Preview
PLD-C-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Siafe Bar number, and address) FOR COURT USE ONLY
Raymond L, Sandelman SBN 078020
Attorney at Law
196 Cohasset Road, Suite 225
Chico, CA 95926-2284
‘TELEPHONE NO.: (530) 343-5090 FAX NO.(Optional): (530) 343-5091
E-MAIL ADDRESS (Optional): Raymond@sandelmanlaw.com
F Superior Court of California F
ATTORNEY FOR (Name): Andrea Schuegraf, Individually and as Successor Trustee
County of Butte
SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE
STREET ADDRESS: 1775 Concord Avenue
|
MAILING ADDRESS: 1775 Concord Avenue 7/15/2020 L
ciTy AND zip cope: Chico, CA 95928 E
BRANCH NAME: North Butte County Courthouse
PLAINTIFF: Bruce McCrea Kim) leper, Clerk D
By Deputy
ctronically ‘D
DEFENDANT: Brigitte Schuegraf, [continued on Attachment 1]
{Cross Complaint caption continued Attachment 1]
C] does 1 To
CONTRACT
(2) ComPLAINT (2) AMENDED COMPLAINT (Number) :
(J CROSS-COMPLAINT (C] AMENDED CROSS-COMPLAINT (Number) :
Jurisdiction (check all that apply): CASE NUMBER,
(C) ACTION IS A LIMITED CIVIL CASE 19CV00236
Amount demanded [] does not exceed $10,000
(L] exceeds $10,000 but does not exceed $25,000
(C) ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
(] ACTION IS RECLASSIFIED by this amended complaint or cross-complaint
(J from limited to unlimited
C] from unlimited to limited
Plaintiff" (name or names): Andrea Schuegraf, successor trustee of the Brigitte Schuegraf Family Trust, Dated March 4, 2004
as Amended and Restated on April 7, 2016 and Amended on April 11, 2017
alleges causes ot action against defendant* (name or names) : Bruce McCrea, Does 6-10
This pleading, including attachments and exhibits, consists of the following number of pages: 20
3. a. Each plaintiff named above is a competent adult
(&) except plaintiff (name): Andrea Schuegraf, successor trustee
(1) () a corporation qualified to do business in California
(2) (LJ an unincorporated entity (describe) :
(3) GQ other (specify) : trustee
b. (2) Plaintiff (name) :
a. [2] has complied with the fictitious business name laws and is doing business under the fictitious name (specify) :
b. (C} has complied with all licensing requirements as a licensed(specify) :
c. Q) Information about additional plaintiffs who are not competent adults is shown in Attachment 3c.
4 a. Each defendant named above is a natural person
(L] except defendant (name) : (CC) except defendant (name) :
(1) (2) a business organization, form unknown (41) (2) a business organization, form unknown
(2) (L) acorporation (2) (LQ acorporation
(3) (LJ an unincorporated entity (describe) : (3) CCQ an unincorporated entity (describe) :
(4) CC) a public entity (describe): (4) () a public entity (describe):
(5) (C) other (specify) : (5) (CQ other (specify) :
“If this form is used as a cross-complaint, plaintiff means cross-complainant and defendant means cross-defendant. Page 1 of2
Form Approved for Optional Use Code of Civil Procedure, § 425.12
Judicial Councit of alifornia CB | Essential
PLD-C-001 (Rev. January 1, 7) ceb.com Forms" COMPLAINT - Contract
Schuegraf
PLD-C-001
SHORT TITLE: CASE NUMBER
McCrea v. Schuegraf 19CV00236
(Continued)
b. The true names of defendants sued as Does are unknown to plaintiff.
(1) (2) Doe defendants (specify Doe numbers): were the agents or employees of the named
defendants and acted within the scope of that agency or employment.
(2) [) Doe defendants (specify Doe numbers): 6-1)
_____+=+=_=_
are persons whose capacities are unknown to
plaintiff.
c. (2) Information about additional defendants who are not natural persons is contained in Attachment 4c.
d. (2) Defendants who are joined under Code of Civil Procedure section 382 are(names):
CC) Plaintiff is required to comply with a claims statute,and
a (C) has complied with applicable claims statutes, or
b. (2) is excused from complying because (specify) :
(C) This action is subject to CQ Civil Code section 1812.10 [2] Civil Code section 2984.4.
This court is the proper court because
{&) a defendant entered into the contract here.
(&) a defendant lived here when the contract was entered into.
(J a defendant lives here now.
(K] the contract was to be performed here.
() a defendant is a corporation or unincorporated association and its principal place of business is here.
(CC) real property that is the subject of this action is located here.
(CY other (specify) :
The following causes of action are attached and the statements above apply to each (each complaint must have one or
more causes of action attached):
(]} Breach of Contract
(CJ Common Counts
(} Other (specify) :
(&) Other allegations: Andrea Schuegraf, successor trustee of the Brigitte Schuegraf Family Trust, Dated March 4, 2004, as
Amended and Restated on April 7, 2016 and Amended on April 11, 2017 is hereafter referred to as
"Andrea Schuegraf, successor trustee".
10. Plaintiff prays fer judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a [) damages of: $ 120,000 or according to proof
b [&} interest on the damages
a) [&) according to proof
(2) (J atthe rate of (specify): percent per year from (date) :
c. CC) attorney's fees
(1) CA of $
(2) CC) according to proof.
d. CC) other (specify) :
41. KJ The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers) : BC-1, BC-2,
BC-3, BC-4, BC-6.
Date: June @ +2020
Raymond _L. Sandelman d xt. Se
(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY)
(If you wish to verify this pleading, affix a verification.)
PLD-C-001 (Rev. January 1, 2007] Page 2 of 2
COMPLAINT - Contract
LB
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i2)Forms” Schuegraf
MC-025
SHORT TITLE: ‘CASE NUMBER:
t- McCrea vy. Schuegraf 19CV00236
ATTACHMENT (Number): 1____
(This Attachment may be used with any Judicial Council form.)
Continuation of Caption at Page I
Defendants [continued from Page 1]: Andrea Schuegraf individually and
as trustee of the Bridgitte Schuegraff Family Trust March 4, 2004.
Cross Complainant: Andrea Schuegraf, successor trustee of the Brigitte
Schuegraf Family Trust, Dated March 4, 2004, as Amended and
Restated on April 7, 2016 And Amended on April 11, 2017,
v.
Bruce McCrea, individually and doing business as McCrea Construction,
Does 6-10.
(If the item that this Attachment concems is made under penalty of perjury, all statements in this Page 3___ of 20.
