Inappl Appendix Volue II of Ii - Toapl' Brief-Pikedogbite t157p 10may19fn Fa190510

Filed: 5/10/2019 11:20 AM
IN THE
INDIANA COURT OF APPEALS
CAUSE NO. 19A-SC-00970
KAY KIM )
CHARLES CHUANG, )
)
Appellants/ Plaintiffs ) Appeal from the Marion County
) Pike Township Small Claims Court
)
v. )
) Cause No. 49K05-1811-SC-004090
)
VILLAGE AT EAGLE HOME OWNERS )
ASSOCIATION [VECHOA] )
MUHAMMED JAVED, OWNER OF 4260 UNIT 6)
ANDLEEB JAVED, OWNER OF 4260 UNIT 6 )
)
Appellees/ Defendants. ) The Honorable A. Douglas Stephens, Judge
APPENDIX TO APPELLANTS’ BRIEF
VOLUME II OF II
Pages 1 through 157
/s/ Charles Chuang

Charles Chuang, Pro Se Plaintiff
4250 Village Pkwy Cir E. Unit 2
Indianapolis, IN 46254
Phone# (317) 641-5977
chang2597@gmail.com
/s/ Kay Kim

Kay Kim, Pro Se Plaintiff
Phone# (317) 641-5977
retypeunitedstates@gmail.com
APPENDIX to Appellants Charles Chuang and Kay Kim's Brief: Vol. II of II.
NOTICE OF APPEAL
STATE OF INDIANA )
IN THE PIKE TOWNSHIP OF
)
MARION COUNTY
COUNTY OF MARION ) ss:
SMALL CLAIMS COURT
)
CAUSE NO. 49K05-1811-SC-004090
KAY KIM )
CHARLES CHUANG )
Plaintiffs. )
)
vs )
)
MUHAMMED JAVED, OWNER OF 4260 UNIT 6 )
Defendants. )
NOTICE OF APPEAL
[FROM MARION COUNTY PIKE TOWNSHIP SMALL CLAIMS COURT]
Plaintiffs Charles Chuang and Kay Kim Pro se, pursuant to Ind. Appellate Rule 9(A),
respectfully gives notice of an appeal from the following judgment(s) entered by the Marion
County Pike Township Small Claims Court: Judge A. Stephens Douglas.
This appeal is from a final judgment order on April 26, 2019 as defined by Appellate
Rule 2(H) and 9(I). [Attachment 1: FINAL JUDGMENT ORDER.]
This appeal will be taken to the Indiana Court of Appeals pursuant to Ind. App Rules 4, 5.
Pursuant to Appellate Rule 10, 11, or 14.1(C), the clerk of Marion County Pike Township
Small Claims Court or Administrative Agency is requested to assemble the Clerk’s Record, as
defined in Appellate Rule 2(E).
2
Pursuant to Appellate Rule 11 or 14.1(C), the Court Reporter of the [Pike Township
Small Claims Court or Administrative Agency] is requested to transcribe [Attachment 2:
Plaintiffs’ STATEMENT OF EVIDENCE.], certify, and file with the clerk of the [Pike
Township Small Claims Court or Administrative Agency] the following hearings of record,
including exhibits: [Pike Township Small Claims Court Judge A. Douglas Stephens refused to
take Exhibits from the Plaintiffs. Judge told us (Appellants/Plaintiffs) that because, this case is
not on trial; so, he will not accept the Exhibit; thus, there is no Exhibits on file. However,
Plaintiffs E-Filed 114 pages of Appendices].
Respectfully submitted,
/s/ Charles Chuang /s/ Kay Kim

Charles Chuang, Plaintiff Pro Se Kay Kim, Plaintiff Pro Se
4250 Village Pkwy Cir E. Unit 2 4250 Village Pkwy Cir E. Unit 2
Indianapolis, IN 46254 Indianapolis, IN 46254
Phone# (317) 641-5977 Phone# (317) 641-5977
chang2597@gmail.com retypeunitedstates@gmail.com
3
VERIFICATION
I sworn, state, under penalties of perjury, that I, Charles Chuang and Kay Kim Plaintiff
Pro Se, in the above-entitled case; being duly sworn, stated the representations contained herein
is true and correct to the best of my knowledge and belief.

4
CERTIFICATE OF SERVICE
I hereby certify that on April 29, 2019, I electronically filed the foregoing document
using the Indiana E-Filing system (IEFS).
I certify that on April 29, 2019, the foregoing document was served to following via
IEFS.
Attorney for Defendant VEC HOA

TANNER LAW GROUP
Scott Allan Tanner (15279-41)
David E. Jacuk Atty no. 35022-49
6125 S East Street (US 31)
scott.tanner@tannerlawgroup.com
info@tannerlawgroup.com
court.notices@tannerlawgroup.com
Phone: (317) 536-7435 Collections Service / (317) 388-5555 Client Service
Fax: (317) 735-2703
Attorney for Muhammed Javed and Andleeb Javed

Steven St. John
SKILES DETRUDE
150 East Market Street, Suite 200
Direct: (317) 321-2404
FAX: (317) 321-2414
sstjohn@skilesdetrude.com

Phone# (317) 641-5977 Phone# (317) 641-5977
5
TABLE OF CONTENTS
ATTACHMENT 1: Final Judgment Order on April 26, 2019 from

Marion County Pike Township Small Claims Court by
Judge A. Stephens Douglas.
ATTACHMENT 2: Plaintiffs’ Statement of Evidence
6
ATTACHMENT 1: Final Judgment Order on April 26, 2019 from

Marion County Pike Township Small Claims Court by
Judge A. Stephens Douglas.
7
8
ATTACHMENT 2: Plaintiffs’ Statement of Evidence
9
STATE OF INDIANA )
)
MARION COUNTY
SMALL CLAIMS COURT
)
CAUSE NO. 49K05-1811-SC-004090
KAY KIM )
CHARLES CHUANG )
Plaintiffs. )
)
vs )
)
Defendants. )
PLAINTIFFS’ STATEMENT OF EVIDENCE
Plaintiffs Charles Chuang and Kay Kim Pro se filed Statement of Evidence on this 29th
day of April, 2019.
Plaintiffs waive attachment of transcript in its entirety and/or portion of pertaining to this
appeal.
Date: April 29, 2019 /s/ Charles Chuang

Charles Chuang, Plaintiff Pro se
Phone# (317) 641-5977
chang2597@gmail.com
Date: April 29, 2019 /s/ Kay Kim

Kay Kim, Plaintiff Pro se
Phone# (317) 641-5977
retypeunitedstates@gmail.com
10
VERIFICATION

I hereby certify that on April 29, 2019, I electronically filed the foregoing document
I certify that on April 29, 2019, the foregoing document was served to following via
IEFS.

