ANSWER to PETERSEN DEAN COMPLAINT

PETERSEN DEAN vs JENNIFER MARSHALL                                                            BC661819

AMENDED ANSWER-CONTRACT 

ATTACHMENT 4

WITH IMPORTANT TYPO/CLERICAL CORRECTIONS MADE 5-5-18 and item by item answer.

DEFENDANT IS VERY ILL AND MAKING MANY CLERICAL ERRORS DUE TO ILLNESS

SEE EXHIBIT C: HEALTH STATUS REPORT TO DR. SEEMA MISSER REGARDING ILLNESS OF JAMES MARSHALL AND JENNIFER MARSHALL

NOTE: DEFENDANT is ill with fever and lung infection and is caring for her ill autistic son JAMES MARSHALL 24/7 while doing this paperwork and in spite of proof reading her work she has still managed to miss glaring clerical errors such as not noticing that STAPLES OFFICE SUPPLY did not copy page two, that the document was left in the copy machine uncopied and that after correcting that, the document was unsigned and after correcting that, discovering that on page 2 of the signed ANSWER-CONTRACT form she had accidentally mixed up PLANTIFF with DEFENDANT and in as much accused herself of placing INVALID MECHANICS LIENS upon her home. Defendant’s form on www.courts.ca.gov printed blank several times after she completed it, making her have to start from the beginning several times. Even after falling down twice and injuring her knee and foot due to illness, DEFENDANT continued to correct mistakes that were pointed out to her. PLAINTIFF said they would not agree to ask the court for an extension due to DEFENDANT’S illness. Working while ill caused many accidents, clerical and physical accidents and injuries plus a relapse into worse illness. ILLNESS and request for a copy of the SUMMONS AND COMPLAINT were the ONLY topics discussed with PLAINTIFF. Attorney for PLAINTIFF, George Milionis refused to return DEFENDANT’S phone calls, would not email her and had a girl at his office email the COMPLAINT to DEFENDANT the day the ANSWER was due and refused to discuss the case.

Please see Attachment: EXHIBIT A: EXAMPLE of ERROR on ANSWER CONTRACT.

DEFENDANT was so distressed on 9-13-16 when her signature was electronically deposited on what appeared to be TWO contracts instead of ONE that she repeatedly complained to DAVE SHANHOLTZER and repeatedly asked for clarification as to why she was being asked to pay for a roof that she had been verbally told was “free with the purchase of the solar package.” DEFENDANT has made and saved recordings of commercials where PETERSEN DEAN sells this “free roof” solar package and can play this recording for the court/jury to hear.

At one point, DAVE SHANHOLTZER said to DEFENDANT that people her AGE often had difficulty understanding the electronic process. In spite of my advanced age, I own a laptop that does not normally flicker and have a jumpy screen. In all my many, many years I also have purchased and leased many cars and while HONDA FINANCE uses electronic signatures, they afford you a hard copy to examine BEFORE depositing your signature on it. It has been my experience with businesses such as H&R Block, who also began using electronic signatures, that I was ALWAYS given a hard copy of what I would be signing and what I signed ALWAYS matched what was discussed verbally. The verbal and written contracts at HONDA always matched. This has been my experience with every business except the HERO/PETERSEN DEAN project where the price was never stable.

I was deeply distressed and alarmed on 9-13-16 and repeatedly called HELENA SHI for some kind of proof that I was really getting the deal that DAVE SHANHOLTZER only verbally confirmed I was getting. HELENA SHI repeatedly verbally reassured me that I was “getting the deal everybody else was getting” and that was the “free roof if you buy the solar package”. Then I was told that perhaps the deal I heard on the radio had expired and that my senior citizen discount had expired but to rest assured I was still getting the same deal under the new promotion. I was not given anything in writing as to what this new promotion was and that it was the same as the old promotion.

The ever-changing information alarmed me further. I continued to ask for something in writing that would prove that all the money in the second contract would “fall off” in a year when payment was due to HERO as I was being verbally assured it would. When I kept asking for things in writing I was given not so subtle insults about my age, as if young people no longer want things in writing and only old people who are not up with the times would be so annoying. I was not directly told, “You are annoying”, it was put to me in such as way as to try to shame me into stopping asking for the deal in writing, inferring, “You don’t want to be that kind of old annoying person, do you?” If requesting documentation is annoying, DEFENDANT wants to continue being annoying.

After many weeks I was finally given a chart (attached) which I made an appointment with H&R BLOCK to verify the veracity of. MR JOHN MARTIN of H&R BLOCK examined the documents and the chart and informed me that it was a tax credit scam, that I was not in a tax bracket to receive one penny of the tax write off, the $10,000+ was NOT going to “fall off” in a year, that I would be hit with a balloon payment I could not afford to pay and most likely I would lose my home to HERO.

I was further distressed on 9-13-16 by DAVE SHANHOLTZER’S shameless, repeated reminders that some of his customers got even MORE discount by NEGLECTING to separate the roofing expense from the solar expense, giving UNCLE SAM the impression that $30,000 was spent on solar instead of $20,000.

I reported the stucco accident and the unfinished work and the information from H&R BLOCK about the tax credit to HERO and at first it seemed HERO was going to be true to their promise to protect their customers from unscrupulous contractors.

(See EXBIBIT B: where HERO warns me not to let the contractor make me sign off that the work was done satisfactorily prematurely, to make sure PLAINTIFF finished the job first. Also see attached letter from attorney GEORGE MILIONIS demanding to be paid and to have the sign off of job completion signed BEFORE PLAINTIFF would make any repairs and compete the job.)

HERO, PETERSEN DEAN and I agreed that the solar panels would be removed (copies of emails confirming this agreement have been filed previously in this case) and that HERO would finance the roof only, and only after PETERSEN DEAN removed the solar panels and completed the rest of the job and repairs. There are MANY emails. DEFENDANT needs an attorney to organize and present the large amount of emails and physical evidence and make amendments to this ANSWER to include all the evidence correctly.

PETERSEN DEAN deceived me the week in January 2017 when they were scheduled to remove the solar panels. I suspected by HELENA SHI’S suddenly different tone of voice that she did not like or want to be dishonest with me but was being told to give me the impression she was arranging the details of the removal of the solar panels when in fact that was not really what was happening. With a copy of the SUMMONS AND COMPLAINT showing the dates PLAINTIFF took certain actions, it lines of with the exact time PLAINTIFF was having HELENA SHI supposedly working on scheduling removal solar panels when in fact GEORGE MILIONIS was preparing and filing MECHANICS LIENS.

I kept letting HELENA SHI know that BUILDING & SAFETY kept informing me that PETERSEN DEAN had not yet applied for a SOLAR PERMIT REFUND, something that is always done. It was sheepishly suggested to me that PETERSEN DEAN did not need the refund. That seemed highly unlikely because PETERSEN DEAN fought tooth and nail to try force me to pay for over half of the damages they did to our home. It seemed like they were trying to trick me into signing off that they had made the repairs and then continue not to make the repairs but I would have absolutely no legal rights because I signed off. Months had gone by and they had not resumed work or made any of the promised repairs. I had ample reason to suspect they were never going to make the repairs.

I stood my ground and told HELENA SHI that BUILDING AND SAFETY said it was a necessary step to clear the title of the property to avoid confusion in any future transaction. It had to be clear, for refinancing or selling purposes, that the solar panels were removed. When I suspected something was off, HELENA SHI told me she was told she was not allowed to talk to me anymore. To clarify for the court: HELENA SHI was my contact at PETERSEN DEAN and she told me she was not allowed to talk to me anymore. The ramification of this is that PETERSEN DEAN shut down all communication on an unfinished project and would not let the contact person in charge of my solar project speak to me. Soon HERO went dark as well and also began saying they were not allowed to speak to me. At no time did GEORGE MILIONIS try to resolve the problem. GEORGE MILIONIS gave and ultimatum in writing to SIGN THE COMPLETION CERTIFICATE in spite of HERO warning me not to sign it or face having our home taken away from us by him via liens. SEE EXHIBIT B letter from GEORGE MILIONIS. At all times GEORGE MILIONIS knew our financial status and knew we were on SSI DISABILITY and did not have $34,000 and he knew the job was not completed and he knew he was violating the terms of HERO FINANCING, that he was reneging on the agreement to remove the solar panels and properly complete the rest of the job. What is not clear to DEFENDANT is why HERO agreed to go along with GEORGE MILIONIS. DEFENDANT on the silent treatment, refusing to talk to DEFENDANT about the job anymore. The FBI recently called DEFENDANT with questions for clarification and DEFENDANT had to tell the FBI that she could not answer that question, that HERO had never given her verbal explanation of why they stopped communication and disappeared, abandoned the project. HERO did not send an email for a letter explaining why they were not allowed to talk to me anymore about the job they were financing on my home. Like HELENA SHI, solar program contact at PETERSEN DEAN, they only told me they were not allowed to talk to me anymore and did not state why. I reported this to the FBI and to the CSLB and to the CFPB. I had never hard of financing disappearing before. I was not familiar with this type of obvious scam. AARP never warned me about this type of “disappearing home improvement financing” and now I am the one sounding the alarm so other senior citizens do not fall prey. My YELP review of RENOVATE AMERICA/HERO has received thanks from citizens who were grateful that I shared what is happening to my son and me at the hands of PLAINTIFF and their partner which they are hiding from the court, HERO/RENOVATE AMERICA. I recently also received thanks from a citizen in my neighborhood who said my blog helped them not fall victim to this property tax scam.