Attachment are made under penalty of penury.) (Add pages as required)
Form Approved for Optional Use ATTACHMENT wwvw.courtinfo.ca.gov|
Judicial Council of alifornia
'MC-025 [Rev. July 1, 2009} to Judicial Council Form
CB [)Forms:
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Essential Schuegraf
PLD-C-004(1)
SHORT TITLE CASE NUMBER,
McCrea v. Schuegraf 19CV00236
FIRST CAUSE OF ACTION-Breach of Contract
(number)
ATTACHMENT TO [2] Complaint (KJ Cross-Complaint
(Use a separate cause of action form for each cause of action.)
BC-1. Plaintiff (name): Andrea Schuegraf, successor trustee
alleges that on or about (date):
a [KJ written CQ oral (2) other (specify):
agreement was made between (name parties to agreement): Brigitte Schuegraf, and Bruce McCrea, indvidually and
doing business as McCrea Construction
CC) A copy of the agreement is attached as Exhibit A, or
[(&] The essential terms of the agreement EX] are stated in Attachment BC-1 (C]} are as follows (specify):
BC-2. On or about (dates): October 30, 2016
defendant breached the agreement by [J the acts specified in Attachment BC-2 [C] the following acts
(specify):
BC-3. Plaintiff has performed all obligations to defendant except those obligations plaintiff was prevented or
excused from performing.
BC-4. Plaintiff suffered damages legally (proximately) caused by defendant's breach of the agreement
(2) as stated in Attachment BC-4 [XK] as follows (specify):
$120,000 or according to proof.
BC-5. (C) Plaintiff is entitled to attorney fees by an agreement or a statute
CO) ofs
(CC) according to proof.
BC-6. KJ Other:
See Attachment BC-6
Page 4of 20
Page 1 of1
Form Approved for Optional Use Code of Civil Procedure, § 425.12
judicial Council of California CAUSE OF ACTION-Breach of Contract ‘wwvw.courtinio.ca.gov
PLD-C-001(1) [Rev. January 1, 2007)
CB Essential
ceb.com * =|Forms"
Schuegraf
MC-025
SHORT TITLE: CASE NUMBER’
[- McCrea v. Schuegraf 19CV00236
ATTACHMENT (Number): BC-1 _
(This Attachment may be used with any Judicial Council form.)
(a) A copy of the written construction contract is attached hereto marked Exhibit 1.
(b) The Exhibit 1 construction contract includes an implied warranty that the dwelling was constructed in a good,
professional, and reasonably workmanlike manner in accordance with the plans and specifications, and other contractual
documents.
(If the item that this Attachment concems is made under penalty of perjury, all statements in this Page 5__ of 20.
Attachment are made under penalty of perjury.) (Add pages as required)
Form Approved for Optional Use ATTACHMENT wivw.courtinfo.ca.gov
Judicial Council of alifornia
1C-025 [Rev. July1, 2009] to Judicial Council Form
LB Essential
ceb,com [2)Forms:
Schuegraf
Attachment BC-2
Breaches Of Contract
The dwelling constructed by Defendants at 11 Hawk Place, Chico, CA 95973 was not
constructed in a good, professional, and reasonably workmanlike manner in accordance with the
plans and specifications, and other contractual documents, and had the following construction defects:
I. Roof: There is evidence of water intrusion into the attic area around the gas fireplace vent
roof penetration. Surfaces in attic area are wet. There is no visible stain noted on interior portion of
gypsum board ceiling below this location at time of inspection. Proper resealing of this penetration
10 should correct this condition.
1 II. GFCI: The general-purpose receptacles in the laundry room were required to be GFCI
12 (ground fault circuit interrupter) protected at the time of construction.
13 Ill. Attic fan: The electrical boxes serving both attic fans have not yet been secured to the
Bs
ae
17
Zo3Zag IV. Exhaust fan: The exhaust fan in the laundry room is currently non-functional (cause
sa7S
62
ee
n= 18 unknown-possible loose wire connection).
5S
Ba
Ba
go 19 V. Light: The light portion of the fan/light fixture in the middle bedroom is currently
20 nonfunctional (cause unknown -fan portion of fixture is energized). The light cover is missing or has
21 not yet been installed on the fan/light fixture mentioned above (possibly removed for repair). The
22 vanity light in the half-bath is loose and should be secured to its electrical box to prevent possible
23 damage to the wire connections (light was functional at time of inspection). One of the four recessed
24 lights in the office/den and one of the five recessed lights in the master bath are currently non-
25 functional (cause unknown-possible faulty bulbs).
26 VI. Dead end wire: There are "dead end" electrical wires extending from two exterior ceiling
27 mount electrical boxes in the patio area on the north side of the house (installed for future use). The
28 ends of these wires are required to be terminated properly inside their electrical boxes with cover
ATTACHMENT BC-2
1 plates attached unless electrical devices are to be installed.
VII. Service requirements: The working platform installed for servicing of the heat/AC unit
in the west attic area is approximately 24 inches in depth. A working platform with a minimum depth
of 30 inches was required to be installed along the firebox side of this unit to meet service
requirements for the time of construction.
VIII. Fireplace: The fuel gas disconnect/shut-off valve and burner controls serving the
factory-built gas fired fireplace are no longer fully accessible due to a decorative marble type trim
installed around the fireplace/casing (marble obstructs the removal/opening of the access
covers/casing). The gas valve and burner controls are required to be accessible for
10 servicing/operation.
ll IX. Door: The exterior side garage door requires adjustment/maintenance for proper
12 operation (the door "binds" on threshold when opened/closed). The latch/catch mechanisms have not
13 yet been installed on the closet doors in the middle bedroom and both sets of closet doors in the
as
ag
<& 14 southeast bedroom (required to secure doors in closed position).
se
B25 15 X. Gutter: The downspouts have not yet been installed for various portions of the rain gutter
B
17
SseEvs LXIV. Door stops broke the day they were installed -incorrect door stops used
z< aa
Sa
Se
eee 18 LXV. Driveway and garage were done with a concrete saw -hideous.
=
5S
Be
Ba
go 19 LXVI. Tankless water heater was defective/replacement.
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ATTACHMENT BC-2
MC-025
SHORT TITLE: CASE NUMBER:
t- McCrea v. Schuegraf 19CV00236
ATTACHMENT (Number): BC-6
(This Attachment may be used with any Judicial Council form.)
(a) All of Brigitte Schuegraf's assets were transferred to Andrea Schuegraf, successor trustee.
(b) Beginning in May of 2016 and on multiple occasions thereafter, Cross- Defendants were advised of construction defects.
(c) The January 22, 2019 filing of the Complaint suspends the statute of limitations of all cross complaints to be filed
against Bruce McCrea, during the pendency of the action.