TANNER LAW GROUP
Phone: (317) 536-7435 Collections Service / (317) 388-5555 Client Service
Fax: (317) 735-2703
Attorney for Muhammed A. Javed and Andleeb Javed

Steven St. John
SKILES DETRUDE
Direct: (317) 321-2404
FAX: (317) 321-2414

Phone# (317) 641-5977 Phone# (317) 641-5977
11
Notice of Completion of Clerk's Record will be provided by Court Clerk and not available as of today.
Notice of Completion of Clerk’s Record (Done by Court Clerk)

Chronological Case Summary (Done by Court Clerk)
…
…
…
12
CCS copied from mycase.in.gov by Appellants on April 30, 2019.

Appellants/Plaintiffs copied the following CCS from https://mycase.in.gov/; thus, the “Notice of Completion of
Clerk’s Report” is not available as of today.
CHRONOLOGICAL CASE SUMMARY (CCS)

CASE NO. 49K05-1811-SC-004090
Kay Kim,Charles Chuang,Charles Chuang v. § Case
SC - Small Claims
Village at Eagle Creek Homeowners Association § Type:
(VEC HOA),(VEC HOA) Owner of the 4260 § Date Filed: 11/08/2018
Unit #6 § Marion County - Pike
Location:
§ Township
PARTY INFORMATION
Attorneys
Defendant (VEC HOA) Owner of the 4260 Unit #6 Steven St. John
c/o OMNI Management Service Retained
212 W. 10th St. Suite B300 150 East Market Street
Indianapolis, IN 46202 Suite 200
317-321-2404(W)
Defendant Village at Eagle Creek Homeowners Association (VEC HOA) David Edward Jacuk
c/o OMNI Management Service Retained
212 W. 10th St. Suite B300 Tanner Law Group
Indianapolis, IN 46202 6125 S East Street
Suite A
317-536-7435(H)
Scott Allan Tanner

Retained
TANNER LAW GROUP
6125 S East Street
Suite A
317-536-7435 x202(W)
Plaintiff Chuang, Charles

4250 Village Parkway CIR E
UNIT 2
Plaintiff Chuang, Charles Pro Se

4250 Village Pkwy Cir East Unit 2
Plaintiff Kim, Kay Pro Se

4250 Village Parkway Cir #2
CCS Page 1 of 9
13
EVENTS & ORDERS OF THE COURT

11/08/2018 Case Opened as a New Filing
11/08/2018 Notice of Claim Filed
Filed By: Kim, Kay
File Stamp: 11/08/2018
11/09/2018 Hearing Scheduling Activity
Hearing scheduled for 12/19/2018 at 9:30 AM.
11/10/2018 Automated Paper Notice Issued to Parties
Hearing Scheduling Activity ---- 11/9/2018 : Village at Eagle Creek
Homeowners Association (VEC HOA);(VEC HOA) Owner of the 4260 Unit
#6
11/10/2018 Automated ENotice Issued to Parties
Hearing Scheduling Activity ---- 11/9/2018 : Kay Kim
11/15/2018 Notice of Claim Filed
Plaintiffs' NOTICE OF CLAIM AND SUMMONS Filed & Stamped on
08Nov18
Filed By: Chuang, Charles
Filed By: Kim, Kay
11/15/2018 RJO Entry
See Scan
Order Signed: 11/15/2018
11/26/2018 Service Returned Served
BY SHERIFF VIA REP. FROM OMN.
Date Served: 11/19/2018
12/14/2018 Motion to Dismiss Filed
Motion to Dismiss
Filed By: Village at Eagle Creek Homeowners Association (VEC HOA)
12/14/2018 Appearance Filed
Appearance for Attorney Scott Tanner
For Party: Village at Eagle Creek Homeowners Association (VEC HOA)
Court takes matter under advisement ( Deft motion to Dismiss ) until
12/19/18 @ 9:30 am
Plaintiff Charles Chuang's APPEARANCE 17Dec18
For Party: Chuang, Charles
For Party: Kim, Kay
Plaintiff Kay Kim's APPEARANCE 17Dec18
For Party: Chuang, Charles
CCS Page 2 of 9
14
For Party: Kim, Kay

12/17/2018 Motion Filed
Plaintiffs' Opposition to Defendant-VECHOA s (Village at Eagle Creek
Homeowners Association) Motion to Dismiss 17Dec18
Filed By: Kim, Kay
12/18/2018 Petition Filed
Plaintiffs' Petition of Opposition's APPENDIX VOLUME I for the Def's
Motion to Dismiss 17Dec18 p410
Filed By: Kim, Kay
12/19/2018 Hearing (9:30 AM) (Judicial Officer Stephens, A. Douglas)
12/19/2018 Administrative Event
Judges notes from today's hearing
12/20/2018 Amended Pleading Filed
Plaintiffs' NOTICE OF AMEND THE MINOMER DEFENDANT OWNER
4260 UNIT 6 20Dec18
Filed By: Kim, Kay
12/20/2018 Subpoena/Summons Filed
Plaintiffs' SUBPOENA DUCES TECUM to Defendant VECHOA c/o defense
counsel 20Ded18
Filed By: Kim, Kay
12/20/2018 Answer Filed
Plaintiffs' RESPONSE to Court s December 19, 2018 Order 20Dec18
Filed By: Kim, Kay
Collection Hearing scheduled for 01/30/2019 at 9:30 AM.
set 1-30-19
Filed By: Kim, Kay
Hearing Scheduling Activity ---- 12/20/2018 : (VEC HOA) Owner of the
4260 Unit #6;Charles Chuang
Hearing Scheduling Activity ---- 12/20/2018 : Kay Kim;Scott Allan Tanner
CCS Page 3 of 9
15

