It's Raining in LA and the PETERSEN DEAN roof is LEAKING

From: Jennifer E Marshall

Date: February 14, 2019 at 6:23:38 AM PST

To: George Konstantin Milionis Petersen Dean Attorney <gmilionis@petersendean.com>, Helena Shi <hshi@petersendean.com>, Rose Montes <rmontes@petersendean.com>, piu@doj.ca.gov, CapSpecialty Pat Framke Claim 00180540-06 # 0041327141 <pframke@capspecialty.com>, Blake J Woodhall Elite Legal Group <blake@elitelegalfirm.com>, Andrew Khouri <andrew.khouri@latimes.com>, Samuel Luquin CA17-013771 <sluquin@dcba.lacounty.gov>, CMiller@isd.lacounty.gov, DOJ AG Desirée Tulleners Deputy Attorney General State <Desiree.Tulleners@doj.ca.gov>, FRONTLINE <viewermail@frol.us>, Ted Lieu <lieu.staff@mail.house.gov>, San Diego Union Jeff McDonald <jeff.mcdonald@sduniontribune.com>, LA CITY ATTORNEY Consumer Protection <mike.n.feuer@lacity.org>, Frank Capetillo <frank.capetillo@lacity.org>, Dakota Smith <dakota.smith@latimes.com>, LA County Pace / HERO Cynthia Miller <rmohr@isd.lacounty.gov>, LA Times David Zahniser <david.zahniser@latimes.com>, CA Dept Of Insurance <thomas.goetzinger@insurance.ca.gov>, Donnette CDSS IHSS APB Cindy Inquiry Response <donnette.desantis@dss.ca.gov>, Court Call Judge Murphy Dept 32 <requestform@courtcall.com>, Joe Buscaino District 15 Fernando Navarrete <fernando.navarrete@lacity.org>, Sam Karimzadeh License 319914 <skarimzadeh.sklaw@gmail.com>, Sam Karimzadeh License 319914 <sam.karimzadeh@gmail.com>

Subject: The roof is leaking. My son might die because of what HERO FINANCING and PETERSEN DEAN have done to his life.

Dear DOJ AG  Desirée Tulleners Deputy Attorney General State,

and

George Konstantin Milionis, Petersen Dean Attorney BC661819, License 213092,

and

Sam Karimzadeh License 319914, Attorney for Petersen Dean who also mocked me in court for mentioning James was ill and in pain.

Blake J Woodhall Elite Legal Group, Attorney for Petersen Dean,

and

CA Dept Of Insurance Tom Goetzinger,

and

Consumer Business Affairs  Case RE 17-01371 Samuel Luquin

and

LA County Pace / HERO Cynthia Miller

and

CapSpecialty Pat Framke Claim 00180540-06 # 0041327141,

and

Congressman Ted Lieu, my representative, et al,

I woke up 2 am to the sound of water leaking from our roof. My autistic son had a long day of medical appointments and tests. Tomorrow we have to get up early for more tests.

As Pat Framke Of Petersen Dean’s bond can confirm by emails and voice mails, I began begging for my son’s life when Petersen Dean and HERO FINANCING took us hostage financially in the fall of 2016. Petersen Dean bullied us after H&R Block warned me that HERO and Petersen Dean we’re scamming me. HERO didn’t dare put the lien on our house once they were caught red handed, they abandoned the project and Petersen Dean ordered me to sign documents that claimed the job was finished when it clearly was not finished. I was given the choice to let HERO take our house via the scam or Petersen Dean would illegality put Mechanics Liens on an unfinished job and take the house that way. If I signed and allowed HERO to complete the scam, I would receive $2000 from Petersen Dean. That was not enough to remediate the stucco dust, exposed wires and rotten wood left of the roof. It was mean to be moving money to help us move out of our home. Samuel Luquin also offered to help us adjust, “transition” to losing our home to criminals but I declined the offer. If LA County was not to to help us fight for justice, because they were over whelmed by the sheer numbers of victims of property tax financing scams, I would fight alone until I found help. In the 2008 housing crisis my elected officials told me to stay and fight and I saved our home by taking their advice. I refused to believe I had to let criminals take our home. Bet Tzedek also refused to help us. The reason we were turned away again and again was that agencies were overwhelmed with the number of victims. The CSLB was so overwhelmed that they told me they had to create a new division to handle the sheer volume of solar scam victims. Going solar is supposed to save you money, not bankrupt you and cause you to lose your home a year after going solar when the property tax scam kicks in. Getting a new roof is not supposed to cause leaking. My old roof didn’t leak. Paying EXTRA to have rotten wood removed only to find out the new shingles are on top of that rotten wood AND you are being sued with Mechanics Liens even after the CSLB verified the rotten wood is still there, is a nightmare. Being cast as the defendant to prevent you from filing as a plaintiff is twisted and almost worked for Petersen Dean because it made the case “too complicated” for pro bono attorneys. My son and I did what our elected officials told us to do during the housing crisis... we stood out ground, we fought for our rights alone when no one would help us because Petersen Dean made it too messy, too complicated, too expensive to take. We are still standing but we are very badly hurt now. My son’s doctor shuttered today when she told us she is so sorry this is happening to us. It is “unimaginable” pain just like Petersen Dean employees promised me it would be when they began threatening us in 2016. They used the word “unimaginable” to describe what George Milionis was going to put us through. They mentioned my son James specifically by name and specifically mentioned that they were aware of his illness and the difficult year he had suffered, especially after they doused him and his stuffed animals with stucco powder and he got the first lung infection. They deliberately mentioned my son while threatening me if I refused to sign documents they wanted signed.

Now they have decided to cut and run. They seem to believe that Roy Guthrie and HERO escaped justice by running and saying it never happened. Now Petersen Dean is abandoning case BC661819 because in spite of all their fear tactics that kept us in fear of homelessness every  single day and night for over two years, we refused to give up our right to a trial by jury, our only hope of getting our lives back.

My autistic son might lose all his teeth and his legs because of our being held hostage so many years. I begged George Milionis for more time to answer his frivolous and life destroying BC661819 Complaint when James could not walk in spring 2018. Mr Milionis cruelly refused to give us another week. James was in a wheelchair for the first time in his life. It was terrifying but I had to answer the complaint while helping James cope with the pain. James got sicker. Petersen Dean’s attorneys mocked me in court for mentioning my son’s agony. The stress put him in James in an even faster downward spiral as he began autistic self injurious behaviors because the stress of the case disrupting his routines was unbearable to him. All 2018 Petersen Dean’s attorneys tried to scare me out of the trial by jury and mocked me when I begged, in writing, over and over from my son’s life.