(If the item that this Attachment concems is made under penalty of perjury, all statements in this Page 12. of 20
Attachment are made under penalty of perjury.) (Add pages as required)
Form Approved for Optional Use ATTACHMENT www.courtinfo.ca.gov
Judicial Council of alifornia
1C-025 [Rev. July 1, 2009} to Judicial Council Form
C TB | | [2)Forms:
ceb.com
Essential Schuegraf
EXHIBIT 1
Metres Construction
Lic#340940 1284. Virage Lane, Chico, CA 95978
Tuesday, March 29, 2016
Bridgette Schuegeraf
30334 Cartier Dr.
Palos Verdes, CA 90275
| hereby propose to build your 2333 SQ FT home according to plans designed by Greg Pietz
Architect dated June 2015 and permitted by Butte County for construction at 11 Hawk Place Chico CA
95973 for the sum of $535,817.00 Five Hundred Thirty Five Thousand Eight Hundred Seventeen dollars.
Please sign to acknowledge your acceptance of this contract which includes an Addendum to Plans
which describes your homes features to the best of our knowledge.
1 lock forward to working with you!
-~f
Signet L Se
Bruce McCrea,
Sy
McCrea
bo.
nstraction
Date IGP -LE
Signed Dalal BA abit 2 fe Date 6 April De
ridgette sthuegeraf, Owner
Signed! cbindrag. Seis he Hae Date (7) Apni [ ZObe
Andrea Schuegeraf, Owners agent
Phone - 580-521-1885 exer:
Email - brucemecreadd@vahoo.com
ADDENDUM TO PLANS
1. Site work to include:
. Clear and Grub 35’ at sides and rear of house, house to
street during construction; Stock pile
organic onsite
1,500 gallon septic tank with 150’ leach line as per County
Spec
Water lines well to garage
Conduit for power to building, PG&E, telephone and cable
TV points of termination
Excavation, backfill and final grading around building
Galvanized culvert at entry, 15” X 26”
Rip 6”deep and compact soil under house
Rock swale with weed fabric
Winterization requirements, wattle ballast rock D.I. protect
ion per plan notes
Propane line to house
Well, casing, concrete seal,2-HP submergible, variable speed
pump, pressure tank in garage
2. Concrete-On-Site:
Driveway to asphalt roads, foundation, patios, walks, two(2)
AC pads and one (1) propane tank
Foundation perimeter walls and piers per plans
Patio #3 rebar, 24” OC
Concrete finish to be Light Broom finish
All gravel under foundation, Garage and patio slabs
3. All material & labor for wood structure:
. Lumber, engineered trusses ,hails, screws and hardware
to complete the framing per plans and
specs
4, Roofing:
. Two Layers of T.6.35 SBS paper
. 2X 2 Redwood battens, including hip Starter, ridge unit, rakes and
valley metal
° Tile is “Boral” flat red tile
e 7%" fascia gutters with downspouts
5. Windows:
¢ Cascade windows, or equal, U Value .31, shge value
.24
* All windows to be Low E, tempered glass per Code
. Alternate for Low E squared and Argon Gas
OwOv— ER
IP(TURL. BE.
6. Three coat stucco system:
All walls, patio beams, post and lids
Two (2) Layers of paper
Wire Lath and stucco ground per industry standerds
Three (3) coat system with Light Lace Knock Down finish
. Note: Open soffits per plan
7. HVAC:
* Installation of one (1) 4-ton, split system, 16 SEER conden
ser, 96.5 AFUE
. Installation of one (1) 3-ton, split system, 16 SEER conden
ser, 96.5 AFUE
° Includes delivery and placement, duct work and insulat
ion, registers and grills, controls, wiring
of control system, refrigeration lines, and conde
nsate pipes
Fuel for heaters are propane
R-8 insulated ductwork, fiberglass coll
Kitchen, bath, laundry and three (3) attic vents
Energy testing (required)
8. Plumbing:
. All fixtures by owner(Allowance $6,500) including sinks, tub,
handle sets, shower controls, toilet,
etal
All trim to be in Nickel finish
Hot water tanks are tankless, two(2) locations propane
5= Hansgrohe 18” oval sinks, model #905983, with faucet control
s
1- Kitchen sink, Farmers style, white cast iron
2- Tile showers with shower heads and controls
1- Cast iron soaking tub, white, deck mount Spout, and
controls
Install dishwasher
Plumbing for clothes washer
11/4” Water service from well to pressure tank in garage
ADA toilet at Master bathroom
9. Fire Sprinklers
. Fire sprinklers per NFPA 13D requirements
. System design, hydraulic calculations and complete submittals
with fees as required per local
Jurisdiction. To be supplied by sub-contractor
awry.
WmAL psig
2
10. Electrical per plans and NEC requirements:
. Dining light, Ceiling fans and Exterior surface mount lights
are by Owner (Allowance $3,000)
. New 200 amp service (complete with grounding and bonding}, installa
tion of sub panel (to be
located in laundry room), purchase of recess can’s and LED trim package
, 2- lamp wrap around
fixtures, under cab LED tape kit and wire and finish electrical devices
.
Keyless fixture focated in attic controlled by single pole switch (service
light)
4 2-Lamp wrap around fixtures located in garage (2 will be
controlled off single pole 0.5. and 2
will be controlled off 3 way 0.5.)
1-2 Lamp wrap around fixture located in laundry closet (controlled
by O.S.)
3-110 cfm Exhaust fans with humidity control (1-kitchen continuous
power supply, 1-hall bath
room controlled by switch, 1-master bath controtled by switch)
1-90 cfm Exhaust fan with humidity control (located in garage bath)
2-Security pre-wire boxes (located at back of house on either side of corners,
continuous power
supply)
2-Exterior man door coach lights pre-wire (1-garage man door controlled
by 3-way switch, 1-
master bedroom slider controlled by single pole switch)
3-Garage door and entry coach pre-wire controlled by single pole dimmer switch
5-Exterlor can’s controlled by single pole switch (back patio)
4-Exterior can’s controlled by single pole dimmer switch (front patio)
6-Exterior GFIC protected outles
3- Bath room vanity pre-wire (1-located in garage bath,1-located in hall
bath, 1-located In
master bath all controlled by 0.5.
