On May 18, 2016 a
Motion-Secondary
was filed
involving a dispute between
Welcome Patricia,
and
Guthrie Douglas,
Housing Authority Of The City Of Los Ang-,
for civil
in the District Court of Los Angeles County.
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FILED
Sup erior Court of Califor nia
‘ounty of Los Angeles
Joseph L. stark and Associates
25129 The Old Road Suite 300 v JUN 02 2017
Stevenson Ranch, CA 91381
T: (661) 799-1880 Sherri R. Caster, Exepative, ficer/Clerk.
F: (661) 799-1881 By. 2
Deputy
Woseph L. Stark - State Bar No. 116261
Attorneys For: Respondent, HOUSING AUTHORITY OF THE CITY OF LOS ANGELES
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES CENTRAL DISTRICT
10 PATRICIA WELCOME, ) Case Number: BS 162572
Dept. 86
11 Plaintiffs, )
12 ) MEMORANDUM OF POINTS AND
) AUTHORITIES IN OPPOSITION TO
13 MOTION TO AMEND JUDGMENT/NEW
HOUSING AUTHORITY OF THE CITY OF LOS) JUDGMENT/ADDITUR
14 ANGELES, DOUGLAS GUTHRIE in his official)
capacity as President and Chief Executive)
15 Officer of the Housing Authority of the City of) DATE: July 5, 2017
Los Angeles, DOES 1 through 10, TIME: 9:30 a.m.
16 DEPT: 86
Defendants )
17
18 There is one fundamental flaw in the analysis and demand by Petitioner. The fact is that
19 Petitioner never received one dime of housing subsidies from Respondent! There is no showing
20 that Petitioner sustained any financial loss by reason of the decision of HACLA to terminate
21 housing subsidies. Nor can Petitioner demonstrate any entitlement to payments to her from
22 HACLA. While, under this court’s ruling, Petitioner is being reinstated to the Section 8 program,
23 Petitioner never has and never can be entitled to any payment from HACLA.
ae
24 1 ALL PAYMENTS MADE BY HACLA WERE MADE
25 DIRECTLY TO PETITIONER’S LANDLORD
oad 26 As PHA, HACLA administers federal housing funds through a HAP contract with a private
27 roperty owner to subsidize rent otherwise payable by the Section 8 Participant. The HAP
28 contract is a form specified by HUD (see Exhibit A attached hereto). As set forth in Part B
1
OPPOSITION TO MOTION TO AMEND JUDGMENT, ETC.
Document Filed Date
June 02, 2017
Case Filing Date
May 18, 2016
Status
Legacy Judgment 04/26/2017
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RO é y @ / FILED Sup erior Court of Califor nia ‘ounty of Los Angeles Joseph L. stark and Associates 25129 The Old Road Suite 300 v JUN 02 2017 Stevenson Ranch, CA 91381 T: (661) 799-1880 Sherri R. Caster, Exepative, ficer/Clerk. F: (661) 799-1881 By. 2 Deputy Woseph L. Stark - State Bar No. 116261 Attorneys For: Respondent, HOUSING AUTHORITY OF THE CITY OF LOS ANGELES SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES CENTRAL DISTRICT 10 PATRICIA WELCOME, ) Case Number: BS 162572 Dept. 86 11 Plaintiffs, ) 12 ) MEMORANDUM OF POINTS AND ) AUTHORITIES IN OPPOSITION TO 13 MOTION TO AMEND JUDGMENT/NEW HOUSING AUTHORITY OF THE CITY OF LOS) JUDGMENT/ADDITUR 14 ANGELES, DOUGLAS GUTHRIE in his official) capacity as President and Chief Executive) 15 Officer of the Housing Authority of the City of) DATE: July 5, 2017 Los Angeles, DOES 1 through 10, TIME: 9:30 a.m. 16 DEPT: 86 Defendants ) 17 18 There is one fundamental flaw in the analysis and demand by Petitioner. The fact is that 19 Petitioner never received one dime of housing subsidies from Respondent! There is no showing 20 that Petitioner sustained any financial loss by reason of the decision of HACLA to terminate 21 housing subsidies. Nor can Petitioner demonstrate any entitlement to payments to her from 22 HACLA. While, under this court’s ruling, Petitioner is being reinstated to the Section 8 program, 23 Petitioner never has and never can be entitled to any payment from HACLA. ae 24 1 ALL PAYMENTS MADE BY HACLA WERE MADE 25 DIRECTLY TO PETITIONER’S LANDLORD oad 26 As PHA, HACLA administers federal housing funds through a HAP contract with a private 27 roperty owner to subsidize rent otherwise payable by the Section 8 Participant. The HAP 28 contract is a form specified by HUD (see Exhibit A attached hereto). As set forth in Part B 1 OPPOSITION TO MOTION TO AMEND JUDGMENT, ETC.