1 Gary Crosier

5779 Arboga Road

2 Olivehurst, CA 95961 12/16/2019
(530) 321-7096
3 C Rodriguez
PLAINTIFF IN PRO PER
4
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
5 COUNTY OF YUBA
6

7 ) CASE NO. CVCV19-02108

GARY CROSIER, )
8 Plaintiff, ) VERIFIED COMPLAINT FOR:
)
9 ) 1. MECHANIC'S LIEN FORECLOSURE
v. 2. BREACH OF CONTRACT
)
10
) 3. BREACH OF COVENANT OF QUIET
) ENJOYMENT
11 JOHN TRAVIS,
) 4. VIOLATION OF CIVIL CODE
12 ) §1942.4
Defendant. ) 5. NEGLIGENT INFLICTION OF
13 ) EMOTIONAL DISTRESS
6. NUISANCE
________________________________________________)
14 7. BUSINESS & PROFESSIONS CODE
17200
15
8. TORTIOUS BREACH OF WARRANTY
16 OF HABITABILITY

17 UNLIMITED CIVIL COMPLAINT

DEMAND FOR JURY TRIAL
18

19
COMES NOW PLAINTIFF, GARY CROSIER, an individual residing in Yuba
20 County, California, for causes of action against defendant, JOHN
TRAVIS, who complain and alleges as follows:
21

22 I. PARTIES

23

24 1. Plaintiff GARY CROSIER is a 49 year old man residing at 5779

Arboga Road Olivehurst, CA 95961.
25
2. Plaintiff GARY CROSIER lives in the State Of California,
County Of Yuba.
26

27 3. Defendant JOHN TRAVIS resides at 13029 Eagle Pine Place Nevada

City, CA 95959.
28
 1 4. Defendant JOHN TRAVIS owns real estate commonly known as 5779
Arboga Road Olivehurst, CA 95961.
2

4 II. JURISDICTION AND VENUE

5 5. Jurisdiction and venue are proper in this Court because the

acts alleged herein occurred in Yuba County, State Of California.
6
Plaintiff GARY CROSIER is also situated in Yuba County.

9
III. GENERAL ALLEGATIONS
10

11 6. Starting on or about August of 2017, GARY CROSIER

("Plaintiff"), was asked by Defendant JOHN TRAVIS, to start repairs to
12 the real property known as 5779 Arboga Road, Olivehurst, CA 95961.
13 7. Plaintiff is informed and believes, and hereon alleges that all
times herein relevant, JOHN TRAVIS requested
14
that Plaintiff GARY CROSIER start improvement work on the
15 above-described property.

16 8. Plaintiff is informed and believes, and thereon alleges that at

all times herein relevant, that defendant owns real property, located
17 at 5779 Arboga Road Olivehurst, CA in Yuba County.
18
9 . Plaintiff is informed and believes, and thereon alleges
19 that at all times herein relevant, that defendant JOHN TRAVIS, is an
individual and is authorized to do business in the County of Yuba.
20

21 10. Plaintiff is informed and believes, and thereon alleges that at

all times herein relevant, that defendant was an agent, servant,
22 employee, successors of interest, partners and or/joint ventures and
were acting within the course, scope, and authority of said defendant.
23
11. Plaintiff GARY CROSIER reallege and incorporate by reference
24
those paragraphs set forth above as if fully set forth herein.
25
12. By Defendant JOHN TRAVIS not keeping his end of the deal,
26 Plaintiff GARY CROSIER further alleges a breach of contract
27

28
 IV. FIRST CAUSE OF ACTION
1
(MECHANIC'S LIEN FORECLOSURE)
Against All Defendants
2
13. Plaintiff GARY CROSIER reallege and incorporate by reference
3 those paragraphs set forth above as if fully set forth herein.

4 14. On September 20th, 2019, Plaintiff GARY CROSIER gave notice

to Defendant JOHN TRAVIS, VIA Demand For Payment and a Notice Of
5
Intent To Withhold Rent letter that he owed Plaintiff for unpaid
labor, materials, services and/or supplies. (PLEASE SEE EXHIBIT "
".) and also that he was going to withhold rent until that amount
6 was paid in full.
7
15. Plaintiff GARY CROSIER had served Defendant JOHN TRAVIS with
the Mechanic's Lien Preliminary 20-day notice(as per C.C.§ 3144)
8

9 16. On 10/01/19, Plaintiff GARY CROSIER filed with the Yuba County
Clerk-Recorder, a Mechanic's Lien for the amount of
10
$8,350.30 including interest for labor, materials, services and/or
supplies. The recording cost was in the amount of $ 98.00. No
part of which has been paid.
11

12
17. Plaintiff GARY CROSIER in good faith, gave Defendant JOHN
TRAVIS 76 days until the filing of this complaint.
13

14

15 V. SECOND CAUSE OF ACTION

(BREACH OF CONTRACT)
16 Against All Defendants

17 18. Plaintiff re-alleges and incorporates by reference every

allegation contained in the preceding paragraphs of this Complaint
18 as though set forth herein.
19
19. On September 18th 2019, plaintiff duly caused a preliminary
20
notice to be given in accordance with the provisions of civil code
section 3097.
21 20. On October 1st 2019, plaintiff duly paid for the recording of
a mechanic's lien, which was recorded the very next morning on
22
October 2nd. The verified Mechanics' Lien Claim, describing the
23 building parcel and the labor, services, equipment, and materials to
be furnished on the work of improvement, document ID # 2019-013193
24 in the official records of Yuba County, California, in accordance
with the provisions of Civil Code section 3084. The cost of
25 recording the Mechanic's Lien Claim was $98.00, no part of which has
been repaid.
26

27 21. Defendant claims some right, title, or interest in or to the

building parcel, each of which claim is junior and inferior to
28 plaintiff's claim.
 1 22. Plaintiff is informed and believes and, based thereon,
alleges that Defendant's breach of their respective duties of
2
paying plaintiff, as set forth above, in causing the filing of this
3 civil action against defendant.

4
VI. THIRD CAUSE OF ACTION
5 (BREACH OF THE COVENANT OF QUIET ENJOYMENT)
Against All Defendants
6

7
18. Plaintiff re-alleges, and incorporates by reference every
8
allegation contained in the preceding paragraphs of this Complaint
9 as though set forth herein.

10 19. Implied in the lease agreement between Defendant and

Plaintiff is a covenant that the Defendant would not and will not
11 interfere with Plaintiff's quiet enjoyment of The Property during
the term of their respective tenancies. This covenant of quiet
12
enjoyment is codified in California Civil Code Section 1927.
13
20. Defendant has breached the implied covenant of quiet
14 enjoyment as alleged herein, including, but not limited to: their
failure and refusal to repair the alleged habitability violations
15 and to maintain The Property in a habitable condition and in a
condition consistent with the purpose for which it was leased.
16

17 21. As a direct and proximate result of Defendants' breach of the

covenant of quiet enjoyment, the value of the leasehold held by
18 Plaintiff has been materially diminished. Consequently, Plaintiff
has been damaged in an amount to be established at trial.
19
22. As a direct and proximate result of Defendant's conduct,
20
Plaintiff has sustained general, special and property damage in
21 amounts to be determined at trial.

22

23
VII. FOURTH CAUSE OF ACTION
24 (VIOLATION OF CIVIL CODE §1942.4)
Against All Defendants
25

26

27

28
 1 23. Plaintiff re-alleges, and incorporates by reference every
allegation contained in the preceding paragraphs of this Complaint
2 as though set forth herein.
3
24. The Property substantially lacks, and at all material times,
4 has lacked the affirmative standard characteristics identified in
Section 1941.1 of the Civil Code and Section 17920.10 of the Health
5 and Safety Code, as alleged above.

6 25. A public code enforcement agency has been notified that

Defendant was in breach of the defective conditions at The
7
Property. The defective conditions were not caused by any act or
8 omission of Plaintiff.

9 26. Without good cause, Defendant failed to make repairs within 35

days of receiving those notices, during which time the substandard
10 conditions continued to exist without abatement.
11
27. Since receiving said notices, Defendant has collected and/or
12 demanded rent from Plaintiff and other tenants.

13 28. By reason of the foregoing, Defendant has violated California

Civil Code Section 1942.4.
14
29. As a direct and proximate result of the foregoing, Plaintiff
15
is entitled to statutory damages pursuant to Section (b)(I) and
16 reasonable attorney's fees and costs pursuant to Section (b)(2).

17

18

19
VIII. FIFTH CAUSE OF ACTION
20
(NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS)
21 Against All Defendants

22

23 30. Plaintiff re-alleges and incorporates by reference every

allegation contained in the preceding paragraphs of this Complaint
24
as though set forth herein.
25
31. As owners, operators and managers of The Property, the
26 Defendant owed Plaintiff the duty to exercise reasonable care in the
ownership, management and control of The Property.
27

28
 1 32. These duties owed by Defendant to Plaintiff to exercise
reasonable care include, but are not limited to: the duty to refrain
2
from interfering with Plaintiff’s full use of and quiet enjoyment of
3
their rented premises; the duty to comply with all applicable state
and local laws governing Plaintiff’s rights as tenant; the duty to
4 maintain Plaintiff's premises in a safe, healthy and habitable
condition for the entire term of Plaintiff's tenancy and the duty to
5 not obstruct Plaintiff’s full use and occupancy of their leased
residences.
6
33. Defendant, by the conduct alleged above, so negligently and
7
carelessly maintained, operated, and managed The Property as to
8 breach the duties that they owed to Plaintiff.

9 34. As a direct and proximate result of these breaches of duty by

Defendants, Plaintiff has sustained general, special and property
10 damage in amounts to be determined at trial.
11

12

13
IX. SIXTH CAUSE OF ACTION
(NUISANCE)
14 Against All Defendants

15
35. Plaintiff re-alleges, and incorporates by reference every
16
allegation contained in the preceding paragraphs of this Complaint
17 as though set forth herein.

18 36. The conditions of The Property that Defendants, and each of

them, negligently and intentionally caused to exist constitute a
19 nuisance within, but not limited to the meaning of Civil Code
Section 3479, et seq. in that said defective conditions were and
20
are injurious to the health and safety of Plaintiff, indecent and
21 offensive to the senses of Plaintiff and did and continue to
interfere substantially with Plaintiff’s comfortable enjoyment of
22 The Property.
Such nuisances have been and are ongoing.
23
37. Such nuisances have caused, and will continue to cause in the
24
future, Plaintiff to suffer general and special damages.

25 38. Pursuant to Civil Code Section 3501, Plaintiff brings this

civil action for private nuisance.
26

27
39. The dangerous and defective conditions at The Property
constituted a nuisance, and deprives Plaintiff of the safe, healthy
28 and comfortable use of the premises.
 1 40. Defendant has failed to adequately abate the nuisance as
required by law. As a direct and proximate result thereof,
2 Plaintiff has sustained general, special and properly damage in
amounts to be determined at trial.
3

5 X. SEVENTH CAUSE OF ACTION

(BUSINESS & PROFESSIONS CODE § 17200 et seq.)
6
Against All Defendants
7
41. Plaintiff re-alleges and incorporates by reference every
8 allegation contained in the preceding paragraphs of this Complaint
as though set forth herein.
9
38. Defendant engaged in unlawful and unfair business practices
10
prohibited by California Business & Professions Code § 17200, et
11
seq. by virtue of the foregoing acts and omissions.

12 39. Plaintiff was harmed as a result of said practices by paying

full monthly rent with material deficiencies.
13
40. The foregoing acts and omissions were and are the regular
14
business practices of the Defendant at The Property.
15
41. As a direct and proximate result of the aforementioned acts and
16 omissions, the Defendants have been unjustly enriched at the expense
of Plaintiff, and Plaintiff is entitled to restitution in an amount
17 to be proven at trial.
18

19

20 XI. EIGHTH CAUSE OF ACTION

(TORTUOUS BREACH OF WARRANTY OF HABITABILITY)
21 Against All Defendants
22

23 42. Plaintiff re-alleges, and incorporates by reference every

allegation contained in the preceding paragraphs of this Complaint
24 as though set forth herein.
25
43. The defective conditions alleged herein constitute violations
26 of state and local housing laws and posed severe health and safety
hazards and breached the implied warranty of habitability.
27

28
 1 44. Defendant had actual and constructive notice of the defective
conditions alleged herein, but despite such notice, failed to
2 adequately repair and abate the conditions at The Property.
3
45. Plaintiff did not cause, create or contribute to the existence
4 of the defective conditions alleged herein.

5 46. By failing to correct said defective conditions, Defendant has

breached the warranty of habitability implied in all rental and
6 lease contracts under California law.
7
47. Defendant knew or should have known that permitting said
8 defective conditions to exist threatened the physical and emotional
health and well being of Plaintiff, and posed a serious threat and
9 danger to their health and safely.
10 48. As a direct and proximate result of Defendants' breach of the
11
warranty of habitability. Plaintiff has sustained special, general
and property damage in amounts to be determined at trial.
12

13 WHEREFORE, plaintiff demands judgment against defendants for the

following:
14

15
1. The sum of $8,350.80, together with interest
16 according to law as damages;

17 2. The sum of $98.00 in costs incurred in recording

the verified Mechanics' Lien Claim;
18
3. The sum of $8,451.30, together with interest, be ordered as a
19
lien against the building parcel, senior and superior to any claim
20 of right, title or interest in or to the real property of any
defendant, and that the real property be ordered sold by the
21 Sheriff of Yuba County, California, according to law, and that all
proceeds of sale be applied to plaintiff's claim and to the cost of
22 these proceedings and the sale of the real property;
23
4. Reasonable costs as allowed under Civil Code section 3148; and
24
5. For statutory damages under Civil Code Section 1942.4 and
25 restitution under Business and Professions Code Section 17200;

26 6. Reasonable attorney fees; (If Applicable)

27
7. Costs of suit;
28
 1
8. For such other relief as the Court may deem just and proper.
2

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28
 1 REQUEST FOR JURY TRIAL
2

3 The Plaintiff hereby demands a jury trial.

5 DATED: December 16th, 2019

6

7 Respectfully submitted,

10

11

12
Gary Crosier
13 Plaintiff in Pro Per
14

15

16

17

18

19

20

21

22

23

24

25

26

27

28
 1
VERIFICATION
2

4
Verification of Pleading (Code Civ. Proc., § 446) Declaration
under Penalty of Perjury Form (Code Civ. Proc., §§ 446,
5
2015.5)
6

7
I, Gary Crosier, do declare; I'm the Plaintiff in the above-
8 entitled matter. I have read the foregoing complaint and
know the contents thereof.
9

10 The same is true to my knowledge, except as to those matters

which are therein stated on information and belief, and, as
11 to those matters, I believe it to be true.

12 Executed on this 16th day of October 2019 at Olivehurst, Yuba

County, California.
13

14 I declare under penalty of perjury that the foregoing is true

and correct.
15

16

17

18

19

20 _____________________________
Gary Crosier
21
Plaintiff IN PRO PER
22

23

24

25

26

27

28
 EXHIBIT a
OFFICIAL RECEIPT-YUBA COUNTY CLERK/ RECORDER-REGISTRAR OF VOTERS
915 8th Street, Suite 107, Marysville, CA 95901

CUSTOMER NAME: 13121

RECEIPT#: -----

Transaction Fees

ovi ttce,oun t
TOTAL

□ Cash □ Check# ---

Terry A. Hansen, County Clerk

10,,0112019 04: 39 PM POT

YUBA COUN1Y Cl.ERK RECORDER
915 8TH STREEL sum 107
MRYSVIL!.E, CA 95901
TERM rnAl NAHt: E80n301
ORDER tt: 96919833

PURCHASE
RECOR[!ER ms $9800
AGENCY SUBTOTAL: $98. 00
lJXISNEXIS SERVICE fEE: $2.50
fOTAl USO: $100. 50

CARu rt: %n VISA

PAYMENT: DEBIT MAGSTRIPE-SWIPE
MID: m.1::n98£7
no: mim8£r
AUTH CO[t 076726
REC ti: 0005
AMOUNT: $100. 50
iu CARD APPROVED m

m1m:ii�iiin�1mim:mmuumm
AMOUH1 PAIO:
$100.50
*******mm1111muii1111mm1iu11

I AGREE TO PAY A�OVE rnTAL AMOUNT

ACCORDING TO mRD ISSUER AGREEMENT
(MfRf'.�ANT AfiRffMfNT Tf rix:nn VOllr�f�)
 - --
Recording requested by (name):
2019-013193
18/82/2019 08:04 AM
Page 1 of�
Gary Crosier Total F ee : $98.00
Recorded in Off icial R1cCAds
When recorded, mail to (name and address): Vuba State o
c0111ty of
A Hans en
T Recorder

111 li:.�li���t.l\t�.lflll
C�::;.{y Clerk and
Gary Crosier

5779 Arboga Road

Olivehurst, CA 95961

Recorder's Use Onl

CLAIM OF Declaration of Exemption From Gov't Code§ 27388.1 Fee

MECHANICS LIEN D Transfer is exempt from fee per GC § 27388.1 (a)(2):

D recorded concurrently "in connection with" transfer subject to OTT
D recorded concurrently "in connection with" a transfer of
(Cal. Civ. Code§ 8416) residential dwelling to an owner-occupier
D Transfer is exempt from fee per GC 27388.1 (a)(1):
D Fee cap of $225.00 reached D Not related to real property
1. _._.........
.,.G.,._A_..R YA ....
L
...
L
...
E
.....N......,,.
C.,..R
....O S....
.......,IE _,_________�--- ("claimant") claims a mechanics lien for the labor
....R
or services or equipment or materials described in paragraph 2, furnished for a work of improvement on that certain real
property located in the County of Yuba , State of California, and more particularly described
as (address and/or sufficient description): 5779 Arboga Road, Olivehurst, CA 95961

2. After deducting all just credits and offsets, the sum of$ 8,350.30 , together with interest at the
rate of 10 per annum from August 2017 (date when balance became due), is due claimant for the
following labor, materials, services, or equipment: _______________________
PLEASE SEE EXHIBIT A FOR COMPLETE LIST

3. Claimant furnished the labor or services or equipment or materials, at the request of _________
JOHN M TRAVIS (employer, person, or entity to whom
labor, materials, services, or equipment were furnished).
4. The name and address of the owner or reputed owner of the real property is/are: JOHN M TRAVIS
13029 Eagle Pine Place Nevada City, CA 95959
5. Claimant's address is: 5779 Arbo a Road Olivehurst

Dated September 20th, 2019

Gavt1
""\ VERIFICATION .
I, C..rOS\t..r ,am the: (),Nne(-Js�lf ("owner,"
"president," "authorized agent," "partner," etc.) of claimant on the foregoing claim of mechanics lien, and am authorized to
make this verification for and on its behalf. I have read the foregoing claim of mechanics lien and know the contents of the
claim of mechanics lien to be true of my own knowledge.

Dated t j O 1 } 19 /-r
I declare under penalty of perjury under the laws of th�,;,State of Caljfprni,� th�t the foregoing is true and correct.
1c'7/�
,,/'". ,1 �
,._____
-

(Signature)
 a
b

NOTICE OF MECHANICS LIEN CI-AII

ATTENT!ON!

Upon the recording of the enclosed ilIECHANICS LIEN with the county recorde/s
office of the county where the propefi is located, your property is sttbiect to the filing of a
legal action seeking a court-ordered foreclosure sale of the real property on nthich the lien
has been recorded. That legal action must be filed with the court no trr than 90 days after
the date the mechanics lien is recorded.

The party identified in the enclosed mechanics lien may have provided labor or
materials for improvements to your property and may not have been paftl for these items.
You are receiving this notice because it is a required step in filing a mechanics lien
foreclosure action against your property. The foreclosure action willseek to pay for unpaid
labor, materials, or improvements provided to your property. This may affect your ability to
borrow against, refinance, or sell the property until the mechanics lien is release.

BECAUSE THE LIEN AFFECTS YOUR PROPERTY, YOU MAYwlSH TO SPEAK WITH
YOUR GONTRAGTOR IMMEDIATELY, OR GONTACT AN ATTORNEY, OR FOR MORE
INFORMATION ON MECHANIGS LIENS GO TO THE GONTRACTORS'STATE LIGENSE
BOARD WEB SITE AT
 =€'

PROOF OF SERVICE AFFIDAVIT

California Civil Code section 8416

Failure to serve the Mechanic's Lien and Notice of Mechanic's Lier: :r the owner, or alternatively if
the owner cannot be served on the lender or direct contractor, shall cause :-: lr'lechanic's Lien to be
unenforceable as a matter of law (Civil Code Section 8024(d)). Service of tre l''lechanic's Lien and Notice c'
Mechanic's Lien must be by (1) registered mail, (2) certified mail, or (3)first-c ass mail evidenced by a
certificate of mailing, postage prepaid and to a residence or business address ror the owner, lender or
contractor. Further, a Proof of Service Affidavit (below) must be completed an: signed by the person serving
the Mechanic's Lien and Notice of Mechanic's Lien. This page should be comp eted (either one of the
sections below) and recorded with the County Recorder along with the Mechan c s Lien and Notice of
Mechanic's Lien.
PROOF OF SERVICE AFFIDAVIT (ON OWNER)
California Civil Code section 8a16(a)(7) and (c)(1)

t, (name), declare that I served a copy of this Mechanic's Lien and

Notice of Mechanic's Lien by registered mail, certified mail, or first-class mail evidenced by a certificate of
mailing, postage prepaid, addressed as follows to the owner(s) or reputed owner(s) of the property:

Com pa ny/Person Served:

Title or capacity of person served (if appropriate):
Service address:
Said service address is the owner's iesidence, place of business, or address showed by thti building permit
on file with the permitting authority for the work.

! i,
1, i r

Executed on !i"
:
20 i'i (date) at

l,'* tI r, ,r
f i- f .
Bvi''
(Signature of person making service)

ALTERNATE PROOF OF SERVICE AFFIDAVIT (ON LENDER OR DIRECT CONTRACTOR)

California Civil Code Section 8416(aX7) and (c)(2)

I, (nare) declare that the owner or
reputed owner cannot be served with a copy of this Mechanic's Lien and Notice of Mechanic's Lien by
registered mail, certified mail, or first-class mail. Pursuant to California civil Code section 8416(c )(2), I
served a copy of this Mechanic's Lien and Notice of Mechanic's Lien by registered mail, certified mail, or
first-class mail evidenced by a certificate of mailing, postage prepaid addressed as follows to the
construction lender or direct contractor as follows:

Company/Person Served:
Title or capacity of person served (if appropriate):
Service address:

Executed on ,20 (city),

(county), California.

By:
(Signature of person making service)
 EXHIBIT A
Claimant's labor, materials, services, and/or equipment:
1. Front Tree Trimming - 485.00
2. Rear Plum Tree Trimming - 250.00
3. Pest Control - 400. 00
4. Skunk Removal - 499.00
5. First Time Water Heater Repair - 200.00
6. First Time Water Damage Repair - 350.00
7. Second Time Water Heater Repair - 200.00
8. Second Time Water Damage Repair - 350.00
9. First Roof Repair - 450.00
10. Second Roof Repair - 450
11. Shop Roof Coating Prep - 450.00
12. Shop Roof Waterproofing Coating - 475.00
13. AC Maintenance - 100.00
14. Dishwasher Repair - 50.00
15. Kitchen Sink Repair - 75.00
16. Yard Restoration - 400.00
17. Hazardous Electrical Disconnection and Removal - 450.00
18. Running Of New Modern Electrical Lines - 450.00
19. Installation Of New Electrical Box - 125.00
20. Breakers And Connectors - 100.00
21. Electrical Meter Panel Board Repair - 100.00
22. First Shop Door Repair - 100.00
23. Second Shop Door Repair - 100.00
24. Third Shop Door Repair - 100.00
25. Heater Repair 250.00

TOTAL 6,959.00
Plus 10% interest from August 2017 totaling $8,350.30

VERIFICATION
I, Gary Allen Crosier am the claimant on the foregoing claim of mechanics lien, and am authorized to make this
verification. I have read the foregoing claim of mechanics lien including Exhibit A and know the contents of the claim of
mechanics lien to be true of my own knowledge.
I declare under penalty of perjury under the laws of the State of California/that the foregoing is true and correct.
Dated September 20th, 2019

(Signature)
September 18th, 2019

Gary Crosier

5779 Arboga Road

Olivehurst, CA 95961

TO JOHN M TRAVIS, OWNER OF 5779 Arboga Road Olivehurst, CA 95961:

I’m writing this letter of intent of withholding rent for the month of October. I paid rent in the month of
September to your authorized agent, Penny Scott. The letter delivered to me by your attorney is simply
not accurate about not having paid rent, therefore there is no Just Cause for evicting my wife and me.

Also, you signed a 2-year lease contract with me signed and dated March 1st, 2019 , effective the date
that Penny Scott, your authorized agent and acting landlord, moved out which was on September 13th,
2019.

Furthermore, you owe me the sum of 6,959.00 , for repairs and maintenance that I’ve done at your
request since August of 2017, including the 10% per annum interest that has accrued on top of the
$6,959.00, FOR A TOTAL OF $ 8,350.80

I am agreeable to a lump sum payment.

This is a formal Demand for Payment and notice of intent.

If you do not contact me on or before September 25th, 2019 , I will file a civil lawsuit against you without
further notice for wrongful eviction and unpaid labor and improvements.

I look forward to resolving this matter with you.

Thank you.

Sincerely,

Gary Crosier. ________________________________

(530) 321-7096 DATED: 9/18/19