4-Ceiling fan pre-wire (1-located in family room, 1-master bed, 1-bed #2, 1- bed
#3, each
controlled by single pole switch)
4- % hot receptacles (1-located in family room, 1-master bed, 1- bed #2, 1-bed #3
each
controlled by single pole switch
2- 6” Recessed can’s in garage entry hall controlled by 4 way dimmable switchin
g
1- Pre-wire box for fixture above kitchen sink controlled by single pole switch
1- Receptacle controlled by switch for garbage dispo
6- 6” RECESS can’s in Kitchen controlled by 3 way dimmable switching
1-Pre-wire dinning fixture box controlled by 3 way dimmable switching
7-6" Recess can’s main hall controlled by 4 way dimmable switching
1. Pre-wire living room fixture box controlled by single pole switch
1- Pre-wire interior entry fixture box controlled by single pole dimmable switch
1- Pre-wire fixture box(2 locations) in office/den controlled by single pole dimmable switch
3-Closet pre-wire boxes 2-masterbed room, 1-bed room #3) controlled by
single pole switch
1-6” recess can over tub in master bath controlled by single switch
ae.
3- Inter-connected smoke alarms (1-master bed, 1- bed #2, 1- bed #3) Own
1y\ Wi
3
2 Under cab LED lighting (1-laundry room cabinets, 1-kitchen
cabinets) each controlled bya
single pole switch
1-Inter-connected smoke/carbon alarm located In main
hallway
5- Cat5 telephone drops (1-master bed, 1-bed #2, 1-
bed #3, 1- office/den, 1- living room
1-50 Amp 240v A/C circuit with non-fused disconnect
2-50 AMP 240v circuits (4-double oven, 1-cook top
1-20 AMP circuit for garage receptacle
3-20 AMP circults for bath room GFIC receptacles (1-gar
age bath, 1- hall bath, 1 master bath)
1-20 AMP circuit for washing machine
1-30 AMP 240v circutt for dryer
2-20 AMP circult for kitchen
1-20 AMP circult for dish washer and garbage disposal
1-20 AMP circuit for down draft micro wave
1-20 AMP dedicated circuit for tankless water heater if needed
1-20 AMP dedicated circuit for FAU with service outlet located
in attic
5- General lighting circuits with AFCI protection
11. Insulation:
° R-19 exterior walls
© — R-38 ceiling and attic areas (blown in loose fill fiberglass insulation)
. R-11 interior walls at bathrooms and bedrooms
12. Drywall:
. Sheetrock to be 5/8” at garage firewall
. Bull nose corners
. Walls are %” drywall with smooth finish level 5
. Prep coat all walls
13. Finish Carpentry:
* Casing for all windows and doors to match DOE Mill residence {per pictures
)
© Baseboard installation in all living areas: 1X 6. $4S, MDF
14, Doors:
Exterior doors are cased with 1X4 sides and 1X6 tops
3080 % Lite insulated Metal
3080 Pair Jeldwin or equal wood clad entry doors
1X4 Trim, MDF with 1X 6 tops
3070 Six panel Masonite HC
1X 4 MFD with 1X 6 Head Trim per picture
oud DER.
vomit 2th
15, Painting:
Interior wood work, fill holes, sand, caulk, prime with two (2) coats
of semi-gloss enamel
Primer and two (2) coats of eggshell on all walls
Walls and ceilings to be painted same color
Exterior gutter, down spouts (tO match stucco}, fascia board and garage
door (same as gutter) to
receive primer and two (2) coats of paint
Front Door accent color
Cabinetry, fill holes, sand, caulk, prime and two (2) coats of semi-glo
ss enamel premium paint
16. Cabinets: European Style Cabinets:
Flat Panel doors Plastic Laminate
Cabinet hinges (Solice 180 degree opening)
White Melamine Interiors
2%" Molding
Cabinets per Kitchen, Laundry, Living Room, Office, and Bathrooms (3)
Open shelving as noted on plans
All drawers and doors shall have open handle pulls
Drawer guides are 60 Ib, full extension
Note: Upper cabinets to be added at cook top wall
All built in bookcases shall be MDF, white paint
17, Hardware:
Baldwin, Nickel Finish
Privacy locks at baths, passage all others
Keyed locks at front entry
Bathroom Accessories: Toilet paper holder, towel bars, shower door and mirrors
18, Counter Tops: $17,826.00 per Ginno’s
. Kitchen: Solid Surface Silestone
. Master Bathroom: 8’ with two (2) under mount sinks
. Jack and Jill Bathroom 6’ with two (2) under mount sinks
. Powder Bath one (1) under mount sink
19. Tile:
. Master Bath (Allowance $9,670.00
. Tub Surround in master bath
Ownege.
POiTlAL 1
20. Appliances (Allowance $10,408.00)
One (1) Dishwasher Stainless Steel Finish, Model #ZDT8
OOSSFSS (Free)
Tax on Free Dishwasher $101.25
One (1) Electric Cook Top Oven, Electric, Silver, Model #ZHU3
6RSISS
One (1) Double wall Oven, Stainless, Model #ZET9500SH
SS
One (1) 36” Downdraft Vent, Model #273603
One (1) Counter Depth French Door Refrigerator,
Stainless, Model #KRFC300ESS
21. Flooring (Allowance $28,267.00):
. Engineered Hardwood
. Vinyl Plank, utility room, % bath
EXCLUSIONS:
Bank, Loan Fees or interest
Course of construction insurance {your Homeowner
insurer can provide)
Any item or change by Owner/Builder authority, County or
City Fire, Utilities orBuilding
Department
PG&E, Pac Bell or Cable Television fees only
Any amount that exceeds the aggregate, owners Allowa
nce (of $57,845.00). Any unused portion
of owner allowance will be credited back to owner
Architectural, Architectural Landscaping, Civil, GEO Technical,
Interior Decorator, or other fee
associated with the design of the project
Window Treatments
Fencing
Landscape
ADDITIONS:
Any additions, and or changes to the approved plans, with addend
um, are happily
accommodated. The item will be identified and defi ined. | will
write up a change order complete
with the associated cost if necessary, to include a 12%
mark-up, for your signature of approval.
After which | will complete the work.
Ow BER Ss
7 OmMAL lhe 6
PROOF OF SERVICE
I, Shyla Anderson, declare as follows:
I am employed in the County of Butte, State of California; I am over the age of 18 years and
not a party to this action; my business address is 196 Cohasset Road, Suite 225, Chico California
95926-2284, in said County and State. On today's date, I served a copy of the Cross-Complaint on
the following person(s) at the following address(s), in the manner indicated below:
Stacie Lynn Power
Power Law P.C.
1058 Mangrove Ave., Suite C
Chico, CA 95926
10
ae BY UNITED STATES MAIL enclosed the documents in a sealed envelope or package
ag
<é 11 xX addressed to the persons at the addresses shown above and placed the envelope for collection
Ge
and mailing, following our ordinary business practices. I am readily familiar with this
gs
225 12
Reza
B30 business's practice for collecting and processing correspondence for mailing, it is deposited in the
Suuas 13 ordinary course of business with the United States Postal Service, in a sealed envelope with postage
ras
Ages
Zex fully prepaid. I am employed in the county where the mailing occurred. The envelope or package
eas 14 was placed in the mail at Chico, CA.