DEFENDANT finds it hard to believe that PETERSEN DEAN would casually not care about getting a permit refund or any refund they were entitled to because of they fought tooth and nail for months not to pay a licensed contractor to repair the electrical damage in the garage PLAINTIFF made with a sledgehammer before my very eyes, the stucco powder remediation and the replacement of rotten wood on the roof that they had neglected to remove and replace and other unfinished repairs noted by the CSLB as violations.

PLAINTIFF offered me a fraction of the money the estimates for repair all the licensed contractors submitted. PLAINTIFF wanted to pay me a fraction of the repair cost instead of making payment directly to licensed contractors. Why would someone who was frantic not to pay for repairs to damages they were witnessed making suddenly be so casual as to say they were not interested in getting their money back from BUILDING AND SAFETY for the solar permit refund? I was suspicious and the SUMMONS AND COMPLAINT confirms that deception was happening on those dates. (See attached emails where I report to HERO that no communication is happening and I suspect something is going on. The LIENS were being prepared and filed at that time).

In my discussions with BUILDING AND SAFETY it was also accidentally discovered in the course of conversation that PETERSEN DEAN never drew a permit to alter my water heater in my garage, which was what PLAINTIFF was doing at the time of the stucco accident that damaged my autistic son, JAMES MARSHALL’S lungs as well as covering our garage, our house and our air vents with fine dust. PETERSEN DEAN never paid either of the two remediation companies who gave estimates to clean up the stucco powder and never made any of the other repairs.

PETERSEN DEAN did complain to their insurance company that JAMES MARSHALL was already sick in bed the day of the accident and had been sick all year. DEFENDANT never suggested that PLAINTIFF caused JAMES MARSHALL’S autism, only that they pushed him into a massive regression that threatens his ability to remain in society and that they made his physical condition deteriorate as well by filling his room, his lungs, his stuffed animals, bedding and clothes closet with stucco powder, a very fine dust made of grey paint, stucco and concrete which PLAINTIFF stubbornly refused to pay a professional licensed remediation company to clean and remove from the air vents. The exterior paint of DEFENDANT’S house formed part of the mixture of fine powder, stucco and concrete and has not been tested for toxins. PLANITIFF used a stucco saw several feet away from the open bedroom window of JAMES MARSHALL and the open garage door that PLAINTIFF had opened to alter the water heater without obtaining a permit to do so from BUILDING AND SAFETY. BUILDING AND SAFETY notified DEFENDANT in conversation that the last permit granted for the water heater was 2008 and no permit had been requested or granted in 2016. PLAINTIFF told DEFENDANT that they did have a permit to alter her water heater but refused to give her a copy.

It has not been determined if the powdered paint from DEFENDANT’S was safe to inhale. JAMES MARSHALL did have to go to the emergency room days after the accident that filled his room and his lungs with a large amount of the stucco/concrete/paint powder and turned into an infection. There is a mold problem/water damage problem on the exterior of DEFENDANTS home in addition to mold that was documented to be in the walls of the home cause by excessive watering by the HOME OWNER’S ASSOCIATION of SHADOWBROOK ESTATES. There have been no tests of the exterior stucco/paint to determine what the toxicity level of inhaling a powder made from these substances. At the time of the accident PLAINTIFF offered immediate remediation but reneged upon receiving quotes from licensed remediators. PLAINTIFF than began making ludicrous suggestions such as having men unlicensed in remediation use leaf blowers to clean the interior of her home. That would only cause destruction of property and every remediation company consulted said it would make the house more dangerous to breath in by making toxins airborne and causing more cross contamination. PLANTIFF began having many strange men employed by PETERSEN DEAN who were not licensed contractors and who did not work on the job call DEFENDANT and try to talk her into signing contracts before they would remove the stucco powder from the home and resume the job. These men talked like thugs, like mob “fixers.”

DEFENDANT requests time to find and hire an attorney with the skills to gather this toxicity and other vital documentation for presentation to the court.

PLAINTIFF’S subcontractor DAVID BLAZELL tired to force electrician GARETT WALLACE to clean the garage and my son’s room and air vents with a leaf blower. MR WALLACE informed his boss, DAVID BLAZELL via phone in front of me on my drive way that he could not do that job, that it would take him four days or more and he could not clean my son’s bedding and clothing and he did not have a leaf blower with him and that it was not the kind of work an electrician does.

DAVID BLAZELL agreed to have a remediator who is licensed to do that that kind of work clean the mess and make JAMES MARSHALL’S room safe to occupy again but balked at the estimates from licensed companies and both he and “goons and thugs” from PETERSEN DEAN began a campaign against me that can only be described as mental torture. I do not used the terms “goons and thugs” lightly. Many different strange me began calling me and working on changing my mind to convince me to sign off that the work was done before it was actually done. It was the most bizarre, unprofessional months of a series of painful phone calls I ever experienced or heard of anyone ever enduring. I was repeatedly accused by different men I had never met before of not wanting the stucco dust removed.

JAMES MARSHALL became very ill after inhaling the stucco powder that formed a cloud in his bedroom and made it unsafe for him to sleep there safely anymore when we came to the house to let contactors in. My home insurance tested the air quality of all the rooms in the house as part of the mold remediation testing and while my son’s room showed no mold, it was the dirtiest room in the house because of the stucco accident. In a matter of days James developed a serious lung infection that required treatment in the emergency room. JAMES was bedridden while PETERSEN DEAN was trying to break me down mentally so I would sign a document saying the job was completed BEFORE they would complete the job and do any of the repairs. PETERSEN DEAN was aware of the emergency room visit and STILL made no move to remove the stucco dust in the air vents and in James’ room and allowed it to continue drift throughout the house instead.

PLAINTIFF repeatedly reminded DEFENDANT that they knew JAMES MARSHALL had a difficult year and that I would be putting him in harms way if I did not sign the document they wanted me to sign. My son JAMES became agitated and upset about these long, agitated phone calls from PLAINTIFF. JAMES would cry for me to put away the phone and grew to not want me to talk on the phone at all. Just the ringing of the phone became enough to upset my autistic son. I told KYLE SMITH to stop calling us because it was having a bad effect upon us. KYLE SMITH said he knew, that he felt bad for us too. That did not make sense. His so called sympathetic calls were crazy making. My son and I always felt so sad and depressed after his long, bizarre calls. Who would like calls from a “sympathetic stranger” out of the blue professing to be a nice person very concerned for you when it was very clear it was all about PLAINTIFF achieving a goal to get a document signed?

KYLE SMITH was most definitely playing the “good cop/bad cop” game with us and chastised me for saying he made me and my son feel horrible. I never met anyone before who acted like they cared about us so much when they didn’t know us, acted offended if the whole ordeal of talking for hours and hours with a stranger who was trying to get you to sign a document made you feel upset. He acted like he was offended that JAMES and I didn’t want to talk to him, didn’t want him to come over to our house, didn’t want him to loan me $500 dollars of his own money. I thought it was highly inappropriate for him to offer me a loan. I didn’t want to meet him but he kept insisting that he come over to our house and meet us and spend days with us helping us clean. He wanted us to leave our emergency housing where JAMES was sick in bed and meet him at the gutted house and work together for days. Where did he expect JAMES to be while this job that should be done by professionals was being done by me and KYLE SMITH? JAMES’ room was not safe to occupy. Was JAMES supposed to sit in a hot car for hours for days, possibly weeks? KYLE SMITH was the kind of person who can’t take a hint and can’t take a direct no. MR SMITH keeps working on you until you tell him you cannot bear to talk to him anymore. JAMES could not take it anymore either. We were both crying the day I told MR SMITH these phone calls had to stop.

PLAINTIFF used my son’s illness as leverage to try to force me to sign more documents. PLAINTIFF played “Good Cop/Bad Cop” with us, different having men I never met before the stucco accident to phone me and tell me they were “good and cared about me and James” and would hate to turn us over to GEORGE MILIONIS because if that happened, it would be irreversible, unimaginable hell for us. The word “unimaginable” was pounded into my brain.

I was so frightened by these months of bizarre calls from different strange men who worked for PLAINTIFF that I told PLAINTIFF I went to the police to discuss the situation. PLAINTIFF was angry with me for telling them I would meet them at the police station, that this had to stop. PLAINTIFF had one man call me to insist that if he could only meet me face to face he felt confident that he could change my thinking. It sounded for all intents and purposes that he was telling me that if he pitched DAVE SHANHOLTZER’S sales pitch to me all over again like a refresher course, that I would believe again that $10,000+ would “fall off” my debt in a year. That sounded crazy to me and I asked why couldn’t the information be mailed to me, why did it require “face to face” refresher courses.

I refused to meet these strangers alone at the gutted property, the job site. Several of the men asked to meet me at the property in pairs, presenting the suggestion of having TWO men as if there were TWO of them I would be less afraid. That idea made me MORE afraid and seemed very unusual and unprofessional. Why couldn’t they mail me a copy of what they wanted me to sign? Why couldn’t they mail me a written document that proved I would save over $10,000?

I insisted they meet me at the police station if they HAD to meet me “face to face” to convince me I should sign papers. This infuriated the men from PETERSEN DEAN who had been calling me and working me over verbally on the phone for many weeks. I believe I have an email from one of the PETERSEN DEAN men expressing in writing that he is angry I suggested meeting at the police station if it was so critical to meet “face to face” instead of mailing me a copy like other businesses do. I felt it was necessary for the safety of my son and myself.

To clearly illustrate the cause of my growing fear, in all my years, no business had EVER kept demanding to meet me alone, especially not in a house they knew was not habitable, a house that was not safe to breath the air in, alone and “face to face” to discuss signing a contract, to have a “face to face” refresher course on why the original contract was a GREAT deal (even after H&R Block said it was a very padded tax credit scam) and to accept an inadequate check that would not cover the cost of completion of the job and repairs. BANK OF AMERICA does not do this. SEARS and HOME DEPOT and COSTCO and LOWES and FLOOR AND DÉCOR and just about any home improvement business you can think of does not send thugs and goons out to your job site to “enlighten your understanding” that you may have forgotten and make you sign things. If it can’t be dropped in the mail, it sounds nefarious. I threatened to file a complaint with the CSLB if PLAINTIFF did not stop trying to scare me into signing documents. My one regret is that I did NOT file the CSLB complaint immediately on November 2, 2016. Giving PLAINTIFF the benefit of the doubt only resulted in PLAINTIFF coming up with schemes to hurt us more.

GENERAL ALLEGATIONS OF PETERSEN DEAN/PLAINTIFF

ITEM 1: The damages of $34,118.06 is undeserved by PLAINTIFF. Once PLAINTIFF realized I found out about the MECHANICS LEINS and found out about case BC661819 from an attorney in Santa Monica that I consulted about suing RENOVATE AMERICA/HERO for breaking their contract and promise to me to protect me from their rogue contractor PETERSEN DEAN (and all senior citizen customers through their SENIOR PROTECTION PROGRAM, which for all intents and purposes never existed and was just an advertising gimmick).

Once PLAINTIFF realized I knew about BC661819, GEORGE MILIONIS called me and asked me to agree to pay $19,000. He seemed extremely and unreasonable angry when I told him I could not and did not qualify for a $34,000 loan in 2016, that I had been told by PETERSEN DEAN that I would only actually owe $20,000 because thousands of dollars would “fall off” with the deal I was given.

PLAINTIFF told an outrageous lie but for the sake of clarifying PLAINTIFF’S argument, even if $10,000+ “fell off”, I STILL would not qualify for $20,000 financing at ANY business for ANY work or product or service due to my low credit score of 420 which was extensively documented by the CFPB in 2016 due to a problem with OCWEN home loan reporting incorrect information to the three credit bureaus. I talked about this extensively with PLAINTIFF’S salesman DAVE SHANHOLTZER and repeatedly reminded DAVE SHANHOLTZER not to run my credit because if he did an inquiry it would lower my 420 score even more. I kept reminding DAVE SHANHOLTZER not to do this to me and my son, that it would damage us financially and I could tell him with complete confidence any application for credit would be denied. It is common knowledge that every time you allow and inquiry by a business into your credit, it lowers your score. DEFENDANT was very worried that DAVE SHANHOLTZER was going to forget and just casually run her credit without her permission, causing her financial harm and the task of having to apply to all three credit bureaus to remove an authorized inquiry, so DEFENDANT made it clear to DAVE SHANHOLTER not to run her credit, not to harm her family by doing this knowing it would result in a denied application for credit and lower her score more.

DAVE SHANHOLTZER fully understood my financial situation and he fully understood that I could only afford to have the work done with the HERO PROGRAM FINANCING if the figures he was giving me were true and accurate. H&R BLOCK confirmed definitely, without a trace of doubt, that the figures I was given by PLAINTIFF were not accurate, did not apply to me and would cause me to lose my home. Not one penny was going to “fall off” the $34,000 in a year via tax credits and I was most not definitely getting the deal both DAVE SHANHOLTZER and HELENA SHI told me I was getting. I was not really getting the “free roof if you go solar deal” that both DAVE SHANHOLTZER and HELENA SHI promised me repeatedly on September 13, 2016 that I was getting.

ITEM 3 of PLAINTIFF’S COMPLAINT/GENERAL ALLEGATIONS:

PLAINTIFF is being dishonest with the court. At all times since summer 2016 PLAINTIFF was acutely aware of the names and capacities of DEFENDANTS. PLAINTIFF was extremely aware of JAMES MARSHALL’S autism and illness and frequently used it as leverage in conversations to try to force signatures from me on questionable documents they refused to mail to me.

PLAINTIFF was very aware that I am a single mom and apparently of the opinion that I am very, very old, according to how they talked down to me about “people my age” not being able to understand computers and the concept of electronic signing. PLAINTIFF was insinuating that my AGE was the reason I could not understand on September 13, 2016 that I was getting the “free roof with solar combo deal”. When I kept asking for clarification in writing, which eventually came after many weeks of asking in the form of a chart which is attached, I was made to feel that my AGE was the reason I was upset and asking so many questions and wanting reassurance in writing, that a normal, young person would not be having the problem I was having believing I was getting a free roof. It was implied that younger person would settle for the verbal explanation. I was made to feel that my request for the deal to be clarified in writing was because I was old and perhaps feeble minded, that people my age frequently give them a hard time like I was doing. I do not doubt that. I believe there might be grounds for a class action of all the elderly, disabled and poor who have been targeted by this type tax credit scam. The very people RENOVATE AMERICA/HERO/PETERSEN DEAN target with this type of financing that can be had with a low credit score are people PLAINTIFF knows full well and in advance are not in the tax bracket to qualify for the tax credit. On behalf of all my feeble-minded peers, I pray a class action eventually does happen to afford people some relief and to put an end to this especially heinous predatory practice specifically aimed at the poor, disabled, ill and elderly. I have been informed by government agencies and attorneys that California is inundated with this type of tax credit scam financing. This makes it even harder to obtain an attorney on contingency because there are so many victims of this type of financing. Most victims find out a year after the contractor has done the work. In that regard, my case is different. I found out before the job was completed. PLAINTIFF began behaving bizarrely when I confronted them with the truth from H&R Block.

It is appalling that PLAINTIFF in Item 3 is claiming to be unaware of the true names and capacities of defendants sued herein in BC661819. PLAINTIFF knew their mark inside and out. This feigned ignorance is part of the effort to paint a false impression of DEFENDANT and convince the court to allow PLAINTIFF to wrongfully take a home away from a citizen with a perfect payment history of all her bills, verified by all three credit bureaus. I may have had a very low credit score in 2016 due to a scam the CFPB stopped OCWEN from getting away with (reversing loan modifications of homeowners with perfect payment histories). My credit score was 420 for a year but my credit history does not lie. I have had a perfect payment history since I became a single mom, since I got power attorney to pay my ex-husband’s debts, since I got a HAMP loan modification with OCWEN and pulled the house out of foreclosure.

In 2016 I received the HAMP INCENTIVE $5000 award applied to my loan principle for NEVER missing a payment, NEVER BEING LATE, EVER on a house payment.  HONDA FINANCE can verify that I was NEVER late on a payment EVER when the court allowed me to reaffirm my HONDA debt keep my HONDA after a horrible slash and burn divorce where my ex-husband told an attorney he WANTED the house to go into foreclosure because he was inheriting his parent’s house and was angry that I chose to stand by my autistic son (his stepson) instead of running off with him without the “burden of autism” which he had grown tired of. The attorney told me that he could see I was frightened but that sometimes divorce is a good thing, that JAMES and I would be better off. It took me six years to save our house. It is shocking that PLAINTIFF is so flippant about taking houses away from people, as if taking homes away from people is their main source of income and home repair is just the gateway to get access to houses to snatch.

PLAINTIFF decided to scrap my real life, the life in which all I asked of my ex-husband was that he sign a power of attorney to allow me to pay his bills so I could keep the house and pull it out of foreclosure. PLAINTIFF decided to ERASE my real life history, a life where I once told a judge in this very courthouse that I did not want child support even though the judge told me that after 14 years of marriage and JAMES MARSHALL being autistic, was entitled. With an embarassing river of tears rolling down my face, 14 years of tears released without warning that day in court, I told the judge I did not want the support. I did not know where those tears came from but I could not stop them. It was like my head was full of water and it was leaking out of my eyes. My ex-husband was likely to fight nonstop about having to pay child support because he had complained that he was AFRAID that he would be forced to pay child support and had already hurt JAMES’ feelings enough. In the best interest of my son, JAMES MARSHALL I decided not to enter into a bitter battle that would go on for years. I canceled my in pro per petition for divorce and told my ex-husband that he could completely control the divorce process, use his family’s attorney and calm down because I was not going to ask for anything. I promised my son peace and quiet. I promised JAMES no one would ever blame him for everything anymore, that it was over.

Even with all my efforts to make my ex-husband calm down, the judge said he would leave it open and I could come back if we ever needed the child support. I never came back to ask for child support even though my ex-husband and his family are all well off and could afford expensive attorneys. Perhaps I cried a river that day because it was finally over. My son and I would have a difficult time financially but there would be no more screaming and yelling about autism being the reason my ex-husband was upset about everything. We were off the hook. I gave James happy birthdays and holidays. I did not subject him to the family that turned him away at the family Christmas party and broke his heart. I did what was best for JAMES. But PLAINTIFF has decided to create a new version of me to portray to the court as a gold digger, as they did in writing to Pat Framke of CAP SPECIALTY, the insurer of their BOND: “Miss Marshall is the kind of person who wants to get something for nothing.”

My actions in life, my documents filed with the CFPB, my credit history, my perfect payment history is not something PLAINTIFF can rob me of, but that is what they are attempting to do in BC661819.

I am not the kind of person who wants to get something for nothing. It is abundantly documented that I am in fact the opposite of that, the type of person who will forego “entitlements” to do the right thing, to afford an autistic person the opportunity to have a happy life and live in society instead of an institution.

