Nancy Duffy McCarron, CBN 164780

950 Roble Lane

Santa Barbara, CA 93103
nancyduffysb@yahoo.com
805-450-0450
October 16, 2017
PERSONAL AND CONFIDENTIAL

Steven J. Moawad
The State Bar of California
Complaint Review Unit
Office of the General Counsel
180 Howard Street
San Francisco, CA 94105-1617
RE: Request to Review CONFLICTS in Case 16-0-16202
Respondent: Richard Nahigian, Robert Williamson
Aggravating Factors: 2 Public Reproval Cases (Nahigian)
1 Private Reproval Case (Nahigian)
CONFLICTS Bar Investigator Lita Abella failed to disclose

I represent Martin Jacinto and wife Carolina Ramirez – complainants in this Case No. 16-0-16202,
in Stubblefield v. Jacinto (CIVDS1208547) and Martin Jacinto v. Richard Nahigian (CIVDS1604759).

The July 21, 2016 bar complaint was filed against Richard Nahigian and Robert Williamson related
to unethical collusion in CIVDS1208547 resulting in a $190,499.00 fee award on a $10,000 mobile home.
LITA ABELLA is the State Bar Investigator assigned to Case 16-0-16202. Ms. Abella never disclosed the
inherent conflicts in her purported investigation resulting in “closing” the case against both respondents.
Ms. Abella should never have been assigned to this case. You have a duty to reassign case 16-0-16202 to
an investigator without multiple inherent conflicts who will actually investigate blatant state bar violations.
We file this request to Review CONFLICTS with attached evidence, separately from a Request to Review
Ms. Abella’s unfounded conclusions in a purported investigation simultaneously filed October 16, 2017.

Conflict 1: Ms. Abella’s Web Promotion of her Commercial “Private Investigator Business” Exhibit A
As you know the State Bar’s advertised Mission is to protect the public from bar attorney misconduct.
As you know lawyers often hire private investigators. You should not allow any State Bar investigator to
simultaneously operate a commercial “private investigator” business receiving income from area law firms.
The inherent conflict is unacceptable and a breach of your Mission to protect the public, not enrich your
investigators’ side businesses by soliciting money from attorneys they may be assigned to now investigate.
Ms. Abella can elect to close cases (after a perfunctory “investigation”--which is what she did in this case),
involving attorneys who hire Abella & Associates (like Robert Williamson and Richard Nahigian here).
We demand to know how much income Ms. Abella has received, or anticipates receiving, from either one.
Robert Williamson charged Jacinto for fees Hart/King firm paid to private investigators. Exhibit B
Williamson failed to disclose the names of the “investigators” or their “business name” on his costs memo.
Williamson charged Jacinto $3,115.95 costs for private investigator & $3,497.00 legal research. Exhibit C

What is to prevent an unscrupulous bar investigator from “cutting deals” with law firms to close cases?
The inherent conflict is clear to any reasonable fact finder or jurist. We demand a new investigation!
Page 1
Conflict 2: Ms. Abella & Mr. Nahigian (criminal defense attorney in LA for 30 years) Animosity for Police
Ms. Abella worked for 20 years in the LA Police Department. She alleged corruption, discrimination,
undisclosed police brutality and dishonest arrests. She was active as the union representative at her job.
She alleged misconduct by police department staff in discriminating against female and minority officers.
Ms. Abella resigned her position when it was imminent she would be fired for her own alleged misconduct.
Ms. Abella was the lead plaintiff in a class action against the LA Police Department. See Exhibit A

Nahigian shares the same disdain for LA police officers, as his practice is mostly in criminal defense.
As you know the criminal defense attorneys nearly always hire private investigators to obtain evidence to
use against police during trial. As a police officer in LA for 20 years, while Nahigian represented criminal
defendants for 30 years, discrediting police officers to obtain acquittals, it is inconceivable that these two
did not know each other. It is hard to believe Nahigian has not hired Abella & Associates to investigate
police in the LA area, especially since they share the same disdain for LA police officers. see Exhibit A
The inherent conflict is clear to any reasonable fact finder or jurist. We demand a new investigation!

Conflict 3: Ms. Abella is Lead Plaintiff in yet Another Class Action Against 24-hour Fitness (Yoga Teacher)

Ms. Abella is a Yoga Teacher soliciting Clients on the Internet. This is an inherent conflict as she is pre-
occupied with enriching herself in a side-business as a Yoga Teacher, spending her time marketing herself.
Abella is now Lead Plaintiff in a second Class Action suit against 24-hr. fitness (first was against LA Police).

Abella is so pre-occupied with litigations and multiple side businesses she has no time to do her job as
a State Bar investigator. Abella failed to conduct any in depth investigation in this case. This is because
Abella intended from the onset to create a pretext of a real “bar investigation” and then “close the case.”

Abella filed class action against her first 20-year employer (LA Police Department) and now a class
action against her second employer (or co-employer) 24-hour Fitness. Will the State Bar be next?
We request that you assign an investigator who actually has time to perform her or his job duties pursuant
to the State Bar’s mission; i.e. to protect the public – not to enrich its employees’ side businesses.
Page 2
Conflict 3: Abella’s Active Role as Union Rep in State Bar Association Consumes a Large Part of her Time
Abella is busy posting videos of picketers in front of the State Bar Offices, undermining her job duties.

It is only a matter of time before Lita Abella sues the State Bar of California for whatever reason!
The State Bar will have to spend our hard-earned annual dues to defend a frivolous class action lawsuit.
Conclusion. Attached under separate cover is our Request for Review (on the substantive merit issues).
Documents are attached in chronological order proving Nahigian and Williamson violated bar rules.
We ask that you personally review, since you continue to employ Lita Abella despite her inherent conflicts,
our Request for Review and re-assign the case to an investigator who is not pre-occupied with promoting
herself, marketing her side-businesses, and prosecuting class actions against her employers, hiding behind
her status as a union representative to bully everyone into exclusively promoting her financial interests.
This complaint is already over a year old. Thank you for your immediate response to our request.

10/16/17

Page 3
EXHIBIT A
Page 4
Page 5
Page 6
Page 7
Page 8
Page 9
Page 10
Page 11
EXHIBIT B
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 MC·Ol0
AT'rC'~NEY OR PARTY WITHOUT A'TTORNEY (Name, !!~:;;;;;;;;;;;:-;.';;;od;:';;dd;;ro;;";;J,- - - - - - - - - - '
John H. Pi~I~sb Esq .. Bar No. 99527. Robert G. Williams~.~p ~It~~ 73176

4 'Hutton Centre Drive. Ste. 900 u" nti\lll; is

Santa Ana. CA 92707
TELEPHONE NO.' 714·432·8700 FAX NO.' 714·546·7457
ATIORNEY FOR (Nama): STUBBLEFIELD PROPERTIES. dba MOUNTAIN SHADOWS MOBILE

INSERT NAME OF COURT, JUDICIAL DISTRICT, AND BRANCH COURT, IF ANY: MAY 2 0 2014
Superior Court of California . County of San Bernardino

J).d~;' ~PUTY
San Bernard ino Civil Division
I-FP~LANINNTnl~FF~:SS~TUU~B~B~LEEFFI~EiLDD~~P8Rn~~b.lMC~nJWNS}iArXlI~----IBY
MOBILE HOME COMMUNITY
DEFENDANT: MARTIN C. JACINTO, et al.
CASE NUMBER:
MEMORANDUM OF COSTS (SUMMARY) CIVDS1208547

The following costs are requested: TOTALS

1. Filing and motion fees . 1. $ 1.180.00

2. Jury fe es .... . ....... 2. $ 000

3. Jury food and lodging 3. $ 0.00

4. Deposition costs ...... .................................. 4. $ 2821.00

5. Service of process ....... .. ...... ..... ... . .................................. .... ....................... ... ..................................... 5. $ 555.46\

6. Attachment expenses .. " 6. $ 0.00\

7. Surety bond premiums ....... .... ..... . 7. $ 000/

8. Witness fees .. ... ... ...... .. ...... ...... .... ..... ,.,., .. ,', .. ....... , .. ....... .... ....................... .. ................ .. ........................... . 8. $ 000/

9. Court-ordered transcripts 9. $ 000/

10. Attomey fees (enter here if contractual or statutory fees are fixed without necessity of a court
determination; otherwise a noticed motion is required) ............................................................................. 10. $ Motion

11. Models . blowups. and photocopies of exhibits .......................................................................................... 11. $ 1,484.85

12. Court reporter fees as established by statute .... ........................................... 12. $ 1.262 .00

13. Other: see attachment 13 ................................ .. .. .......................................... 13. $ 9,4 18.61

1 TOTAL COSTS ............ .. .................. ..... ..... .. ................................... ............................................... ..................... $ 16,721. 92 1

I am the attorney, agent. or party who claims these costs. To the best of my knowledge and belief this memorandum of costs is correct
and these costs were necessarily incurred in this case.

Date: May (1. 2014

Rob~.r:t.S3 c 'l>' il~a.!:"s.~!L Esq _._
(TYPE OR PRINT NAME) ~ ~'GNATURE% s :»
(Proof of service on reverse)
Form Approved for Optional U!)e Code of Civil Procedure.
JudiCIal Cou nCil o f CalifornIa MEMORANDUM OF COSTS (SUMMARY) §§ 1032. 1033.5
MC-Ql0 [Rev. July 1.1999)

Page 13
 CASE NUMSER:
S!-10RT TITLE :
STUBBLEFIELD PROPERTIES V . JACINTO , et al. CIVDS1208547

MEMORANDUM OF COSTS (WORKSHEET)

1. Filing and motion fees

Paper fi led Fil ing fee

a. Complaint $ 435 .00

b. First Appea rance (cross-complainVThomas Parr ish) $ 435.00

c. Motion to Strike $ 90 .00

d. Ex-Parte Application $ 60 .00

e. Motion $ 120.00

f. Stipulation for Continuance (2) $ 40 .00

g. 0 Information abou t additional filing and motion fees is contained in Attach ment 19.

TOTAL 1.1'-'$'--_ _1'-'-,1.co8",0",.0=0I

2. Jury fees
Fee & mileage

a. $

b. $

c. $

d. $

e. 0 Information about additional jury fees is contained in Attachment 2e.

TOTAL 2 . 1$ 0.00 1

3. Juror food : $ _ _ _ _ _ _ _ and lodging: $ _ __ _ __ T OTAL 3. 1$ 0.00 1

4. Deposition costs
Name of Video-
deponent Tak ing Transcribing Travel ~ Subtotals
Martin Jacinto!
a. Ca rolyn Jacinto $ 1,250 .00 $ 1,571 .00 $ $ $ 2,821.00

b. $ $ $ $ $ 0.00

c. $ $ $ $ $ 0.00

d. $ $ $ $ $ 0.00

e. 0 Information about additiona l deposition costs is contain ed in Attachment 4e.

TOTAL 4 I$ 2,821.00 1

(Contin ued on reve rs e) Page 1 of 1

Form Approved for OptIonal Use
Jud,caal Counal of California
MEMORANDUM OF COSTS (WORKSHEET) men can LegaiNel. In ~
COde of Olli l Procedure
§§ 1032,1033.5
Me ·Ol 1 (Re v, July 1, 1999) .USCourtForms .c o

Page 14
 .
r-
SHORT TITLE : •
STUBBLEFIELD PROPERTIES . :JACINTO . et al.

5. Service of process
• CASE NUMBER:
CIVDS 120854 7

Name of person Public Registered Other

served officer process Publication (specify)

a. Martin C. Jacinto $ $ 108.18 $ $

JGI/Service of Notice of
b. Depos ition $ $ 162.28 $ $
First Legal/Service of Ex-
c. P~e $ $ 285.00 $ $

d. 0 Information about additional costs for service of process is contained in Attachment 5d .

TOTAL 5 1~$===5=55=.4~61
6. Attachment expenses (specify): ..... .. . . ..... . ..... . . . .... 1 . . . . .. . .. . .. . . . . . . . . .. . .
6. $'---_
,-,I _ _-=0-=-0:.::.0.::J01

7. Surety bond premiums (itemize bonds and amounts): ..... • . . . • ... . ..... • .. •.. . ..•. .• .• • .. • ... . 7. 1
"'$:.-_ _ _ _-'0:,:;.0::,:0""1

8. a. Ordinary witness fees

Name of witness Daily fee Mileage

(1 ) days at $/day miles at _ _ _ ¢/mile . $ _ _---"'0.:.::0"-0

(2) days at $/day miles at _ _ _ ¢/mile. $ _ _-,,-

0':.::
0,,-0

(3) days at $/day miles at _ _ _ ¢/mile ... $ _ _-,,-

0 ':.::0,,-
0

(4) days at $/day miles at _ _ _ ¢/mile. $ _ _-"0,,,.0,,-0

(5) days at S/day miles at _ _ _ ¢/mile . $ _ _~O':'::O-=-O

(6) 0 Information abou t additional ordinary witness fees is contained in Attachment 8a(6).

SUBTOTAL 8a. 1~$:.-_ __ ~o.:.: o.: Jol

Page 2 of4
Me-Ol l [AeY . JlJly 1, 1999]
MEMORANoffiJi'Bl!"eb'§'1'§'Mt'mKsHEET) !American legalN el, Inc.
,USCourtFo nT1s.com

Page 15
 .
f--
SHORT TITLE: •
STUBBLEFIELD PROPERTIES . JACINTO, el aL

MEMORANDUM OF COSTS (WORKSHEET) (Continued)

• CASE NUMBER:
CIVDS'208547

B. b. Expert fees (per Code of Civil Procedure section 998)

Name of witness

(' ) hours al $ Ihr $ 0 .00

(2) hours al $ Ihr $ 0 .00

(3) hours al $ Ihr $ 0 .00

(4) hours at $ Ihr $ 0 .00

(5) 0 Information about additional expert witness fees is contained in Attachment 8b(5).

SUBTOTAL Bb. "I$'----_ _ _.:<

0"'.0"'"0I
C. Court-ordered expert fees
Name of witness

____ hours at $ _ _ _ _ _ /hr

(1 )
$ - - - - - " ' - ' 0.00
'''-
(2) ____ hours al $ _____ /hr
$ - - - - - " ' - '0.00
'''-
(3) 0 Information about additional court-ordered expert witness fees is contained in Attachment Bc(3).

SUBTOTAL 0.00 1

TOTAL (Ba, Bb, & Be) B. Is 0001

9. Court-ordered transcripts (specify): 9. 1$ 0.001

10. Attorney fee s (ente r here if contractual or statutory fees are fixed without necessity of a court
determination; otherwise a noticed motion is required) : .......... . ...... . . .. 10. 1$ MO,ion l

11 . Models, blowups, and photocopies of exhibits (specify): 11. 1$ , .484.851

12. Court reporter fees (as established by statute)

a. (Name of reporter): San Bernardino Superior Court Fees: $ 631.00

b. (Name of reporter) : San Bernardino Superior Court Fees: $ 63' .00

c. 0 Information about add itional court reporter fees is con tained in Attachment 12c.

TOTAL 12. ~I
$===,=,:::26::2:::.0:=01

13. Other (specify): See Attachmenl 13. 1$ 9.418.6, 1

1 TOTAL COSTS
.. · 1$ 16,721 .92

(Additional information may be supplied on the reverse) Page 3 of 4

MC-ol 1 IRe .... July 1. 1999]
MEMORANDUM OF COSTS (WORKSHEET) merican LegalNe1. Inc
N.USCourtFOml$.com

Page 16
 -
SHORT TITLE:
ST UBBLEFIELD PROPERTIE
, '
..
"AC INTO, et 31.

MEMORANDUM OF COSTS (WORKSHEET) (Continued)

• CASE NUMBER:
CIVDS1208547

2 Sd . Add itional costs for service of proces s

3
Name of person Public Registered Other
4 served officer process Publication (specify)

5 d. $ $ $ $

e. $ $ $ $
6
f. $ $ $ $
7
e. $ $ $ $
B f. $ $ $ $

9 f. $ $ $ $

10 f. $ $ $ $

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

Page 1 of 1
MC..{)11 [Rev. Jl.l y 1, 19991
MEMORANDUM OF COSTS (WORKSHEET) rnencal'1 LegatNel, Inc .
.USCourtForms.com

Page 17
CU"CT TITLE: NUMBER:
CIVDS1208547
STUBBLEFIELD PROPERTIES V. JACINTO , et al.

ATTACHMENT (Number): .:.

1"'3 _ _ _ _ __

(This Attachment may be used with any Judicial Council form.)

Clear Language/Spanish interpreter $ 613.00
Martin Investigative Services/Private investigator $ 3,115.95
Computerized legal research $ 3,497 .00
Court Call fees $ 320 .00
Attorney Service Fees/filings and delivery for filing $ 1,277 .93
Fed Ex $ 85.4 1
Travel Expenses $ 509.32

Total: $9,418.61

(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 1 of 1
Atrachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Opbana! Use
Judicial Council of Cal ifornia
ATTACHMENT www.courtirlfo.ca.gov
American Lega lNe!, Inc,
MC-<l 25 (Rev. July 1, 20091 to Judicial Council Form www.FormsWorldlow.com
Page 18
 • PROOF OF SERVICE •
Stubblefield Properties v. Ja cinto, et 01.
Court Case No. ClVDSl208547
2
3 STATE OF CALIFORNIA, COUNTY OF ORANGE
I am employed in the County of Orange, State of California. I am over the age of I 8 years and am not a party
4 to the within action. My business address is 200 Sandpointe, Fourth Floor, Santa Ana, California 92707-
0507. On May /!l,
2014, I caused the foregoing document(s) described as MEMORANDUM OF COSTS
5 to be served on the interested parties in thi s action as follows:
6 [g] ~ placing 0 the original 0 a true copy thereof enclosed in sealed envelopes addressed as stated below
or ~ by sending a copy as stated and addressed below:
7 SEE ATTACHED SERVICE LIST
8 [g] BY MAIL: I am "readily familiar" with the firm ' s practice of collection and processing
correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that
9 same day with postage thereon fully prepaid Santa Ana, California in the ordinary course of business. I am
aware that on motion of the party served, service is presumed invalid if the postal cancellation date or postage
10 meter date is more than one day after date of deposit for mailing in the affidavit.
o BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by
11 an overnight delivery carrier and addressed to the persons identified herein. I placed the envelope or package
for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery
12 carrIer.
13 0 BY ELECTRONIC SERVICE. Based on a court order or an agreement of the parties to accept
service by electronic transmission, I caused the documents to be sent to the persons at the electronic
14 notification addresses listed herein. I did not receive, within a reasonable time after the transmission, any
electronic message or other indication that the transmission was unsuccessful.
15 0 BY FACSIMILE: Based on an agreement of the parties to accept service by fax transmission, I
faxed the documents from a fax machine, at Santa Ana, Cal ifornia, with the telephone number, (714) 546-
16 7457 to the parties and/or attorney for the parties at the facsimile transmission number(s) shown herein. The
facsimi le transmission was reported as complete without error by a transmission report, issued by the
17 facsimi le transmission machine upon which the transmission was made, a copy of which is attached hereto.
18 0 BY PERSONAL SERVICE: I personally delivered the documents to the persons at the addresses
listed herein. ( 1) For a party represented by an attorney, delivery was made to the attorney or at the attorney 's
19 office by leaving the documents, in an envelope or package clearly labeled to identify the attorney being
served, with a receptionist or an individual in charge of the office, between the hours of nine in the morning
20 and five in the evening. (2) For a party, delivery was made to the party or by leaving the documents at the
party 's residence with some person not younger than 18 years of age between the hours of eight in the
21 morning and six in the evening.
o BY MESSENGER SERVICE: I served the documents by placing them in an envelope or package
22 addressed to the persons at the addresses listed herein and providing them to a professional messenger service
for service. A declaration by the messenger will be filed separately.
23 rv1
IC>I [State) I declare under penalty ofpeIjury under the laws of the State of California that the foregoing
24 is true and correct.
Executed on May L!1, 2014, at Santa Ana, California. ~
25 _~ ~
26 /Sandy Moore

27
28
]6568.050/4829-3! 32'()B50v.l
PROOF OF SERVICE

Page 19
 • SERVICE LIST •
Stubblefield Properties v. Jacinto. et at.
Court Case No. crvos 1208547
2
3
4 Moises A. Aviles, Esq . Attorney for Defendant. Martin C. Jacinto
5 Aviles & Associates
560 N. Arrowhead Avenue, Suite 2A
6 San Bernardino, CA 92401
Tel: 909.383.2333
7 Fax: 909.383.9550
Email: maviles 1232@aol.com
8
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18
19
20
21
22
23
24
25
26
27
28
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36568 .050/4829·3 132-0850v. 1
PROOF OF SERVICE

Page 20
EXHIBIT C
Page 21
CIVDS1208547 Minute Orde %in Bernardino Main Page 1 of 1
\-

Pending Case
Home ComplaintslParties Actions Minutes Hearings Images
Report
Case Type: 1
Case Number: D

-
Case CIVDSl208547 STUBBLEFIELD -V-JACINTO
Action: [(choose) v

EX PARTE HEARING RE: FOR ORDER AMENDING JUDGMENT TO ADD COSTS

-
10/01/2014 8:30 AM DEPT. S35X

BRYAN F FOSTER, JUDGE

CLERK: LORI MOWLES
COURT REPORTER KATHY SELLERS 4420
COURT ATTENDANT R DELGADO
-
APPEARANCES: c'
ATTORNEY ROBERT WILLIAMSON PRESENT FOR PLAlNTIFF/PETITIONER.
ATTORNEY RICHARD NAHlGlAN PRESENT FOR DEFENDANTIRESPONDENT.
-
PROCEEDINGS:
PREDISPOSITION HEARING HELD
EX-PAR'TE HEARING IS HELD.
EX PAR'TE ORDERS GRANTED
EX PARTE ORDER SIGNED BY THE COURT.
AMENDED JUDGMENT IN FAVOR OF PLAINTIFF AND
AGAINST DEFENDANT AFTER TRIAL.
ACTION - COMPLETE
=== MINUTE ORDER END ===

Page 22
 t Legal Support (95 1)779-0 100 00/00/ 0
F'Ax@l~

O C T . : I 2014

RRIl
c a -
5

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN BERNARDINO - CIVIL DIVISION

STUBBLEFIELD PROPERTIES, a Case No. CIVDS 1208547

California general partnership, dba
MOUNTAIN SHADOWS MOBILE
HOME COMMUNITY, [PfWPHWUl] AMENDED JUDGMENT
IN FAVOR OF PLAINTIFF
Plaintiff, STUBBLEFIELD PROPERTIES, A
CALIFORNIA GENERAL
PARTNERSHIP DBA MOUNTAIN
SHADOWS MOBILE HOME
COMMUNITY, AND AGAINST
MARTIN C. JACINTO, DEFENDANT MARTIN C. JACINTO
I AFTER JURY TRIAL.
Defendant.

20 A Stubblefield
The court having directed a verdict in favor Plaintiff Cross Defendant
and
21
I Properties, a California general partnership dba Mountain Shadows Mobile

1I
22 Home Colnrnunity and Cross Defendant Thomas Parrish, sued as Mr. Parrish, against

I
-73 Defendant and Cross Complainant Martin C. Jacinto on the issue of liability and having
24
I dismissed the Cross Coinplaint on March 17,2014;

25I On March 1 8, 20 14, the jury on a special verdict found that Defendant Martin C.

- I
76 Jacinto's wrongful conduct caused harm to Plaintiff Stubblefield Properties entitling Plaintiff

- I
77 to damages for past and future rental value lost and cost of removal of the lnobileho~nefrom
1
25 space 120 and restoration of mobilehome site, and the Court Clerk having recorded and filed
1
Page 23
(PROPOSED] A M E N D E D JVDGhiENT
 t Legal Support (951)779-0100 0010012
0

I- 1
1 the special verdict, IT IS HEREBY ORDERED, ADJUDGED AND DECREED,
Judgment in favor of Plaintiff Stubblefield Properties, a California general pa~tnership
dba Mountain Shadows Mobile Home Co~n~nunity
and against Defendant Martin C. Jacinto
in the sum of $4 1, I 66.58;
5 That Defendant Martin C. Jaci~ltohas no interest in or possessory right or rights to
6 space 120 in Mountain Shadows Mobilehome Community, 4040 E. Piedmont Drive,

7 Highland, CA; and

8 That Defendant Martin C. Jacinto shall be and hereby is ordered to remove his

I1/
g mobileho~ne from Mountain Shadows Mobilehome Community in accordance with
10 Plaintiffs requirements set forth in Mountain Shadows Mobilehome Community's move out

12
/I
1 1 letter dated April 17: 2013. Defendant's removal of his mobilehome shall be partial
satisfaction of this judgment to the extent of his verified costs incurred for said removal.
13 Plaintiff to recover its costs in the sun1 of $ 16,72 1.92 for a total judgment in the sum
14 of $57,888.50.

l5
16
H1 The Court Clerk shall forthwith enter this Amended Judgment.
IT IS SO ORDERED.

Court '

Page 24