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Kevin Singer
Superior Court Receiver of California
Receivership Specialists Superior Co ‘ott
Placer
980 9th Street, 16th Floor
Sacramento, California 95814 SEP 28 2020
Telephone: (916) 449-9655
Facsimile: (916) 446-7104 Jake Chatte rs ate
3 ‘ : . so & Cl
E-mail: Kevin@ReceivershipSpecialists.com By: i ove acum Deputy
Receivership Property:
1237 Wagon Wheel, Truckee, California 96161
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER, BILL SANTUCCI JUSTICE CENTER
CHARLES B. GOLSON, an Individual and ) Case No.: SCV0042787
as Trustee of the Charles B. Golson ) Z
Revocable Trust, ) SUPERIOR COURT RECEIVER’S
1? ) REPORT FOR AUGUST 2020 AND
Plaintiff, ) NOTICE OF INTENT TO PAY
) RECEIVER’S FEES AND EXPENSES
v. ) .
14 ) Commissioner: Hon. Glenn M. Holley
BETHANY BARRY CROSS, an Individual, )
15 and DOES | through 20, inclusive, } Dept.: 31
)
16 Defendants. ) Court: Placer County Superior Court
) Hon. Howard G. Gibson Courthouse
Le ) Bill Santucci Justice Center
) 10820 Justice Center Drive
18 ) Roseville, California 95678
)
19
20
21
22
23
24
25
27
28
Page |
RECEIVER'S REPORT 1237
RECEIVERSHIP SPECIALISTS
STATE AND U.S. FEDERAL COURT RECEIVERS/REFEREES/TRUSTEES
Corporate
Headquarters
LosAngeles
11500W. OlympicBlyd
Suite
$30
LosAngeles,CA 90064
SUPERIOR COURT RECEIVER’S REPORT FOR AUGUST 2020 AND Tel:(310}552-9064
NOTICE OF INTENT TO PAY RECEIVER’S FEES AND EXPENSES | See
SanFrancisco
: . ; 795Foisom Street
‘
Presented By: Kevin Singer, Superior Court Receiver istFloor
SanFrancisco,
CA 94107
Tel:(415)848-2984
Fax:(415)848-2301
SanDiego
4660La Jolla
Village
Drive
Suite100
SanDiego,CA 92122
Tel.(858)546-4813
CHARLES B. GOLSON Fax:(B58)646-3097
an Individual and as Trustee of the Charles B. Golson Revocable Trust
Plaintiff Ventura/Santa
Barbara
1500Palma Drive
2ndFloar
Vv. Ventura,CA93003
Tel. (805)267-1283
BETHANY BARRY CROSS os a
an Individual, and DOES 1 through 20, inclusive a
Defendants 9809thStreet
[6thFloor
CA
Sacramento, 95814
Fel:(916)449-9655
Fax:(916)446-7104
Las Vegas
725)W. LakeMead Blvd.
Suite
300
Placer County Superior
i
Court Case No. SCV0042787 Tal
Las
(HD}
Vegas,
fe-an
NV 89128
Fax:(702)562-4001
Commissioner: Hon. Glenn M. Holley
Reno
200§. Virginia
Street
Suite800
Reno,NV 89501
Tel:(775)398-3103
Fax:(775)686-240
Receivership Property:
‘ 3 Phoenix
1237 Wagon Wheel, Truckee, California 96161 > NCentralAvenue
Suite1800
Phoenix,
AZ 85004
Page 2 Tel;(602)343-1889
Fax:(602)343-180
RECEIVER'S REPORT 1237
September 25, 2020
Dear Vested Parties:
After having issued a Tentative Ruling on September 26, 2019, to which
neither plaintiff Charles B. Golson, an Individual and as Trustee of the Charles B.
Golson Revocable Trust (‘‘Plaintiff’) nor defendant Bethany Barry Cross
(“Defendant”) requested a hearing, on October 22, 2019, the Court, the Honorable
Glenn M. Holley presiding, entered an Order after Hearing on Motion for Order
Appointing Receiver and Enjoining Defendant (the “Appointing Order”)
appointing me, Kevin Singer, as receiver (“Receiver”) with the authority to take
possession of, manage, lease, collect the rents from, bring into good and
marketable condition, and ultimately market and sell the four-bedroom, single-
family residential property (used as a vacation rental property) commonly known
as 1237 Wagon Wheel, Truckee, California 96161, located in an unincorporated
area of the County of Placer, and legally defined as:
LOT 50 AS SHOWN ON THAT CERTAIN SUBDIVISION MAP
ENTITLED “TRACT NO, 224, NORTHSTAR UNIT NO. 1 C”
FILED IN THE OFFICE OF THE COUNTY RECORDER OF
PLACER COUNTY, CALIFORNIA ON FEBRUARY 23, 1972,
IN BOOK “J” OF MAPS, PAGE 46.
