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JOYCE SHANKS, Sr. P.O. BOX 2794 LONG BEACH, CA. 90801-2794 (562) 673-0623 PLAINITFF IN PRO PER

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES JOYCE SHANKS, Sr ) ) PLAINTIFF, ) ) vs. ) ) HOUSING AUTHORTIES of LOS ) ANGELES; CARMELITOS HOUSING ) COMMUNITY; SEAN ROGAN (Exec. Dir.); ) LYNN ANDERSON (Property Manager)1; ) and DOES 1-20, INCLUSIVE, ) ) DEFENDANTS. ) ) PLAINTIFFS UNLIMITED COMPLAINT FOR (1) NEGLIGENCE; (2) NEGLIGENCE ; (3) FRAUD; (4) INTENTIONAL TORT; (5) WRONGFUL EVICTION (6) BREACH OF LEASE AGREEMENT; (7) BREACH OF THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING (8) RETAILATION (9) DEFAMTION/LIBLE DEMAND JURY TRIAL

TO THIS HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN; Plaintiffs hereby allege as follows:

PARTIES 1. Defendant HOUSING AUTHORTIES of LOS ANGELES is, and at all times herein
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mentioned was, a governmental public entity business organized and existed under the laws of the State of California, doing business in Los Angeles County, California. 2. Defendant CARMELITOS HOUSING COMMUNITY a business entity of unknown

form, doing business in Los Angeles County, California. 3. Defendant SEAN ROGAN (Exec. Dir.) is a natural person and a resident of Los Angeles

County, California. 4. Defendant LYNN ANDERSON (Property Manager) is a natural person and a resident

of Los Angeles County, California. 5. Plaintiff do not know the true names and capacities of the defendants sued herein as

DOES 1 through 20 (DOE Defendants), inclusive, and therefore sues said DOE Defendants by fictitious names. Plaintiffs are informed and believe and based on such information and belief aver that each of the DOE Defendants is contractually, strictly, negligently, intentionally, vicariously liable and or otherwise legally responsible in some manner for the acts and omissions described herein. Plaintiffs will amend this Complaint to set forth the true names and capacities of each DOE Defendant when same are ascertained. 6. Plaintiff is informed and believes and based on such information and belief avers that

Defendants HOUSING AUTHORTIES of LOS ANGELES, CARMELITOS HOUSING COMMUNITY, SEAN ROGAN (Exec. Dir.), LYNN ANDERSON (Property Manager) and DOE Defendants 1 through 10, inclusive, and each of them, are and at all material times have been, the agents, servants or employees of each other, purporting to act within the scope of said agency, service or employment in performing the acts and omitting to act as averred herein. HOUSING AUTHORTIES of LOS ANGELES, CARMELITOS HOUSING COMMUNITY, SEAN ROGAN (Exec. Dir.), LYNN ANDERSON (Property Manager are hereinafter collectively referred to as the Defendants.
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7.

Each of the Defendants named herein are believed to, and are alleged to have been acting

in concert with, as employee, agent, co-conspirator or member of a joint venture of, each of the other Defendants, and are therefore alleged to be jointly and severally liable for the claims set forth herein, except as otherwise alleged. GENERAL ALLEGATIONS 8.
Plaintiff is an individual and is now, and at all times mentioned in this complaint was, a resident Plaintiff is legally disable and has resided

of the City of Long Beach, Los Angeles County, California.

at 761 E. Via Carmelitos, APT# 330, Long Beach Ca. 90805, since 2010. Plaintiff has during all this time enjoyed a good reputation, both generally and in her occupation.

9.

In the year of 2011, plaintiff attempt to apply to add addition of family members to her

lease, which is permitted by the defendants. Defendants have misrepresented that this process take 24 months, with no intension of every allowing plaintiff to add any family member to her lease. 10. Plaintiff also applied for a Special Unit because of her disability. Plaintiff was

required to submit Verification of Need for Reasonable Accommodation, an application generated by the defendants to ascertain if the applicant is disabling as define under the law. Plaintiff is and all time mentioned in this complaint was disabled as defined by law, in a wheelchair and living on a 3rd floor. Plaintiff needed to be place on a lower level in order to accommodate her disability. Although, plaintiff submitted several applications to the defendants, but was denied a unit that would accommodate her as others that are similarly situated. The defendants illegally denied plaintiff placement into a special unit to have been waived by plaintiff. 11. The defendants had plaintiff sign a waiver the first year she signed her lease agreement

to take the 3rd floor unit because a special unit that would accommodate plaintiff would not be available and that if plaintiff did not sign the wavier the unit would go to the next person on the
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list. Plaintiff was assurance that when a special unit became available she would be placed in that special unit. One of the reason the defendants gave for its denial of the special unit, was plaintiff singing of the wavier in 2010, however, plaintiff have signed consecutive lease agreements annually since the singing of the 2010 where no wavier was signed by plaintiff. 12. Plaintiff after constantly being denied her requests for adding additional family

members or her requests for a special unit to accommodate her disability began to make verbal complaints to the defendants for what she believed to be unfair treatment by the defendants. The defendants began to retaliate against plaintiff. This retaliation came in the form of making false statement that plaintiff had allowed her son to reside in the premises without the proper authority and the deformation statements that plaintiff has in some form engaged in illegal drug activities while a resident of the defendants, or relying on those false and defamation statements when they knew were false. The defendants then published or had published the false and defamation statements, to commence bring about an illegal eviction process against the plaintiff. 13. The defendants sole purpose for making or publishing the false and defamation

statements was to cause or bring about an adverse action against the plaintiff to deter her from continuing to engage in the pursuit of either obtaining additional family members to her lease or a special unit that would accommodating her disability. 14. The defendants did the above acts or conduct as an use, or threaten to use, force,

willful threats, or menacing conduct constituting a course of conduct that interferes with the plaintiffs quiet enjoyment of the premises in violation of Section 1927 that would create an apprehension of harm in a reasonable person. 15. The defendants after plaintiff continue to complain and inquire in to either obtaining

additional family members to her lease or a special unit that would accommodate her disability, issued plaintiff with a 30 Day Notice to Quit on the false and defamation statements they themselves had generated and subsequently file an Unlawful Detainer complaint employing the
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same false and defamation statements stated and published in the 30 Day Notice to Quit. This was done because plaintiff exercised her right to either obtaining additional family members to her lease or a special unit that would accommodate her disability. The two events occur at the same time and in the same place; one event immediately precedes the other; the second event appears unlikely to have happened without the first event having occurred.

FIRST CAUSE OF ACTION FOR NEGLIGENCE (AGAINST EACH OF THE F DEFENDANTS) 16. Plaintiffs incorporate herein by reference the allegations made in paragraphs 1 through

15, inclusive, as though fully set forth herein. 17. At all times relevant herein, the Defendants, acting as Plaintiffs landlord, had a duty to

exercise reasonable care in presenting and relying on truthful evidence before commencing eviction process against the plaintiff and to discharge and fulfill the other terms of the lease agreement before the eviction of the plaintiff. 18. In taking the actions alleged above, and in failing to take the actions as alleged above, the

Defendants breached their duty of care to Plaintiffs in the knowing relying on false and defamation statements which brought into being defendants serving the Plaintiff a 30 Day notice to Quit and the filing of the unlawful detainer complaint, among other things, failing to properly and accurately investigate information made by plaintiffs with respect to her son use of her P.O. Box address, and filing false documents, and evicting or having plaintiff evicted form the property on information and statement they knew was false or unfounded. 19. As a direct and proximate result of the negligence and carelessness of the Defendants as

set forth above, Plaintiffs suffered general and special damages in an amount to be determined at trial. SECOND CAUSE OF ACTION FOR
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NEGLIGENCE (AGAINST DEFENDANT CARMELITOS HOUSING COMMUNITY) Plaintiffs incorporate herein by reference the allegations made in paragraphs 1 through

19, inclusive, as though fully set forth herein. 21. In or around December 19, 2012, Defendants Carmelitos Housing Community served

plaintiff a 30 Day Notice to Quit, alleging that plaintiff breached several provision of the lease agreement. 22. Defendants have acted on manufactured unfounded facts or false statements they

generated that caused plaintiff to be wrongfully evicted. Therefore, Defendant is liable under a theory of negligence per se as they acted with 'criminal negligence' with respect to a result or to a circumstance described by a statute defining an offense when they fails to perceive a substantial and unjustifiable risk that such result would occur or that such circumstance exists. 23. Additionally, Defendant Carmelitos Housing Community failed to use reasonable skill

and care in the investigation of the allegations made against plaintiff in that they failed to take any action other than making a misrepresentation of facts and/or falsely reporting false and misleading statements in the 30 Day Notice to Quit and in the failing of an unlawful detainer complaint in the superior court. 24. Plaintiffs are informed and believe, and on the basis of that information and belief allege,

that had Defendant Carmelitos Housing Community used proper skill and care in the handling of Plaintiffs matter, Plaintiffs would not have been wrongfully evicted from her unit and/or causing her harm to her reputation. 25. As a direct and proximate result of the negligence and carelessness of Defendant

Carmelitos Housing Community as set forth above, Plaintiffs reputation was put in such a bad light that she was subsequently evicted from the defendants housing unit, resulting in general and special damages to Plaintiffs in an amount to be determined at trial.
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THIRD CAUSE OF ACTION FOR FRAUD (AGAINST EACH OF THE DEFENDANTS) Plaintiffs incorporate herein by reference the allegations made in paragraphs 1 through

25, inclusive, as though fully set forth herein. 27. The Defendant Carmelitos Housing Community engaged in a pattern and practice of

defrauding Plaintiff in that, during the life of the lease agreements after the initial 2010 lease agreement which included plaintiffs wavier to a special unit because no special unit ware available at that time, misrepresented to plaintiff, that she when a special unit become available, plaintiff would be place in that unit. Defendant Carmelitos Housing Community after the wavier had expired failed to place plaintiff in a special unit based on Plaintiffs signing of the 2010 wavier which they knew to have expired. 28. The Defendant Carmelitos Housing Community had actual knowledge that the Plaintiffs

wavier to a special unit was not legally binding after the year 2010, but that the Defendant could use the 2010 wavier to deny plaintiff a special unit. Plaintiffs in the year of 2011 made her initial request for a special unit and were told by Defendant Carmelitos Housing Community that the 2010 wavier was still in effect. This was a misrepresentation based on the improper, inaccurate, and fraudulent representations as to the 2010 wavier. The Defendants also utilized statement generated by them and known to the Defendant to be false and inaccurate such as their allegation that plaintiff had allowed for her son to live in the premises, to deny plaintiff a special unit and to wrongfully evict plaintiff. 29. Additionally, the Defendants concealed material facts known to them but not to Plaintiffs

regarding personal P.O. Box usage as it apply to the defendants practice and policies with the intent to defraud Plaintiff.

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30.

The Defendants made the above-referenced false representations, concealments and non-

disclosures with knowledge of the misrepresentations, intending to induce Plaintiffs' reliance, which the unsuspecting Plaintiffs justifiably relied upon, resulting in damage to plaintiff, loss of property. Plaintiffs were unaware of the true facts. Had Plaintiffs known the true facts, Plaintiffs, among other things, would not have maintained the Defendants as her landlord, and/or would have taken legal action immediately to prevent herm to reputation and or the wrongful eviction. 31. As a result of the Defendants fraudulent conduct, Plaintiffs have suffered compensatory,

general and special damages in an amount to proof. Additionally, the Defendants acted with malice, fraud and/or oppression and, thus, Plaintiffs are entitled to an award of punitive damages. FOUTH CAUSE OF ACTION INTENTIONAL TORT (AGAINST EACH OF THE DEFENDANTS) 32. Plaintiffs incorporate herein by reference the allegations made in paragraphs 1 through

31, inclusive, as though fully set forth herein. 33. On or about December 19, 2012, defendants published or published and issued plaintiff a

30 Day Notice to Quit, stating that plaintiff had illegally allowed Charles Edward Moore to live in the premises without written approval from management and in some form had engaged in illegally drug activity. 34. On or about March 9, 2013, defendants published and/or issued plaintiff a Notice of

Decision, stating that plaintiff had illegally allowed Charles Edward Moore to live in the premises without written approval from management and in some form had engaged in illegally drug activity.

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35.

On or about March 9, 2013, defendants published or issued plaintiff an Unlawful

Detainer Complaint, stating that plaintiff had illegally allowed Charles Edward Moore to live in the premises without written approval from management and in some form had engaged in illegally drug activity. 36. The 30 Day Notice to Quit, Notice of Decision, and Unlawful Detainer Complaint,

referred to plaintiff by name throughout, was made of and concerning plaintiff, and was so understood by those who read the 30 Day Notice to Quit, a Notice of Decision, and Unlawful Detainer Complaint that is related to her. 37. The entire statement (1) The Housing Authority is informed that at certain times during

the period of the Lease Agreement CHARLES EDWARD MOORE has been residing in the Premises and (2) On or about November 4, 20L2, CHARLES EDWARD MOORE engaged in drug-related criminal activity, i.e., the misdemeanor possession of marijuana while a guest, member or other person related to the Premises is false as it pertains to plaintiff. 38. The 30 Day Notice to Quit is libelous on its face. It clearly exposes plaintiff to hatred,

contempt, ridicule and obloquy because plaintiff has not allow CHARLES EDWARD MOORE to reside in premises nor was there any other form of additional income received by plaintiff. 39. The statements in the 30 Day Notice to Quit, Notice of Decision, and Unlawful Detainer

Complaint was seen and read on or about May 10, 2013 at the Long Beach Superior Court by judge/Commissioner __________________________. 40. As a proximate result of the above-described publication, plaintiff has suffered loss of

lease of the premises her reputation, shame, mortification, and injury to her feelings, all to her damage in a total amount to be established by proof at trial.

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41.

The above-described publication was not privileged because it was published by

defendants with malice, hatred and ill will toward plaintiff and the desire to injure her, in that defendants had expressed a desire to "retaliate against plaintiff. Because of defendants' malice in publishing, plaintiff seeks punitive damages in a total amount to be established by proof at trial. FIFTH CAUSE OF ACTION WRONGFUL EVICTION (AGAINST EACH OF THE DEFENDANTS) 42. Plaintiffs incorporate herein by reference the allegations made in paragraphs 1 through

41, inclusive, as though fully set forth herein. 43. Plaintiff is informed and believe and thereon allege that defendants have held plaintiff to

illegal or overbroad terms and or a provision of the lease agreement in that they have accrue jurisdiction of U.S. postal services as to what mail can be received at these intuitions which none of the Defendants in this action could legally do. Moreover, none of the Defendants in this action were lawfully in a position to govern plaintiff incoming mail at her P.O. Box address. Accordingly, none of the Defendants in this action had the right to hold that the use of the P.O. Box address was in violation of the lease agreement. The plaintiff was not in violation of the lease agreement at any time with regard to Plaintiffs leasing of the housing unit. 44. Plaintiff further allege on information and belief that the terms or provisions was added

to the lease agreement by the defendants without notifying the Plaintiffs in writing. Therefore, the added terms or provision is void of legal rights to enforce it. 45. Additionally, the Defendants violated California Civil Code 1940.2(a)(3) , which

prohibits a landlord to do any of the following for the purpose of influencing a tenant to vacate a dwelling: Use, or threaten to use, force, willful threats, or menacing conduct constituting a

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course of conduct that interferes with the tenant's quiet enjoyment of the premises in violation of Section 1927 that would create an apprehension of harm in a reasonable person. 46. None of the Defendants contacted Plaintiff to discuss their amendment to the lease

agreement. Moreover, none of the Defendants explored options with Plaintiff to avoid eviction. Additionally, none of the Defendants informed Plaintiff of the right to have a meeting as to the amended terms and or provisions of said lease agreement. Accordingly, the Defendants did not fulfill their legal obligation to Plaintiffs. 47. Thus, the Defendants engaged in a fraudulent conduct to begin eviction process against

plaintiff in that the Defendants did not have the legal authority to evict plaintiff for her letting her son using of the P.O. Box address. 48. As a result of the above alleged wrongs, Plaintiffs have suffered general and special

damages in an amount to be determined at trial. SIXTH CAUSE OF ACTION FOR BREACH OF LEASE AGREEMENT (AGAINST EACH OF THE DEFENDANTS) 49. Plaintiffs incorporate herein by reference the allegations made in paragraphs 1 through

48, inclusive, as though fully set forth herein. 50. Plaintiffs original singed lease agreement had a wavier as to the special unit, which was

valid for one year. The defendants have not obtained any other wavier when plaintiff renewed her lease agreement thereafter annually. 51. Plaintiff is informed and believe and thereon allege that defendants have held plaintiff to

illegal or overbroad terms and or a provision of the lease agreement in that they have accrue jurisdiction of U.S. postal services as to what mail can be received at these intuitions which none of the Defendants in this action could legally do. Moreover, none of the Defendants in this action were lawfully in a position to govern plaintiff incoming mail at her P.O. Box address.
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Accordingly, none of the Defendants in this action had the right to hold that the use of the P.O. Box address was in violation of the lease agreement. The plaintiff was not in violation of the lease agreement at any time with regard to Plaintiffs leasing of the housing unit. 52. Plaintiff further allege on information and belief that the terms or provisions was added

to the lease agreement by the defendants without notifying the Plaintiffs in writing. Therefore, the added terms or provision is void of legal rights to enforce it. 53. Additionally, the Defendants violated California Civil Code 1940.2(a)(3) , which

prohibits a landlord to do any of the following for the purpose of influencing a tenant to vacate a dwelling: Use, or threaten to use, force, willful threats, or menacing conduct constituting a course of conduct that interferes with the tenant's quiet enjoyment of the premises in violation of Section 1927 that would create an apprehension of harm in a reasonable person. 54. None of the Defendants contacted Plaintiff to discuss their amendment to the lease

agreement. Moreover, none of the Defendants explored options with Plaintiff to avoid eviction. Additionally, none of the Defendants informed Plaintiff of the right to have a meeting as to the amended terms and or provisions of said lease agreement. Accordingly, the Defendants did not fulfill their legal obligation to Plaintiffs. 55. The Defendants breached the lease agreement by applying terms and or provisions to it,

the result of which led to the Defendants eventually evicting plaintiff from the housing unit on. 56. As a proximate result of Defendants' breaches, Plaintiffs have suffered compensatory

damages in an amount to be proven at trial.

SEVEN CAUSE OF ACTION FOR BREACH OF THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING (AGAINST THE DEFENDANTS)

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57.

Plaintiffs incorporate herein by reference the allegations made in paragraphs 1 through

56, inclusive, as though fully set forth herein. 58. Every lease agreement imposes upon each party a duty of good faith and fair dealing in

its performance and its enforcement. This implied covenant of good faith and fair dealing requires that no party will do anything that will have the effect of impairing, destroying, or injuring the rights of the other party to receive the benefits of their agreement. The covenant implies that in all contracts each party will do all things reasonably contemplated by the terms of the contract to accomplish its purpose. This covenant protects the benefits of the contract that the parties reasonably contemplated when they entered into the agreement. 59. Alternatively, if the following lease agreement after the 2010 lease agreement and wavier

of the special unit was validly and properly assign to Defendants, the Defendants did not act in good faith and did not deal fairly with Plaintiff in connection with the 2011 and 2012 lease agreements, that is, the defendants never obtain waivers of the special unit demanded by the plaintiff, even though there ware proof of the non-existing of any waivers as to the 2011 and 2012 lease agreement. 60. The Defendants enjoyed substantial discretionary power affecting the rights of Plaintiff

during the events alleged in this Complaint. They were required to exercise such power in good faith. 61. The Defendants engaged in such conduct to deny Plaintiff of the right to a special unit

housing community and to subsequently have plaintiff evicted from the property altogether. These actions were a bad faith breach of the lease agreement between Plaintiffs and the Defendants which show that they had no intention of performing the contract, consisting of the 2011 and 2012 lease agreements and wavier of the special unit, in good faith.

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62.

Defendants willfully breached their implied covenant of good faith and fair dealing with

Plaintiff when defendants continued to hold the 2010 wavier to a special unit valid in order to deny plaintiff a special unit and then commence eviction process because plaintiff began to complain about defendants action being unfair. 63. As a result of the Defendants breaches of this covenant, Plaintiffs have suffered general

and special damages in an amount to be determined at trial. EIGHTH CAUSE OF ACTION FOR RETAILATION (AGAINST THE DEFENDANTS) 64. Plaintiffs incorporate herein by reference the allegations made in paragraphs 1 through

63, inclusive, as though fully set forth herein 65. That plaintiff Joyce Shanks was eligible for special unit that would accommodate her

disabilities and eligible to add additional family members to her lease agreement. 66. That plaintiff in 2011 after her initial 2010 wavier to a special unit had expired, began to

submit her request to be removed from the 3 rd floor unit and to place in a ground unit that would allow plaintiff to utilize her motorized wheelchair and any other apparatus that would be afforded to her under ADA. 67. That defendants created and or misrepresented facts they knew was false to have plaintiff

evicted from the housing unit, or caused plaintiff to be evicted on terms and provisions of the lease agreement that did not exist under the lease agreement between defendants and the plaintiff. 68. That plaintiffs request to be removed from the 3 rd floor unit and to be place in a ground

unit that would allow plaintiff to utilize her motorized wheelchair and any other apparatus that would be afforded to her under ADA was a motivating reason for defendants evicting or having plaintiff evicted for the housing unit.
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69.

That plaintiff was harmed by being denied the special unit that she was entitled to

likewise , plaintiff further suffer harm in that she ware subsequently evicted from the housing unit. 70. That defendants retaliatory conduct was a substantial factor in causing plaintiff harm. NINTH CAUSE OF ACTION FOR DEFAMTION/LIBLE 71. (AGAINST THE DEFENDANTS) Plaintiffs incorporate herein by reference the allegations made in paragraphs 1 through

70, inclusive, as though fully set forth herein 72. Plaintiff is an individual and is now, and at all times mentioned in this complaint was, a Plaintiff is legally disable

resident of the City of Long Beach, Los Angeles County, California.

and has resided at 761 E. Via Carmelitos, APT# 330, Long Beach Ca. 90805, since 2010. Plaintiff has during all this time enjoyed a good reputation, both generally and in her occupation. 73. Defendant Sean Rogan (Exec. Dir.); Lynn Anderson (Property Manager), is an individual

and is now, and at all time mentioned in this complaint was, a resident of Los Angeles County, California. 74. Defendant Lynn Anderson (Property Manager), is an individual and is now, and at all

time mentioned in this complaint was, a resident of Los Angeles County, California. 75. Defendant Housing Authorities of Los Angeles and Carmelitos Housing Community , is

now, and at all times mentioned in this complaint was, a corporation organized and existing under the laws of the State of California, with its principal place of business in California in Los Angeles County California. 76. Plaintiff is informed and believes, and based on that information and belief alleges, that

at all times mentioned in this complaint, defendants were the agents and employees of their
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codefendants and in doing the things alleged in this complaint were acting within the course and scope of such agency and employment. 77. On or about December 19, 2012, defendants published or issued plaintiff a 30 Day

Notice to Quit, stating that plaintiff had illegally allowed Charles Edward Moore to live in the premises without written approval from management and in some form had engaged in illegally possession of marijuana. 78. On or about March 9, 2013, defendants published or issued plaintiff a Notice of

Decision, stating that plaintiff had illegally allowed Charles Edward Moore to live in the premises without written approval from management and in some form had engaged in illegally possession of marijuana. 79. On or about March 9, 2013, defendants published or issued plaintiff an Unlawful

Detainer Complaint, stating that plaintiff had illegally allowed Charles Edward Moore to live in the premises without written approval from management and in some form had engaged in illegally possession of marijuana. 80. The 30 Day Notice to Quit, Notice of Decision, and Unlawful Detainer Complaint,

referred to plaintiff by name throughout, was made of and concerning plaintiff, and was so understood by those who read the 30 Day Notice to Quit, a Notice of Decision, and Unlawful Detainer Complaint 81. The entire statement (1) The Housing Authority is informed that at certain times during

the period of the Lease Agreement CHARLES EDWARD MOORE has been residing in the Premises and (2) On or about November 4, 20L2, CHARLES EDWARD MOORE engaged in drug-related criminal activity, i.e., the misdemeanor possession of marijuana while a guest, member or other person related to the Premises is false as it pertains to plaintiff.
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82.

The 30 Day Notice to Quit is libelous on its face. It clearly exposes plaintiff to hatred,

contempt, ridicule and obloquy because plaintiff has not allow CHARLES EDWARD MOORE to reside in premises nor was there any other form of additional income received by plaintiff. 83. The statements in the 30 Day Notice to Quit, Notice of Decision, and Unlawful Detainer

Complaint was seen and read on or about May 10, 2013 in the Long Beach Superior Court by Judge/Commissioner ____________________________. 84. As a proximate result of the above-described publication, plaintiff has suffered loss of

lease of the premises her reputation, shame, mortification, and injury to her feelings, all to her damage in a total amount to be established by proof at trial. 85. The above-described publication was not privileged because it was published by

defendants with malice, hatred and ill will toward plaintiff and the desire to injure her, in that defendants had expressed a desire to "retaliate against plaintiff. Because of defendants' malice in publishing, plaintiff seeks punitive damages in a total amount to be established by proof at trial.

PRAYER FOR RELIEF Wherefore, Plaintiffs pray for judgment against the Defendants and each of them, jointly and severally, as follows: 1. For a declaration of the rights and duties of the parties, specifically that the

Plaintiffs eviction was wrongful. 2. For compensatory, special, general and punitive damages according to proof

against all Defendants. 3. Pursuant to Cal. Civil Code 1940.2, that all Defendants, their successors,

agents, representatives, employees, and all persons who act in concert with them be permanently

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enjoined from committing any acts in violation of 1940.2, including, but not limited to, the violations alleged herein. 4. For civil penalties pursuant to statute, restitution, injunctive relief and reasonable

attorneys fees according to proof. 5. proper. For reasonable costs of suit and such other and further relief as the Court deems

DATED: _____

By:

____________________________ JOYCE SHANKS, Sr. Plaintiff In Pro Per

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