Defendant ANDLEEB JAVED, OWNER OF 4260 UNIT 6 19Dec18
Filed By: Kim, Kay
Defendant MUHAMMED JAVED, OWNER OF 4260 UNIT 6 19Dec18
Filed By: Kim, Kay
ct finds parties obligated to use alternate dispute resolution including
mediation/arbitration motion to dismiss DENIED Ct stays all matters in this
ct pending report of mediator/arbetrator / matter set for status conference
other than joing of add'l def all other matters stayed SET 2-6-19 at 9.30 am
Collection Hearing scheduled for 01/30/2019 at 9:00 AM.
Hearing Scheduling Activity ---- 1/2/2019 : (VEC HOA) Owner of the 4260
Unit #6;Charles Chuang Hearing Scheduling Activity ---- 1/2/2019 : (VEC
HOA) Owner of the 4260 Unit #6;Charles Chuang
01/04/2019 Affidavit of Non-Military Filed
Def. Response to Plaintiff's Response to Court Order
File Date: 01/02/2019
Def. Objection to Plaintiff's Notice to Amend
Motion to Quash Subpoena Duces Tecum
01/04/2019 Counterclaim Filed
Counterclaim
CCS Page 4 of 9
16
plaintiff and def file various motions/pleadings. The letters plaintiff files do
not need a response from Ct nor does the itemization of damages SEE
SCANNED RJO for full details remains set for 2-6-19 at 9:30am
plaintif and def have made filings relating tto subpoena's and
sanctions/fees that Ct previous ruling disposes of and makes def motion to
quash and response to fees/judgment moot
01/07/2019 Certified Mail Returned
signed and returned served on 1/2/19.
Date Signed: 01/02/2019
01/07/2019 Certified Mail Returned
signed and dated 1/2/19 received.
Date Signed: 01/02/2019
Motion to Designate a Mediation Panel
def villages request ct to appoint panel/ct notes def's Javed have not
appeared and hearing set on them for 01-30-19 crt reserves setting panel
until 1-30-19, unless def appear wuth or withour counsel prior to 1-30-19
Plaintiffs' 1st Supplement Claims 17Jan19
Filed By: Kim, Kay
Plaintiffs' Notice to Court to Update Defendant's Info 17Jan19
Filed By: Kim, Kay
Notice to Court to Update Defendant-Owner of 4260 Unit 6 as Mr & Mrs
Javed 17Jan19
Filed By: Kim, Kay
plaintiff files 1st supplemental claim & updated def information/ CT strikes
supplemental claim/ ct strikes supplemental claim as stay is in effect .
Court does direct clerk to update Def's info as provided by plaintiff
CCS Page 5 of 9
17
Notice to Court to Update Defendant Mr & Mrs Javed's Info [Telephone#

has been added] 18Jan19
Filed By: Kim, Kay
plaintiff files second notice regarding def information ct notes this
information is already on system from previous filing
Appearance of Steven St. John on Behalf of Defendants Muhammed Javed
and Andleeb Javed
For Party: (VEC HOA) Owner of the 4260 Unit #6
01/28/2019 Motion for Continuance Filed
First Motion to Continue January 30, 2019 Hearing
Filed By: (VEC HOA) Owner of the 4260 Unit #6
01/28/2019 Document Filed
AS ANSWERED BY JUDGE.
01/28/2019 Order Granting Motion for Continuance (Judicial Officer: Stephens, A.
Douglas )
Collection Hearing scheduled for 01/30/2019 at 9:00 AM was cancelled.
Reason: Other.
MAILED COPY OF ORDER GRANTING CONTINUANCE TO BOTH
PARTIES TODAY.
Hearing scheduled for 02/06/2019 at 9:30 AM was cancelled. Reason:
Other.
Order Granting Motion for Continuance ---- 1/28/2019 : Charles Chuang
Hearing Scheduling Activity ---- 1/28/2019 : Charles Chuang Hearing
Scheduling Activity ---- 1/28/2019 : Charles Chuang
Order Granting Motion for Continuance ---- 1/28/2019 : Kay Kim;Scott Allan
Tanner;Steven St. John Hearing Scheduling Activity ---- 1/28/2019 : Kay
Kim;Scott Allan Tanner;Steven St. John Hearing Scheduling Activity ----
1/28/2019 : Kay Kim;Scott Allan Tanner;Steven St. John
Appearance - Attorney Jacuk
For Party: Village at Eagle Creek Homeowners Association (VEC HOA)
CCS Page 6 of 9
18

Defendants Muhammed Javed and Andleeb Javed's Notice of Naming
Nonparty
plaintiff has filed their own list of mediators which the court STRIKES and
directs the parties to strike from the COURT"S list additionally a settlement
offer has been made ct directs parties to take notice and act accordingly
01/30/2019 CANCELED Collection Hearing (9:00 AM) (Judicial Officer Stephens, A.
Douglas)
Other
02/06/2019 CANCELED Hearing (9:30 AM) (Judicial Officer Stephens, A. Douglas)
Other
Plaintiffs' MOTION FOR SUMMARY JUDGMENT 24FEB19
Filed By: Kim, Kay
02/25/2019 Hearing Journal Entry (Judicial Officer: Stephens, A. Douglas )
Court Strikes Plaintiff's Motion for Summary Judgment, proceedings stayed
pending mediation. Plaintiff to Strike from courts panel within 15 days of
this order or the court will strike as well. See scanned entry.
Hearing Date: 02/25/2019
Request granted now set for hearing on 6/20/19 AT 1:30PM.
02/28/2019 Notice Filed
Defendant Village at Eagle Creek Homeowners Association, Inc's Notice to
Strike Mediator Steven Crell
02/28/2019 Notice Filed
Defendants Muhammed Javed and Andleeb Javed's Notice to Strike
Mediator Charles O'Connor
Plaintiffs' NOTICE of STRIKE-MEDIATOR from the Judge s List 27Feb19
Filed By: Kim, Kay
02/28/2019 Court Appoints Mediator (Judicial Officer: Stephens, A. Douglas )
Mark Matheny, Atty. (317) 639-3315
CCS Page 7 of 9
19

by Plaintiff re: Mediator
03/19/2019 Mediation Status Report Filed
Mediator Files Report to the Court and tenders Resignation as Mediator
Filed By: Matheny, Marc
03/20/2019 Order Granting Motion for Rule to Show Cause (Judicial Officer:
Stephens, A. Douglas )
Rule to Show Cause on Charles Chuang. Set 04-26-19@ 10:00am
03/20/2019 Order Granting Motion for Rule to Show Cause (Judicial Officer:
Stephens, A. Douglas )
Rule to Show Cause on Kay Kim Set 04-26-19 @ 10:00am
All Parties served via Email & US Mail
03/20/2019 Order Granting (Judicial Officer: Stephens, A. Douglas )
Order Granting Motion for Rule to Show Cause ---- 3/20/2019 : Charles
Chuang Order Granting Motion for Rule to Show Cause ---- 3/20/2019 :
Charles Chuang Hearing Scheduling Activity ---- 3/20/2019 : Charles
Chuang Order Granting ---- 3/20/2019 : Charles Chuang
Order Granting Motion for Rule to Show Cause ---- 3/20/2019 : Kay
Kim;Scott Allan Tanner;David Edward Jacuk;Steven St. John Order
Granting Motion for Rule to Show Cause ---- 3/20/2019 : Kay Kim;Scott
Allan Tanner;David Edward Jacuk;Steven St. John Hearing Scheduling
Activity ---- 3/20/2019 : Kay Kim;Scott Allan Tanner;David Edward
Jacuk;Steven St. John Order Granting ---- 3/20/2019 : Kay Kim;Scott Allan
Tanner;David Edward Jacuk;Steven St. John
Plaintiffs' ANSWER to Court s Order to Show Cause 21Mar19
Filed By: Kim, Kay
03/22/2019 Correspondence to/from Court Filed
Plaintiffs Kim & Chuang file "Answer to Courts Order to Show Cause" Court
reviews matters raised and cannot deal with matter by motions. Case
remains set for hearing 4-26-19 @ 10:00 am
CCS Page 8 of 9
20
04/09/2019 Service Returned Not Served

Rule to Show Cause returned not served. Locked building...no
maintenance man
04/26/2019 Hearing (10:00 AM) (Judicial Officer Stephens, A. Douglas)
Rule to Show Cause
04/26/2019 Order of Dismissal (Judicial Officer: Stephens, A. Douglas )
Trial held. Plaintiff's refuse to attend court ordered mediation or mediators.
Case Dismissed w/Prejudice
Order of Dismissal ---- 4/26/2019 : Charles Chuang
Order of Dismissal ---- 4/26/2019 : Kay Kim;Scott Allan Tanner;David
Edward Jacuk;Steven St. John
04/30/2019 Notice of Appeal Received
Plaintiffs' NOTICE OF APPEAL from Final Judgment Order 29Apr19
Filed By: Kim, Kay
Plaintiffs' STATEMENT OF EVIDENCE 29Apr19
Filed By: Kim, Kay
Please note that any Balance Due does not reflect interest that has accrued since
the last payment.
CCS Page 9 of 9
21
Plaintiffs' COMPLAINT
49K05-1811-SC-004090
22
CONSTABLES RETURN OF SERVICE OF NOTICE OF CLAIM

I certify that I have served this Notice of Claim on
1) By reading a Claim to the Defendant,
2) By leaving a copy of the Notice of Claim at which is the dwelling
place or usual place of abode of and by mailing a copy of the
Notice of Claim to said Defendant at the such address.
3) Other service remarks:
THIS COMMUNICATION IS
FROM A DEBT COLLECTOR. Constable
NOTICE TO ALL PARTIES

- You may appear either in person or by attorney on the date set for trial and hearing of Plaintiff’s claim.
- Both the Plaintiff and the Defendant should bring to the hearing all witnesses and all documents in their possession
concerning this claim.
- If the Defendant does not wish to dispute the claim of the Plaintiff, he may appear to consent to a judgment and for the
purpose of allowing the court to establish the method by which the judgment shall be paid.
- If the Defendant cannot appear at the time and place set in the notice he should contact the party filing this claim to request
that the hearing be continued to another date.
- If the Defendant fails to appear in Court at the time set for the hearing, a default judgment may be entered against the
Defendant.
- A defendant in a small claims case waives the right to trial by jury unless the defendant request a jury trial at least three
(3) calendar days before the trial date that appears on the complaint.
- The party requesting a jury trial shall pay the clerk the additional amount required by statue to transfer the claim to the
plenary docket; otherwise, the party requesting a jury trial shall be deemed to have waived the request.
- The Defendant may within ten days (10) of service of the summons file a change of venue of this matter. Proper venue is
determined by the court in the following order.
(1) In an action upon a debt or account, venue is in the township where any defendant has consented to venue in a writing
signed by the defendant.
(2) Venue is in the township where a transaction or occurrence giving rise to any part of the claim took place.
(3) Venue is in the township (in a county of the Small Claims Court) where the greater percentage of individual defendants
included in the complaint resides, or, if there is no such greater percentage, the place where any individual defendant so
named resides, owns real estate, or rents an apartment or real estate or where the principal office or place of business of any
defendant is located.
(4) Venue is in the township where the claim was filed if there is no other township in the count in which the small claims
court sites in which required venue lies.
Claims between landlord and tenants shall be in the township where the real estate is located.
23
Noah's Vet Bill $317.53 for BamBam
24
Noah_BamBam's Diagnose
25
Bean Blossom Vet Bill $200.00 for BamBie
26
CVS wound care $32.91
27
CVS w.Care $4.19
28
CVS w.Care $10.69
29
AMAZON w.Care 1 $35.49
30
31
AMAZON w.Care 2 $5.34
32
Dr. FOSTER and SMITH $8.80
33
4260-6 Tenant will pay VET BILL 10/30/18_signed
34
TEXT Message by Rico (Boyfriend of Pitbull owner) to Pl Kay Kim.

November 02, 2018
4260-6 TEXT by Rico-not my responsibility due to ur wife
That bill is not my responsibility anymore because of your wife charles

4260-6 TEXT by Rico 317913029p417: Friday, November 02, 2018
November 02, 2018

4260-6 TEXT by Rico-nothing to do with
I have nothing to do with anything you are referring to that is something you yourself made
sure of
4260-6 TEXT by Rico 3176676523p418_Friday, November 02, 2018
November 02, 2018

4260-6 TEXT by Rico-deal w_owner & HOA
Do not call or text my phone for that matter anymore that is something you have deal with
with the owner now because of you going to the association about the matter
4260-6 TEXT by Rico 3176676523 p421_Friday, November 02, 2018-U deal w_owner&HOA
February 21, 2019

4260-6 TEXT by Rico-Boyfriend of Pitbull Owner
Thursday, February 21, 2019 7:56 PM

3176464089©vtextcom <3176464089@vtext.com>
Lol IG the courts decided u wasn't gone get nothing u can thank yourself
for that goodnight
35
Update Status & Umbrella Insurance Claim Requested
36
VECHOA Gia to kk_Claim under Homeowner Ins & info or q to Omni Property Mgmt
37
PHOTO OF DOG-BamBam INJURY
38
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40
41
42
43
44
PHOTO OF DOGBam Bie's INJURY
45
46
47
48
49
50
51
52
VECHOA Gia-Consault w_Attorney NO FURTHER ACTION 29Oct18
53
kk to VECHOA Property mgt Richard Meza: Pls, RESPOND TO T#465-6702 & 466-0539
54
CORRESPONDENCE between kk & VECHOA: Attached vet bills, photos, etc.
55
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57
58
59
60
61
62
63
64
65
66
67
68
69
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VECHOA (Village at Eagle Creek Homeowners Association DOG RULE 2018
73
VECHOA Bylaw_Ownership of Common Area
74
VECHOA 2014 Master Insurance Policy
75
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77
VECHOA Site Layout Dog Park Map

Where the Pitbull attacked: Appellant was going back to own unit 42502 Lake View.
78
Pls' PROPOSED SETTLEMENT to Defendants 29Jan19

fa 1/29/2019 3:53 PM EST E# 6791257
STATE OF INDIANA )
MARION COUNTY)
SMALL CLAIMS COURT
)
CAUSE NO. 49K05-1811-SC-004090
KAY KIM )
CHARLES CHUANG )
Plaintiffs. )
)
vs )
)
Defendants. )
PLAINTIFFS’ NOTICE OF
PROPOSED SETTLEMENT TO DEFENDANTS
Come now, Plaintiffs Kay Kim and Charles Chuang Pro Se, filed Plaintiffs’ Notice of
Proposed Settlement to Defendants as follows and not limited to:
1. The following proposed settlement were emailed to defendants prior to this Court
filing.
2. Plaintiffs will settle for total of $732.:
$591 (vet bill) + $115 (court cost) + $26. (additional court processing fee) = $732.
3. Plaintiffs will claim additional cost & expense for mediation if/when all parties
don’t settle before the mediation.
79
I hereby certify that on January 29, 2019, I electronically filed the foregoing document
I certify that on January 29, 2019 the foregoing document was served to the Defendants
via IEFS of email (if not register with IEFS).

Scott Allan Tanner (15279-41) ()
TANNER LAW GROUP
(317) 536-7435 Collections Service
(317) 388-5555 Client Service
Attorney for 4260 unit 6 owners of Muhammed Javed and Andleeb Javed
Steven St. John Steven St. John
SKILES DETRUDE
Direct: (317) 321-2404
FAX: (317) 321-2414

Phone# (317) 641-5977 Phone# (317) 641-5977
chang2597@gmail.com chang2597@gmail.com
80
Dated: January 29, 2019 /s/ Charles Chuang

Phone# (317) 641-5977
chang2597@gmail.com
/s/ Kay Kim

Phone# (317) 641-5977
chang2597@gmail.com
VERIFICATION

81
MEDIATOR's LIST for Parties to STRIKE prepared by Pls 29Jan19fa

fa190129 Envelope Number: 6791257
STATE OF INDIANA ) IN THE PIKE TOWNSHIP OF
) MARION COUNTY
COUNTY OF MARION ) ss: SMALL CLAIMS COURT
) CAUSE NO. 49K05-1811-SC-004090
KAY KIM )
CHARLES CHUANG )
Plaintiffs. )
)
vs )
)
Defendants. )
PLAINTIFFS’ NOTICE THE DEFENDANTS TO STRIKE MEDIATOR
Come now, Plaintiffs Kay Kim and Charles Chuang Pro Se, filed Plaintiffs’ Notice The
Defendants to Strike Mediator as per Court Order issued on January 28, 2019 as follows:
1. DEFENDANT [VECHOA][MR. & MRS JAVED] STRIKE:
Name: Reham Samir Hewedak, Mediator Number: 31342-49

Address: 4150 N Keystone Ave; Indianapolis, Indiana, 46205
Phone: 317-644-9658 / Fax:Not specified
Email: reham.hewedak@dcs.in.gov
Rate: $70.00, Negotiable, Will take pro bono cases
Name: Mr. David Joseph Remondini, Mediator Number: 20333-49

Address: Not specified
Phone: 317-847-7041 / Fax:3178477041
Email: daveremo@comcast.net
Rate: $105.00 - $150.00, Negotiable, Will take pro bono cases
82
3. PLAINTIFFS STRIKE: XXX
DEFENDANT [VECHOA][MR. & MRS JAVED] STRIKE:
Name: Ms. Sharon Lynne Buechler, Mediator Number: 15713-49

Address: 7323 N. Tuxedo Street Indianapolis, Indiana, 46240
Phone: 317-294-2482 / Fax:Not specified
Email: sharonbue6@comcast.net
Rate: $125.00 - $250.00, Negotiable, Will take pro bono cases
Name: Mr. Rodney Alan Tucker, Mediator Number: 20708-49

Address: 10142 Brooks School Road, Suite 215
Fishers, Indiana, 46037
Phone: 317-762-9006 / Fax: 317-732-1049
Email: rodtuckerlaw@gmail.com
Rate: $150.00 - $200.00
5. Plaintiffs will set up/arrange meeting-date, time, & place with survived mediator
and notify the defendants.
Dated: January 29, 2019 /s/ Charles Chuang

Phone# (317) 641-5977
chang2597@gmail.com
/s/ Kay Kim

Phone# (317) 641-5977
chang2597@gmail.com
83
VERIFICATION

I hereby certify that on January 29, 2019, I electronically filed the foregoing document
I certify that on January 29, 2019 the foregoing document was served to the Defendants
via IEFS of email (if not register with IEFS).

TANNER LAW GROUP
Attorney for 4260 unit 6 owners of Muhammed Javed and Andleeb Javed
Steven St. John Steven St. John
SKILES DETRUDE
Direct: (317) 321-2404
FAX: (317) 321-2414

Phone# (317) 641-5977 Phone# (317) 641-5977
84
MEDIATOR LIST for Parties to STRIKE prepared by JUDGE 29Jan19scanned
85
Filed: 2/24/2019 6:22 PM
Judge
Pike Township of Marion County Small Claims Court
Pls' MOTION for SUMMARY JUDGMENT (Ref. Rico's LOL) fa190224

STATE OF INDIANA ) IN THE PIKE TOWNSHIP OF
) MARION COUNTY
COUNTY OF MARION ) ss: SMALL CLAIMS COURT
) CAUSE NO. 49K05-1811-SC-004090
KAY KIM )
CHARLES CHUANG )
Plaintiffs. )
)
vs )
)
Defendants. )
PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT
Comes now, Plaintiffs Kay Kim and Charles Chuang Pro Se, moves the Court to grant
summary judgment in favor of Plaintiffs on this February 24, 2019 as follows and not limited to:
1. On January 29, 2019, the Court entered RJO for mediation.

plaintiff has filed their own list of mediators which the court
STRIKES and directs the parties to strike from the COURT"S list
additionally a settlement offer has been made ct directs parties to
take notice and act accordingly Order Signed:
01/29/2019
2. On February 24, 2019, Defendants did not respond to Court’s RJO [Plaintiffs’
filing of list of mediators to strike by Defendants.]; unlikely, there will be a mediation.
3. On December 17, 2018, Plaintiffs filed the 114 pages Appendix to show the Court
beyond reasonable doubt that the incident (Pitbull bite another small dogs in the VECHOA
common area) is no fault of Plaintiffs.
Page 1 of 5
86
4. The Court entered in the CCS the following:
01/30/2019 CANCELED Collection Hearing (9:00 AM) (Judicial Officer Stephens,

A. Douglas)
Other
02/06/2019 CANCELED Hearing (9:30 AM) (Judicial Officer Stephens, A. Douglas)
Other
5, The following copy of Bam Bam’s full report is Appendix page 4 of 114.
Veterinary Specialty & Emergency Care

Conclusions/Treatments:
Initial stabilization approved - IV catheter placed left front leg, 0.18m1 hydromorphone IV
Radiographs of thorax and right front leg, abdominal FAST scan, heavy sedation for wound
exploration and closure if stable recommended and declined.
Once mildly sedate from the hydromorphone, Bam Barn's wounds were clipped and
scrubbed with chlorhexidine. During the period of time where Bam Barn was being cleaned
up, his breathing progressively worsened. He became tachypnic and had increased
respiratory effort. Discussed this with the owners. Due to financial limitation, they are unable
to pursue additional diagnostics and treatments. Advised the owners that Bam Barn is likely
to pass on his own tonight. Humane euthanasia recommended and declined. The owners
wish to take him home.
5-1. Bam Bam’s Initial consultant vet bill was over $1,200. and another special
care would adds over $1,000. I, Plaintiff Kay Kim asked the clinic to limit the treatment up to
$400. and that’s all I can afford; regardless, who is responsible for the vet bill.
5-2. It happened on Saturday closed business. Bam Bie’s coat color was
copper color which disguise blood color and we did not noticed until late Sunday. We drove
over 100 miles round trip to save vet bills.
5-3. We take care of dogs ourselves for cleaning and dressing; so, we can save
money for vet bills; but, we had to purchase whatever it needs to take care of the wounds.
Page 2 of 5
87
6. As we/Plaintiffs filed in the Appendix, $591. was less than what we actually spent
and does not include driving over 100 miles round trips three (3) times (Initial visit, follow up,
removing stitch.)
7. It happened in the Condo VECHOA common area which privately owned;
besides, VECHOA Board of Director authorized the residents/tenants to have Pitbulls in the
condo. Also, VECHOA have criminal and civil insurance to cover/protect the victim.
8. I/Plaintiff Kay Kim got the following cell phone text from person-Rico who had
the two Pitbulls involved in our/Plaintiffs’ dogs attack:
Thursday, February 21, 2019 7:56 PM

3176464089©vtextcom <3176464089@vtext.com>
Lol IG the courts decided u wasn't gone get nothing u can thank yourself
for that goodnight
9. I/Plaintiff Kay Kim contacted the VECHOA Board of Directors and Property
Manager for them to pay $591. repeatedly to settle the incident without going to Court; but, they
never contacted me/Plaintiff Kay Kim back and ignored until we/Plaintiffs filed the lawsuit.
10. Plaintiffs prepared the list of mediator for the Defendants to strike; but, still non-
response/ignore the Court’s RJO all together.
11. The Court’s initial docket entry shows who is responsible for Plaintiffs’ vet bills.
[See. Above paragraph 4.]
12. It is dangerous for us/Plaintiffs to collect directly from whoever is responsible for
vet bills.
Page 3 of 5
88
13. Under the circumstances, our vet bills are incredibly reasonable. Despite that,
what we have to collect the money back is insult to injury. It is not nice for Defendants to
taunting us/Plaintiffs directly and indirectly.
WHEREFORE, Plaintiffs respectfully request the Court to grant summary judgment of
$591. plus Court cost for all other relief just and proper in the premises for the Plaintiffs.
Dated: February 24, 2018 /s/ Charles Chuang

Phone# (317) 641-5977
chang2597@gmail.com
/s/ Kay Kim

Phone# (317) 641-5977
chang2597@gmail.com
VERIFICATION

Page 4 of 5
89
I hereby certify that on February 24, 2019, I electronically filed the foregoing document
I certify that on February 24, 2019 the foregoing document was served to following via
IEFS.

TANNER LAW GROUP
David E. Jacuk Atty Number: 35022‐49
6125 S. East St, Suite A, Indianapolis IN 46227
Phone: (317) 536‐7435
FAX: (317) 735‐2703

SKILES DETRUDE
Direct: (317) 321-2404
FAX: (317) 321-2414

Phone# (317) 641-5977 Phone# (317) 641-5977
Page 5 of 5
90
MEDIATOR Marc Matheny's Demand $300.Retainer for Half day $plus
+ + <chang2597@gmail.com>
Mediation of Chang v. Village at Eagle Creek Homeowners Association

5 messages
Marc Matheny <mmatheny@oblawindy.com> Wed, Mar 13, 2019 at 6:27 PM

To: cc <chang2597@gmail.com>, "court.notices@tannerlawgroup.com"
<court.notices@tannerlawgroup.com>
Mr. and Mrs. Chang, and David Jacuk,
I have been chosen as your court mediator. The first thing I would like to let you
know is that I have done a conflicts check, so I can serve as your mediator.
My rate for mediation is $200 per hour, split equally between the parties, unless
otherwise agreed.
Based on this is a Small Claims case, I would suggest a ½ day mediation.
I have the following dates available for mediation:

March 22 (a.m.), March 26 or 27 (either a.m. or p.m.), April 1 or 2nd (a.m. or p.m.),
April 16th, (a.m. or p.m.), April 22, 23, 24 or 25th , (a.m. or p.m.), April 30th, (a.m. or
p.m.).
If we need to go into May, 2019, we may do so, but my dates in May are also limited.
Once we have agreed on a date, I will send out engagement letters to both parties,
along with a retainer agreement. I expect a $300 retainer from both sides, and if
we go over three hours, the remainder of the fee must be paid on the date of
mediation.
If you have other questions, feel free to contact me on the particulars.
Please send me your available dates as soon as possible.
Marc Matheny
Marc W. Matheny
Attorney at Law
244 N. College Avenue
USA
Tel: (317) 639-3315
Fax: (317) 639-3318
mmatheny@ameritech.net
mmatheny@oblawindy.com
91
Email: Apln/Pl KK to MEDIATOR Marc Matheny Page 1 of 2
Wed, Mar 13, 2019 at 6:50 PM

cc <chang2597@gmail.com>
To: Marc Matheny <mmatheny@oblawindy.com>, sstjohn@skilesdetrude.com,
Cc: "court.notices@tannerlawgroup.com" <court.notices@tannerlawgroup.com>
Mr. Matheny,
With all due respect, the Mediation fee $200. per hour must split among three parties.
Thus, my fee should not exceeds more than $70. per hour at the most.
The following are the all involved parties:

TANNER LAW GROUP

SKILES DETRUDE
Direct: (317) 321-2404
FAX: (317) 321-2414
I already filed with the Court and sent to all counsel that I demand $ 591. (vet
bills) + Court Cost + Mediation Cost.
My $demand is not a negotiable.
My comply to mediation meeting is because the Judge order. I am going to pay
you $70.00 for one hour of mediation.
You have to refund me 1/2 if/when we don't stay at the mediation more than 1/2
hour which I have no intention to stay more than 1/2 hour of mediation.
No matter what you or anyone say, my $demand will not change.
I will pay you $70.00 check (or money order if you wish) when we go to your
office for mediation.
I can adjust our schedule any day or time after April 03, 2019; so, you and
opposing counsels
agrees to time and date and let me know. Unless, we have life of death
situation, we will be at the meeting.
Sincerely,
kay kim
92
Email: Apln/Pl KK to MEDIATOR Marc Matheny Page 2 of 2
cc <chang2597@gmail.com> Wed, Mar 13, 2019 at 7:11 PM

Mr. Matheny,
Like I said, my attending of mediation will be definitely less than one hour.
I will not pay you more than $70.00 for mediation.
Again, let me reiterate that I will walk out of your mediation meeting within
1st 1/2 hour (30 minutes); so, we both don't have to argue about for my mediation
fee payment to you more than $70.00. More likely, you have to refund me $35.00
Sincerely,
kay kim
cc <chang2597@gmail.com> Wed, Mar 13, 2019 at 7:14 PM

Mr. Matheny,
I write you two checks of $35.00; so, you can return my one check $35.0 back to me
when I am done with mediation within 1/2 hour. Thanks.
Sincerely,
kay kim
93
E# 7353442 D/Ts 3/18/2019 3:58 PM EST

STATE OF INDIANA ) IN THE MARION SMALL CLAIMS COURT
) SS:
COUNTY OF MARION ) CAUSE NO. 49K05-1811-SSC-004090
KAY KIM, CHARLES CHUANG, )

)
Plaintiffs/Counter Defendants, )
)
v. )
)
VILLAGE AT EAGLE CREEK )
HOMEOWNER’SASSOCIATION; and )
VEC-HOA, owner of the 4206 Unit #5 , )
)
Defendants/Counterclaimants. )
REPORT OF MEDIATOR AND RESIGNATION OF MEDIATOR
Comes now, Marc W. Matheny, the court-appointed mediator in this cause of action, who
respectfully reports to the court as follows:
1. That he has been contact with all of the parties or their counsel in this cause and
has attempted to begin the mediation process by exchanging possible dates and sending out terms
of mediation to the parties.
2. That the Plaintiff, Kay Kim, has indicated that she would not be participating in
the mediation under the terms set forth in the mediator’s Agreement to Mediate.
3. That due to the correspondence between the Plaintiff and the mediator, the
mediator feels that he is now in an adversarial relationship with the Plaintiff and can no longer
act as mediator in this cause of action and would tender his resignation as mediator.
4. That no mediation has taken place, no mediation has been scheduled, nor have the
parties agreed to the terms of mediation at this point.
94
s/Marc W. Matheny
Marc W. Matheny, #9849-49
Mediator
I hereby certify that a copy of the foregoing was served by the court’s electronic filing
system and/or first class mail on the 18th day of March 2019 upon:
Kay Kim
Charles Chuang
4250 Village Parkway Circle #2
David Edward Jacuk

Tanner Law Group
6125 Southeast Street, Suite A
Steven St. John

Skiles DeTrude
150 E. Market Street, Suite 200
s/Marc W. Matheny
Marc W. Matheny
Marc W. Matheny
Attorney at Law
244 N. College Avenue
317-639-3315
95
Judge's Order Accepting MEDIATOR'S REPORT & RESIGNATION
96
97
Filed: 3/21/2019 5:11 AM
Judge
Pike Township of Marion County Small Claims Court
STATE OF INDIANA )
)
MARION COUNTY
SMALL CLAIMS COURT
)
CAUSE NO. 49K05-1811-SC-004090
KAY KIM )
CHARLES CHUANG )
Plaintiffs. )
)
vs )
)
Defendants. )
PLAINTIFFS’ ANSWER TO COURT’S ORDER TO SHOW CAUSE
Comes now, Plaintiffs Kay Kim and Charles Chuang Pro Se, filed Answer to Court’s
Order to Show Cause as follows and not limited to:
1. Mediator demanded retainer fee of three hundred (300) dollars from us/Plaintiffs.
2. Mediator stated that it will start with half (1/2) day of mediation. Sounded like,
retainer fee of $300.00 is just to begin the mediation.
3. Plaintiffs are willing to attend mediation if the Mediator’s fees are acceptable and
reasonable.
4. As it is stands, unless, Your Honor appoint a pro bono mediator or the Defendants
agree to pay the cost of mediation, the Plaintiffs will not be able to attend the mediation due to its
cost.
5. Are two (2) Defendants paying $300.00 each total of $600.00 retainer fees for the
mediation? Mediator and all parties have open email correspondence. No Defendant ever
replied to mediator’s demand whether any or all Defendant will pay the $300.00 retainer fee +
98
hourly mediation fees. Have your Honor ask the Defendants whether they will pay $300.00
each?
6. Your Honor, if the Defendant are willing to pay $300.00 each for mediation, why
don’t they pay $400.00 each to us/Plaintiffs to resolve the lawsuit? OR,
7. Is it some kind of scam of conspiracy among mediator and the Defendants to
demand/collect $300.00 only from the us/Plaintiffs? Maybe the mediator is waving the retainer's
fees for the Defendants.
8. Plaintiff told the mediator that we/Plaintiffs will only pay two checks $35.00 each
total of $70.00 because, his hourly rate is $200.00 divide by 3 i.e. $70.00/per party as a formality
because of the Court’s order.
9. Plaintiffs told the mediator what we/Plaintiffs told the Court and the Defendants
that our amount of demands are vet bills $591.00+Court Cost+Mediation (if we/Plaintiffs
pays+etc.(cost of appeals) is not negotiable. So, we/Plaintiffs will more likely attend and
complete the mediation within 30 minutes.
10. Unless, this case is set for jury trial; there is no legal authority for your Honor to
force us pay for the mediation.
11. Plaintiffs stated clearly to Court and the Defendants that no mediator will change
our mind on the amount of judgement we are seeking which is vet bills $591.+ Court Cost +
Mediation (if we have to pay) + etc. (if this case go on appeal)
12. Our demand of vet bill $591. is less than what we actually spent for the injuries to
my dogs. The initial bills asked by the vet is more than $2,000. When we cannot afford to pay
for the treatment, the vet recommended the euthanasia of the dog. We/Plaintiffs brought our male
dog home to die and had to be awake the whole night to take care and comfort my dogs.
99
13. The Plaintiffs had to borrow $300.00 to pay for the vet bill.
14. We/Plaintiffs were eager to pay off the debt; so, we asked VECHOA to pay
$591.00 The Defendants ignored and remain silent on the matter. We had no choice; but, to file
a lawsuit.
15. We respectively ask Your Honor to review if the order to force the Plaintiffs to
pay for the mediation is legal.
16. Your Honor denied Plaintiffs’ summary judgment.
17. The Plaintiffs are waiting your final order of judgment so, Plaintiffs can appeal
the case.
Dated: March 21, 2018 /s/ Charles Chuang

Phone# (317) 641-5977
chang2597@gmail.com
/s/ Kay Kim

Phone# (317) 641-5977
chang2597@gmail.com
VERIFICATION

100
I hereby certify that on March 21, 2019, I electronically filed the foregoing document
I certify that on February March 21, 2019, the foregoing document was served to
following via IEFS.

TANNER LAW GROUP

SKILES DETRUDE
Direct: (317) 321-2404
FAX: (317) 321-2414

Phone# (317) 641-5977 Phone# (317) 641-5977
101
VECHOA BYLAW
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
VERIFICATION OF ACCURACY
I verify under penalties of perjury that the documents in this Appendix are accurate
copies of parts of the Record on Appeal.

VERIFICATION

156
I hereby certify that on May 10, 2019, I electronically filed the foregoing document using
the Indiana E-Filing system (IEFS).
I certify that on May 10, 2019, the foregoing document was served to following via IEFS.

TANNER LAW GROUP
Phone: (317) 536-7435, ext. 202 Collections Service / (317) 388-5555 Client Service
Fax: (317) 735-2703
dave.jacuk@tannerlawgroup.com

Steven St. John
SKILES DETRUDE
Direct: (317) 321-2404
FAX: (317) 321-2414

Phone# (317) 641-5977 Phone# (317) 641-5977
157

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Filed: 5/10/2019 11:20 AM

CAUSE NO. 19A-SC-00970

APPENDIX TO APPELLANTS’ BRIEF

Pages 1 through 157

/s/ Charles Chuang

/s/ Kay Kim

County Pike Township Small Claims Court: Judge A. Stephens Douglas.

Rule 2(H) and 9(I). [Attachment 1: FINAL JUDGMENT ORDER.]

defined in Appellate Rule 2(E).

Small Claims Court or Administrative Agency] is requested to transcribe [Attachment 2:

Plaintiffs E-Filed 114 pages of Appendices].

/s/ Charles Chuang /s/ Kay Kim

/s/ Charles Chuang /s/ Kay Kim

Attorney for Defendant VEC HOA

Attorney for Muhammed Javed and Andleeb Javed

/s/ Charles Chuang /s/ Kay Kim

ATTACHMENT 1: Final Judgment Order on April 26, 2019 from

ATTACHMENT 2: Plaintiffs’ Statement of Evidence

ATTACHMENT 1: Final Judgment Order on April 26, 2019 from

ATTACHMENT 2: Plaintiffs’ Statement of Evidence

PLAINTIFFS’ STATEMENT OF EVIDENCE

day of April, 2019.

Date: April 29, 2019 /s/ Charles Chuang

Date: April 29, 2019 /s/ Kay Kim

/s/ Charles Chuang /s/ Kay Kim

Attorney for Defendant VEC HOA

Attorney for Muhammed A. Javed and Andleeb Javed

/s/ Charles Chuang /s/ Kay Kim

Notice of Completion of Clerk’s Record (Done by Court Clerk)

CCS copied from mycase.in.gov by Appellants on April 30, 2019.

CHRONOLOGICAL CASE SUMMARY (CCS)

Scott Allan Tanner

Plaintiff Chuang, Charles

Plaintiff Chuang, Charles Pro Se

Plaintiff Kim, Kay Pro Se

EVENTS & ORDERS OF THE COURT

For Party: Kim, Kay

12/28/2018 Subpoena/Summons Filed

Notice to Court to Update Defendant Mr & Mrs Javed's Info [Telephone#

File Stamp: 01/28/2019

Order Signed: 02/28/2019

04/09/2019 Service Returned Not Served

CONSTABLES RETURN OF SERVICE OF NOTICE OF CLAIM

NOTICE TO ALL PARTIES

Noah's Vet Bill $317.53 for BamBam

Bean Blossom Vet Bill $200.00 for BamBie

CVS wound care $32.91

CVS w.Care $4.19

CVS w.Care $10.69

AMAZON w.Care 1 $35.49

AMAZON w.Care 2 $5.34

TEXT Message by Rico (Boyfriend of Pitbull owner) to Pl Kay Kim.

That bill is not my responsibility anymore because of your wife charles

November 02, 2018

November 02, 2018

February 21, 2019

Thursday, February 21, 2019 7:56 PM

CORRESPONDENCE between kk & VECHOA: Attached vet bills, photos, etc.

VECHOA (Village at Eagle Creek Homeowners Association DOG RULE 2018

VECHOA 2014 Master Insurance Policy

VECHOA Site Layout Dog Park Map

Pls' PROPOSED SETTLEMENT to Defendants 29Jan19

Proposed Settlement to Defendants as follows and not limited to: