

CUD-14-648536

"3, AFFIRMATIVE DEFENSES (cont'd)
k. Facts supporting affirmative defenses checked above (identify facts for each item by its letter from page 1 below or on form
MC-028):
(QD Description of facts is on MC-025, titled as Attachment 3k.
d. Amended complaint changes Notice terminating tenancy by eliminating part of the Notice.
e. Defendant made complaints to the police regarding the management/owners including assault prior to getting notice. Also made
complaints to Rent Board and DBI regarding uninhabitable conditions, including lack of heat and electric before Notice was issued.
4, OTHER STATEMENTS
a. (} Defendant vacated the premises on (date):
b. (XJ The fair rental value of the premises alleged in the complaint is excessive (explain below or on farm MC-025):
(2) Expianation is on MC-026, titled as Attachment 4b.
The premises have severe habitability defects and the plaintiffs waived the rent completely duc to habitabilit
Issues,

c. (2) Other (specify below or on form MC-025 in attachment):
[2 Other statements are on MC-025, titled as Attachment 4c.

5. DEFENDANT REQUESTS

a. that plaintiff take nothing requested in the