2205
<4
Se
aa 15
be
aR I certify under penalty of perjury that the foregoing is true and correct, and this declaration
ge 16 of service was executed on July iS , 2020 at Chico, California.
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18 hyla Anderson
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28 m:lorig_data\workiclient directories \schuegraf, andrea\mecrea v schuegraf, 1770\pos 320.docx
PROOF OF SERVICE
STS
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PLD-C-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Siafe Bar number, and address) FOR COURT USE ONLY Raymond L, Sandelman SBN 078020 Attorney at Law 196 Cohasset Road, Suite 225 Chico, CA 95926-2284 ‘TELEPHONE NO.: (530) 343-5090 FAX NO.(Optional): (530) 343-5091 E-MAIL ADDRESS (Optional): Raymond@sandelmanlaw.com F Superior Court of California F ATTORNEY FOR (Name): Andrea Schuegraf, Individually and as Successor Trustee County of Butte SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE STREET ADDRESS: 1775 Concord Avenue | MAILING ADDRESS: 1775 Concord Avenue 7/15/2020 L ciTy AND zip cope: Chico, CA 95928 E BRANCH NAME: North Butte County Courthouse PLAINTIFF: Bruce McCrea Kim) leper, Clerk D By Deputy ctronically ‘D DEFENDANT: Brigitte Schuegraf, [continued on Attachment 1] {Cross Complaint caption continued Attachment 1] C] does 1 To CONTRACT (2) ComPLAINT (2) AMENDED COMPLAINT (Number) : (J CROSS-COMPLAINT (C] AMENDED CROSS-COMPLAINT (Number) : Jurisdiction (check all that apply): CASE NUMBER, (C) ACTION IS A LIMITED CIVIL CASE 19CV00236 Amount demanded [] does not exceed $10,000 (L] exceeds $10,000 but does not exceed $25,000 (C) ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) (] ACTION IS RECLASSIFIED by this amended complaint or cross-complaint (J from limited to unlimited C] from unlimited to limited Plaintiff" (name or names): Andrea Schuegraf, successor trustee of the Brigitte Schuegraf Family Trust, Dated March 4, 2004 as Amended and Restated on April 7, 2016 and Amended on April 11, 2017 alleges causes ot action against defendant* (name or names) : Bruce McCrea, Does 6-10 This pleading, including attachments and exhibits, consists of the following number of pages: 20 3. a. Each plaintiff named above is a competent adult (&) except plaintiff (name): Andrea Schuegraf, successor trustee (1) () a corporation qualified to do business in California (2) (LJ an unincorporated entity (describe) : (3) GQ other (specify) : trustee b. (2) Plaintiff (name) : a. [2] has complied with the fictitious business name laws and is doing business under the fictitious name (specify) : b. (C} has complied with all licensing requirements as a licensed(specify) : c. Q) Information about additional plaintiffs who are not competent adults is shown in Attachment 3c. 4 a. Each defendant named above is a natural person (L] except defendant (name) : (CC) except defendant (name) : (1) (2) a business organization, form unknown (41) (2) a business organization, form unknown (2) (L) acorporation (2) (LQ acorporation (3) (LJ an unincorporated entity (describe) : (3) CCQ an unincorporated entity (describe) : (4) CC) a public entity (describe): (4) () a public entity (describe): (5) (C) other (specify) : (5) (CQ other (specify) : “If this form is used as a cross-complaint, plaintiff means cross-complainant and defendant means cross-defendant. Page 1 of2 Form Approved for Optional Use Code of Civil Procedure, § 425.12 Judicial Councit of alifornia CB | Essential PLD-C-001 (Rev. January 1, 7) ceb.com Forms" COMPLAINT - Contract Schuegraf PLD-C-001 SHORT TITLE: CASE NUMBER McCrea v. Schuegraf 19CV00236 (Continued) b. The true names of defendants sued as Does are unknown to plaintiff. (1) (2) Doe defendants (specify Doe numbers): were the agents or employees of the named defendants and acted within the scope of that agency or employment. (2) [) Doe defendants (specify Doe numbers): 6-1) _____+=+=_=_ are persons whose capacities are unknown to plaintiff. c. (2) Information about additional defendants who are not natural persons is contained in Attachment 4c. d. (2) Defendants who are joined under Code of Civil Procedure section 382 are(names): CC) Plaintiff is required to comply with a claims statute,and a (C) has complied with applicable claims statutes, or b. (2) is excused from complying because (specify) : (C) This action is subject to CQ Civil Code section 1812.10 [2] Civil Code section 2984.4. This court is the proper court because {&) a defendant entered into the contract here. (&) a defendant lived here when the contract was entered into. (J a defendant lives here now. (K] the contract was to be performed here. () a defendant is a corporation or unincorporated association and its principal place of business is here. (CC) real property that is the subject of this action is located here. (CY other (specify) : The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): (]} Breach of Contract (CJ Common Counts (} Other (specify) : (&) Other allegations: Andrea Schuegraf, successor trustee of the Brigitte Schuegraf Family Trust, Dated March 4, 2004, as Amended and Restated on April 7, 2016 and Amended on April 11, 2017 is hereafter referred to as "Andrea Schuegraf, successor trustee". 10. Plaintiff prays fer judgment for costs of suit; for such relief as is fair, just, and equitable; and for a [) damages of: $ 120,000 or according to proof b [&} interest on the damages a) [&) according to proof (2) (J atthe rate of (specify): percent per year from (date) : c. CC) attorney's fees (1) CA of $ (2) CC) according to proof. d. CC) other (specify) : 41. KJ The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers) : BC-1, BC-2, BC-3, BC-4, BC-6. Date: June @ +2020 Raymond _L. Sandelman d xt. Se (TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY) (If you wish to verify this pleading, affix a verification.) PLD-C-001 (Rev. January 1, 2007] Page 2 of 2 COMPLAINT - Contract LB ceb.com Essential i2)Forms” Schuegraf MC-025 SHORT TITLE: ‘CASE NUMBER: t- McCrea vy. Schuegraf 19CV00236 ATTACHMENT (Number): 1____ (This Attachment may be used with any Judicial Council form.) Continuation of Caption at Page I Defendants [continued from Page 1]: Andrea Schuegraf individually and as trustee of the Bridgitte Schuegraff Family Trust March 4, 2004. Cross Complainant: Andrea Schuegraf, successor trustee of the Brigitte Schuegraf Family Trust, Dated March 4, 2004, as Amended and Restated on April 7, 2016 And Amended on April 11, 2017, v. Bruce McCrea, individually and doing business as McCrea Construction, Does 6-10. (If the item that this Attachment