1 LEWIS PEDIGO

3222 OAK KNOLL DRIVE

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ROSSMOOR CA 90720
3 562-650-6146 |
lewispedigo@icloud.com
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SUPERIOR COURT OF THE STATE OF CALIFORNIA, county of orange
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central justice center

7 Gloria Daily, Case No.: 30-2023-01307144-CL-UD-CJC

8 Plaintiff,

9 PLEADING TITLEIN RESPONSE TO GLORIA DAILY’S

vs.
UNLAWFUL DETAINER COMPLAINT;
10 AFFIRMATIVE DEFENSES,
Lewis Pedigo, Does 1-10 and All Occupants
ATTACHMENTS
11 Defendants
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COMES NOW, the defendant, Lewis Pedigo, who answers the unlawful detainer complaint of
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plaintiff , Gloria Daily as follows:
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15 1. Defendant denies the allegations in paragraph 1, 6c, 6d, 9d, 9e, and 11
16 2. Defendant admits the allegations in paragraph 1,2,3,4

17 3. Defendant has no information or belief that the allegations in paragraphs 5, 7, 8,

9a, 10, 11, 12, 13, 14 and 15 are true so Defendant denies them
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4. Except as expressly admitted herein, Defendant denies all of the allegations of the
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complaint
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FURTHER, AS SEPARATE AFFIRMATIVE DEFENSES to each and every cause of action of
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the complaint, this answering defendant is informed and believes, and on such information and
23 belief alleges as follows:
24 FIRST AFFIRMATIVE DEFENSE
25 5. As a First and Separate Affirmative Defense to the complaint this answering defendant

26 alleges that the complaint fails to state a cause of action for unlawful detainer on the

27 CASE NO. - 1

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1 grounds that the Plaintiff did not provide the Defendant with the mandatory written
2 notice of the tenants right to request an initial inspection of the rental during the last 14

3 days of the tenancy. On or about January 20 the Plaintiff daughter knocked on the door

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and said they (the Plaintiff and her daughter) would be doing the inspection on the 31st.
The Defendant didn’t know he was even being deprived of any rights he had.
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Nor was the Defendant informed about any other of his tenant rights that are
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mandatory to be delivered by the Plaintiff. Even the Rent Cap addendum was buried in
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the lease on pages 13-15 between the flood hazard and water heater disclosures, if
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there are any.
9 6. The complaint as well as the supplemental forms have minor errors in them.
10 a) UD 100 item 3a the city is Rossmoor. 3222 Oak Knoll Drive is specifically within the
11 parameters of Rossmoor.

12 b) As it is written on the complaint the property is in an unincorporated city of Orange

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County - Los Alamitos is NOT unincorporated, Rossmoor is.
c) 6c Samantha Jones is not technically a subtenant. She does not rent from the
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defendant, nor is there a written agreement of any kind. The Plaintiff knows her 3
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years and know she is my fiancé. The correct answer would have been to select (3)
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Other.
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7. The Plaintiff only made it more difficult for the Defendant to financially afford to move by asking
18 for 7795.00 . For lack of a better term she put the squeeze on me
19 8. She had the opportunity to try to help the defendant with his Ex-Parte request. She then created

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more difficulties by filing this action.
9. .The defendant has a doctors letter keeping him off work until March 31,2023.
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10. The defendant has refiled an RFO for the Request to withdraw funds and the hearing is set for
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April 3 8:30 am in Whittier Courthouse.
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24 PRAYER FOR RELIEF

25 WHEREFORE, the Cross-Plaintiff prays for judgement in his favor and PLAINTIFF as follows:

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27 CASE NO. - 2

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1 1. I pray to the court today to dismiss Gloria daily’s complaint and to allow me to stay here until I

2 can have my hearing for the Request for funds and find a place with the fund. If this court has
any power to assist me in the release of those funds I request that too. I don’t want to be where I
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am not wanted.
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2. An order sealing the record after judgment or dismissal.
5 3. Plaintiff be ordered to assist the Defendant with a statement and if necessary, an appearance for
6 any proceedings in his Request for the Funds in Trust for living and moving expenses

7 4. And attachment UD-105 page 5

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I, LEWIS PEDIGO, under the penalty of perjury under the LAWS of the STATE OF CALIFORNIA,
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declare the foregoing is true and correct.
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13 February 27 , 2023

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Lewis Pedigo
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27 CASE NO. - 3

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