APN: 110-190-004-000
(the “Property”). Plaintiff and Defendant are referred to herein individually as a
“Party” and collectively as the “Parties,”
According to the Tentative Ruling, Plaintiff and Defendant each hold a
fifty-percent interest in the Property pursuant to a grant deed. At the time of my
appointment as Receiver in this matter, the Property was unoccupied.
The following summarizes what has transpired since |assumed my role as
Receiver in this matter through the end of August 2020:
September 2019 Activity:
> 9/30/2019 I posted my bond.
October 2019 Activity:
> 10/1/2019 In preparation for the eventual sale of the Property and the
issuance of a title insurance policy, I researched and
obtained a Combined Property Report (the “Combined
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RECEIVER’S REPORT 1237
Report”) from First American Title Company (‘First
American”). The Combined Report provided a property
profile, transaction history, comparable sales, and a tax
map.
e 10/1/2019 ] investigated the tax status of the Property. According to
Placer County's Treasurer-Tax Collector's website (the
“Tax Collector’s Website”), as of this date, 2019-2020
property taxes had not yet been paid. The first installment
in the amount of $5,034.57 will be delinquent if not paid by
December 10, 2019, and the second installment in the same
amount will be delinquent if not paid by April 10, 2020.
> 10/1/2019 Utilizing a link available at the Tax Collector's Website,
we downloaded a copy of the 2019—2020 property tax bill
for the Property.
> 10/4/2019 I prepared, filed, and served my Oath of Receiver.
> 10/29/2019 Pursuant to the directions of the Appointing Order, we
researched potential property management companies to
manage the Property under my supervision. We identified
Mountain Lion Home Management & Concierge (“MLH”)
as being the best property management company for the
Property as ithas relationships with other local businesses
that can assist with repairs to the Property as well as
rentals.
» 10/30/2019 My Senior Project Manager for this matter, CJ Gross
(“Gross”), conducted our initial visit to and inspection of
the Property. Plaintiff met Gross at the Property and
provided him access. Gross observed that the fully-
furnished Property had been well-maintained, but was in
need of cleaning. While there, Gross met with Charles
Slusher (“Slusher”), CEO of MLH, went through Property,
and noted several repairs that need to be made. Slusher
will prepare a property management agreement for our
review and execution.
> 10/30/2019 We contracted with Alpine Lock and Key to rekey the front
door to the Property and disable an electronic access panel
on the lock. We also contacted Liberty Utilities to restore
power to the Property.
> 10/31/2019 Gross returned to the Property. While there he met with a
workman from Liberty Utilities who restored the power.
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RECEIVER'S REPORT 1237
Gross again met with Slusher and they conducted a more
detailed walk-through of the Property, photographing itas
they went. In accord with the Appointing Order, the
photographs will be utilized to prepare an inventory of
property. Gross and Slusher identified various leaks at the
Property as well drywall repairs. They further noted that
the top of a pine tree had broken-off and that the twelve to
fifteen-foot spear-shaped portion of dried out wood was
hanging from the tree and pointing directly at the entrance
to the Property. MLH agreed to engage a landscaper to
remove the dangerous portion of the pine tree.
» 10/31/2019 Gross met with Rachel Lyons (“Lyons”) of Granite Peak
Management (“GPM”) at the Property. Because MLH does
not have a broker’s license, it is unable to lease out the
Property. Lyons and Tahoe Vacation Rentals (owned by
GPM) will handle renting out the four bedrooms at the
Property. Because the Property is a vacation rental
property, we believed it most-cost effective and profitable
to individually rent out each of the rooms on a six-month
basis to persons working in the resort community.
Northstar Lodge by Welk Resorts (“Northstar Lodge”) is
the main resort in the area and Lyons has connections with
Northstar Lodge that should prove helpful in leasing the
Property. The Property will be leased through about April
or May 2020, depending upon when the ski season ends,
after which, we will begin to market and sellthe Property.
> 10/31/2019 Gross met with realtor Doug Flynn (“Flynn”) of Tahoe
Mountain Realty (“TMR”), a top-producing agent in the
Tahoe-Truckee region, who we anticipate engaging to sell
the Property.
> 10/31/2019 We communicated Defendant who stated she was putting
together various requested documents to provide to us in
early November 2019.
> 10/31/2019 We began investigating whether there isadequate insurance
in place for the Property. Presuming there is sufficient
insurance on the Property, we will request I be named as an
additional insured to the policy. If there is insufficient
insurance, we will have the Property added to my master
insurance policy.
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fff
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RECEIVER’S REPORT 1237
November 2019 Activity:
> 11/1/2019 We reviewed and revised a draft property management
agreement prepared and sent to us by MLH. We prepared
an addendum thereto and returned it to MLH for its
execution.
11/6/2019 MLH forwarded us a bid from a licensed plumbing
contractor to address the plumbing issues atthe Property.
11/6/2019 We executed the MLH property management agreement
and addendum.
11/8/2019 We reviewed and revised a draft agreement prepared and
sent to us by GPM. We prepared an addendum thereto and
returned it to GPM for itsexecution.
11/14/2019 We spoke with Slusher regarding the plumbing repairs and
estimates and approved the repairs for the leaks under the
kitchen sink, the bathroom sink and the closet piping.
11/14/2019 We spoke with Stars Snow Removal and requested a quote
for snow removal service during the snow period.
11/14/2019 Gross spoke with Defendant who stated that she would
provide us access to Rent Tec’s online portal so that we
may view the management files for the Property.
11/18/2019 Gross spoke with Marysia Olkegak, Esq. (“Olkegak”),
attorney for Plaintiff. She advised us that she would be
communicating with us directly and not through Plaintiff.
We provided Olkegak an update with respect to the repairs
and cleaning and informed her that the Property would be
rent-ready intime for the ski season.
11/18/2019 Olkegak provided me bank statements from Defendant.
They were all heavily redacted; we are requesting
unredacted copies.
11/19/2019 Slusher informed us that the plumbing repairs had been
completed and that a drywaller would be coming to patch
the walls. Slusher also informed us that the master
bathroom sinks and four straps needed to be replaced. We
approved the repairs.
AiG
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RECEIVER’S REPORT 1237
> 11/18/2019 During an inspection of the Property, it was discovered that
the railings on the outside deck were loose and needed
repairs. The deck is approximately nine to sixteen feet off
the ground at various points and the railing on the deck has
significant play when pressed against. Working with MLH,
we obtained an estimate to repair the balcony railings from
Dog Valley Builders (‘Dog Valley”). We authorized Dog
Valley to conduct the repairs. Once the weather
cooperates, Dog Valley will commence the repairing the
railings. In the interim, we directed Lyons to have each of
the tenants sign an addendum to their leases wherein they
agree not to use the deck untilthe railing is repaired.
> 11/21/2019 i was provided three copies of a Notice of Delinquent
Assessment that was recorded by Northstar Property
Owners’ Association in the Placer County Recorder’s
office against the Property on November 4, 2019, and sent
to: (i)Plaintiff; (ii)Defendant; and (iii)Eric Bernard
Golson, Trustee.
> 11/25/2019 The twelve to fifteen-foot spear-shaped portion of dried out
wood that was hanging from the tree and pointing directly
at the entrance to the Property was removed.
> 11/26/2019 We executed a snow-removal agreement with Stars Snow
Services.
> 11/30/2019 Lyons forwarded us copies of three leases for the Property
for our review and execution, one each for: (i)Melanie
Garrison (“Garrison”); (it)Benjamin Rice (“Rice”); and
(ili)Jon Holmes (“Holmes”). First month’s rent and
$1,000 rental deposits were included with each of the
leases. The master bedroom will be rented to Garrison, a
ski instructor, for $1,000 per month. The three remaining
bedrooms will be rented for $750 per month. Garrison,
Rice, and Holmes are anticipated to take occupancy of the
Property on December 1, 2019. Lyons is working to secure
a fourth and final tenant for the Property.
> 11/2019 We were advised that Plaintiff maintains insurance on the
Property and will have me named as an additional insured
to the policy. We have requested a copy of the policy and
anticipate receiving itin December 2019.
DAE
ffl
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RECEIVER'S REPORT 1237
December 2019 Activity:
> 12/1/2019 We received a copy of the insurance on the Property, which
showed that | was named as an additional insured on the
policy.
> 12/1/2019 Two of the three tenants moved into the Property as
scheduled. The third tenant moved into the Property the
following week.
> 12/9/2019 During the month of December 2019, we had several
companies provide repair and maintenance services at the
Property. We also brought in a pest control company to
address an issue with spiders.
> 12/12/2019 We prepared, filed, and served our Notice of Inventory in
the action and included photographs taken by Gross during
his most recent inspection of the Property. The Notice of
Inventory depicted the personal property at the Property as
well as specific areas that needed repair.
> 12/2019 We collected rents from Lyons for each of the three
tenants. Lyons continued to look for a fourth tenant to
lease the remaining bedroom at the Property.
January 2020 Activity:
> 1/6/2020 We received MLH’s invoice in the amount of $300 for its
monthly property inspection.
> 1/15/2020 Lyons succeeded in finding a fourth tenant, Emma Steuer,
to lease the remaining bedroom at the Property, for a rent of
$750 per month through April 1, 2020, as reflected in the
Residential Lease or Month-to-Month Rental Agreement
(the “Steuer Lease”). Steuer moved into the Property.
> 1/29/2020 The railing repair work on the deck was completed.
Galvanized stee! brackets were used to strengthen the posts
and the post bolts were tightened. The railing has
significantly less play after the repair than itdid before.
February 2626 Activity;
ra 2/17/2020 We received MLH’s invoice in the amount of $300 for its
monthly property inspection. The MLH invoice charged an
additional $2,575, comprised of hand shoveling of snow
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RECEIVER’S REPORT 1237
and for repair of the loose deck railing, including costs of
supplies, labor, and GC oversight.
Y 2/18/2020 All four bedrooms at the Property remain occupied and the
tenants all timely paid their February 2020 rents.
March 2020 Activity:
> 3/17/2020 We received MLH’s invoice in the amount of $752.56 for
itsmonthly property inspection and maintenance charges.
> 3/23/2020 Due to the Coronavirus pandemic that resulted in the
closure of ski resorts and other public locations, Holmes,
Rice, and Steuer each requested to extend their lease
through the end of April 2020 at a reduced rate. We
offered each of them a reduced rate of $500 through the
end of April 2020.
> 3/27/2020 Rice and Steuer each paid the reduced rate of $500 and
extended their respective leases through the end of April
2020. Lyons had Rice and Steuer each sign an addendum
to their respective leases to reflect the extension and
reduced rate. Holmes and Garrison each indicated that they
would vacate the Property by April 1,2020.
April 2020 Activity:
> 4/2/2020 We received MLH’s invoice in the amount of $300.00 for
itsmonthly property inspection.
> 4/30/2020 Tenants Garrison and Holmes moved out. Lyons had each
of their bedrooms cleaned, and charged them each $100 for
cleaning and $85 for carpet cleaning. Steuer and Rice
continued to rent the two remaining bedrooms and both
timely paid their April 2020 rent. Rice executed a
document indicating he would vacate the Property by May
31, 2020.
> 4/30/2020 We received a letter from David Ditora, Esq. (“Ditora”)
stating that he has substituted for Olkegak as counsel for
Plaintiff and directing us to address all future
correspondence to him. Although our initial plan was to
rent the Property through the end of ski-season and then
begin marketing and listing the Property for sale, Ditora
communicated to Gross that we should refrain from
engaging a broker because Plaintiff is considering renting
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RECEIVER’S REPORT 1237
the Property for another season. We await further
instructions from the Parties’ counsel before we begin
marketing the Property for sale, or marketing the two
vacant bedrooms at the Property for rent. However, if the
Parties want to wait until next rental season to sell the
Property, the Receiver’s outstanding fees and expenses in
the amount of $16,576 will need to be paid current.
May 2026 Activity:
> 5/4/2020 We received MLH’s invoice in the amount of $300.00 for
itsmonthly property inspection
> 5/27/2020 [ executed a month-to-month $1,000 per month lease with a
$1,000 security deposit commencing June 1, 2020, with
Steuer and her boyfriend Tal Kliger (“collectively “Tenants
Steuer and Kliger”) to rent the master bedroom at the
Property. The lease may be terminated by either party
upon providing thirty-days’ written notice.
> 5/31/20 Tenant Rice moved out as planned, We had multiple
communications throughout May 2020 with Plaintiff
regarding his decision either to support marketing the
Property for sale, or to rent out the three empty bedrooms at
the Property. If we continue to rent the Property and hold
off on the sale, one the Parties will need to pay our
outstanding fees and expenses. We are awaiting a final
decision from Plaintiff and will reach out to the Defendant
as well to get her position.
> 3/2020 Plaintiff advised us that Ditora no longer represents
Plaintiff in connection with this matter. Plaintiff requested
we direct allcommunications to him.
June 2020Activity:
> 6/1/2020 Tenants Steuer and Kliger timely paid their $1,000 rent for
June 2020.
> 6/1/2020 Plaintiff informed us that he did not wish for us to continue
renting the Property for another season and requested that
we move forward with listing the Property for sale. We
attempted to reach Defendant to obtain her position, but
Defendant has been uncommunicative and is not
represented by counsel. Consequently, we will move
forward with preparing for a sale of the Property.
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RECEIVER’S REPORT 1237
> 6/1/2020 We agreed to engage broker Tim Lampe (“Lampe”), who
was referred to us by Plaintiff, to list,market, and sell the
Property. We do not yet have a listing agreement as we
have not yet set a listing price. After we obtain an
appraisal of the Property, we will work with Lampe to
establish a listing price.
> 6/1/2020 There are only a few appraisers in the area. Consequently,
itwill take some time to obtain an appraisal. We requested
appraiser Tom Jackson (“Jackson”) provide us an appraisal
of the Property. Jackson isscheduled to visit the Property
on June 29, 2020.
> 6/4/2020 We received MLH’s invoice in the amount of $300.00 for
itsmonthly property inspection.
> 6/18/2020 Out of an abundance of caution and to ensure that the
Property will be vacant at the time of sale due to the
Coronavirus pandemic, Lyons served Tenants Steuer and
Kliger a Notice of Termination of Tenancy, informing them
that they will need to vacate the Property within thirty days
or by July 18, 2020, whichever is later (the “Termination
Notice”). Tenants Steuer and Kliger indicated that they
will comply with the Termination Notice. We anticipate
they will timely pay their July 2020 rent. If they pay more
than the pro-rated amount, we will refund any
overpayment. Should they not pay their July 2020 rent, we
will deduct the applicable amount from their security
deposit.
> 6/29/2020 Jackson was to visit the Property to prepare his appraisal.
As of the end of June 2020, we had not yet received his
appraisal of the Property. Once itis received, we will be
able to set a listing price for the Property.
July 2020Activity:
, 7/1/2020 Tenants Steuer and Kliger did not pay their July 2020 rents
in the amount of $500 each. Consequently, we will deduct
Preview
Kevin Singer Superior Court Receiver of California Receivership Specialists Superior Co ‘ott Placer 980 9th Street, 16th Floor Sacramento, California 95814 SEP 28 2020 Telephone: (916) 449-9655 Facsimile: (916) 446-7104 Jake Chatte rs ate 3 ‘ : . so & Cl E-mail: Kevin@ReceivershipSpecialists.com By: i ove acum Deputy Receivership Property: 1237 Wagon Wheel, Truckee, California 96161 SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF PLACER, BILL SANTUCCI JUSTICE CENTER CHARLES B. GOLSON, an Individual and ) Case No.: SCV0042787 as Trustee of the Charles B. Golson ) Z Revocable Trust, ) SUPERIOR COURT RECEIVER’S 1? ) REPORT FOR AUGUST 2020 AND Plaintiff, ) NOTICE OF INTENT TO PAY ) RECEIVER’S FEES AND EXPENSES v. ) . 14 ) Commissioner: Hon. Glenn M. Holley BETHANY BARRY CROSS, an Individual, ) 15 and DOES | through 20, inclusive, } Dept.: 31 ) 16 Defendants. ) Court: Placer County Superior Court ) Hon. Howard G. Gibson Courthouse Le ) Bill Santucci Justice Center ) 10820 Justice Center Drive 18 ) Roseville, California 95678 ) 19 20 21 22 23 24 25 27 28 Page | RECEIVER'S REPORT 1237 RECEIVERSHIP SPECIALISTS STATE AND U.S. FEDERAL COURT RECEIVERS/REFEREES/TRUSTEES Corporate Headquarters LosAngeles 11500W. OlympicBlyd Suite $30 LosAngeles,CA 90064 SUPERIOR COURT RECEIVER’S REPORT FOR AUGUST 2020 AND Tel:(310}552-9064 NOTICE OF INTENT TO PAY RECEIVER’S FEES AND EXPENSES | See SanFrancisco : . ; 795Foisom Street ‘ Presented By: Kevin Singer, Superior Court Receiver istFloor SanFrancisco, CA 94107 Tel:(415)848-2984 Fax:(415)848-2301 SanDiego 4660La Jolla Village Drive Suite100 SanDiego,CA 92122 Tel.(858)546-4813 CHARLES B. GOLSON Fax:(B58)646-3097 an Individual and as Trustee of the Charles B. Golson Revocable Trust Plaintiff Ventura/Santa Barbara 1500Palma Drive 2ndFloar Vv. Ventura,CA93003 Tel. (805)267-1283 BETHANY BARRY CROSS os a an Individual, and DOES 1 through 20, inclusive a Defendants 9809thStreet [6thFloor CA Sacramento, 95814 Fel:(916)449-9655 Fax:(916)446-7104 Las Vegas 725)W. LakeMead Blvd. Suite 300 Placer County Superior i Court Case No. SCV0042787 Tal Las (HD} Vegas, fe-an NV 89128 Fax:(702)562-4001 Commissioner: Hon. Glenn M. Holley Reno 200§. Virginia Street Suite800 Reno,NV 89501 Tel:(775)398-3103 Fax:(775)686-240 Receivership Property: ‘ 3 Phoenix 1237 Wagon Wheel, Truckee, California 96161 > NCentralAvenue Suite1800 Phoenix, AZ 85004 Page 2 Tel;(602)343-1889 Fax:(602)343-180 RECEIVER'S REPORT 1237 September 25, 2020 Dear Vested Parties: After having issued a Tentative Ruling on September 26, 2019, to which neither plaintiff Charles B. Golson, an Individual and as Trustee of the Charles B. Golson Revocable Trust (‘‘Plaintiff’) nor defendant Bethany Barry Cross (“Defendant”) requested a hearing, on October 22, 2019, the Court, the Honorable Glenn M. Holley presiding, entered an Order after Hearing on Motion for Order Appointing Receiver and Enjoining Defendant (the “Appointing Order”) appointing me, Kevin Singer, as receiver (“Receiver”) with the authority to take possession of, manage, lease, collect the rents from, bring into good and marketable condition, and ultimately market and sell the four-bedroom, single- family residential property (used as a vacation rental property) commonly known as 1237 Wagon Wheel, Truckee, California 96161, located in an unincorporated area of the County of Placer, and legally defined as: LOT 50 AS SHOWN ON THAT CERTAIN SUBDIVISION MAP ENTITLED “TRACT NO, 224, NORTHSTAR UNIT NO. 1 C” FILED IN THE OFFICE OF THE COUNTY RECORDER OF PLACER COUNTY, CALIFORNIA ON FEBRUARY 23, 1972, IN BOOK “J” OF MAPS, PAGE 46. APN: 110-190-004-000 (the “Property”). Plaintiff and Defendant are referred to herein individually as a “Party” and collectively as the “Parties,” According to the Tentative Ruling, Plaintiff and Defendant each hold a fifty-percent interest in the Property pursuant to a grant deed. At the time of my appointment as Receiver in this matter, the Property was unoccupied. The following summarizes what has transpired since |assumed my role as Receiver in this matter through the end of August 2020: September 2019 Activity: > 9/30/2019 I posted my bond. October 2019 Activity: > 10/1/2019 In preparation for the eventual sale of the Property and the issuance of a title insurance policy, I researched and obtained a Combined Property Report (the “Combined Page 3 RECEIVER’S REPORT 1237 Report”) from First American Title Company (‘First American”). The Combined Report provided a property profile, transaction history, comparable sales, and a tax map. e 10/1/2019 ] investigated the tax status of the Property. According to Placer County's Treasurer-Tax Collector's website (the “Tax Collector’s Website”), as of this date, 2019-2020 property taxes had not yet been paid. The first installment in the amount of $5,034.57 will be delinquent if not paid by December 10, 2019, and the second installment in the same amount will be delinquent if not paid by April 10, 2020. > 10/1/2019 Utilizing a link available at the Tax Collector's Website, we downloaded a copy of the 2019—2020 property tax bill for the Property. > 10/4/2019 I prepared, filed, and served my Oath of Receiver. > 10/29/2019 Pursuant to the directions of the Appointing Order, we researched potential property management companies to manage the Property under my supervision. We identified Mountain Lion Home Management & Concierge (“MLH”) as being the best property management company for the Property as ithas relationships with other local businesses that can assist with repairs to the Property as well as rentals. » 10/30/2019 My Senior Project Manager for this matter, CJ Gross (“Gross”), conducted our initial visit to and inspection of the Property. Plaintiff met Gross at the Property and provided him access. Gross observed that the fully- furnished Property had been well-maintained, but was in need of cleaning. While there, Gross met with Charles Slusher (“Slusher”), CEO of MLH, went through Property, and noted several repairs that need to be made. Slusher will prepare a property management agreement for our review and execution. > 10/30/2019 We contracted with Alpine Lock and Key to rekey the front door to the Property and disable an electronic access panel on the lock. We also contacted Liberty Utilities to restore power to the Property. > 10/31/2019 Gross returned to the Property. While there he met with a workman from Liberty Utilities who restored the power. Page 4 RECEIVER'S REPORT 1237 Gross again met with Slusher and they conducted a more detailed walk-through of the Property, photographing itas they went. In accord with the Appointing Order, the photographs will be utilized to prepare an inventory of property. Gross and Slusher identified various leaks at the Property as well drywall repairs. They further noted that the top of a pine tree had broken-off and that the twelve to fifteen-foot spear-shaped portion of dried out wood was hanging from the tree and pointing directly at the entrance to the Property. MLH agreed to engage a landscaper to remove the dangerous portion of the pine tree. » 10/31/2019 Gross met with Rachel Lyons (“Lyons”) of Granite Peak Management (“GPM”) at the Property. Because MLH does not have a broker’s license, it is unable to lease out the Property. Lyons and Tahoe Vacation Rentals (owned by GPM) will handle renting out the four bedrooms at the Property. Because the Property is a vacation rental property, we believed it most-cost effective and profitable to individually rent out each of the rooms on a six-month basis to persons working in the resort community. Northstar Lodge by Welk Resorts (“Northstar Lodge”) is the main resort in the area and Lyons has connections with Northstar Lodge that should prove helpful in leasing the Property. The Property will be leased through about April or May 2020, depending upon when the ski season ends, after which, we will begin to market and sellthe Property. > 10/31/2019 Gross met with realtor Doug Flynn (“Flynn”) of Tahoe Mountain Realty (“TMR”), a top-producing agent in the Tahoe-Truckee region, who we anticipate engaging to sell the Property. > 10/31/2019 We communicated Defendant who stated she was putting together various requested documents to provide to us in early November 2019. > 10/31/2019 We began investigating whether there isadequate insurance in place for the Property. Presuming there is sufficient insurance on the Property, we will request I be named as an additional insured to the policy. If there is insufficient insurance, we will have the Property added to my master insurance policy. ffi fff Page 5 RECEIVER’S REPORT 1237 November 2019 Activity: > 11/1/2019 We reviewed and revised a draft property management agreement prepared and sent to us by MLH. We prepared an addendum thereto and returned it to MLH for its execution. 11/6/2019 MLH forwarded us a bid from a licensed plumbing contractor to address the plumbing issues atthe Property. 11/6/2019 We executed the MLH property management agreement and addendum. 11/8/2019 We reviewed and revised a draft agreement prepared and sent to us by GPM. We prepared an addendum thereto and returned it to GPM for itsexecution. 11/14/2019 We spoke with Slusher regarding the plumbing repairs and estimates and approved the repairs for the leaks under the kitchen sink, the bathroom sink and the closet piping. 11/14/2019 We spoke with Stars Snow Removal and requested a quote for snow removal service during the snow period. 11/14/2019 Gross spoke with Defendant who stated that she would provide us access to Rent Tec’s online portal so that we may view the management files for the Property. 11/18/2019 Gross spoke with Marysia Olkegak, Esq. (“Olkegak”), attorney for Plaintiff. She advised us that she would be communicating with us directly and not through Plaintiff. We provided Olkegak an update with respect to the repairs and cleaning and informed her that the Property would be rent-ready intime for the ski season. 11/18/2019 Olkegak provided me bank statements from Defendant. They were all heavily redacted; we are requesting unredacted copies. 11/19/2019 Slusher informed us that the plumbing repairs had been completed and that a drywaller would be coming to patch the walls. Slusher also informed us that the master bathroom sinks and four straps needed to be replaced. We approved the repairs. AiG Page 6 RECEIVER’S REPORT 1237 > 11/18/2019 During an inspection of the Property, it was discovered that the railings on the outside deck were loose and needed repairs. The deck is approximately nine to sixteen feet off the ground at various points and the railing on the deck has significant play when pressed against. Working with MLH, we obtained an estimate to repair the balcony railings from Dog Valley Builders (‘Dog Valley”). We authorized Dog Valley to conduct the repairs. Once the weather cooperates, Dog Valley will commence the repairing the railings. In the interim, we directed Lyons to have each of the tenants sign an addendum to their leases wherein they agree not to use the deck untilthe railing is repaired. > 11/21/2019 i was provided three copies of a Notice of Delinquent Assessment that was recorded by Northstar Property Owners’ Association in the Placer County Recorder’s office against the Property on November 4, 2019, and sent to: (i)Plaintiff; (ii)Defendant; and (iii)Eric Bernard Golson, Trustee. > 11/25/2019 The twelve to fifteen-foot spear-shaped portion of dried out wood that was hanging from the tree and pointing directly at the entrance to the Property was removed. > 11/26/2019 We executed a snow-removal agreement with Stars Snow Services. > 11/30/2019 Lyons forwarded us copies of three leases for the Property for our review and execution, one each for: (i)Melanie Garrison (“Garrison”); (it)Benjamin Rice (“Rice”); and (ili)Jon Holmes (“Holmes”). First month’s rent and $1,000 rental deposits were included with each of the leases. The master bedroom will be rented to Garrison, a ski instructor, for $1,000 per month. The three remaining bedrooms will be rented for $750 per month. Garrison, Rice, and Holmes are anticipated to take occupancy of the Property on December 1, 2019. Lyons is working to secure a fourth and final tenant for the Property. > 11/2019 We were advised that Plaintiff maintains insurance on the Property and will have me named as an additional insured to the policy. We have requested a copy of the policy and anticipate receiving itin December 2019. DAE ffl Page 7 RECEIVER'S REPORT 1237 December 2019 Activity: > 12/1/2019 We received a copy of the insurance on the Property, which showed that | was named as an additional insured on the policy. > 12/1/2019 Two of the three tenants moved into the Property as scheduled. The third tenant moved into the Property the following week. > 12/9/2019 During the month of December 2019, we had several companies provide repair and maintenance services at the Property. We also brought in a pest control company to address an issue with spiders. > 12/12/2019 We prepared, filed, and served our Notice of Inventory in the action and included photographs taken by Gross during his most recent inspection of the Property. The Notice of Inventory depicted the personal property at the Property as well as specific areas that needed repair. > 12/2019 We collected rents from Lyons for each of the three tenants. Lyons continued to look for a fourth tenant to lease the remaining bedroom at the Property. January 2020 Activity: > 1/6/2020 We received MLH’s invoice in the amount of $300 for its monthly property inspection. > 1/15/2020 Lyons succeeded in finding a fourth tenant, Emma Steuer, to lease the remaining bedroom at the Property, for a rent of $750 per month through April 1, 2020, as reflected in the Residential Lease or Month-to-Month Rental Agreement (the “Steuer Lease”). Steuer moved into the Property. > 1/29/2020 The railing repair work on the deck was completed. Galvanized stee! brackets were used to strengthen the posts and the post bolts were tightened. The railing has significantly less play after the repair than itdid before. February 2626 Activity; ra 2/17/2020 We received MLH’s invoice in the amount of $300 for its monthly property inspection. The MLH invoice charged an additional $2,575, comprised of hand shoveling of snow Page 8 RECEIVER’S REPORT 1237 and for repair of the loose deck railing, including costs of supplies, labor, and GC oversight. Y 2/18/2020 All four bedrooms at the Property remain occupied and the tenants all timely paid their February 2020 rents. March 2020 Activity: > 3/17/2020 We received MLH’s invoice in the amount of $752.56 for itsmonthly property inspection and maintenance charges. > 3/23/2020 Due to the Coronavirus pandemic that resulted in the closure of ski resorts and other public locations, Holmes, Rice, and Steuer each requested to extend their lease through the end of April 2020 at a reduced rate. We offered each of them a reduced rate of $500 through the end of April 2020. > 3/27/2020 Rice and Steuer each paid the reduced rate of $500 and extended their respective leases through the end of April 2020. Lyons had Rice and Steuer each sign an addendum to their respective leases to reflect the extension and reduced rate. Holmes and Garrison each indicated that they would vacate the Property by April 1,2020. April 2020 Activity: > 4/2/2020 We received MLH’s invoice in the amount of $300.00 for itsmonthly property inspection. > 4/30/2020 Tenants Garrison and Holmes moved out. Lyons had each of their bedrooms cleaned, and charged them each $100 for cleaning and $85 for carpet cleaning. Steuer and Rice continued to rent the two remaining bedrooms and both timely paid their April 2020 rent. Rice executed a document indicating he would vacate the Property by May 31, 2020. > 4/30/2020 We received a letter from David Ditora, Esq. (“Ditora”) stating that he has substituted for Olkegak as counsel for Plaintiff and directing us to address all future correspondence to him. Although our initial plan was to rent the Property through the end of ski-season and then begin marketing and listing the Property for sale, Ditora communicated to Gross that we should refrain from engaging a broker because Plaintiff is considering renting Page 9 RECEIVER’S REPORT 1237 the Property for another season. We await further instructions from the Parties’ counsel before we begin marketing the Property for sale, or marketing the two vacant bedrooms at the Property for rent. However, if the Parties want to wait until next rental season to sell the Property, the Receiver’s outstanding fees and expenses in the amount of $16,576 will need to be paid current. May 2026 Activity: > 5/4/2020 We received MLH’s invoice in the amount of $300.00 for itsmonthly property inspection > 5/27/2020 [ executed a month-to-month $1,000 per month lease with a $1,000 security deposit commencing June 1, 2020, with Steuer and her boyfriend Tal Kliger (“collectively “Tenants Steuer and Kliger”) to rent the master bedroom at the Property. The lease may be terminated by either party upon providing thirty-days’ written notice. > 5/31/20 Tenant Rice moved out as planned, We had multiple communications throughout May 2020 with Plaintiff regarding his decision either to support marketing the Property for sale, or to rent out the three empty bedrooms at the Property. If we continue to rent the Property and hold off on the sale, one the Parties will need to pay our outstanding fees and expenses. We are awaiting a final decision from Plaintiff and will reach out to the Defendant as well to get her position. > 3/2020 Plaintiff advised us that Ditora no longer represents Plaintiff in connection with this matter. Plaintiff requested we direct allcommunications to him. June 2020Activity: > 6/1/2020 Tenants Steuer and Kliger timely paid their $1,000 rent for June 2020. > 6/1/2020 Plaintiff informed us that he did not wish for us to continue renting the Property for another season and requested that we move forward with listing the Property for sale. We attempted to reach Defendant to obtain her position, but Defendant has been uncommunicative and is not represented by counsel. Consequently, we will move forward with preparing for a sale of the Property. Page 10 RECEIVER’S REPORT 1237 > 6/1/2020 We agreed to engage broker Tim Lampe (“Lampe”), who was referred to us by Plaintiff, to list,market, and sell the Property. We do not yet have a listing agreement as we have not yet set a listing price. After we obtain an appraisal of the Property, we will work with Lampe to establish a listing price. > 6/1/2020 There are only a few appraisers in the area. Consequently, itwill take some time to obtain an appraisal. We requested appraiser Tom Jackson (“Jackson”) provide us an appraisal of the Property. Jackson isscheduled to visit the Property on June 29, 2020. > 6/4/2020 We received MLH’s invoice in the amount of $300.00 for itsmonthly property inspection. > 6/18/2020 Out of an abundance of caution and to ensure that the Property will be vacant at the time of sale due to the Coronavirus pandemic, Lyons served Tenants Steuer and Kliger a Notice of Termination of Tenancy, informing them that they will need to vacate the Property within thirty days or by July 18, 2020, whichever is later (the “Termination Notice”). Tenants Steuer and Kliger indicated that they will comply with the Termination Notice. We anticipate they will timely pay their July 2020 rent. If they pay more than the pro-rated amount, we will refund any overpayment. Should they not pay their July 2020 rent, we will deduct the applicable amount from their security deposit. > 6/29/2020 Jackson was to visit the Property to prepare his appraisal. As of the end of June 2020, we had not yet received his appraisal of the Property. Once itis received, we will be able to set a listing price for the Property. July 2020Activity: , 7/1/2020 Tenants Steuer and Kliger did not pay their July 2020 rents in the amount of $500 each. Consequently, we will deduct