concems is made under penalty of perjury, all statements in this Page 3___ of 20. Attachment are made under penalty of penury.) (Add pages as required) Form Approved for Optional Use ATTACHMENT wwvw.courtinfo.ca.gov| Judicial Council of alifornia 'MC-025 [Rev. July 1, 2009} to Judicial Council Form CB [)Forms: ceb.com Essential Schuegraf PLD-C-004(1) SHORT TITLE CASE NUMBER, McCrea v. Schuegraf 19CV00236 FIRST CAUSE OF ACTION-Breach of Contract (number) ATTACHMENT TO [2] Complaint (KJ Cross-Complaint (Use a separate cause of action form for each cause of action.) BC-1. Plaintiff (name): Andrea Schuegraf, successor trustee alleges that on or about (date): a [KJ written CQ oral (2) other (specify): agreement was made between (name parties to agreement): Brigitte Schuegraf, and Bruce McCrea, indvidually and doing business as McCrea Construction CC) A copy of the agreement is attached as Exhibit A, or [(&] The essential terms of the agreement EX] are stated in Attachment BC-1 (C]} are as follows (specify): BC-2. On or about (dates): October 30, 2016 defendant breached the agreement by [J the acts specified in Attachment BC-2 [C] the following acts (specify): BC-3. Plaintiff has performed all obligations to defendant except those obligations plaintiff was prevented or excused from performing. BC-4. Plaintiff suffered damages legally (proximately) caused by defendant's breach of the agreement (2) as stated in Attachment BC-4 [XK] as follows (specify): $120,000 or according to proof. BC-5. (C) Plaintiff is entitled to attorney fees by an agreement or a statute CO) ofs (CC) according to proof. BC-6. KJ Other: See Attachment BC-6 Page 4of 20 Page 1 of1 Form Approved for Optional Use Code of Civil Procedure, § 425.12 judicial Council of California CAUSE OF ACTION-Breach of Contract ‘wwvw.courtinio.ca.gov PLD-C-001(1) [Rev. January 1, 2007) CB Essential ceb.com * =|Forms" Schuegraf MC-025 SHORT TITLE: CASE NUMBER’ [- McCrea v. Schuegraf 19CV00236 ATTACHMENT (Number): BC-1 _ (This Attachment may be used with any Judicial Council form.) (a) A copy of the written construction contract is attached hereto marked Exhibit 1. (b) The Exhibit 1 construction contract includes an implied warranty that the dwelling was constructed in a good, professional, and reasonably workmanlike manner in accordance with the plans and specifications, and other contractual documents. (If the item that this Attachment concems is made under penalty of perjury, all statements in this Page 5__ of 20. Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use ATTACHMENT wivw.courtinfo.ca.gov Judicial Council of alifornia 1C-025 [Rev. July1, 2009] to Judicial Council Form LB Essential ceb,com [2)Forms: Schuegraf Attachment BC-2 Breaches Of Contract The dwelling constructed by Defendants at 11 Hawk Place, Chico, CA 95973 was not constructed in a good, professional, and reasonably workmanlike manner in accordance with the plans and specifications, and other contractual documents, and had the following construction defects: I. Roof: There is evidence of water intrusion into the attic area around the gas fireplace vent roof penetration. Surfaces in attic area are wet. There is no visible stain noted on interior portion of gypsum board ceiling below this location at time of inspection. Proper resealing of this penetration 10 should correct this condition. 1 II. GFCI: The general-purpose receptacles in the laundry room were required to be GFCI 12 (ground fault circuit interrupter) protected at the time of construction. 13 Ill. Attic fan: The electrical boxes serving both attic fans have not yet been secured to the Bs ae 17 Zo3Zag IV. Exhaust fan: The exhaust fan in the laundry room is currently non-functional (cause sa7S 62 ee n= 18 unknown-possible loose wire connection). 5S Ba Ba go 19 V. Light: The light portion of the fan/light fixture in the middle bedroom is currently 20 nonfunctional (cause unknown -fan portion of fixture is energized). The light cover is missing or has 21 not yet been installed on the fan/light fixture mentioned above (possibly removed for repair). The 22 vanity light in the half-bath is loose and should be secured to its electrical box to prevent possible 23 damage to the wire connections (light was functional at time of inspection). One of the four recessed 24 lights in the office/den and one of the five recessed lights in the master bath are currently non- 25 functional (cause unknown-possible faulty bulbs). 26 VI. Dead end wire: There are "dead end" electrical wires extending from two exterior ceiling 27 mount electrical boxes in the patio area on the north side of the house (installed for future use). The 28 ends of these wires are required to be terminated properly inside their electrical boxes with cover ATTACHMENT BC-2 1 plates attached unless electrical devices are to be installed. VII. Service requirements: The working platform installed for servicing of the heat/AC unit in the west attic area is approximately 24 inches in depth. A working platform with a minimum depth of 30 inches was required to be installed along the firebox side of this unit to meet service requirements for the time of construction. VIII. Fireplace: The fuel gas disconnect/shut-off valve and burner controls serving the factory-built gas fired fireplace are no longer fully accessible due to a decorative marble type trim installed around the fireplace/casing (marble obstructs the removal/opening of the access covers/casing). The gas valve and burner controls are required to be accessible for 10 servicing/operation. ll IX. Door: The exterior side garage door requires adjustment/maintenance for proper 12 operation (the door "binds" on threshold when opened/closed). The latch/catch mechanisms have not 13 yet been installed on the closet doors in the middle bedroom and both sets of closet doors in the as ag <& 14 southeast bedroom (required to secure doors in closed position). se B25 15 X. Gutter: The downspouts have not yet been installed for various portions of the rain gutter B 17 SseEvs LXIV. Door stops broke the day they were installed -incorrect door stops used z< aa Sa Se eee 18 LXV. Driveway and garage were done with a concrete saw -hideous. = 5S Be Ba go 19 LXVI. Tankless water heater was defective/replacement. 