When I find an attorney to represent us on contingency in BC661819, I will also ask them if I may sue DEFENDANT for defamation of character for that letter they wrote to CAP SPECIALTY trying to portray me as a gold digger. For the sake of argument, if I was a gold digger, what kind of gold digger goes after solar panels and roof shingles? We could not afford to run an air-conditioner and every summer SOCIAL SERVICES calls to remind us when it is not safe to stay in our home certain hours of that day due to the heat. What kind of gold digger spends 35 years taking care of an autistic person, changing diapers, sleeping in a chair by his bed when he is ill, doesn’t date, doesn’t hang out in bars to con gullible men out of fur coats and diamonds but is still evil and decides to express her evilness by being a 24/7 care-provider and stealing solar panels powerful enough to power the neighborhood but she doesn’t own an air-conditioner and can’t afford to buy one? None of this adds up. Who buys solar panels so expensive they can’t afford to buy an air-conditioner? H R Block said I would be approximately 88 years old before I could finally afford to buy an air-conditioner, IF I didn’t lose the house and I would lose the house because I would not be able to afford the balloon. Not only is PLAINTIFF maligning me by calling me the kind of woman who rips people off, they are insinuating I am so bad at being a gold digger that I would steal solar panels and roof shingles instead of a hot car, jewelry, fun vacations and the stuff other gold diggers go for. For the record, when H&R Block verified that RENOVATE AMERICA/HERO/PETERSEN DEAN were conducting a tax credit scam, I agreed and even was the first to suggest the settlement of removing the unaffordable solar panels, panels it was crystal clear I could not afford. I am not the party that broke that agreement. PLAINTIFF broke that agreement.

ITEM 7 GENERAL ALLEGATIONS PETERSEN DEAN COMPLAINT:

On September 12, 2016 HERO/RENOVATE AMERICA approved the project. AT ALL TIMES PLAINTIFF understood that they were to be paid directly by HERO/RENOVATE AMERICA and not by DEFENDANT. On September 13, 2016 PLAINTIFF did electronically deposit DEFENDANTS signature on TWO questionable contracts that did not match the “free roof with solar package” DEFENDANT had verbally entered into an agreement to accept on the basis that it would cost approximately $20,000 after discounts and possibly less with all the savings factored in and DEFENDANT has been raising sand about it ever since.

DEFENDANT kept asking, “Why are there TWO contracts?” HR BLOCK confirmed absolutely that there would be NO SAVINGS, NO TAX CREDIT and DEFENDANT and her disabled son would be living in stark poverty till she was 88 years old, unable to afford an air-conditioner while paying off solar panels that could power the whole neighborhood. DEFENDANT would be enslaved paying for solar panels she would never be able to use for air-conditioning and would be paying three times more for electricity than she would have if she never met PLAINTIFF and never fell for their scam. HR BLOCK said in all likelihood DEFENDANT would lose her house in 2017 if she signed off on the deal as it was.

Again, PLAINTIFF reneged on the January 2017 agreement to remove the unaffordable solar panels. Walter Smith of the Los Angeles Department of Water and Power can confirm the job was never finished and the solar panels were never turned on.

Furthermore, in 2017 DWP solar program #303146129 advised me that I was eligible to be paid $300 a year by DWP if I let DWP put solar panels on our house. I wanted to accept the offer but PLAINTIFF refused to allow me to accept the offer by refusing to keep their promise to remove the solar panels that had never been activated. DWP said PETERSEN DEAN had to remove their panels so DWP could install theirs.

In the course of finding out from BUILDING AND SAFETY that PETERSEN DEAN was refusing to ask for a SOLAR PERMIT REFUND that is routinely asked for when solar panels are removed, BUILDING AND SAFETY informed me that PETERSEN DEAN lied about having a permit to alter my water heater. BUILDING AND SAFETY told me that the last permit drawn concerning my water heater was in 2008. PETERSEN DEAN altered my water heater on November 2, 2016 and lied about having a permit to do so. PETERSEN DEAN also asked me to sign a document stating that my fire alarms and carbon monoxide monitors had been inspected by a man. No man had come into the house to inspect these items. I protested that no man had inspected my fire alarms, that two of them are broken and that I do not have carbon monoxide monitors. PETERSEN DEAN told me the form didn’t matter, I just had to sign it for routine reasons. AGAIN, I was made to feel that my concern, worry and questions were because of my advanced AGE, that young, healthy, reasonable people do not fret the details and hold things up like us old people do.

ITEM 9

DEFENDANT did NOT agree to pay PLAINTIFF directly. DEFENDANT agreed that PLAINTIFF was to be paid according to the HERO FINANCING PROGRAM guidelines after satisfactory completion of the job including the repair of any damages made by PLAINTIFF to the property. There were considerable damages as documented by CSLB CASE SF 2016 9935 and none of those damages have been repaired or remediated at all. PLAINTIFF has deliberately concealed from the court repair estimates that PLAINTIFF asked for from contractors.

ITEM 10

This is an egregious and deliberate lie to the court. PLAINTIFF is playing the court system as a fool. There is plenty of credible documentation from multiple agencies and witnesses that the job was abandoned, not completed. The CSLB is a respectable agency and found PETERSEN DEAN to be in violation for not doing the job correctly, not finishing the job. It is DEFENDANT’S belief that PLAINTIFF fully expected this case to move though the court without DEFENDANT finding out about it until after PLAINTIFF conned a judgement out of the court.

DEFENDANT was made aware of the case by a law firm in Santa Monica that DEFENDANT was consulting about suing RENOVATE AMERICA/HERO FINANCING for letting their contractor go rogue on DEFENDANT after all their promises that it would not happen, that PETERSEN DEAN would take down the panels and that DEFENDANT should not take the constant threats of MECHANICS LIENS seriously. Had DEFENDANT only sought remedy through the complaint to the CSLB and had DEFENDANT not consulted an attorney, PLAINTIFF might have successfully navigated their corrupt, dishonest BC661819 through the court without getting caught until after the fact.

On the first occasion that DEFENDANT’S autistic son JAMES and DEFENDANT appeared in court, DEFENDANT arrived early and DEFENDANT kept trying the door to Department 32, but it was locked. To DEFENDANT’S horror she recognized PLAINTIFF’S attorney GEORGE MILIONIS from his photograph on the web and he looked equally horrified to see DEFENDANT and her son JAMES. DEFENDANT had been told so many stories by PETERSEN DEAN men about what GEORGE MILIONIS was going to do to DEFENDANT and her son that DEFENDANT was shocked by PLAINTIFF’S attorney’s reaction to them. GEORGE MILIONIS was seated close to DEFENDANT could see JAMES was in pain and that DEFENDANT had to keep taking JAMES back to the bathroom.

(DEFENDANT had to keep changing JAMES’ double diapers, due to excessive urination and loss of bladder control that can be verified by Dr. Ronald Solomon, JAMES MARSHALL’s urologist. Medications meant to help JAMES cope with the unbearable stress this housing nightmare caused JAMES to lose all control of his bladder and the excessive urination made it necessary to wear two diapers. It is astounding the volume he urinates, the diapers hit the trash can with a thud and feel so heavy with urine it is as if they had a cantaloupe in them. Thankfully the bathroom was nearby.)

GEORGE K MILIONIS saw DEFENDANT trying the door of Department 32. He saw DEFENDANT was nervous. DEFENDANT noticed that GEORGE MILIONIS looked uncomfortable as well. GEORGE MILIONIS was sitting on the bench next to DEFENDANT, not across the hall from DEFENDANT. DEFENDANT worried if she would know what to say if he said something to her. He did not say hello. He did not say anything.

Very close to 8:30 am JAMES cried out and DEFENDANT rushed him to the bathroom and changed his diapers as fast as she could and rushed back to the courtroom. The door was unlocked and DEFENDANT saw GEORGE K MILIONIS going down the hallway as if a fire drill was being conducted. DEFENDANT was mortified to learn that GEORGE K MILIONIS deliberately let the court think DEFENDANT was not present. GEORGE K MILIONIS definitely saw and recognized DEFENDANT. GEORGE K MILIONIS had seen plenty of photos of us on social media as well because DEFENDANT used social media to contact him, HERO, RENOVATE AMERICA, and various government agencies that help with housing problems as well as attorneys who might potentially represent DEFENDANT in this matter.

GEORGE MILIONIS has been outraged that DEFENDANT used twitter, yelp, blogspot and other forms of social media to seek help in this distressing and dangerous matter. GEORGE K MILIONIS’S anger made it seem like if it was up to him, he would remove our yelp review and ban DEFENDANT from being able to use social media to publicly discuss her situation and how it was impacting her autistic son. DEFENDANT missed the hearing that day by several minutes. DEFENDANT tried to call GEORGE MILIONIS but he did not return DEFENDANT’S phone call. DEFENDANT believes that her use of social media and her complaint to the CSLB caused GEORGE MILIONIS to back off and refrain from using aggressive forms of intimidation because he was made to realize by DEFENDANT that everything he said to DEFENDANT was being reported to government agencies and published on DEFENDANT’S diary of events on blogspot. GEORGE MILIONIS’S skittish behavior that day in the courthouse hallway confirmed DEFENDANT’S suspicion that PLAINTIFF never expected to encounter DEFENDANT and never had any intention of speaking to DEFENDANT again.

PLAINTIFF was clearly trying to get a judgement to take DEFENDANT’S home before DEFENDANT found out about it. PLAINTIFF avoided DEFENDANT like the plague while giving the court false and conflicting impressions that PLAINTIFF was in constant contact asking DEFENDANT to pay a bill without actually billing her and claiming DEFENDANT was refusing to pay bills that were never sent, producing no copies of billings mailed, no evidence of use of a collection agency, no evidence of reporting the debt to the credit bureaus and yet at the same time PLAINTIFF claimed on the other hand that PLAINTIFF could not find DEFENDANT they claimed to be getting refusals from and yet PLAINTIFF wrote letters to their insurance CAP SPECIALTY which prove PLAINTIFF knew where DEFENDANT was and prove that DEFENDANT was in constant communication with CAP SPECIALITY and the CSLB regarding this matter and everyone knew where to find DEFENDANT except PLAINTIFF.

DEFENDANT submits that PLAINTIFF’S bizarre, skittish, conflicting behaviors present a pattern that suggests PLAINTIFF was nefariously attempting to seize DEFENTANT’S property.

As stated previously, the last time GEORGE MILIONIS spoke to DEFENDANT was over the phone when he made the offer to DEFENDANT to settle for $19,000 instead of $34,000 knowing fully well DEFENDANT could not qualify for a loan of that amount, that PLAINTIFF needed to go back to the original financing at the HERO FINANCING PROGRAM to resolve this matter and stop trying to get DEFENDANT to be afraid enough to frighten DEFENDANT into dropping her HERO FINANCING. During that phone conversation he gruffy told DEFENDANT that HERO has nothing to do with this, that this was only between him and her. It was clear that if DEFENDANT didn’t take his $19,000 offer and give up her HERO FINANCING, he was going to take away DEFENDANT’S home. MR MILIONIS knew at all times that DEFENDANT could not afford to take his offer to pay for the roof and half of the solar when all of the solar was supposed to be taken down and it had never been finished and turned on. MR MILIONIS has not talked to DEFENDANT since.

DEFENDANT believes that by publishing this situation in her blog/diary of this ordeal PETERSENDEAN.BLOGSPOT.COM, MR MILIONIS grew to feel blocked from treating DEFENDANT the way he might have because DEFENDANT made public what MR MILIONIS’S “good cop” told DEFENDANT the “bad cop” would do to her and her son.

DEFENDANT believes MR MILIONIS still has hope of winning the case by default, on the merits of DEFENDANT making a serious enough clerical error to cause DEFENDANTS to lose their home. As the court has seen, DEFENDANT has made errors while learning how to properly file documents. DEFENDANT’S son is autistic. Both DEFENDANT and her son JAMES MARSHALL are ill at this time and bedridden when not in court trying to file this ANSWER properly. DEFENDANT is dyslexic and under stress DEFENDANT also has difficulty doing unfamiliar paperwork. If it is something DEFENDANT knows how to do, DEFENDANT can do it but if it is new, DEFENDANT makes mistakes and has to keep correcting them as she finds them. DEFENDANT believed she was supposed to get the document stamped by the court, then serve it and then come back and file the proof of service. It was a process of trial and error for DEFENDANT to figure out what she was doing wrong. It was exacerbated by both DEFENDANT and her son having fever, dehydration, lung infections and finding it difficult to stand up in line at the filing window. JAMES leaned on DEFENDANT and a stranger said how sweet is was that he loved his mommy so. If fact JAMES was leaning on DEFENDANT because he could not stand up on his own. DEFENDANT was also dizzy and could not hold the weight of her purse and the legal documents. DEFENDANT had to place them on the floor and push them forward until it was her turn at the filing window.  The terror of the possibly of losing their home because of a clerical error by DEFENDANT is palpable like a constant heavy weight upon DEFENDANTS.

Having a copy of the SUMMONS AND COMPLAINT would have helped DEFENDANT. The week before the April 23, deadline DEFENDANT was seriously ill with a bad fever and recurrent lung infection (which DEFENDANT still has) and DEFENDANT was talking on the phone with an attorney in Orange County who said DEFENDANT had a good case but that his firm could not take it on contingency, DEFENDANT would have to raise money some how to hire an attorney or keep looking for a firm large enough to afford take it on contingency. He spoke to me for two hours approximately and went stone cold silent, then sputtered a bit when he heard me say I still did not get served a copy of the SUMMONS and COMPLAINT yet, and that PETERSEN DEAN had to be given my email directly by the judge before they would use it again even though it was plastered all over the case filings and they had used it in 2016 when they WANTED to. “You don’t have a copy of the complaint?” He sputtered the words because it seemed outrageous to him. DEFENDANT explained to the Orange County law firm that PLAINTIFF had been giving me the silent treatment while maintaining to the court that I was rejecting requests they were not actually making to me. It was and is dumbfounding that PLAINTIFF is behaving in this bizarre manner.

PETERSEN DEAN only finally emailed DEFENDANT the complaint on 4-23-18 after days of DEFENDANT calling, leaving messages on their machine stating that she needed a copy of the COMPLAINT and sending emails demanding they properly serve her a hard copy via the mail and email her the COMPLAINT since they can no longer claim they don’t know how to contact her after the judge told them how and read her email to PLAINTIFF. It took DEFENDANT threating to tell the court to get them to email a copy of the COMPLAINT. PLAINTIFF still has not OFFICIALLY served DEFENDANT a copy of the COMPLAINT. It is DEFENDANT’S guess that maybe PLAINTIFF thinks they are exempt because they filed a document saying they TRIED to serve DEFENDANT at the house (when PLAINTIFF knew full well DEFENDANT was living in emergency housing at the MARRIOT). Documents that DEFENDANT received from PLAINTIFF were not copies of the COMPLAINT. Documents DEFENDANT received from PLAINTIFF were CASE MANAGEMENT documents.

DEFENDANT believes GEORGE MILIONIS intends to win this case by demanding the court rule that DEFENDANT made a fatal clerical error, not by the “merit” of PLAINTIFF’S false claims.

The week before April 23, 2018 with multiple attorneys DEFENDANT consulted as potentially representing her as witnesses who can be called upon to testify, DEFENDANT was so sick she could hardly talk or finish sentences without choking and coughing for long periods. DEFENDANT called PLAINTIFF and begged them to ask the court for a delay due to fever and lung infection. JAMES was bedridden as well and dizzy. JAMES MARSHALL’S doctor was concerned JAMES might fall or faint again and be injured again by falling. DEFENDANT fell from physical weakness twice on APRIL 23, 2018 and injured/bruised her knee on the first fall and bruised her toes on the second fall.

GEORGE MILIONIS refused to return DEFENDANT’S urgent calls. He refused to talk to DEFENDANT at all yet had the gall to state in his CASE MANAGEMENT STATEMENT that he communicated with DEFENDANT. His receptionist relayed a message to me: “No”. I could not reschedule until after my fever broke. GEORGE MILIONIS did not discuss the case with DEFENDANT as he falsely suggested to the court. GEORGE MILIONIS flat refused to communicate with DEFENDANT at all other than that one phone call asking her to pay $19,000 and give up the HERO FINANCING, never mention HERO again.

If GEORGE MILIONIS calls DEFENDANT tomorrow and asks DEFENDANT if she will agree to a delay on the May 14, 2018 hearing because of his health or the health of a family member or office member, DEFENDANT would without hesitation agree. Nothing in this world is worth becoming a bad person over. DEFENDANT wouldn’t be nice because she is a fool or a “sucker” or as DAVE SHANHOLTZER put it, she is a person “her AGE” and therefore not too bright. DEFENDANT would be nice because she wants to feel good about herself. DEFENDANT wants to have a happy life with her autistic son for however much longer they are on this earth. Being mean to someone would only mess her up inside. DEFENDANT maintains that standing up for her rights is not the same thing as being mean.

ITEM 11:

At all times PLAINTIFF knew it was unprofessional, cruel, illegal and wrong to directly ask DEFENDANT to pay. PLAINTIFF did it only to create an impression to justify filing case BC661819. PLAINTIFF knew they could not successfully file BC661819 if they included the true and correct fact that PLAINTIFF was to be paid by HERO FINANCE, not DEFENDANT. AT ALL TIMES PLAINTIFF knew they were to be paid by RENOVATE AMERICA/HERO FINANCING but pretended otherwise to deceive the court into making a judgement. This charade is for the benefit of convincing the court that an agreement existed that in fact did not exist and that the viable agreement with RENOVATE AMERICA/HERO FINANCING did not exist because PLAINTIFF didn’t want to pay for damages to the property, didn’t want to remove the solar panels as agreed and went rogue and decided to create a new reality and convince the court it was true. That is the fake reality where DEFENDANT is supposed to be a bum, a gold digger who runs around stealing roof shingles instead of the usual vacations, diamonds and pearls. What a dismal portrait of DEFENDANT.

DR RONALD SOLOMON probably wondered why my eyes filled with tears when he said DEFENDANT was a good mom, that he doesn’t know how DEFENDANT does it, how she weathers JAMES’ painful regressions caused by this housing nightmare. DR SOLOMON doesn’t know that PLAINTIFF is telling the court that DEFENDANT is a bad, irresponsible person. Getting a compliment from DR SOLOMON brought tears to DEFENDANT’S eyes.

DEFENDANT is not going to abandon JAMES MARSHALL for not being able to tolerate what PLAINTIFF has done to JAMES’ bedroom, his lungs, his life. DEFENDANT will admit it takes super strength to stay up 24/7 with someone who is so distressed that they are giving up on life and trying to head bang their head through the wall and can’t stop screaming. In the back of DEFENDANT’S mind she fears the regressions might become permanent since they began happening almost back to back since PETERSEN DEAN disrupted their lives. The terror that this might become who JAMES MARSHALL is permanently is very real. It happens. Autistic people can’t take this stuff. This is what the PETERSEN DEAN’S “good cop” was referring to when he said DEFENDANT better do as he says or GEORGE MILIONIS will step in and DEFENDANT’S lives will become unimaginable.  It is terrifying but DEFENDANT is determined to save her son and walk him out of this and back into normal life. DEFENDANTS lives have been a living hell since November 2, 2016 when PETERSEN DEAN began trying to manipulate and victimize them. PETERSEN DEAN actually was victimizing DEFENDANT from the start but it was November 2, 2018 when the pain hit very bad and kept getting worse and it became very clear something was seriously wrong, that PLAINTIFF meant us harm.

FIRST CAUSE OF ACTION

ITEM 13

On or about January 13, 2017, while GEORGE K MILIONIS was secretly filing MECHANICS LIENS that he did not send DEFENDANT notice of, PETERSEN DEAN had HELENA SHI convincing DEFENDANT that PETERSEN DEAN was in the process of arranging to remove the solar panels as per agreement with HERO and DEFENDANT. The deceptive game began here but did not end here. There are numerous examples of this deceptive behavior that continued on even to the present. It is astounding the PLAINTIFF is putting so much effort into concealing information and creating an alternate version of reality in order to gain financially.

That much effort and cunning placed into honest labor would make a business prosper. PLAINTIFF could make more HONEST money if they hired someone with even the limited social media experience DEFENDANT has instead of trying to cheat money out of people. Hiring a skilled social media employee would help PLANTIFF learn that a good, reputable business doesn’t “BLOCK” customers on twitter. The focus should be on promoting an affordable solar product, not tricking people into buying a life-destroying, iceberg hitting TITANIC of a product and then “BLOCKING” the customers on twitter as they cry for rescue. It boggles the mind why anyone still believes crime pays. Crime, from my observation of this matter only seems to cause enormous human suffering and eats away at the soul of the person willing to destroy lives for money. I do not believe there is such a thing as a happy criminal. They seem pretty angry all the time to me. To me, from where I see what is unfolding, this is a miserable way to make money.

My son and I might not survive this ordeal. It became time to notify my son’s doctors of the seriousness of this life-threatening case. SEE EXHIBIT C

SECOND CAUSE OF ACTION

ITEM 18

DEFENDANT did not breach the contract. PLAINTIFF breached the contract. PLAINTIFF did not complete the job as agreed. PLAINTIFF violated the terms of HERO FINANCING and lied to DEFENDANT. PLAINTIFF had an opportunity to settle the matter and agreed to that opportunity then reneged on the agreement to remove the solar panels as per agreement with me and HERO FINANCING. Falsely accusing DEFENDANT of BREACH OF CONTRACT was the only way PLAINTIFF could think of to attempt to pull of this heist. To get away with this heist, PLAINTIFF needed to conceal information from DEFENDANT and the courts. DEFENDANT was warned by PETERSEN DEAN employees that GEORGE MILIONIS was adept at this and that my son and I likely would not survive it. DEFENDANT as told by various PETERSEN DEAN and one anonymous PETERSEN DEAN employee who sent a letter, that PLAINTIFF destroys people, that the situation would become unbearable and hopeless. I think that is an accurate description but I think it would have been worse for JAMES and me if I had not filed a CSLB complaint, had not written a yelp review and had not started a diary of events on blogspot.com. My son and I probably would have died of the horrible stress by now if I had not done those things to give us some bearing and hope.

THIRD CAUSE OF ACTION

ITEM 19

DEFENDANT did not promise to pay PLAINTIFF directly. DEFENDANT agreed that PLAINTIFF would be paid via HERO FINANCING as per agreement upon satisfactory completion of the job. The open CSLB case is evidence that the job was not completed. PLAINTIFF sought to defy all of the HERO FINANCING rules, demanding to be paid in advance, refusing to make repairs, agreeing to remove panels and then reneging of the agreement. PLAINTIFF behaved erratic, out of control and not at all like a proper business. DEFENDANT feared/fears she is dealing with mobsters who make more money doing shady things like this than they make doing home repairs.

ITEM 20

PLAINTIFF is trying to deceive the court into believing DEFENDANT was supposed to receive payment from DEFENDANT. PLANITIFF knows full well they were to paid by RENOVATE AMERICA, not directly from DEFENDANT. PLAINTIFF is putting on a show for the court, knowing full well that what PLAINTIFF is telling the court is not factual.

FOURTH CAUSE OF ACTION

ITEM 22

PLAINTIFF is a HERO PROGRAM/RENOVATE AMERICA contractor. PLAINTIFF is deliberately neglecting to inform the court of this third party which is the actual party that was to pay PLAINTIFF. DEFENDANT had an agreement to pay HERO a year after the project was completed and it never was completed. HERO agreed that the cost of the solar panels had been misrepresented and agreed with the solution of removing the solar panels and financing the roof only. PLAINTIFF blew this deal deliberately and deceptively, pretending to agree to it the very same week PLAINTIFF was in court filing MECHNICS LEINS.

ITEM 23:

PLAINTIFF kept a deceptive record, a second set of books designed to trick the court into believing there was no HERO financing. PLAINTIFF tried to keep DEFENDANT from telling the court by not serving her the SUMMONS and COMPLAINT and lying to the court and maintaining they could not serve DEFENDANT.

ITEM 24:

The balance due on this project has changed so many times that it boggles the mind almost as much as the new term DEFENDANT learned from PLAINTIFF: “thirsty wood”.  PLAINTIFF explained to DEFENDANT that the rotten wood left on her roof was not actually rotten wood, it was “thirsty wood”. Unfortunately for DEFENDANT, PLAINTIFF has equally wild ideas when it comes to money and accounting as well. I was told $10,000+ would “fall off” my debt to HERO…”fall off” the way one falls off cliff? I was told I would save $300 a month on my LADWP electrical bill when in fact I pay an average of $60 - $80 per month. HERO FINANCING had other contractors give me estimates for other projects such as replacing a front door that had been damaged by mold. The HERO Home Depot contractor wanted to charge thousands more for the door than if I just went to Home Depot without the HERO program. When asked WHY he wanted to charge thousands for the same door, he said in writing that he had to dispose of it. I wrote back that I could drag it to the curb for a free WASTE MANAGEMENT pick up, that it was not nuclear waste. This HERO contractor told me that my insurance would probably pay for it, why didn’t I just run it by them. I called both the HOA insurance, FARMERS and my home insurance ASSURANT, since they were bickering over who was responsible for the mold and I reported it to TOM GOETZINGER of the California Department of Insurance. This may be the reason HERO FINANCING disappeared like a thief in the night, just vanished. HERO did try to resolve the matter by agreeing to remove the solar panels but apparently PLAINTIFF had other ideas and concocted the story you see in court in case BC661819 today.

After the shock of seeing DEFENDANT found out about the case and appeared in court with her autistic son JAMES, PLAINTIFF’S attorney GEORGE MILIONIS tried to get DEFENDANT to agree to pay $19,000.00 outside of the HERO program. Before that occasion, both HERO FINANCING and PLAINTIFF agreed that the panels would be removed and that DEFENDANT would pay HERO $10,000 for the roof only minus the electrical, stucco and wood repairs which most estimates said would be $4000.00 stucco remediation, $2,000+ for electrical repairs but I did not receive the estimates for the broken concrete in the back yard where PETERSEN DEAN employees used my patio planter as a work bench and knocked a large chunk of concrete out, causing the very large planter to split open and I did not receive an estimate yet for the roof because no one is allowed up there until CSLB completes their case because PLAINTIFF would blame anyone who went up there for any damages found. Rather than deal with being caught red handed by H&R BLOCK for the tax credit scam and rather than facing that everyone must pay for property they damage, PLAINTIFF decided to take our home away from us.

AT ALL TIMES PLAINTIFF knew asking me for money was wrong. PLAINTIFF was to be paid by HERO, not me. PLAINTIFF threatened me then gave me the silent treatment for nearly two years. PLAINTIFF would have the court believe there was communication where there was none. PLAINTIFF would have the court believe there was a monthly payment that was not being made. There was no such arrangement. There was no financial arrangement with PETERSEN DEAN. DEFENDANT’S payment arrangement was with HERO FINANCING.

ITEM 25:

DEFENDANT at no time agreed to directly pay PLAINTIFF. PLAINTIFF tried for months from November 2, 2016 to January 2017 to trick and scare DEFENDANT into signing documents that would cause her to lose her home. AT ALL TIMES PLAINTIFF knew they were supposed to be paid by HERO FINANCING. PLAINTIFF is a RENOVATE AMERICA/HERO contractor. They know full well where they get their paycheck from and what they have to do to get that pay check. Harassing and threating DEFENDANT is not how a RENOVATE AMERICA/HERO contactor gets paid. DEFENDANT never agreed to pay PLAINTIFF directly.

PLAINTIFF electronically put DEFENDANT’S name and initials on more contracts than they discussed verbally with DEFENDANT. PLAINTIFF openly falsified inspection documents on two occasions in front of DEFENDANT as if every body does this, as if it is common practice to say an inspection happened when it didn’t. With this appalling pattern of deception, any contract presented by PLAINTIFF should be viewed as suspect. I never experienced so many desperate, crazy financial changes in my life.

No business I have ever done business with has acted this crazy, not even did OCWEN LOAN SERVICING act this erratic and OCWEN has a reputation with the CFPB for pulling stunts. From the frantic, desperate, petty behavior of PLAINTIFF I wondered if PLAINTIFF might be in serious financial trouble because the way they were acting seemed so desperate.

On more than one occasion I feared for our lives.

AS TO THE CHARGE THAT PLAINTIFF MADE AGAINST DEFENDANT IN WRITING TO CAP SPECIALTY INSURANCE, THE INSURER OF PETERSEN DEAN’S BOND:

TO REFUTE what PLAINTIFF has told their insurance company, CAP SPECIALTY bond insurance about me being just another example of a person who wants to get something for nothing, I must provide documented history of my life that refutes I was ever that sort of person, information that is documented in divorce records and other public documents that goes to this point. I am not a bad person. I do not rip people off. I have a perfect payment history documented by the three credit bureaus. I am a single mom who told a judge she would make do without child support. I want my son to be safe and happy. I saw firsthand what monsters money can make of people. The Israeli consulate notified me that my son’s birth father committed suicide in Israel many years ago after nearly 30 years of refusing to pay child support and hiding from the law. My son and I had therapy in the 1980’s because of how violent my husband became over money. He would beat me during his visitation visits for having purchased oranges, for having given his son James oranges because he said his mother wouldn’t give him oranges when he was little. I went to a battered woman’s shelter when I was pregnant and doctors told me I was so badly beaten that I should prepare myself, that I would lose the baby. I did not lose JAMES but he was born very weak and hurt and after years of therapy I made my choice in life. I chose life over money hands down.

When I recently learned of an inheritance in Israel that JAMES was entitled to, I spoke to the attorneys in Israel and learned that my ex-husband had committed suicide and that his suicide note mentioned money. I called the psychiatrist my son and I had seen for years in the 1980’s to recover from being battered. Back in the 1980’s all the therapists had warned me and other women in the battered woman’s shelter that if they stayed in the relationship they were afraid to leave, murder, suicide were very likely in their future. They were right in our case. He probably would have killed us too. He killed himself just like the psychiatrist predicted he would. I did not call the psychiatrist to start up therapy again. I called to touch base, to speak to someone who knew, to say, “You were right. It happened. Thank you for helping us escape that fate.” After many painful discussions and countless emails which I still have stored on my laptop and can provide copies to the court for review, I told the Israeli attorneys I wouldn’t fight with the child my ex-husband fathered after he went into hiding. That child was not disabled but he is bitter, angry and feels betrayed and abandoned by his father, so much so that he lied to the courts and told them JAMES MARSHALL did not exist. I told the attorney that it was my personal opinion that the court should split the inheritance between the two children and I would leave it to the court to decide what to do.

PLAINTIFF wants SUPERIOR COURT in LOS ANGELES to believe I am a greedy gold digger who goes around stealing roofing shingles and solar panels instead of the usual stuff gold diggers go for. If you compare notes with the Israeli court, they would never recognize the version of me that PLAINTIFF has concocted for financial PLAINTIFF’S gain.

I let the Israeli court know that if I received funds for JAMES from the inheritance that I would use the money for the three emergency dental surgeries to attempt to save what is left of JAMES’ teeth. I told the Israeli court that PETERSEN DEAN/ PLAINTIFF had tied up the equity in our house and that I was unable to access it to help my son get his broken, medication dissolved teeth capped to prevent them from all being lost. AT ALL TIMES I updated PETERSEN DEAN and their insurance CAP SPECIALTY as to the pain that JAMES MARSHALL was suffering, the agonizing pain JAMES was living with on a daily basis because PETERSEN DEAN had tied up our equity that was slated to be used to repair JAMES’s teeth once the CFPB got OCWEN LOAN MANAGING to correctly report my perfect payment history to the three credit bureaus. Almost to the day that my credit score shot up from 420 to 730, PETERSEN DEAN tied up our equity and prevented the three dental surgeries. I am currently asking DR SNOW ORTHODONTICS in ENCINO to help me find help for JAMES since this PETERSEN DEAN nightmare is still going on and several dentists say they can no longer save many of JAMES’ teeth because of the delay.

ITEM 26:

PLAINTIFF did not “repeatedly demand” payment. PLAINTIFF went dark as of January 2017. PLAINTIFF tried unsuccessfully to coerce DEFENDANT into signing suspicious documents from November 2, 2017 until January 13, 2017 and then both DEFENDANT and RENOVATE AMERICA/HERO seemed to fall off the face of the earth. Both refused to take my calls. Both refused to answer my emails. I began consulting attorneys to sue HERO and I filed the CSLB compliant against PLAINTIFF for abandoning the job and the financing. JAMES was so ill that I could not have filed the CSLB without the help of the MARRIOT staff at our emergency housing hotel. Our emergency housing was running out. Everyone was worried about how James would survive the onslaught of distress.

PLAINTIFF never once sent me a normal bill. It would have been illegal if they did. PLAINTIFF’S interactions with DEFENDANT were more like being mugged than any sort of business transaction. PLAINTIFF merely made ludicrous demands that I cough different amounts of money at different times ranging from $34,000 to $10,000 and that I pull this money out of thin air. I did not have a financing arrangement with PETERSEN DEAN. I was to pay HERO but both HERO and PETERSEN DEAN vanished. The demands for money they knew I didn’t have stopped. No reasonable financing plan was presented to as a possible plan to replace the miraculously vanished without a trace HERO FINANCING. The last time I spoke to GEORGE MILIONIS was when he called after he saw me and JAMES sitting on the bench in the hallway outside of Department 32. He asked for $19,000 out of the blue, no financing, just pull $19,000 out of thin air and give it to him. No HERO FINANCING, just cough up $19,000. MR MILIONIS came across as desperate and angry. I think he was angry because I said no and because JAMES and I found out about the case and showed up in court to try to hold the fort until we could find an attorney who would clean up this mess on contingency.

PLAINTIFF did not repeatedly demand the money. PLAINTIFF started the silent treatment in January 2017 and is still maintaining the silent treatment. GEORGE MILIONIS will not talk to me. He broke his vow of silence to call me and ask me for $19,000 and never spoke to me again since then. He does not send me bills.

ITEM 27:

DEFENDANT has not “failed to pay” any of her debts. PLAINTIFF has not reported DEFENDANT to the credit bureaus for nonpayment of debt because PLAINTIFF does not have that sort of contract with me and would likely get into more legal trouble for making false reports to the credit bureaus. DEFENDANT has suffered compounding financial hardships due to PLAINTIFF’S scheme and some of the losses suffered by JAMES MARSHALL are irrevocable. The calcifications he has developed in his leg muscles from hitting his legs repeatedly with his fists have cost him range of motion and are now a cancer risk we must monitor. The teeth he is losing cannot be replaced and due to his autism he is not a candidate for false teeth. How will JAMES eat food? He loves to eat. As is he cries when he eats because it hurts so. Will he have to drink liquified shakes and give up all the food he loves?  The damages are gut wrenching to list because they are ongoing and horrifying.

DEFENDANT most certainly did not refuse to pay PLAINTIFF. DEFENDANT refused to be bullied by PLAINTIFF into signing contracts. PLAINTIFF knows full well that any and all payment was due to him from HERO FINANCING, not DEFENDANT.

FIFTH CAUSE OF ACTION

OPEN BOOK ACCOUNT

ITEM 30:

This is the first time DEFENDANT has heard of this open book account. DEFENDANT cannot imagine how entries could be made in this cooked up book since no statements were ever generated, no bills were ever sent. That book must be page after page of:

Today we did not send anything to PLAINTIFF. PLAINTIFF called and we refused to take her call.

We told the court we didn’t know where she was and we told our insurance company we were not going to reimburse her for the emergency housing at the MARRIOTT where we knew she was staying.

It must be an interesting read if it reflects the bizarre “hide from JENNIFER MARSHALL but tell the court we don’t know where she is and tell CAP SPECIALTY we are not paying for that emergency housing at her room at the MARRIOTT”.  I imagine there are only falsified entries in that cook book.

ITEM 31:

The balance shown in this fictional book has nothing to do with the amount of money actually owed or the settlement arrangements agreed upon with HERO FINANCING and DEFENDANT. The actual settlement figure would be less than $10,000 after repairs, assuming PETERSEN DEAN didn’t owe DEFENDANT money for some of the repairs that estimates were not given that might bring the amount to over $10,000 in repairs. It is very likely that PLAINTIFF had to resort to an earlier figure that did not include the fake tax credit of $10,000 plus in order to justify filing this case in court for the opportunity to steal a house. The correct figure would not have permitted this case to be filed in small claims court because it would be in the red, PLAINTIFF would be filing a case in court telling the judge they owed me money for botching a job and attempting to pull off a tax credit scam as well. It was greed that opened the door for me to discover the tax credit scam. If PLAINTIFF has just made the repairs I would have signed off to allow HERO FINANCING to pay them before discovering from HR BLOCK in Spring 2017 that I was not going to get $10,000 off. Because of the unusual, erratic greedy actions of PLAINTIFF I demanded documents that made it clear it was a scam. The mold remediation going haywire also helped me discover the tax credit scam. HERO was so greedy and eager to get to replace the moldy door that they raised red flags when they told me to go ahead and rip off my insurance company, they might pay the grotesquely inflated figure, no harm in trying. I was flabbergasted by the suggestion. Over the top desperate greed displayed by both HERO FINANCING and PLAINTIFF was what tipped me off that something was very wrong. Most victims of this financing scam do not find out until a year after the contractor is long gone and HERO seizes the house because the bewildered homeowner finds out the hard way they are not really getting a $10,000+ tax credit. I found out BEFORE because both HERO and the PLAINTIFF were wigging out with greed. They felt the need for greed and had no shame. I lingered in the San Pedro police station long after the officer gave me the advice I needed. Don’t agree to meet strange men alone at the property. Don’t get bullied into signing things. Contact government agencies that help with housing problems. Discuss the situation with legal aid and attorneys. I wasn’t in a hurry to leave the station. I had to orient myself to the seriousness of the situation. When James and I got back to the Marriott emergency housing, I called my insurance adjuster, DAVID KLEIN and left a message on his voice mail saying that I know the emergency housing is not for this purpose but I am extremely grateful for the safety it is affording James and me during this frightening time. The hotel assured me that we were safe. They bent over backward to help me prepare and fax documents to the CSLB and attorneys to request help.

The balance in this fake account PLAINTIFF refers to in ITEM 31 has nothing to do with the reality of the balance of job in question. This number was selected so an UNLIMITED case could be filed in the hopes PLAINTIFF would be allowed to take our home away from us before we found out the case was filed.

ITEM 32:

This is a ludicrous claim. PLAINTIFF shot himself in the foot and it trying make others pay for his foot pain. After two years of being trapped in this real-life horror story, DEFENDANT’S son is losing his teeth, his legs and his sanity because due to autism he cannot comprehend what is going on and by now believes it will never end. What has PLAINTIFF lost? Is failing to complete a scam the sort of “loss” you can seek compensation for in court and from insurance?

PLAINTIFF did not finish the job. PLAINTIFF derailed mold remediation causing us to be exposed to stachybotrys mold all this time when it would have been removed in the fall of 2016 had they not frozen our world to a screeching halt. Did PLAINTIFF spend Thanksgiving 2016 vomiting their guts out in a hotel room with a high fever like DEFENDANT’S son did? Did PLAINTIFF fear for their life, fear they would lose their home every day and night for two years? What exactly did PLAINTIFF actually lose? PLAINTIFF committed the heinous acts of putting MECHANICS LEINS on a house that they did not complete work upon, misusing the MECHANICS LEIN process to try to coerce signatures prematurely, to circumvent justice and get money they did not honestly earn. Our loss is massive and ongoing. I could never afford the repairs DEFENDANT tried to stick me with. My son’s loss is gut wrenching to review but it must be reviewed. The PETERSEN DEAN “good cop” told me we would be steam rolled and our pain would be unimaginable, avoidable only by signing documents prematurely before the work was actually done. I made the choice to fight for our lives. If I signed my son and I would have lost our home in 2017 to the tax credit scam. I am literally fighting for our lives. DEFENDANT probably has many cases like this in court and probably never lost a night of sleep. Destroying us is just one of many “opportunities” to take money they do not deserve and have not honestly earned. We are not the first or the last victim of PLAINTIFF. PLAINTIFF cannot credibly claim a loss on an account that is in the red because of unfinished work, unrepaired damages to the property and financial fraud, misrepresentation of the costs and so on.

PLAINTIFF did not send the account to a collection agency and did not report the lack of payment to the three credit bureaus. These red flags should alert the court that something is very fishy about this claim.

SIXTH CAUSE OF ACTION

Quantum Meruit

ITEM 34:

DEFENDANT did not fail to pay for materials. AGAIN, PLAINTIFF was to be paid in full by RENOVATE AMERICA/HERO FINANCING for all expenses, materials, labor and equipment. PLAINTIFF could not be bothered to bring necessary equipment for cutting wood and other tasks. DEFENDANT saw PLAINTIFF use her concrete patio fixtures as work benches and split the concrete in two. DEFENDANT didn’t care and made no offer to repair the damage. If DEFENDANT had been foolish to sign the document PLAINTIFF was trying to force her to sign, none of these repairs would ever get done. PLAINTIFF was demanding I sign that they already fixed the broken items they had not actually fixed.

ITEM 35:

PLAINTIFF understands full well that the reasonable value of all unpaid labor, materials and services was to be paid by RENOVATE AMERICA/HERO FINANCE. PLAINTIFF is a contractor of RENOVATE AMERICA and understand completely that PLAINTIFF was not supposed to ask DEFENDANT for payment. PLAINTIFF should be denied attorney fees and should have to pay the court for DEFENDANTS legal expenses, reimburse the fee waiver program for unjustly causing the need for DEFENDANT to use that program to defend her family in a case that never should have been filed in the first place.

ALSO, PLAINTIFF is giving the impression to the court that PLAINTIFF actually billed DEFENDANT, sent bills to DEFENDANT. No bill was ever sent. There was not financing with PLAINTIFF. PLAINTIFF never sent this matter to a collection agency or reported it to the credit bureaus because that would risk discovery of the tax credit scam with the HERO PROGRAM that PLAINTIFF was attempting to bury.

SEVENTH CAUSE OF ACTION

Violation of Prompt Payment Statute

ITEM 37:

DEFENDANT did not violate California’s prompt-payment statues. PLAINTIFF abandoned the job, failed to comply with the rules of the HERO PROGRAM which was to pay DEFENDANT. PLAINTIFF is not entitled to 2% per month on the amounts not paid because DEFENDANTS actions and inactions caused HERO FINANCING not to pay PLAINTIFF.

ITEM 38:

PLAINTIFF is not entitled to attorney fees under the prompt-payment statues because the funds were not wrongfully withheld by HERO FINANCING. HERO FINANCING did not pay PLAINTIFF because PLAINTIFF abandoned the job and did not finish the work as agreed.

EIGHTH CAUSE OF ACTION

Declaratory Relief

ITEM 40:

Again, PLAINTIFF is concealing from the court that RENOVATE AMERICA/HERO FINANCE, who PETERSEN DEAN works with, decided not to pay PLAINTIFF when PLAINTIFF reneged on the agreement to remove the solar panels, complete the job and make repairs on the items PLAINTIFF damaged.

ON THE FIRST CAUSE OF ACTION

ITEM 1:

PLAINTIFF is not entitled to a judgement of $34,118.06. PLAINTIFF is not entitled to be paid for placing invalid MECHANICS LIENS upon a house when PLAINTIFF abandoned the job on November 2, 2016. When invalid MECHANIC LIENS are filed and the court and DEFENDANT are abused by malicious misuse of LIENS, PLAINTIFF is responsible for the expenses of PROPER removal of said LIENS and any legal expenses the malicious, improper use of the court cause DEFENDANT.  DEFENDANT was forced to buy copies of the MECHANICS LIENS with cash at the time because she did not have a fee waver yet and PLAINTIFF did not serve her a copy of the LIENS.

ITEM 2:

DEFENDANTS home should not be sold. PLAINTIFF is attempting to illegally seize DEFENDANT’S home with invalid MECHANICS LIENS. The two MECHANICS LIENS should be declared invalid and PLAINTIFF should pay for all the expenses of PROPERLY removing the LIENS from the title and for all the medical and dental damages caused to JAMES MARSHALL by PLAINTIFF making it impossible for DEFENDANT to access equity to pay for JAMES MARSHALLS three dental surgeries. PLAINTIFF should pay for the severe emotional distress caused to DEFENDANTS by making them live in fear day and night for years worrying if they would become homeless.

ITEM 3

PLAINTIFF should not be allowed for foreclose on a home when PLAINTIFF walked off the job on November 6, 2016 and never finished the work. PLAINTIFF was to be paid by RENOVATE AMERICA/HERO and yet concealed RENOVATE AMERICA/HERO from the court. PLAINTIFF may have promised HERO/RENOVATE AMERICA money to “disappear” so PLAINTIFF could concoct this attempted miscarriage of justice and seize a home.

ITEM 4

PLAINTIFF should not be granted a deficiency judgement. PLAINTIFF was to be paid by RENOVATE AMERICA/HERO FINANCING, their business partner, not directly by JENNIFER MARSHALL. PLAINTIFF caused the crisis by going rogue with greed.

ITEM 5

PLAINTIFF SHOULD NOT BE GRANTED A JUDGEMENT ALLOWING PLAINTIFF TO BECOME A PURCHASER OF DEFENDANT’S HOME AT A FORCLOSURE SALE. PLAINTIFF threatened to do this in 2016 if DEFENDANT did not sign documents that would push DEFENDANT into bankruptcy. PLAINTIFF appears to be in the business of stealing people’s homes, not in the business of home repair. PLAINTIFF did sloppy work and deliberately left our home in a state of disrepair and began talking about taking our home away from us the day they had a careless accident and didn’t feel like repairing it.

ON THE SECOND, THIRD, and FORTH CAUSES OF ACTION

ITEM SIX:

DEFENDANT PRAYS that PLAINTIFF not be granted this judgement.

ITEM SEVEN:

DEFENDANT PRAYS that PLAINTIFF be denied General and Compensatory damages because PLAINTIFF concealed HERO FINANCING from the court to trick the court into making this judgement.

ITEM EIGHT:

DEFENDANT PRAYS that PLAINTIFF be denied the 2% per month under the BUSINESS AND PROFESSIONS CODE. PLAINTIFF was unprofessional, did not finish the job and was supposed to be paid by their partner RENOVATE AMERICA/HERO FINANCE, not directly by DEFENDANT, so DEFENDANT did not and could not have done the things PLAINTIFF is accusing her of.

ITEM NINE:

DEFENDANT PRAYS that PLAINTIFF not be awarded attorney fees because it was DEFENDANTS idea to file an invalid case on an unfinished job and break the rules of HERO FINANCING.

ITEM NINE:

DEFENDANT PRAYS that PLAINTIFF not be granted attorney fees and costs.

ITEM TEN:

DEFENDANT PRAYS that PLAINTIFF not be granted interest, that PLAINTIFF be paid nothing for filing an invalid case.

ON THE EIGHTH CAUSE OF ACTION

ITEM 11

DEFENDANT PRAYS that PLAINTIFF not be granted this judgement.

ON ALL CAUSES OF ACTION

ITEM 12

DEFENDANT PRAYS PLAINTIFF be denied for the cost incurred herein.

ITEM 13

DEFENDANT PRAYS that the Court deems BC661819 to be an invalid case and that PLAINTIFF takes nothing.

Dated May 7, 2018                                                                                      

JENNIFER MARSHALL