In August 2018 the CSLB fined and cited Petersen Dean. That did not stop Petersen Dean from STILL trying to get the court to let them take away our home with the invalid Liens on an unfinished job. They were determined to try to enforce invalid Liens.

I begged Petersen Dean Attorneys and Cap Specialty for my son’s life in the winter of 2018 when doctors said I must stop working on the legal case and focus only on James and surely Petersen Dean would not expect me to do legal work during the Christmas holiday, but Petersen Dean hit me with an ex parte action, made me use my fee waiver to cover the hearing expenses and then canceled the night before and threatened to do it again when they felt like it with a one day notice for me to drop everything and scramble to prepare for. In November and December 2018 James was in the emergency room for fainting, then again for extreme pain and then again for limping and trouble walking and again for loss of control of his bodily function and again for swollen feet and again for infection. All the while Petersen Dean Attorneys were pressuring me, complaining that I wasn’t doing legal work to their satisfaction fast enough.

I begged and begged for my son’s life. In writing and over the phone. Petersen Dean and Cap Specialty were ice cold without mercy. Now Petersen Dean has decided to follow HERO FINANCING’S example and run away as if none of this happened. They don’t want to help James get the surgeries they blocked when they held us captive financially for years. They don’t want to fix the roof that the CSLB fined them for. They left the rotten wood they wanted to be paid for replacing and they are running away from the jury that was going to hold them accountable in April 2019. And now the Roof is leaking and instead of resting before James’s medical test tomorrow, we are looking for buckets to put under the leaks.

A jury might have saved James’s life in April 2019 by holding Petersen Dean accountable for their actions. Now I have to find a way to save James without that trial by jury i was counting on for rescue.

To be tortured, falsely imprisoned financially and wrongfully and systematically and slowly destroyed financially since November 2, 2016 via a trumped up case with invalid liens on an unfinished job, to have James’s three dental surgeries canceled because we could no longer access our own equity because Petersen Dean thought if they held us hostage long enough they would win by “crushing” us and then to have the roof leak on top of it all is all the more painful.

Not only has Petersen Dean made no offer to help James have a shot at recovering from the devastating mental and physical harm that having his life hijacked and his daily routines taken away from him has caused, Petersen Dean is dismissing their frivolous BC661819 with the stipulation that the threat CONTINUE to loom over us forever, that we may know no peace emotionally in addition to having no help recovering from the financial devastation they caused us. They are asking the court to dismiss their own case “WITHOUT PREJUDICE” so they can blow up our lives again whenever they feel like it.

God help us. I have been begging Petersen Dean, HERO and Cap Specialty for my son’s life for years now. Petersen Dean employee’s warned me in 2016 that if I did not sign documents that would amount to financial suicide, they would turn me over to George Milionis and there would be no mercy, that they knew James had a bad summer and was ill and they asked me if I wanted to put James through that. I told Pat Framke at Cap Specialty that Petersen Dean employee’s threatened my son’s life and tried to force me to sign documents that would ALSO destroy his life by destroying us financially.

HERO ran and lied to LA County attorneys, claiming they were not the financing the project in spite of mountains of documentation proving they had been the financing it and now Petersen Dean is running away too.

What is going on here is two businesses trying to escape responsibility by pretending they are not liable because they did not successfully complete the financial crimes. It is exactly as if a bank robber held a gun to everyone in a bank, demanding the money and upon hearing police sirens, abandoned the scene before collecting any money. Petersen Dean, HERO and Cap Specialty are asking the law to excuse them because their financial fraud crimes were interrupted by H&R Block stating they were conducting a scam, a Property Tax Financing Scam.

Petersen Dean threatened my son in 2016 and now in 2019 they are running away from the April 2019 trial by jury I begged Judge Daniel Murphy for while Petersen Dean was telling Judge Murphy they were not expecting a trial and never prepared for it. I was forced to do interrogatories while my son was in agony. Petersen Dean does not want a jury to hear all the employees listed in my interrogatories testify. Petersen Dean employees threatened my son and their actions in the years after the threat caused him permanent harm that he is struggling to survive and may not survive.

I can’t let the terror of all this freeze me. Yesterday I saw the mortified look on my son’s doctor’s face as she considered what James endured because we were at Petersen Dean’s merciless pressure in BC661819 for so long. It’s incomprehensible to many doctors. They can’t believe an autistic person was treated this way. They couldn’t believe Petersen Dean pulled the ex parte stunt right before Christmas and threatened to pull it again, “when they felt like it”, constantly keeping the terror of homelessness looming over our heads. Petersen Dean didn’t care that James was in the emergency room in agony, they just kept the pressure on us to drop everything to defend our home, even if it killed James. Doctors told me to forget BC661819 and focus on James. I told them Petersen Dean will take our home and that might be enough stress to destroy James’s chances of recovery. I was in a no win situation. I had to do my legal work or we would lose our home.

How is this to end? I will remain calm and take James to the doctor in the morning.

We were also referred to the UCSF to see if they can do James’s dental surgery with his insurance or pro bono. We can’t afford the trip to San Francisco and the hotel stay during the treatments. We could no longer qualify for a home equity loan to pay for surgery because we are so damaged financially by the years Petersen Dean and HERO have held us hostage. Mold remediation was disrupted. 

Our home is not fit to live in but we ran out of funds for a hotel. Hotel expenses were astronomical and documented by Cap Specialty and in BC661819 case filings. Our hope was that a jury would hold Petersen Dean and HERO responsible for their outrageous actions against us and make them pay for James’s dental surgeries that are not covered by his insurance as well as relocation funds to a safe place to live. The lower floor is where the mold remediation was disrupted. The second story is where the roof is leaking. The garage is where Petersen Dean knocked electrical wires out of the wall with a sledgehammer and never put the wires safely back inside the wall. The air vents are sealed shut because Petersen Dean filled them with stucco powder on November 2, 2016 and decided it was too expensive to clean the vents and the house of the powder. That means we could not use the heater. There is a HAZE in the house that will not go away. James and I both ended up in the emergency room with breathing problems and bloody noses, burning eyes.

I have to focus on James now. When he reaches a stable point I will seek justice in all ways possible, in criminal and civil courts.

A criminal isn’t absolved of crime simply because they ran from the scene of the crime before the police arrived. A criminal isn’t innocent simply because the crime was not successfully executed. HERO FINANCING has been trying to sell that theory to LA County. It’s only a crime if you get caught? It’s only a crime if the crime is profitable? I don’t agree.

To be continued...

Sincerely,

Jennifer Marshall and son James Marshall

STATE BAR OF CALIFORNIA COMPLAINT AGAINST GEORGE MILIONIS

STATE BAR OF CALIFORNIA

Complaint Review Unit

Office of The General Counsel

180 Howard Street

San Francisco, California 94105-1617

July 24, 2018

Inquiry Number 18-20383

Dear State Bar of California Complaint Review Unit,

I respectfully request a review my three separate complaints regarding three separate attorneys that got lumped together as one. I believe the more serious complaint is the one against Attorney George Milionis and that lumping him with less serious offenses was a mistake. Perhaps the mistake was mainly mine for reporting unprofessional behavior of two attorneys from the same firm at the same time I reported what I believe to be the criminal behavior of George Milionis.

Mr. Milionis is deliberately abusing the MECHANICS LIENS process and using the process as his personal tool to avoid detection of PETERSEN DEAN and HERO FINANCING’S multiple wrong doings and to cover up financial fraud PETERSEN DEAN committed with HERO FINANCING when they acted as HERO’S unlicensed broker.

As per the enclosed HOMEOWNER’S GUIDE TO PREVENTING MECHANICS LIENS, there is a LIEN REQUIREMENTS CHECKLIST. Mr. George Milionis knows full well he did not meet those requirements. He is aware he is not using MECHANICS LIENS correctly for the purpose that they exist for. MECHANICS LEINS used to cover up a crime is nefarious and such an attorney should not be allowed to continue committing financial crimes with impunity.

Mr. Milionis knows that a job must be completed before he can place a MECHANICS LIEN. In June 2018 Petersen Dean paid a $500 citation (Copy of Citation enclosed) to the CSLB for not removing and replacing rotten wood, for covering rotten wood with new shingles, for not doing the work they were hired to do up to standard. That citation will remain on Petersen Dean’s record for five years and yet Mr. Milionis shrugs it off as if it is nothing because the fine was laughably small and he can still leave the work unfinished, still leave rotten wood under the new shingles, still remove the financing and demand more money than was agreed for the job and still file Mechanics Liens to cover up the financial fraud. Petersen Dean and George Milionis flaunt their lawlessness in your face, in the court’s face, in my face. Mr. Milionis clearly feels he may act with impunity and that the laws that apply to others do not apply to him and his client PETERSEN DEAN.

Mr. Milionis knows the CSLB Lien Checklist requires that the homeowner must accept the improvement and be using the improvement and he knows the job was never completed, that the homeowner did not sign off the completion documents with HERO FINANCING because was never completed in 2016. The solar panels were never turned on all these years. DWP never inspected the panels. Both HERO and PETERSEN DEAN agreed to remove the solar panels after H&R Block indicated that I most certainly would not receive $10,000 tax credit because as a senior citizen caring for my adult autistic son, we do not pay taxes. Mr. Milionis decided to withdraw the HERO FINANCING and pretend it never existed and he proceeded to deliberately misuse the MECHANICS LIEN process to cover up financial fraud that had become noticed by the homeowner’s tax preparer Mr. Martin of H&R Block.

I believe many of the actions of Mr. Milionis rise to a criminal level.

The other two SEPARATE complaints against Mr. Karimzadeh and Mr. Mendoza, (all three given the same INQUIRY NUMBER) are for unprofessional conduct and do not rise to a criminal level. Lumping all three separate attorneys under one INQUIRY served to water down the very serious complaint against George Milionis. Mr. Mendoza was toying with me. Mr. Karimzadeh was faking having communication with me just so he could say he tried but I wouldn’t’ cooperate. He made no real effort to discuss the case with me. Who sues a person then refuses to communicate with them?

Mr. Karimzadeh was unprofessional and did not make any true effort to have a legitimate meet and confer with me. He wanted Judge Murphy to believe true communication was offered but in his emails to me you can clearly see no real settlement offers were discussed, no mention of the financing was discussed. Mr. Karimzadeh limited his communication to trying to manipulate me to give up my right to a trial by jury. He refused to discuss any details of the case with me. That is not an opinion. That is supported by his emails, our only means of communication. The emails do not show any good faith discussion of the case and the financing. Mr. Mendoza asked questions about the incomplete work….questions he knew the answer to because the CSLB citation made it clear…and he was not the attorney of record. Mr. Karimzadeh did not discuss the incomplete work, the rotten wood under new shingles, the removal of the solar panels or ANY of the details of the financing and the case. He stubbornly refused to discuss the financing that had vanished into thin air. Where did the HERO financing go? Why is PETERSEN DEAN allowed to get rid of HERO and call for $34,000 cash ($10,000 more than agreed) without financing and without finishing the job?

Mr. Mendoza emailed me until I told him to stop. There was no reason for him to contact me at all, even once, ever. Mr. Karimzadeh is the attorney of record and it was his job to tell me anything that Mr. Mendoza told me. I only answered Mr. Mendoza because I thought he acted like he was taking over the case for Mr. Karimzadeh. These two men both behaved unprofessionally. I filled out separate complaints for each attorney because no attorney deserves to be lumped together and accused of another attorney’s behavior and actions. Especially when those actions of one individual rise to a criminal level.

I believe George Milionis is a criminal and that he has done great harm to many homeowners in the State of California. Please separate his Inquiry from the other two nuisance complaints for attorneys acting unprofessionally and take a second look at the actions of George Milionis.

It is my opinion that George Milionis should not be practicing law in the State of California in light of how he has blatantly, undeniably, deliberately abused the MECHANICS LIENS process. Mr. Milionis is making up his own MECHANICS LEINS laws as he goes along. He changes the MECHANICS LIENS law to suit his need and uses it as a weapon to control and intimidate people, wielding the threat of the MECHANICS LIENS in writing to force signatures from homeowners long before the job is finished, YEARS before the job is finished in this case. Mr. Milionis helps PETERSEN DEAN broker HERO FINANCING without a license and revokes the financing and demands instant cash payment in full, more money than agree upon and with no financing if someone (in my case H&R Block) discovers the property tax financing fraud in progress.

Please take a second, closer look at this.

Thank you for considering this matter.

Sincerely,

Jennifer Marshall

*******************************************************************

COPY OF LETTER SENT TO PETERSEN DEAN AS PER CSLB BOOKLET:

FROM: Jennifer E. Marshall

April 9, 2017

VIA CERTIFIED MAIL

TO: Petersen Dean, Inc.

39300 Civic Center Drive, Suite 300

Fremont, California 94538

RE: INVALID LIEN 20170093119

       INVALID LIEN 29170093193

Dear Petersen Dean, Inc,

I was not served a copy of the two liens in question. I purchased copies from the courthouse in El Segundo, California via check and have the receipt.

Both liens are invalid because they do not adhere to the strict time frames and lien requirements.

Both liens are invalid because the job was abandoned by you on November 2, 2016.

The work and necessary repairs were not completed. The stucco powder you refused to hire Building Cleaning Services or any other reputable cleaning service to remove has drifted and contaminated the entire house making it uninhabitable. Numerous contractors interviewed to rebuild the kitchen refused to enter the house until the stucco powder is remediated as it made them instantly feel sick. I suffered a bloody nose, sore throat and burning eyes. My autistic son James developed a severe lung infection. Assurant Insurance paid for air quality testing of the entire house. The powder you refused to remove from my son’s room on November 2, 2016 has contaminated the air vents and the carpeting and is everywhere now. The mold remediation being done in the kitchen by Assurant was disrupted by your abandonment of the job on November 2, 2016 and put on hold until you made the air quality safe again, which you still have not done.

The solar panels are not in use. You agreed in writing to remove the solar panels after H&R Block examined your figures and determined that I would not receive ANY of the savings, that it was a tax credit scam. You did not remove the panels as agreed. The roof is creaking and you did not fix that or any of the items you previous agreed to repair. A complete list of everything you didn’t finish and left in disrepair is attached to the CSLB claim and is being verified by the Contractors State Licensing Board Case Number: SF20169935.

I hereby request that you immediately remove both of the invalid liens. If I have to hire an attorney to make you remove the invalid liens, I am instructed to remind you that I am entitled to be awarded all reasonable attorney fees.

Sincerely,

Jennifer E. Marshall

********************************************************************

I SENT PETERSEN DEAN THE ABOVE CERTIFIED LETTER AS PER THESE CSLB BOOKLET INSTRUCTIONS:

*************************************************************************

IT IS SO ORDERED

IT IS SO ORDERED

BACKGROUND

            This is an action brought by Plaintiff Petersen-Dean Inc. (“Plaintiff”), against Defendant Jennifer Marshall (“Defendant”), regarding nonpayment for the installation of solar panels done at 1328 Abraham Terrace, Harbor City, California 90710.  Plaintiff alleges eight causes of action including (1) foreclosure of mechanic’s lien; (2) breach of written contract; (3) common counts; (4) account stated; (5) open book account; (6) quantum meruit; (7) violation of prompt payment statute; and (8) declaratory relief.

ANALYSIS

Any party, within the time allowed to response to a pleading, may serve and file a notice of motion to strike the whole or any part" of that pleading. (CCP 435(b). The Court may, upon a motion made pursuant to Section 435, or at any time in its discretion, and upon terms it deems proper: (a) Strike out any irrelevant, false or improper matter asserted in any pleading; (b) Strike out all or any part of any pleading not drawn or filed in conformity with the laws of this state, a court rule, or an order of the Court." (CCP 436.) The Court's authority to strike improper pleadings includes the power to strike those pleadings that are "not filed in conformity with its prior ruling." (Janis v. California State Lottery Com(1998) 68 Cal.App.4th 824, 829.)  A plaintiff has only 10 after service of an answer to file a demurrer or motion to strike the answer.  (CCP 435(b) and CRC 3.1322(b).)

            As set forth in the moving papers, Defendant has filed multiple responses to Plaintiff’s Complaint: a Motion to Strike on January 22, 2018; an Answer on April 23, 2018; a First Amended Answer on April 27, 2018; a Second Amended Answer on May 4, 2018; and a Third Amended Answer on May 7, 2018.  Since plaintiff did not file this Motion to Strike that Third Amended Answer until July 3, 2018, the Court DENIES Plaintiff’s motion to strike as untimely.

            IT IS SO ORDERED.

ADDITIONAL INVESTIGATIONS, DISCOVERY & DOCUMENTATION OF ZERO COMMUNICATION POLICY OF HERO AND PETERSEN DEAN

UPDATED LETTER TO PETERSEN DEAN'S ATTORNEY SAM KARIMZADEH

INSURANCE FRAUD ON TOP OF FINANCIAL FRAUD
CC: CAP SPECIALTY INSURANCE
CC: CALIFORNIA DEPARTMENT OF INSURANCE

CC:
LOS ANGELES COUNTY CONSUMER & BUSINESS AFFAIRS   

INTERNAL SERVICES DEPARTMENT

ENERGY AND ENVIRONMENTAL SERVICES

INVESTIGATION OF HERO AND PETERSEN DEAN 2016 JOB ON JENNIFER MARSHALL PROPERTY / PROPERTY TAX FINANCING FRAUD / INSURANCE FRAUD 

CC: Sam Luquin: Los Angeles & Business Consumer Affairs

UPDATED LETTER,  WITH NEW INFO RE CAP SPECIALTY LETTER WITH FALSE INFORMATION WRITTEN BY A PETERSEN DEAN ATTORNEY TO DECEIVE CAP SPECIALTY FOR THE PURPOSE OF ESCAPING LIABILITY

PETERSEN DEAN IS NOT LOOKING FORWARD TO THEIR DAY IN COURT, IN FACT THEY ARE FRANTIC TO AVOID A TRIAL BY JURY.

Dear Mr. Karimzadeh, Attorney for PETERSEN DEAN:

After the November 2, 2016 stucco accident (where a Petersen Dean attorney lied IN WRITING to CAP SPECIALTY INSURANCE, (which I was given a copy of ), indicating PETERSEN DEAN "had to do stucco work IN THE GARAGE", where there happens to be no stucco and that only a few pieces of silverware and a few dishes got coated with stucco powder, that powder moved in mysterious ways and miraculously stayed out of my my son's lungs, cut around corners and refused to go into the air vents and bypassed everything we owned and that two separate, unrelated, licensed remediation contractors, BUILDING CLEANING SERVICES and MIDA CLEANING SERVICES who provided PETERSEN DEAN with estimates wanted $4,000 + to clean a few pieces of silverware and a few dishes that PETERSEN DEAN offered to clean with leaf blowers and that the emergency room that treated James for the lung and breathing problems he had after inhaling powder from the cloud that filled his room and covered his bed, his clothing and all his toys, books and possessions while he was asleep in on November 2, 2016 in his room....all this, according to PETERSEN DEAN'S ATTORNEY'S letter to CAP SPECIALTY was nothing.... reduced to just a few forks and dishes. 