20 21 22 23 24 25 26 27 m\orig_data\work\client directories\schuegraf, andrea\mccrea v schuegraf, 1770\attachment bc2 608.docx 28 u ATTACHMENT BC-2 MC-025 SHORT TITLE: CASE NUMBER: t- McCrea v. Schuegraf 19CV00236 ATTACHMENT (Number): BC-6 (This Attachment may be used with any Judicial Council form.) (a) All of Brigitte Schuegraf's assets were transferred to Andrea Schuegraf, successor trustee. (b) Beginning in May of 2016 and on multiple occasions thereafter, Cross- Defendants were advised of construction defects. (c) The January 22, 2019 filing of the Complaint suspends the statute of limitations of all cross complaints to be filed against Bruce McCrea, during the pendency of the action. (If the item that this Attachment concems is made under penalty of perjury, all statements in this Page 12. of 20 Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use ATTACHMENT www.courtinfo.ca.gov Judicial Council of alifornia 1C-025 [Rev. July 1, 2009} to Judicial Council Form C TB | | [2)Forms: ceb.com Essential Schuegraf EXHIBIT 1 Metres Construction Lic#340940 1284. Virage Lane, Chico, CA 95978 Tuesday, March 29, 2016 Bridgette Schuegeraf 30334 Cartier Dr. Palos Verdes, CA 90275 | hereby propose to build your 2333 SQ FT home according to plans designed by Greg Pietz Architect dated June 2015 and permitted by Butte County for construction at 11 Hawk Place Chico CA 95973 for the sum of $535,817.00 Five Hundred Thirty Five Thousand Eight Hundred Seventeen dollars. Please sign to acknowledge your acceptance of this contract which includes an Addendum to Plans which describes your homes features to the best of our knowledge. 1 lock forward to working with you! -~f Signet L Se Bruce McCrea, Sy McCrea bo. nstraction Date IGP -LE Signed Dalal BA abit 2 fe Date 6 April De ridgette sthuegeraf, Owner Signed! cbindrag. Seis he Hae Date (7) Apni [ ZObe Andrea Schuegeraf, Owners agent Phone - 580-521-1885 exer: Email - brucemecreadd@vahoo.com ADDENDUM TO PLANS 1. Site work to include: . Clear and Grub 35’ at sides and rear of house, house to street during construction; Stock pile organic onsite 1,500 gallon septic tank with 150’ leach line as per County Spec Water lines well to garage Conduit for power to building, PG&E, telephone and cable TV points of termination Excavation, backfill and final grading around building Galvanized culvert at entry, 15” X 26” Rip 6”deep and compact soil under house Rock swale with weed fabric Winterization requirements, wattle ballast rock D.I. protect ion per plan notes Propane line to house Well, casing, concrete seal,2-HP submergible, variable speed pump, pressure tank in garage 2. Concrete-On-Site: Driveway to asphalt roads, foundation, patios, walks, two(2) AC pads and one (1) propane tank Foundation perimeter walls and piers per plans Patio #3 rebar, 24” OC Concrete finish to be Light Broom finish All gravel under foundation, Garage and patio slabs 3. All material & labor for wood structure: . Lumber, engineered trusses ,hails, screws and hardware to complete the framing per plans and specs 4, Roofing: . Two Layers of T.6.35 SBS paper . 2X 2 Redwood battens, including hip Starter, ridge unit, rakes and valley metal ° Tile is “Boral” flat red tile e 7%" fascia gutters with downspouts 5. Windows: ¢ Cascade windows, or equal, U Value .31, shge value .24 * All windows to be Low E, tempered glass per Code . Alternate for Low E squared and Argon Gas OwOv— ER IP(TURL. BE. 6. Three coat stucco system: All walls, patio beams, post and lids Two (2) Layers of paper Wire Lath and stucco ground per industry standerds Three (3) coat system with Light Lace Knock Down finish . Note: Open soffits per plan 7. HVAC: * Installation of one (1) 4-ton, split system, 16 SEER conden ser, 96.5 AFUE . Installation of one (1) 3-ton, split system, 16 SEER conden ser, 96.5 AFUE ° Includes delivery and placement, duct work and insulat ion, registers and grills, controls, wiring of control system, refrigeration lines, and conde nsate pipes Fuel for heaters are propane R-8 insulated ductwork, fiberglass coll Kitchen, bath, laundry and three (3) attic vents Energy testing (required) 8. Plumbing: . All fixtures by owner(Allowance $6,500) including sinks, tub, handle sets, shower controls, toilet, etal All trim to be in Nickel finish Hot water tanks are tankless, two(2) locations propane 5= Hansgrohe 18” oval sinks, model #905983, with faucet control s 1- Kitchen sink, Farmers style, white cast iron 2- Tile showers with shower heads and controls 1- Cast iron soaking tub, white, deck mount Spout, and controls Install dishwasher Plumbing for clothes washer 11/4” Water service from well to pressure tank in garage ADA toilet at Master bathroom 9. Fire Sprinklers . Fire sprinklers per NFPA 13D requirements . System design, hydraulic calculations and complete submittals with fees as required per local Jurisdiction. To be supplied by sub-contractor awry. WmAL psig 2 10. Electrical per plans and NEC requirements: . Dining light, Ceiling fans and Exterior surface mount lights are by Owner (Allowance $3,000) . New 200 amp service (complete with grounding and bonding}, installa tion of sub panel (to be located in laundry room), purchase of recess can’s and LED trim package , 2- lamp wrap around fixtures, under cab LED tape kit and wire and finish electrical devices . Keyless fixture focated in attic controlled by single pole switch (service light) 4 2-Lamp wrap around fixtures located in garage (2 will be controlled off single pole 0.5. and 2 will be controlled off 3 way 0.5.) 1-2 Lamp wrap around fixture located in laundry closet (controlled by O.S.) 3-110 cfm Exhaust fans with humidity control (1-kitchen continuous power supply, 1-hall bath room controlled by switch, 1-master bath controtled by switch) 1-90 cfm Exhaust fan with humidity control (located in garage bath) 2-Security pre-wire boxes (located at back of house on either side of corners, continuous power supply) 2-Exterior man door coach lights pre-wire (1-garage man door controlled by 3-way switch, 1- master bedroom slider controlled by single pole switch) 3-Garage door and entry coach pre-wire controlled by single pole dimmer switch 5-Exterlor can’s controlled by single pole switch (back patio) 4-Exterior can’s controlled by single pole dimmer switch (front patio) 6-Exterior GFIC protected outles 3- Bath room vanity pre-wire (1-located in garage bath,1-located in hall bath, 1-located In master bath all controlled by 0.5. 4-Ceiling fan pre-wire (1-located in family room, 1-master bed, 1-bed #2, 1- bed #3, each controlled by single pole switch) 4- % hot receptacles (1-located in family room, 1-master bed, 1- bed #2, 1-bed #3 each controlled by single pole switch 2- 6” Recessed can’s in garage entry hall controlled by 4 way dimmable switchin g 1- Pre-wire box for fixture above kitchen sink controlled by single pole switch 1- Receptacle controlled by switch for garbage dispo 6- 6” RECESS can’s in Kitchen controlled by 3 way dimmable switching 1-Pre-wire dinning fixture box controlled by 3 way dimmable switching 7-6" Recess can’s main hall controlled by 4 way dimmable switching 1. Pre-wire living room fixture box controlled by single pole switch 1- Pre-wire interior entry fixture box controlled by single pole dimmable switch 1- Pre-wire fixture box(2 locations) in office/den controlled by single pole dimmable switch 3-Closet pre-wire boxes 2-masterbed room, 1-bed room #3) controlled by single pole switch 1-6” recess can over tub in master bath controlled by single switch ae. 3- Inter-connected smoke alarms (1-master bed, 1- bed #2, 1- bed #3) Own 1y\ Wi 3 2 Under cab LED lighting (1-laundry room cabinets, 1-kitchen cabinets) each controlled bya single pole switch 1-Inter-connected smoke/carbon alarm located In main hallway 5- Cat5 telephone drops (1-master bed, 1-bed #2, 1- bed #3, 1- office/den, 1- living room 1-50 Amp 240v A/C circuit with non-fused disconnect 2-50 AMP 240v circuits (4-double oven, 1-cook top 1-20 AMP circuit for garage receptacle 3-20 AMP circults for bath room GFIC receptacles (1-gar age bath, 1- hall bath, 1 master bath) 1-20 AMP circuit for washing machine 1-30 AMP 240v circutt for dryer 2-20 AMP circult for kitchen 1-20 AMP circult for dish washer and garbage disposal 1-20 AMP circuit for down draft micro wave 1-20 AMP dedicated circuit for tankless water heater if needed 1-20 AMP dedicated circuit for FAU with service outlet located in attic 5- General lighting circuits with AFCI protection 11. Insulation: ° R-19 exterior walls © — R-38 ceiling and attic areas (blown in loose fill fiberglass insulation) . R-11 interior walls at bathrooms and bedrooms 12. Drywall: . Sheetrock to be 5/8” at garage firewall . Bull nose corners . Walls are %” drywall with smooth finish level 5 . Prep coat all walls 13. Finish Carpentry: * Casing for all windows and doors to match DOE Mill residence {per pictures ) © Baseboard installation in all living areas: 1X 6. $4S, MDF 14, Doors: Exterior doors are cased with 1X4 sides and 1X6 tops 3080 % Lite insulated Metal 3080 Pair Jeldwin or equal wood clad entry doors 1X4 Trim, MDF with 1X 6 tops 3070 Six panel Masonite HC 1X 4 MFD with 1X 6 Head Trim per picture oud DER. vomit 2th 15, Painting: Interior wood work, fill holes, sand, caulk, prime with two (2) coats of semi-gloss enamel Primer and two (2) coats of eggshell on all walls Walls and ceilings to be painted same color Exterior gutter, down spouts (tO match stucco}, fascia board and garage door (same as gutter) to receive primer and two (2) coats of paint Front Door accent color Cabinetry, fill holes, sand, caulk, prime and two (2) coats of semi-glo ss enamel premium paint 16. Cabinets: European Style Cabinets: Flat Panel doors Plastic Laminate Cabinet hinges (Solice 180 degree opening) White Melamine Interiors 2%" Molding Cabinets per Kitchen, Laundry, Living Room, Office, and Bathrooms (3) Open shelving as noted on plans All drawers and doors shall have open handle pulls Drawer guides are 60 Ib, full extension Note: Upper cabinets to be added at cook top wall All built in bookcases shall be MDF, white paint 17, Hardware: Baldwin, Nickel Finish Privacy locks at baths, passage all others Keyed locks at front entry Bathroom Accessories: Toilet paper holder, towel bars, shower door and mirrors 18, Counter Tops: $17,826.00 per Ginno’s . Kitchen: Solid Surface Silestone . Master Bathroom: 8’ with two (2) under mount sinks . Jack and Jill Bathroom 6’ with two (2) under mount sinks . Powder Bath one (1) under mount sink 19. Tile: . Master Bath (Allowance $9,670.00 . Tub Surround in master bath Ownege. POiTlAL 1 20. Appliances (Allowance $10,408.00) One (1) Dishwasher Stainless Steel Finish, Model #ZDT8 OOSSFSS (Free) Tax on Free Dishwasher $101.25 One (1) Electric Cook Top Oven, Electric, Silver, Model #ZHU3 6RSISS One (1) Double wall Oven, Stainless, Model #ZET9500SH SS One (1) 36” Downdraft Vent, Model #273603 One (1) Counter Depth French Door Refrigerator, Stainless, Model #KRFC300ESS 21. Flooring (Allowance $28,267.00): . Engineered Hardwood . Vinyl Plank, utility room, % bath EXCLUSIONS: Bank, Loan Fees or interest Course of construction insurance {your Homeowner insurer can provide) Any item or change by Owner/Builder authority, County or City Fire, Utilities orBuilding Department PG&E, Pac Bell or Cable Television fees only Any amount that exceeds the aggregate, owners Allowa nce (of $57,845.00). Any unused portion of owner allowance will be credited back to owner Architectural, Architectural Landscaping, Civil, GEO Technical, Interior Decorator, or other fee associated with the design of the project Window Treatments Fencing Landscape ADDITIONS: Any additions, and or changes to the approved plans, with addend um, are happily accommodated. The item will be identified and defi ined. | will write up a change order complete with the associated cost if necessary, to include a 12% mark-up, for your signature of approval. After which | will complete the work. Ow BER Ss 7 OmMAL lhe 6 PROOF OF SERVICE I, Shyla Anderson, declare as follows: I am employed in the County of Butte, State of California; I am over the age of 18 years and not a party to this action; my business address is 196 Cohasset Road, Suite 225, Chico California 95926-2284, in said County and State. On today's date, I served a copy of the Cross-Complaint on the following person(s) at the following address(s), in the manner indicated below: Stacie Lynn Power Power Law P.C. 1058 Mangrove Ave., Suite C Chico, CA 95926 10 ae BY UNITED STATES MAIL enclosed the documents in a sealed envelope or package ag <é 11 xX addressed to the persons at the addresses shown above and placed the envelope for collection Ge and mailing, following our ordinary business practices. I am readily familiar with this gs 225 12 Reza B30 business's practice for collecting and processing correspondence for mailing, it is deposited in the Suuas 13 ordinary course of business with the United States Postal Service, in a sealed envelope with postage ras Ages Zex fully prepaid. I am employed in the county where the mailing occurred. The envelope or package eas 14 was placed in the mail at Chico, CA. 2205 <4 Se aa 15 be aR I certify under penalty of perjury that the foregoing is true and correct, and this declaration ge 16 of service was executed on July iS , 2020 at Chico, California. 17 18 hyla Anderson 19 20 21 22 23 24 25 26 27 28 m:lorig_data\workiclient directories \schuegraf, andrea\mecrea v schuegraf, 1770\pos 320.docx PROOF OF SERVICE STS Sr KE fis