We should have scientists do a special investigation into this very talented stucco dust that has the ability to pick and chose what it will land upon, to form a cloud, go into a house and garage and refuse to land on most possessions, walls, ceilings, air vents, lungs and just specifically pick out a few items to land on. 

Even the contractors who were there that day will not commit perjury about magic stucco powder. They will NOT swear under penalty of perjury that they were doing stucco work IN THE GARAGE that had no stucco in it. They will not back the lie the PETERSEN DEAN attorney put in writing to CAP SPECIALTY that they were doing stucco work inside the garage. They know there was no stucco in the garage and they won't throw away their lives to protect PETERSEN DEAN with this ridiculous lie. Those contractors will not support the lies PETERSEN DEAN'S ATTORNEY put in writing to CAP SPECIALTY INSURANCE. You would be hard pressed to find any contractor on earth willing to throw away their life for such a foolish lie.

Probably no homeowner has stucco inside their garage. Have you every been inside a garage that has stucco on the interior walls? This has to be the sloppiest lie ever told and PETERSEN DEAN either believes CAP SPECIALTY is unbelievably stupid or willing to go along with criminal activity backed by ridiculous lies that no one would believe. 

PETERSEN DEAN contractors opened the garage and did not bother to close it when they finished altering the water heater. They were horrified by the mess they made, apologized and told their supervisor it would take them four days or more to clean up the mess they made, that they were not qualified to do the remediation and that they couldn't clean my son's bedding and clothes and toys, that they could not do it. They were told by their supervisors to do the remediation with leaf blowers.  

There was no reason to fill our house with stucco powder.  This was the sloppiest lie I ever read in my life and it is my belief that PETERSEN DEAN is desperate to avoid a trial by jury because they do not want a jury to read this letter and other letters and emails that will prove financial crimes were committed. 

I know Petersen Dean does not allow you to communicate with me other than to try to force me to settle against myself and accept some version of devastating, unjust and life destroying loss and this ZERO COMMUNICATION POLICY began in January 2017 before you were hired, but since you frequently try to convince Judge Murphy to believe (in BC661819 ) that you actually DO try to communicate, you at the very least should know it was a fact that we had a settlement underway in January 2017 and were arranging to have the solar panels removed after H&R BLOCK reviewed documents in 2016 and found out this was a property tax financing scam and informed me it wasn’t true that I would be getting $10,000 off via my property taxes. 

I was horrified when TWO contracts materialized that an electronic signature of my name and initials was deposited on and that the second contact was for $10,000. I kept asking why there was an additional $10,000 when I was told I was getting the deal where customers get the roof free if they go solar with Petersen Dean. I have a video tape of that offer. I was told not to worry, that I wouldn’t have to pay the $10,000, that it would “fall off” via property taxes. I immediately called Helena Shi about it. Both she and Mr Shanholtzer confirmed I was getting that free roof if you go solar deal. Helena Shi of
Peterson Dean Solar: hshi@PetersenDean.com (510) 946-2338.
I talked to Dave Shanholtzer of
Peterson Dean Solar about it.  dshanholtzer@petersendean.com   (714) 309-0837 (LA County is also investigating this). Matthew Monning:  (714) 858-9278, might lie under oath but I don’t believe Helena Shi and others will want to lie under oath to protect Petersen Dean.
The agreement was to remove the solar panels because they were not the price I was quoted and I could not afford them. Then suddenly without explanation Matthew Monning and Helena Shi were not allowed to talk to me anymore, just like you are not allowed to really communicate with me, Mr Karimzadeh. Matthew Monning blocked my emails.
All these Petersen Dean employees will be called upon to testify in this case and in other cases that will arise until this matter is properly settled. Multiple agencies are investigating this property tax financing scam and one way or another, this matter will eventually come to justice.
You have not discussed what happened in 2016 with me yet you want me to attend a settlement conference with you and to agree to things without having any understanding of the events of 2016 between us. Your client still wants to steam roll me and that is why he won’t allow you to have any meaningful communication with me.
This email establishes, again, that lack of communication. I am verifying it for the record in BC661819 and sharing this information with related investigations.

“For the records: There has been no discussion of the actual events of 2016 between me and Attorney Sam Karimzadeh. Mr. Karimzadeh sought to proceed to the settle phase without ANY discussion of the job performed by Petersen Dean in 2016 and the financing arrangements of 2016.”

It is my understanding that Petersen Dean just wants Judge Murphy to fork over our home ASAP without any discussion of the events of 2016, to allow you to seize our home simply over procedure errors, paperwork problems that happened because I am in pro per and never went to law school, not on the merits of the case. Even with The Public Law Center doing intake to find a match for this expensive case with cross complaint, Petersen Dean is frantic about avoiding a trial by jury by hook or by crook. It is confusing to be sued and to find the person who sued you is desperate not to have a trial by jury. This is yet another of MANY RED FLAGS in an ongoing pattern that suggests a strong consciousness of guilt. Petersen Dean sought to swiftly abuse the MECHANICS LIEN process, seize a property and thereby destroy evidence of the 2016 property tax financing. Petersen Dean never had any intention of discussing the events of 2016 in a court of law. There is a pattern of behavior that Petersen Dean does not want to be reviewed by a jury. Usually when a person brings a matter before the court, they WANT the events reviewed.

Petersen Dean’s desperate need to skip discovery and just have Judge Murphy fork over the only home that we have ever owned, that KEEP YOUR HOME CALIFORNIA helped us keep, makes it seem like Petersen Dean is the one facing homeless, not my autistic son and I.

Sincerely,
Jennifer Marshall 

REPORTING CRIME: DEFENDANT'S REPLY IN OPPOSITION

NOTATION: This kind of crime is out of control in CALIFORNIA. Property tax financing is not well regulated and contractors like PETERSEN DEAN conspire with HERO FINANCING to take advantage of the lack of regulation. The section of the population they victimize most, the elderly and disabled are usually unable to pay to retain an attorney and legal aid is inundated by the epidemic.

    

Jennifer Marshall

Temporarily Self-Represented

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

PETERSEN DEAN, INC.                                          Plaintiff,             v. JENNIFER MARSHALL,                                         Defendant

) ) ) ) ) ) ) ) ) ) ) )

Case No.: BC661819 DEFENDANT’S REPLY IN OPPOSITION TO PLAINTIFF’S SUPPORT OF PLAINTIFF’S MOTION TO STRIKE AND CONCURRENT DEMURRER DECLARATION OF JENNIFER MARSHALL Date: August 1, 2018 Time: 8:30 AM Notice of Intent to Appear by Telephone by JENNIFER MARSHALL

TO THE COURT, ALL PARTIES, AND THEIR COUNSEL OF RECORD:

        Defendant JENNIFER MARSHALL hereby respectfully submits this REPLY in OPPOSITION of

PLAINTIFF’S DEMURRER, concurrently filed with a MOTION TO STRIKE.

                                                                   INTRODUCTION

        1. I, JENNIFER MARSHALL am the DEFENDANT in this action and I am currently forced to be in pro per but I am not qualified to represent myself and I am suffering mentally and physically due to the prolonged and illegal actions of PLAINTIFF. I am a victim of crime. PLAINTIFF has committed crimes that have destroyed my life and the life of my autistic son JAMES MARSHALL.

        2. DEFENDANT has failed to file and serve an OPPOSITION in a timely manner because to do so would have endangered the life of her autistic son JAMES MARSHALL. Our local police can be called upon to testify in court that JAMES MARSHALL has been suffering from toxic stress as a result of his living conditions caused by PLAINTIFF and that they, the police had to explain to new neighbors that JAMES MARSHALL is screaming nonstop, suffering insomnia, exhibiting severe separation anxiety to the extent that he screams if his mother is not visible to him and the police have witnessed JAMES MARSHALL in this state of toxic stress and have witnessed that the condition the house is in as a result of PLAINTIFF disrupting mold remediation and blocking DEFENDANT’S access to equity for JAMES MARSHALL’S badly needed DENTAL SURGERY as well as restoration of JAMES MARSHALL’S home so that it is safe to live in again. The state of the home is frightening for an adult and completely overwhelming for an autistic person. The police kindly asked DEFENDANT if there was anything they could do. DEFENDANT replied that doctors reported that they felt as if their hands were tied and they were at a loss what to do because the problem is environmental, being caused by an outside force and we are all powerless to make PETERSEN DEAN stop this immediately, we are trapped in a long process that is ripping JAMES MARSHALL apart. The police have witnessed the frightening looking environment that is distressing JAMES MARSHALL so badly and said they would explain to concerned neighbors that JAMES MARSHALL was not being assaulted, that he is in pain but unable to take pain medications and sedatives due to allergic reactions and that the source of his pain cannot be addressed until this legal case is resolved, allowing access to home equity to pay for his surgeries not covered by MEDICARE/MEDICAL. DEFENDANT and her son have to try to hang in and stay alive. The police can testify that they witnessed that it is impossible to have a complex conversation, to do paper work or read while JAMES MARSHALL is in this state and that to attempt to do so would be endangering JAMES MARSHALL’S life and a criminal offense of unjustifiable neglect. In this state JAMES MARSHALL attempts self-injury. The entire neighborhood is aware of JAMES MARSHALL’S suffering, his fear of his own home and his being trapped in limbo regarding his dental surgeries. When new people moved into the neighborhood, they called the police because the intensity and months of duration of JAMES MARSHALL’S screams frightened them.

         DEFENDANT’S son has had a few days of calm and DEFENDANT immediately called attorneys to request representation. With each call, JAMES MARSHALL showed signs of increased anxiety and began clapping his hands nonstop, which he does before he regresses into full on head-banging. DEFENDANT spoke to ROMAN E. DARMER of the law firm of JONES DAY. MR DARMER heard JAMES MARSHALL crying for DEFENDANT not to talk on the phone, not to talk about this case. The mere act of discussing this case drives JAMES MARSHALL to scream and hurt himself. He has also become terrified of people talking to his mother. He reacts as if everyone might hurt us as PLAINTIFF has. MR. DARMER of JONES DAY put us in contact with PUBLIC LAW CENTER. I reported to PUBLIC LAW CENTER that I was also beginning to show signs of toxic stress myself, that I was forgetful, experiencing shortness of breath, dizziness and constantly fighting off a feeling of  utter dread and panic that we will lose our home, that I felt I was also succumbing to the YEARS of unrelenting stress. While PUBLIC COUNSEL and BET TZEDEK has not been able to help us because they are inundated with homeowners who have been scammed like we have been, fortunately PUBLIC LAW CENTER was able to begin the intake process and will try to match us with a PRO BONO attorney. I am on my last leg. I will not survive without help. I do not know how my son JAMES and I survived approximately two years of this unjustified abuse from PLAINTIFF. LEIGH E FERRIN, Directing Attorney, Consumer Law & Pro Bono of PUBLIC LAW CENTER, 601 Civic Center Drive West, Santa Ana, CA 92701 told me that unfortunately she would not be able to match us with a pro bono attorney in time for the AUGUST 1, 2018 hearing. MS FERRIN said she would need several weeks. Therefore, I respectfully ask that the court grant additional time for MS FERRIN to process and match us with the correct attorney for our case.

        3. Furthermore, as DEFENDANT believes PLAINTIFF is guilty of serious crimes, she asks the court to consider that PLAINTIFF is so keenly desperate to avoid a trial by jury because PLAINTIFF knows full well that the discovery process will unearth those white collar financial crimes. PLAINTIFF has exhibited patterns of behaviors that suggest consciousness of guilt and a burning need to avoid discussing any of the details of the extremely strange and illegal financing of 2016. PLAINTIFF simply wants the court to fork over DEFENDANT’S home to them and be done with it. DEFENDANT has expressed her concern that GEORGE K MILIIONIS is guilty of crimes in a complaint to the STATE BAR which is attached as EXHIBIT A. DEFENDANT also begs the court to consider PLAINTIFF’S brazen disregard for human life, the eagerness to mow down innocent human beings to cover up a sloppy tax credit scam and avoid justice.

       4. In response to PLAINTIFF’S item 2 of DECLARATION OF SAM KARIMZADEH IN SUPPORT OF PLAINTIFF’S MOTION TO STRIKE AND DEMURRER TO DEFENDANT’S THIRD AMENDED ANSWER, I JENNIFER MARSHALL agree that I did ask to communicate via email only because my autistic son JAMES MARSHALL becomes upset when this case is discussed verbally and because on many occasions in 2016, many different men who worked for PETERSEN DEAN began calling me and working on me verbally for many months and it was a horrifying experience. To avoid a repeat of such abuse, I felt it would be safer if everything was in writing. The court will notice there are no specific settlement offers presented to DEFENDANT by PLAINTIFF. If this had been done verbally, DEFENDANT strongly suspects PLAINTIFF would claim they made many good offers and that I turned them all down.

       5.  In response to item 3 of the DECLARATION of SAM KARIMZADEH, I did not understand the law well enough to make an informed response and that is why I asked the court for more time to search for an attorney. The saying that a person who represents them self has a fool for a client is based on solid truth. I am only representing myself until I can find help. I do not know how to properly answer a complaint. PLAINTIFF wants me to do the work anyway and pressures me to focus on doing work I am not qualified to do rather than use what precious few moments of time I have when my son is calm enough to search for an attorney instead. It is clear that PLAINTIFF does not want me to find an attorney. PLAINTIFF is also aware of what crimes they have committed and they know full well that most small firms cannot afford to take a case like this. PLAINTIFF is fully aware that they have harmed my son JAMES MARSHALL and that this also makes it harder to focus on searching for an attorney since the time needs to be spent seeking medical and emotional help. PLAINTIFF has discussed JAMES MARSHALL with their insurance CAP SPECIALITY (since they filled his lungs with stucco powder on November 2, 2016 and began engaging in deliberately frightening us) because they wish not to be liable to what is happening to him as a result of their actions.

        6. In response to item 4, the pressure SAM KARIMZADEH placed upon me to have a settlement conference to narrow the scope of the case when in fact justice can only be served by expanding the scope of the case was palpable. Again, PLAINTIFF is in a very big hurry to take our home away from us without getting into the details of what exactly happened in 2016. I did not want to be railroaded. I was very concerned about the lack of any real communication. PLAINTIFF wanted to publish in a newspaper instead of serving me a copy of the complaint. To this day the only complete copy of the compliant I have is the one I purchased with my fee waiver. I made the mistake of TRUSTING that the copy PETERSEN DEAN emailed to me THE DAY MY ANSWER WAS DUE was a complete copy. Since the copy I got from the court was a hard copy, I forwarded the emailed copy of the complaint to THE PUBLIC LAW CENTER when they requested that I send a copy. To my shock, I received an email from PUBLIC LAW CENTER informing me that the emailed copy of the COMPLAINT BC661819 was incomplete, most of it was missing. I told PUBLIC LAW CENTER I was sorry, that I never realized it was in incomplete copy because I never had occasion to rely on it because it was sent to me so late, on the very day my answer was due. I had used the copy I purchased from the court to answer the complaint. This is a prime example of the dirty tricks PETERSEN DEAN plays and played since 2016. PETERSEN DEAN is desperate to avoid a trial by jury because when all the dirty tricks are paraded out in front of a jury there will only be one conclusion to be had and that is that PETERSEN DEAN is in the business of dirty tricks and they don’t care if people suffer and die because of it. In 2016 PETERSEN DEAN employees BRAGGED about how GEORGE MILIONIS would mow us down, how it was hopeless and I should just sign the document they wanted me to sign.

       6. In regards to MR KARIMZADEH’s Item 5. Yes, the documents are forgeries. The electronically generated initials and signature were not my handwriting and the amount of money in the contracts the signatures were deposited on was not the amount of money I agreed to. Even after I found out about the incorrect amounts, PETERSEN DEAN employees engaged in more trickery and kept trying to convince me I was still getting the $10,000 off as part of the free roof for going solar package even if it didn’t look that way. It is forgery. I will swear to this under oath.

         7. In regards to MR. KARIMZADEH’S Item 6. I do not understand item 6 and have requested time to find an attorney because there is so much I do not understand regarding case filings. I cannot put my son’s life in further danger by neglecting him to attempt to do something I clearly am not qualified to do. I did not ask for months, I asked for until August 1, 2018 in my previous filing, praying to God that somehow, some way I would be able to take care of JAMES and seek an attorney too. I came very close to the deadline I asked for. PUBLIC LAW CENTER said they would need weeks, not months, to process my intake, review the case filings and find a match. Again, I must emphasize that most of the legal aid organizations are swamped with solar scam victims, tax credit scam victims. PLAINTIFF is aware of this and counting on it. PLAINTIFF has no intention of winning this case on the merits of the case because PLAINTIFF knows full well they committed crimes. The day I talked to JONES DAY law firm I apologized and warned them my son would grow increasingly agitated the longer I talked and that I couldn’t call back later because it would still happen. I told them I would email information and talk as fast as I could but I wouldn’t be able to talk long. JAMES screams for weeks on end. This started in fall 2017 when we were forced to move back into our gutted house because we ran out of hotel money. The first night we spent in the gutted house James screamed so loud the neighbors thought someone was being murdered. The doctors were at their wits end as to what to do about an environmentally caused stress with no end in sight. Since we finally have some hope, I respectfully ask the court to grant PUBLIC LAW CENTER time to process us.

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

Executed on this 26th day of July, 2018         SIGNED__________________________________

                                                                                               JENNIFER MARSHALL

 

EXHIBIT A

STATE BAR OF CALIFORNIA

Complaint Review Unit

Office of The General Counsel

180 Howard Street

San Francisco, California 94105-1617

July 24, 2018

Inquiry Number 18-20383

Dear State Bar of California Complaint Review Unit,

I respectfully request a review my three separate complaints regarding three separate attorneys that got lumped together as one. I believe the more serious complaint is the one against Attorney George Milionis and that lumping him with less serious offenses was a mistake. Perhaps the mistake was mainly mine for reporting unprofessional behavior of two attorneys from the same firm at the same time I reported what I believe to be the criminal behavior of George Milionis.

Mr. Milionis is deliberately abusing the MECHANICS LIENS process and using the process as his personal tool to avoid detection of PETERSEN DEAN and HERO FINANCING’S multiple wrong doings and to cover up financial fraud PETERSEN DEAN committed with HERO FINANCING when they acted as HERO’S unlicensed broker.

As per the enclosed HOMEOWNER’S GUIDE TO PREVENTING MECHANICS LIENS, there is a LIEN REQUIREMENTS CHECKLIST. Mr. George Milionis knows full well he did not meet those requirements. He is aware he is not using MECHANICS LIENS correctly for the purpose that they exist for. MECHANICS LEINS used to cover up a crime is nefarious and such an attorney should not be allowed to continue committing financial crimes with impunity.

Mr. Milionis knows that a job must be completed before he can place a MECHANICS LIEN. In June 2018 Petersen Dean paid a $500 citation (Copy of Citation enclosed) to the CSLB for not removing and replacing rotten wood, for covering rotten wood with new shingles, for not doing the work they were hired to do up to standard. That citation will remain on Petersen Dean’s record for five years and yet Mr. Milionis shrugs it off as if it is nothing because the fine was laughably small and he can still leave the work unfinished, still leave rotten wood under the new shingles, still remove the financing and demand more money than was agreed for the job and still file Mechanics Liens to cover up the financial fraud. Petersen Dean and George Milionis flaunt their lawlessness in your face, in the court’s face, in my face. Mr. Milionis clearly feels he may act with impunity and that the laws that apply to others do not apply to him and his client PETERSEN DEAN.

Mr. Milionis knows the CSLB Lien Checklist requires that the homeowner must accept the improvement and be using the improvement and he knows the job was never completed, that the homeowner did not sign off the completion documents with HERO FINANCING because was never completed in 2016. The solar panels were never turned on all these years. DWP never inspected the panels. Both HERO and PETERSEN DEAN agreed to remove the solar panels after H&R Block indicated that I most certainly would not receive $10,000 tax credit because as a senior citizen caring for my adult autistic son, we do not pay taxes. Mr. Milionis decided to withdraw the HERO FINANCING and pretend it never existed and he proceeded to deliberately misuse the MECHANICS LIEN process to cover up financial fraud that had become noticed by the homeowner’s tax preparer Mr. Martin of H&R Block.

I believe many of the actions of Mr. Milionis rise to a criminal level.

The other two SEPARATE complaints against Mr. Karimzadeh and Mr. Mendoza, (all three given the same INQUIRY NUMBER) are for unprofessional conduct and do not rise to a criminal level. Lumping all three separate attorneys under one INQUIRY served to water down the very serious complaint against George Milionis. Mr. Mendoza was toying with me. Mr. Karimzadeh was faking having communication with me just so he could say he tried but I wouldn’t’ cooperate. He made no real effort to discuss the case with me. Who sues a person then refuses to communicate with them?

Mr. Karimzadeh was unprofessional and did not make any true effort to have a legitimate meet and confer with me. He wanted Judge Murphy to believe true communication was offered but in his emails to me you can clearly see no real settlement offers were discussed, no mention of the financing was discussed. Mr. Karimzadeh limited his communication to trying to manipulate me to give up my right to a trial by jury. He refused to discuss any details of the case with me. That is not an opinion. That is supported by his emails, our only means of communication. The emails do not show any good faith discussion of the case and the financing. Mr. Mendoza asked questions about the incomplete work….questions he knew the answer to because the CSLB citation made it clear…and he was not the attorney of record. Mr. Karimzadeh did not discuss the incomplete work, the rotten wood under new shingles, the removal of the solar panels or ANY of the details of the financing and the case. He stubbornly refused to discuss the financing that had vanished into thin air. Where did the HERO financing go? Why is PETERSEN DEAN allowed to get rid of HERO and call for $34,000 cash ($10,000 more than agreed) without financing and without finishing the job?

Mr. Mendoza emailed me until I told him to stop. There was no reason for him to contact me at all, even once, ever. Mr. Karimzadeh is the attorney of record and it was his job to tell me anything that Mr. Mendoza told me. I only answered Mr. Mendoza because I thought he acted like he was taking over the case for Mr. Karimzadeh. These two men both behaved unprofessionally. I filled out separate complaints for each attorney because no attorney deserves to be lumped together and accused of another attorney’s behavior and actions. Especially when those actions of one individual rise to a criminal level.

I believe George Milionis is a criminal and that he has done great harm to many homeowners in the State of California. Please separate his Inquiry from the other two nuisance complaints for attorneys acting unprofessionally and take a second look at the actions of George Milionis.

It is my opinion that George Milionis should not be practicing law in the State of California in light of how he has blatantly, undeniably, deliberately abused the MECHANICS LIENS process. Mr. Milionis is making up his own MECHANICS LEINS laws as he goes along. He changes the MECHANICS LIENS law to suit his need and uses it as a weapon to control and intimidate people, wielding the threat of the MECHANICS LIENS in writing to force signatures from homeowners long before the job is finished, YEARS before the job is finished in this case. Mr. Milionis helps PETERSEN DEAN broker HERO FINANCING without a license and revokes the financing and demands instant cash payment in full, more money than agree upon and with no financing if someone (in my case H&R Block) discovers the property tax financing fraud in progress.

Please take a second, closer look at this.

Thank you for considering this matter.

Sincerely,

Jennifer Marshall

COPY OF LETTER SENT TO PETERSEN DEAN AS PER CSLB BOOKLET:

FROM: Jennifer E. Marshall

April 9, 2017

VIA CERTIFIED MAIL

TO: Petersen Dean, Inc.

39300 Civic Center Drive, Suite 300

Fremont, California 94538

RE: INVALID LIEN 20170093119

       INVALID LIEN 29170093193

Dear Petersen Dean, Inc,

I was not served a copy of the two liens in question. I purchased copies from the courthouse in El Segundo, California via check and have the receipt.

Both liens are invalid because they do not adhere to the strict time frames and lien requirements.

Both liens are invalid because the job was abandoned by you on November 2, 2016.

The work and necessary repairs were not completed. The stucco powder you refused to hire Building Cleaning Services or any other reputable cleaning service to remove has drifted and contaminated the entire house making it uninhabitable. Numerous contractors interviewed to rebuild the kitchen refused to enter the house until the stucco powder is remediated as it made them instantly feel sick. I suffered a bloody nose, sore throat and burning eyes. My autistic son James developed a severe lung infection. Assurant Insurance paid for air quality testing of the entire house. The powder you refused to remove from my son’s room on November 2, 2016 has contaminated the air vents and the carpeting and is everywhere now. The mold remediation being done in the kitchen by Assurant was disrupted by your abandonment of the job on November 2, 2016 and put on hold until you made the air quality safe again, which you still have not done.

The solar panels are not in use. You agreed in writing to remove the solar panels after H&R Block examined your figures and determined that I would not receive ANY of the savings, that it was a tax credit scam. You did not remove the panels as agreed. The roof is creaking and you did not fix that or any of the items you previous agreed to repair. A complete list of everything you didn’t finish and left in disrepair is attached to the CSLB claim and is being verified by the Contractors State Licensing Board Case Number: SF20169935.

I hereby request that you immediately remove both of the invalid liens. If I have to hire an attorney to make you remove the invalid liens, I am instructed to remind you that I am entitled to be awarded all reasonable attorney fees.

Sincerely,

Jennifer E. Marshall

I SENT PETERSEN DEAN THE ABOVE CERTIFIED LETTER AS PER THESE CSLB INSTRUCTIONS: