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HomeMy WebLinkAboutPRR25357 Emails1 From:Evan Harris <eharris@crla.org> Sent:Monday, May 19, 2025 5:09 PM To:Symens, Sadie Cc:Patsy Van Dyke; Mariah Thompson Subject:Request for Inquiry Regarding Rent Stabilization and Deceptive Business Practices at South Peak Mobile Home Park Dear Ms. Symens, I hope this message finds you well. My name is Evan Harris, and I’m an attorney in CRLA's SLO office representing Linda Valentine, a resident of Space A28 at 145 South Street in the South Peak Mobile Home Park, managed by Harmony Communities. I was recently referred to you by Assistant District Attorney Ken Jorgensen after reaching out to his office about a substantial rent increase imposed on my client that I believe may violate Chapter 5.44, Mobile Home Park Rent Stabilization, of the City's Municipal Code. I understand that SLOMC § 5.44.070 allows tenants to file a rent increase complaint with the City Clerk. I’ve advised my client to pursue this option, and she is currently speaking with neighbors who have experienced similar increases. However, it remains unclear whether Harmony is applying these rent hikes in a legally consistent way that would support a coordinated complaint. What is clear is that Harmony’s tactics appear intended to sidestep the City’s rent control ordinance, raising serious concerns about enforcement and tenant protections. Given these circumstances, I believe the matter warrants prompt attention from your office. Background Ms. Valentine owns a 2018 Champion Redman Park Model RV—commonly referred to as a park trailer—located at Space A28. She purchased the unit in July 2023 from California MHP Investors 3, LLC, a company affiliated with Harmony Communities. The trailer has been her daughter’s primary residence since purchase and is permanently installed and connected to park utilities. Harmony consistently represented the unit to her as a mobile home—including in the lease, park rules, rent notices, and other materials. In November 2024, Harmony Communities filed an unlawful detainer action against Ms. Valentine, alleging violations of the park’s guest policy. The matter was resolved in March 2025 via a court-approved settlement. Under the terms of that agreement, Ms. Valentine must vacate the premises by June 30, 2025, but she is permitted to conduct an on-site sale of her unit through November 30, 2025. She is actively trying to sell the home and has received interest from multiple prospective buyers, but each time they learn of the extraordinarily high space rent, they back out. April 2024 Rent Increase and Legal Dispute On April 1, 2024, Harmony’s Senior Regional Manager informed Ms. Valentine that any buyer of her home would be charged $1,595/month in space rent—more than double the current rent of $767.91. I objected on the grounds that SLOMC § 5.44.060(C) limits rent increases to 10% when a mobile home is sold in place and the space is not vacated. In response, Harmony’s attorney, Judy Tsai, argued that the City's ordinance does not apply because: 2 1. Ms. Valentine is not a “tenant.” Ms. Tsai asserts that my client lost her tenant status when her lease terminated following the UD notice and settlement. While I don’t dispute the lease termination, I also don’t believe tenancy status determines the applicability of SLOMC § 5.44.060(C). In fact, that chapter contains a narrow exemption for residents on long-term leases—but not for licensees or occupants under a court-approved settlement. By remaining in possession under the agreement and conducting a sale, Ms. Valentine should still qualify for the ordinance’s protections. 2. Ms. Valentine does not own a “mobile home.” It is true that Ms. Valentine’s unit is a park trailer, not a mobilehome under the technical definition in the Mobilehome Residency Law (MRL). However, the trailer is permanently installed, used as her daughter's primary residence in a mobile home park, and— crucially—was repeatedly represented by Harmony Communities as a mobil e home. Ms. Valentine made her investment and long-term housing decisions in reliance on those representations. Furthermore, the city ordinance does not make any attempt to carve out RVs and trailers from its rent protections. Deceptive Practices and Potential B&P § 17500 Violation These circumstances appear to mirror the deceptive practices alleged by the San Joaquin County DA, in conjunction with the SLO DA, in People v. Harmony Communities, LLC, Case No. STK-CV-UBT-2024-0007043. In that case, Harmony was accused of misrepresenting recreational vehicles and trailers as mobile homes, in violation of Business and Professions Code § 17500. The complaint led to a stipulated judgment barring Harmony from engaging in misleading sales and lease practices that obscure the legal distinction between mobile homes and RVs. Ms. Valentine’s experience suggests a similar pattern: Harmony leased a park trailer as a mobile home, collected rent and administered rules under that classification, and is now disclaiming the classification to avoid rent control protections. This misrepresentation has tangible harms—Ms. Valentine is struggling to find a buyer due to the steep rent hike, and she reports that other residents attempting to sell have faced similar increases that make on-site sales nearly impossible. Request for Review Given the potential implications for multiple households and the City’s ability to enforce its rent control laws, I respectfully request that your office consider opening an inquiry into Harmony Communities’ rent-setting practices and related misrepresentations at South Peak. I would be happy to speak further or provide supporting documents. I’ve also copied CRLA attorneys Mariah Thompson and Patsy Van Dyke who are monitoring this issue. Thank you for your time and consideration. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org Office: (805) 544-7994 1880 Santa Barbara Ave #240, San Luis Obipso, CA 93401 3 CRLA.org NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. 1 From:Symens, Sadie Sent:Thursday, May 22, 2025 5:22 PM To:Evan Harris Cc:Patsy Van Dyke; Mariah Thompson Subject:RE: Request for Inquiry Regarding Rent Stabilization and Deceptive Business Practices at South Peak Mobile Home Park Hello, Thank you for reaching out to our office. While we evaluate your inquiry and consider next steps, I have a couple initial questions:  You stated in your email, “The trailer has been her daughter’s primary residence since purchase and is permanently installed and connected to park utilities.” Has the trailer also been Ms. Valentine’s primary residence since then? If not, when did the trailer become Ms. Valentine’s primary residence?  It is my intention to contact South Peak Mobile Home Park to let them know we have received information that suggests they may be in violation of the Mobile Home Rent Stabilization Ordinance. I do not intend to initially name Ms. Valentine or her unit or otherwise provide details that would reveal her identity. However, my investigation may be limited if I cannot ask specific questions about South Peak’s treatment of this situation, given what your email has indicated about their reasons for the rent increase; does Ms. Valentine authorize disclosure of details of her tenancy to South Peak? Given Ms. Valentine’s vacate date, our office is treating this matter with due haste and diligence. Please reach out if you have any further information that may be helpful to our investigation. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 2 From: Evan Harris <eharris@crla.org> Sent: Monday, May 19, 2025 5:09 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Request for Inquiry Regarding Rent Stabilization and Deceptive Business Practices at South Peak Mobile Home Park Dear Ms. Symens, I hope this message finds you well. My name is Evan Harris, and I’m an attorney in CRLA's SLO office representing Linda Valentine, a resident of Space A28 at 145 South Street in the South Peak Mobile Home Park, managed by Harmony Communities. I was recently referred to you by Assistant District Attorney Ken Jorgensen after reaching out to his office about a substantial rent increase imposed on my client that I believe may violate Chapter 5.44, Mobile Home Park Rent Stabilization, of the City's Municipal Code. I understand that SLOMC § 5.44.070 allows tenants to file a rent increase complaint with the City Clerk. I’ve advised my client to pursue this option, and she is currently speaking with neighbors who have experienced similar increases. However, it remains unclear whether Harmony is applying these rent hikes in a legally consistent way that would support a coordinated complaint. What is clear is that Harmony’s tactics appear intended to sidestep the City’s rent control ordinance, raising serious concerns about enforcement and tenant protections. Given these circumstances, I believe the matter warrants prompt attention from your office. Background Ms. Valentine owns a 2018 Champion Redman Park Model RV—commonly referred to as a park trailer—located at Space A28. She purchased the unit in July 2023 from California MHP Investors 3, LLC, a company affiliated with Harmony Communities. The trailer has been her daughter’s primary residence since purchase and is permanently installed and connected to park utilities. Harmony consistently represented the unit to her as a mobile home—including in the lease, park rules, rent notices, and other materials. In November 2024, Harmony Communities filed an unlawful detainer action against Ms. Valentine, alleging violations of the park’s guest policy. The matter was resolved in March 2025 via a court-approved settlement. Under the terms of that agreement, Ms. Valentine must vacate the premises by June 30, 2025, but she is permitted to conduct an on-site sale of her unit through November 30, 2025. She is actively trying to sell the home and has received interest from multiple prospective buyers, but each time they learn of the extraordinarily high space rent, they back out. April 2024 Rent Increase and Legal Dispute On April 1, 2024, Harmony’s Senior Regional Manager informed Ms. Valentine that any buyer of her home would be charged $1,595/month in space rent—more than double the current rent of $767.91. I objected on the grounds that SLOMC § 5.44.060(C) limits rent increases to 10% when a mobile home is sold in place and the space is not vacated. In response, Harmony’s attorney, Judy Tsai, argued that the City's ordinance does not apply because: 1. Ms. Valentine is not a “tenant.” Ms. Tsai asserts that my client lost her tenant status when her lease terminated following the UD notice and settlement. While I don’t dispute the lease termination, I also don’t believe tenancy status determines the applicability of SLOMC § 5.44.060(C). In fact, that chapter contains a narrow exemption for residents on long-term leases—but not for licensees or occupants 3 under a court-approved settlement. By remaining in possession under the agreement and conducting a sale, Ms. Valentine should still qualify for the ordinance’s protections. 2. Ms. Valentine does not own a “mobile home.” It is true that Ms. Valentine’s unit is a park trailer, not a mobilehome under the technical definition in the Mobilehome Residency Law (MRL). However, the trailer is permanently installed, used as her daughter's primary residence in a mobile home park, and— crucially—was repeatedly represented by Harmony Communities as a mobil e home. Ms. Valentine made her investment and long-term housing decisions in reliance on those representations. Furthermore, the city ordinance does not make any attempt to carve out RVs and trailers from its rent protections. Deceptive Practices and Potential B&P § 17500 Violation These circumstances appear to mirror the deceptive practices alleged by the San Joaquin County DA, in conjunction with the SLO DA, in People v. Harmony Communities, LLC, Case No. STK-CV-UBT-2024-0007043. In that case, Harmony was accused of misrepresenting recreational vehicles and trailers as mobile homes, in violation of Business and Professions Code § 17500. The complaint led to a stipulated judgment barring Harmony from engaging in misleading sales and lease practices that obscure the legal distinction between mobile homes and RVs. Ms. Valentine’s experience suggests a similar pattern: Harmony leased a park trailer as a mobile home, collected rent and administered rules under that classification, and is now disclaiming the classification to avoid rent control protections. This misrepresentation has tangible harms—Ms. Valentine is struggling to find a buyer due to the steep rent hike, and she reports that other residents attempting to sell have faced similar increases that make on-site sales nearly impossible. Request for Review Given the potential implications for multiple households and the City’s ability to enforce its rent control laws, I respectfully request that your office consider opening an inquiry into Harmony Communities’ rent-setting practices and related misrepresentations at South Peak. I would be happy to speak further or provide supporting documents. I’ve also copied CRLA attorneys Mariah Thompson and Patsy Van Dyke who are monitoring this issue. Thank you for your time and consideration. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org Office: (805) 544-7994 1880 Santa Barbara Ave #240, San Luis Obipso, CA 93401 4 CRLA.org NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. 1 From:Evan Harris <eharris@crla.org> Sent:Friday, May 23, 2025 1:55 PM To:Symens, Sadie Cc:Patsy Van Dyke; Mariah Thompson Subject:Re: [EXTERNAL] RE: Request for Inquiry Regarding Rent Stabilization and Deceptive Business Practices at South Peak Mobile Home Park Attachments:Ms. Valentine's Certificate of Title.jpg; South Peak Park Rules.pdf; March 12 UD Stipulation Agreement.pdf; Western Manufactured Housing Communities Association Rent Increase Form.pdf; Ms. Valentine's Lease.pdf; Communications between South Peaks and CRLA concerning Rent Increase.pdf Hello Ms. Symens, Thank you for your message and for your careful attention to Ms. Valentine’s situation. To clarify, the trailer has never been and is not presently Ms. Linda Valentine’s primary residence. Since the date of purchase in July 2023, the trailer has served as the primary residence of her daughter, Vanessa Valentine. Both Linda and Vanessa Valentine are listed as homeowners on the lease agreement with South Peak Mobile Home Park. Additionally, Ms. Valentine gives full authorization to the City to disclose details of her tenancy as needed to facilitate your investigation. She understands that disclosure may be necessary to evaluate potential violations of the Mobile Home Rent Stabilization Ordinance and supports your efforts to look into this matter thoroughly. Attached are various tenancy documents that may be helpful in your investigation:  Ms. Valentine's Certificate of Title  Ms. Valentine's Lease  March 12, 2025 Unlawful Detainer Stipulation Agreement between South Peaks and Linda and Vanessa Valentine  Western Manufactured Housing Communities Association Rent Increase Form  South Peak Park Rules  Communications between South Peaks and CRLA concerning Rent Increase Please don’t hesitate to reach out if you need any further information. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org Office: (805) 544-7994 1880 Santa Barbara Ave #240, San Luis Obipso, CA 93401 2 CRLA.org NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Thursday, May 22, 2025 5:22 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: [EXTERNAL] RE: Request for Inquiry Regarding Rent Stabilization and Deceptive Business Practices at South Peak Mobile Home Park Hello, Thank you for reaching out to our office. While we evaluate your inquiry and consider next steps, I have a couple initial questions:  You stated in your email, “The trailer has been her daughter’s primary residence since purchase and is permanently installed and connected to park utilities.” Has the trailer also been Ms. Valentine’s primary residence since then? If not, when did the trailer become Ms. Valentine’s primary residence?  It is my intention to contact South Peak Mobile Home Park to let them know we have received information that suggests they may be in violation of the Mobile Home Rent Stabilization Ordinance. I do not intend to initially name Ms. Valentine or her unit or otherwise provide details that would reveal her identity. However, my investigation may be limited if I cannot ask specific questions about South Peak’s treatment of this situation, given what your email has indicated about their reasons for the rent increase; does Ms. Valentine authorize disclosure of details of her tenancy to South Peak? Given Ms. Valentine’s vacate date, our office is treating this matter with due haste and diligence. Please reach out if you have any further information that may be helpful to our investigation. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege 3 and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Monday, May 19, 2025 5:09 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Request for Inquiry Regarding Rent Stabilization and Deceptive Business Practices at South Peak Mobile Home Park Dear Ms. Symens, I hope this message finds you well. My name is Evan Harris, and I’m an attorney in CRLA's SLO office representing Linda Valentine, a resident of Space A28 at 145 South Street in the South Peak Mobile Home Park, managed by Harmony Communities. I was recently referred to you by Assistant District Attorney Ken Jorgensen after reaching out to his office about a substantial rent increase imposed on my client that I believe may violate Chapter 5.44, Mobile Home Park Rent Stabilization, of the City's Municipal Code. I understand that SLOMC § 5.44.070 allows tenants to file a rent increase complaint with the City Clerk. I’ve advised my client to pursue this option, and she is currently speaking with neighbors who have experienced similar increases. However, it remains unclear whether Harmony is applying these rent hikes in a legally consistent way that would support a coordinated complaint. What is clear is that Harmony’s tactics appear intended to sidestep the City’s rent control ordinance, raising serious concerns about enforcement and tenant protections. Given these circumstances, I believe the matter warrants prompt attention from your office. Background Ms. Valentine owns a 2018 Champion Redman Park Model RV—commonly referred to as a park trailer—located at Space A28. She purchased the unit in July 2023 from California MHP Investors 3, LLC, a company affiliated with Harmony Communities. The trailer has been her daughter’s primary residence since purchase and is permanently installed and connected to park utilities. Harmony consistently represented the unit to her as a mobile home—including in the lease, park rules, rent notices, and other materials. In November 2024, Harmony Communities filed an unlawful detainer action against Ms. Valentine, alleging violations of the park’s guest policy. The matter was resolved in March 2025 via a court-approved settlement. Under the terms of that agreement, Ms. Valentine must vacate the premises by June 30, 2025, but she is permitted to conduct an on-site sale of her unit through November 30, 2025. She is actively trying to sell the home and has received interest from multiple prospective buyers, but each time they learn of the extraordinarily high space rent, they back out. April 2024 Rent Increase and Legal Dispute On April 1, 2024, Harmony’s Senior Regional Manager informed Ms. Valentine that any buyer of her home would be charged $1,595/month in space rent—more than double the current rent of $767.91. I objected on the grounds that SLOMC § 5.44.060(C) limits rent increases to 10% when a mobile home is sold in place and the space is not vacated. 4 In response, Harmony’s attorney, Judy Tsai, argued that the City's ordinance does not apply because: 1. Ms. Valentine is not a “tenant.” Ms. Tsai asserts that my client lost her tenant status when her lease terminated following the UD notice and settlement. While I don’t dispute the lease termination, I also don’t believe tenancy status determines the applicability of SLOMC § 5.44.060(C). In fact, that chapter contains a narrow exemption for residents on long-term leases—but not for licensees or occupants under a court-approved settlement. By remaining in possession under the agreement and conducting a sale, Ms. Valentine should still qualify for the ordinance’s protections. 2. Ms. Valentine does not own a “mobile home.” It is true that Ms. Valentine’s unit is a park trailer, not a mobilehome under the technical definition in the Mobilehome Residency Law (MRL). However, the trailer is permanently installed, used as her daughter's primary residence in a mobile home park, and— crucially—was repeatedly represented by Harmony Communities as a mobil e home. Ms. Valentine made her investment and long-term housing decisions in reliance on those representations. Furthermore, the city ordinance does not make any attempt to carve out RVs and trailers from its rent protections. Deceptive Practices and Potential B&P § 17500 Violation These circumstances appear to mirror the deceptive practices alleged by the San Joaquin County DA, in conjunction with the SLO DA, in People v. Harmony Communities, LLC, Case No. STK-CV-UBT-2024-0007043. In that case, Harmony was accused of misrepresenting recreational vehicles and trailers as mobile homes, in violation of Business and Professions Code § 17500. The complaint led to a stipulated judgment barring Harmony from engaging in misleading sales and lease practices that obscure the legal distinction between mobile homes and RVs. Ms. Valentine’s experience suggests a similar pattern: Harmony leased a park trailer as a mobile home, collected rent and administered rules under that classification, and is now disclaiming the classification to avoid rent control protections. This misrepresentation has tangible harms—Ms. Valentine is struggling to find a buyer due to the steep rent hike, and she reports that other residents attempting to sell have faced similar increases that make on-site sales nearly impossible. Request for Review Given the potential implications for multiple households and the City’s ability to enforce its rent control laws, I respectfully request that your office consider opening an inquiry into Harmony Communities’ rent-setting practices and related misrepresentations at South Peak. I would be happy to speak further or provide supporting documents. I’ve also copied CRLA attorneys Mariah Thompson and Patsy Van Dyke who are monitoring this issue. Thank you for your time and consideration. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org Office: (805) 544-7994 1880 Santa Barbara Ave #240, San Luis Obipso, CA 93401 5 CRLA.org NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. Rural Roots, Justice for All 1880 Santa Barbara Avenue, Suite 240 • San Luis Obispo, CA 93401• Tel: 805-544-7994• Fax: 805-544-3904• crla.org Evan Harris California Rural Legal Assistance 1880 Santa Barbara Ave #240 San Luis Obispo, CA 93401 April 28, 2025 Judy Tsai Law Office of Judy Tsai 710 Lakeway Dr Ste 180 Sunnyvale, CA 94085-4048 Subject: Invalid Rent Increase – Space A28, 145 South Street, San Luis Obispo Dear Ms. Tsai, As you are aware, I represent Linda Valentine, the owner of the mobile home located at Space A28 in your client’s park at 145 South Street, San Luis Obispo, CA 93401. I am writing regarding the unlawful rent increase recently imposed by your client. You are already familiar with the relevant facts, as you represented Harmony Communities in its settlement with Ms. Valentine and were copied on the email correspondence between Ms. Valentine and your client’s property management team regarding the rent increase. Ms. Melissa Lawley, Senior Regional Manager for Harmony Communities, appears to misunderstand both the terms of the settlement agreement and the applicable local rent control ordinance. The agreement filed by your office on March 12 does not preserve or continue the prior lease—it replaces it. A valid 60-day notice terminates the tenancy upon expiration of that period. The agreement contains no lease terms and does not incorporate the prior lease by reference. Instead, it grants a temporary right to occupy and complete an on-site sale, with rent deducted from sale proceeds—not paid by the occupants as tenants, and explicitly replaces all prior agreements. Additionally, nothing in the agreement requires Ms. Valentine to assign her lease to a buyer. She is free to sell her mobile home to any buyer lawfully approved by the park, and the park may then enter into a new lease directly with that buyer. Accordingly, the long-term lease exemption under San Luis Obispo Municipal Code § 5.44.030(E) that Ms. Lawley referenced does not apply. The governing provision is instead § 5.44.060(C), which prohibits rent increases exceeding “ten percent of the then-existing space rent” when a mobile home is sold in place and the space is not vacated. The proposed rent Rural Roots, Justice for All 1880 Santa Barbara Avenue, Suite 240 • San Luis Obispo, CA 93401• Tel: 805-544-7994• Fax: 805-544-3904• crla.org increase from Ms. Vale ntine’s current $767.91 space rent to $1,595 constitutes a 108% increase and is therefore plainly unlawful. Please confirm receipt of this letter within seven (7) business days and advise whether Harmony Communities intends to comply with the terms of the settlement agreement and the local rent control ordinance. Sincerely, Evan Harris 1 From:Symens, Sadie Sent:Friday, May 30, 2025 3:36 PM To:judy@judytsai.com Cc:eharris@crla.org Subject:Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Attachments:Letter to South Peak Mobile Home Park 053025.pdf To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. May 30, 2025 Harmony Communities c/o South Peak Mobile Home Park 145 South Street San Luis Obispo, ca 93401 Judy Tsai Law Office of Judy Tsai 710 Lakeway Drive, Ste. 180 Sunnyvale, CA 94085 Re: Proposed South Peak Mobile Home Park Rent Increase To Judy Tsai and Harmony Communities: The City is in receipt of information suggesting that the management of South Peak Mobile Home Park may be operating out of compliance with the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance.”) Specifically, the City has received a report from Linda Valentine’s legal counsel that you have proposed a 108% increase in space rent for a mobile home upon sale in place, in violation of San Luis Obispo Municipal Code (“SLOMC”) § 5.44.060(C), as to Space A28. Ms. Valentine’s counsel reports that South Peak declines to recognize Ms. Valentine as a “tenant.” SLOMC § 5.44.020(D) defines “mobile home tenant” or “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” It is the City’s position that, under the Ordinance, Ms. Valentine is a person “entitled” to occupy the mobile home pursuant to her ownership thereof. The report also indicates that South Peak management is improperly excluding certain types of homes from the Ordinance. The Ordinance does not define “mobile home,” either by inclusion or exclusion. However, the Purpose and Intent statements are guiding. The City’s legislative body identified certain characteristics of mobile homes that warrant protection against unreasonable rent increases: “high cost and impracticability of moving mobile homes, the potential for damage resulting therefrom, the requirements relating to the installation of mobile homes, including permits, landscaping and site preparation, the lack of alternative homesites for mobile home residents, and the substantial investment of mobile home owners in such homes[.]” (SLOMC 5.44.010). Homes typically considered “mobile homes” and any other structure described by the above are subject to the protections of the Ordinance. Additionally, Section 798.3 of the Mobilehome Residency Law includes in the definition of a mobile home within a mobile home park, trailers and other recreational vehicles of all types defined in Section 18010 of the Health and Safety Code, other than motor homes, truck campers, and camping trailers, which are used for human habitation if the occupancy criteria of either paragraph (1) or (2), as follows, are met: (1) The trailer or other recreational vehicle occupies a mobilehome site in the park, on November 15, 1992, under a rental agreement with a term of one month or longer, and the trailer or other recreational vehicle occupied a mobilehome site in the park prior to January 1, 1991. (2) The trailer or other recreational vehicle occupies a mobilehome site in the park for nine or more continuous months commencing on or after November 15, 1992. (Ca. Civ. Code § 798.3.) “Mobilehome” does not include a trailer or other recreational vehicle located in a recreational vehicle park subject to the Recreational Vehicle Park Occupancy Law. It is the City’s understanding that Ms. Valentine’s trailer is used for human habitation and has occupied a mobile home site in South Peak Mobile Home Park for nine or more continuous months and therefore meets the definition of a mobile home. Finally, SLOMC §5.44.060(C) states that monthly space rent may, upon change of ownership affecting a mobile home, be increased by no more than ten percent of the space rent existing at the time of such change when the change of ownership does not result in vacation of the space. This limitation is intended to be absolute; in adopting Section 5.44.060(C), the City Council recognized that, prior to the limitation, “Tenants in mobile home parks desiring to sell their mobile homes may have difficulty finding buyers because, upon a change of ownership, the park owner is able to raise the rent without regard to the city’s mobile home rent stabilization ordinance.” (see Ordinance No. 1226 (1992) Series) and SLOMC §5.44.010(E).) It is the City’s position that this section governs the permissible rent increases for spaces upon change in ownership in place, including Space A28, notwithstanding the unlawful detainer filed against Ms. Valentine and subsequent stipulated judgment executed by the parties. Please consider this letter the City’s notice that management’s proposed increase in the space rent for space A28 at South Peak Mobile Home Park by 108% upon change in ownership would constitute a violation of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. Sincerely, Sadie Symens Deputy City Attorney 1 From:Evan Harris <eharris@crla.org> Sent:Friday, May 30, 2025 4:18 PM To:Symens, Sadie Subject:Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, Your letter looks great. Thank you for putting this together so quickly. Best, Evan Harris () | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the 2 designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Symens, Sadie Sent:Tuesday, June 3, 2025 4:03 PM To:Judy Tsai; Evan Harris Subject:RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Judy, Thank you for your response. The City is happy to discuss, at your convenience, its determination that Ms. Valentine’s home is subject to the Ordinance, based on the language of the MRL and evidence that the home has been treated as a mobile home by South Peak MHP Management since at least 2023. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> 2 Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org 3 slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Judy Tsai <judy@judytsai.com> Sent:Tuesday, June 3, 2025 3:56 PM To:Evan Harris Cc:Symens, Sadie Subject:RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> 2 Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Evan Harris <eharris@crla.org> Sent:Tuesday, June 3, 2025 3:44 PM To:judy@judytsai.com Cc:Symens, Sadie Subject:Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney 2 City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Evan Harris <eharris@crla.org> Sent:Tuesday, June 10, 2025 12:35 PM To:Symens, Sadie; Judy Tsai Subject:Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Judy, It has now been more than ten days since the City provided written notice that your client’s proposed rent increase violates the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. Please respond promptly with your client’s position. As you are aware, this ongoing delay is materially harming my client, who is under significant time pressure to sell her unit. Without clarity on the space rent, she cannot move forward with the sale. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 1880 Santa Barbara Ave, Suite 240, San Luis Obispo, CA. 93401 CRLA.org NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribu tion, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Tuesday, June 3, 2025 4:02 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Judy, Thank you for your response. The City is happy to discuss, at your convenience, its determination that Ms. Valentine’s home is subject to the Ordinance, based on the language of the MRL and evidence that the home has been treated as a mobile home by South Peak MHP Management since at least 2023. Sadie Symens pronouns she/her/hers Deputy City Attorney 2 City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. 3 Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Matt Davies <matt@harmonycom.com> Sent:Tuesday, June 10, 2025 9:14 AM To:Symens, Sadie Subject:RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, I am back in the country. I will review this week and get back to you on the recreational vehicle in question. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Judy Tsai <judy@judytsai.com> Sent: Friday, May 30, 2025 4:17 PM To: Matt Davies <matt@harmonycom.com>; Jason Dilday <jason@harmonycom.com> Subject: FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:36 PM To: Judy Tsai <judy@judytsai.com> Cc: eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications 2 The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Evan Harris <eharris@crla.org> Sent:Friday, June 13, 2025 4:36 PM To:Symens, Sadie Subject:Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Sadie, I'm becoming increasingly concerned that Judy will continue to delay providing a formal response to your letter. As she’s aware, this delay effectively preserves the status quo, allowing South Peak’s unlawful rent increase to remain in place and preventing my client from proceeding with the sale of her unit. Given the harm this is causing, it’s critical that South Peak’s delay tactics not be allowed to continue unchecked. Could you please let me know what the City’s next steps will be if Judy continues to stall, and how much longer the City intends to wait before intervening? Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 10, 2025 12:34 PM To: Symens, Sadie <ssymens@slocity.org>; Judy Tsai <judy@judytsai.com> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Judy, It has now been more than ten days since the City provided written notice that your client’s proposed rent increase violates the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. Please respond promptly with your client’s position. As you are aware, this ongoing delay is materially harming my client, who is under significant time pressure to sell her unit. Without clarity on the space rent, she cannot move forward with the sale. Best, Evan Harris (he/him) | Attorney 2 California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 1880 Santa Barbara Ave, Suite 240, San Luis Obispo, CA. 93401 CRLA.org NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribu tion, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Tuesday, June 3, 2025 4:02 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Judy, Thank you for your response. The City is happy to discuss, at your convenience, its determination that Ms. Valentine’s home is subject to the Ordinance, based on the language of the MRL and evidence that the home has been treated as a mobile home by South Peak MHP Management since at least 2023. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 3 From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. 4 Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Symens, Sadie Sent:Friday, June 13, 2025 5:05 PM To:Evan Harris Subject:RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, While I am certainly sympathetic to your client’s predicament, the City cannot preemptively cite the mobile home park under the rent stabilization ordinance for an unlawful rent increase it has not yet imposed. Our likely next step would be to notify Harmony Communities of the possible enforcement action(s) against the park if they proceed with an unlawful increase. I will follow up with Judy next week. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Friday, June 13, 2025 4:36 PM To: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Sadie, I'm becoming increasingly concerned that Judy will continue to delay providing a formal response to your letter. As she’s aware, this delay effectively preserves the status quo, allowing South Peak’s unlawful rent increase to remain in place and preventing my client from proceeding with the sale of her unit. 2 Given the harm this is causing, it’s critical that South Peak’s delay tactics not be allowed to continue unchecked. Could you please let me know what the City’s next steps will be if Judy continues to stall, and how much longer the City intends to wait before intervening? Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 10, 2025 12:34 PM To: Symens, Sadie <ssymens@slocity.org>; Judy Tsai <judy@judytsai.com> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Judy, It has now been more than ten days since the City provided written notice that your client’s proposed rent increase violates the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. Please respond promptly with your client’s position. As you are aware, this ongoing delay is materially harming my client, who is under significant time pressure to sell her unit. Without clarity on the space rent, she cannot move forward with the sale. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 1880 Santa Barbara Ave, Suite 240, San Luis Obispo, CA. 93401 CRLA.org NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribu tion, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. 3 From: Symens, Sadie <ssymens@slocity.org> Sent: Tuesday, June 3, 2025 4:02 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Judy, Thank you for your response. The City is happy to discuss, at your convenience, its determination that Ms. Valentine’s home is subject to the Ordinance, based on the language of the MRL and evidence that the home has been treated as a mobile home by South Peak MHP Management since at least 2023. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 4 Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications 5 The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Evan Harris <eharris@crla.org> Sent:Monday, June 16, 2025 9:09 AM To:Symens, Sadie Subject:Fw: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, Thank you for your response, and please do include me in your follow up with Judy. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, June 13, 2025 5:05 PM To: Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, While I am certainly sympathetic to your client’s predicament, the City cannot preemptively cite the mobile home park under the rent stabilization ordinance for an unlawful rent increase it has not yet imposed. Our likely next step would be to notify Harmony Communities of the possible enforcement action(s) against the park if they proceed with an unlawful increase. I will follow up with Judy next week. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications 2 The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Friday, June 13, 2025 4:36 PM To: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Sadie, I'm becoming increasingly concerned that Judy will continue to delay providing a formal response to your letter. As she’s aware, this delay effectively preserves the status quo, allowing South Peak’s unlawful rent increase to remain in place and preventing my client from proceeding with the sale of her unit. Given the harm this is causing, it’s critical that South Peak’s delay tactics not be allowed to continue unchecked. Could you please let me know what the City’s next steps will be if Judy continues to stall, and how much longer the City intends to wait before intervening? Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 10, 2025 12:34 PM To: Symens, Sadie <ssymens@slocity.org>; Judy Tsai <judy@judytsai.com> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Judy, It has now been more than ten days since the City provided written notice that your client’s proposed rent increase violates the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. 3 Please respond promptly with your client’s position. As you are aware, this ongoing delay is materially harming my client, who is under significant time pressure to sell her unit. Without clarity on the space rent, she cannot move forward with the sale. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 1880 Santa Barbara Ave, Suite 240, San Luis Obispo, CA. 93401 CRLA.org NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribu tion, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Tuesday, June 3, 2025 4:02 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Judy, Thank you for your response. The City is happy to discuss, at your convenience, its determination that Ms. Valentine’s home is subject to the Ordinance, based on the language of the MRL and evidence that the home has been treated as a mobile home by South Peak MHP Management since at least 2023. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent 4 error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> 5 Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From: Sent:Monday, June 16, 2025 2:05 PM To:Symens, Sadie Subject:rent increase double at south peak mobile park Hi Sadie, I received your information from a neighbor at South Peak Mobile Home Park. Are you the best contact in DA office to provide information? When I informed Harmony Communities that I would be selling and asked what the rent space would be to new owner they more than doubled it. My understanding is that the city will be undergoing an Administrative Remedy. I am very eager to get this going because my place is vacant and I will be responsible for paying rent space – yet when I told the 24 potential buyers what the new rent space would be, nobody is even remotely interested. The previous Manager of South Peak is Rita Castro and she would like to talk to you or whomever it may be as she quit because of all of the ethics and illegalities of HC. Her phone number is If I can help get this moving along, please reach out to me at Evan Harris is my attorney. Thanks, Linda Valentine Virus-free.www.avast.com 1 From:Symens, Sadie Sent:Monday, June 16, 2025 2:12 PM To:eharris@crla.org Subject:Email from Linda Valentine Attachments:rent increase double at south peak mobile park Hello Evan, I received the attached email from, purportedly, Linda Valentine. I am not sure the email is legitimate (see sender’s email address), but in any case, I do not intend to respond since you represent Linda Valentine. Please clarify with your client that I cannot speak with her directly, nor do I work for the DA. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From: Sent:Monday, June 16, 2025 2:05 PM To:Symens, Sadie Subject:rent increase double at south peak mobile park Hi Sadie, I received your information from a neighbor at South Peak Mobile Home Park. Are you the best contact in DA office to provide information? When I informed Harmony Communities that I would be selling and asked what the rent space would be to new owner they more than doubled it. My understanding is that the city will be undergoing an Administrative Remedy. I am very eager to get this going because my place is vacant and I will be responsible for paying rent space – yet when I told the 24 potential buyers what the new rent space would be, nobody is even remotely interested. The previous Manager of South Peak is Rita Castro and she would like to talk to you or whomever it may be as she quit because of all of the ethics and illegalities of HC. Her phone number is If I can help get this moving along, please reach out to me at Evan Harris is my attorney. Thanks, Linda Valentine Virus-free.www.avast.com 1 From:Evan Harris <eharris@crla.org> Sent:Monday, June 16, 2025 2:21 PM To:Symens, Sadie Subject:Re: [EXTERNAL] Email from Linda Valentine Hello Sadie, Thank you for bringing this to my attention. Yes, this email is from my client. I’ll follow up with her and make the appropriate clarifications. Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Monday, June 16, 2025 2:11 PM To: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Email from Linda Valentine Hello Evan, I received the attached email from, purportedly, Linda Valentine. I am not sure the email is legitimate (see sender’s email address), but in any case, I do not intend to respond since you represent Linda Valentine. Please clarify with your client that I cannot speak with her directly, nor do I work for the DA. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications 2 The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Evan Harris <eharris@crla.org> Sent:Wednesday, June 18, 2025 3:40 PM To:Symens, Sadie Subject:Automatic reply: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello, Thank you for your message. I will be out of the office and not checking email from June 18 through June 30. I will respond to your message as soon as possible upon my return. If your matter is urgent, please contact Sasha Aguilar at saguilar@crla.org. Best regards, Evan Harris Hola, Gracias por su mensaje. Estaré fuera de la oficina y no estaré revisando correos electrónicos del 18 de junio al 30 de junio. Responderé su mensaje tan pronto como me sea posible a mi regreso. Si se trata de un asunto urgente, por favor comuníquese con Sasha Aguilar al saguilar@crla.org. Atentamente, Evan Harris 1 From:Judy Tsai <judy@judytsai.com> Sent:Wednesday, June 18, 2025 3:51 PM To:Symens, Sadie; Evan Harris Subject:RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Attachments:RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Sadie, I believe Mr. Davies already reached out to you directly. I was copied on the email. From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 3:48 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello, Thank you for your reply. Can you please provide me with the contact information for your client or their counsel, if they are represented in this matter? Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Wednesday, June 18, 2025 3:43 PM To: Symens, Sadie <ssymens@slocity.org>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 2 Hi. I am not the attorney that will be handling this issue. I have forwarded your email to my client. From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 3 This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers 4 Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Matt Davies <matt@harmonycom.com> Sent:Tuesday, June 10, 2025 9:14 AM To:Symens, Sadie Subject:RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, I am back in the country. I will review this week and get back to you on the recreational vehicle in question. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Judy Tsai <judy@judytsai.com> Sent: Friday, May 30, 2025 4:17 PM To: Matt Davies <matt@harmonycom.com>; Jason Dilday <jason@harmonycom.com> Subject: FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:36 PM To: Judy Tsai <judy@judytsai.com> Cc: eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications 2 The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Symens, Sadie Sent:Wednesday, June 18, 2025 6:20 PM To:Matt Davies Cc:Jason Dilday; eharris@crla.org Subject:RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Attachments:Letter to South Peak Mobile Home Park 053025.pdf Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 2 Did you receive my prior email? You never responded. This is an RV as well. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 3 From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 4 This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers 5 Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. May 30, 2025 Harmony Communities c/o South Peak Mobile Home Park 145 South Street San Luis Obispo, ca 93401 Judy Tsai Law Office of Judy Tsai 710 Lakeway Drive, Ste. 180 Sunnyvale, CA 94085 Re: Proposed South Peak Mobile Home Park Rent Increase To Judy Tsai and Harmony Communities: The City is in receipt of information suggesting that the management of South Peak Mobile Home Park may be operating out of compliance with the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance.”) Specifically, the City has received a report from Linda Valentine’s legal counsel that you have proposed a 108% increase in space rent for a mobile home upon sale in place, in violation of San Luis Obispo Municipal Code (“SLOMC”) § 5.44.060(C), as to Space A28. Ms. Valentine’s counsel reports that South Peak declines to recognize Ms. Valentine as a “tenant.” SLOMC § 5.44.020(D) defines “mobile home tenant” or “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” It is the City’s position that, under the Ordinance, Ms. Valentine is a person “entitled” to occupy the mobile home pursuant to her ownership thereof. The report also indicates that South Peak management is improperly excluding certain types of homes from the Ordinance. The Ordinance does not define “mobile home,” either by inclusion or exclusion. However, the Purpose and Intent statements are guiding. The City’s legislative body identified certain characteristics of mobile homes that warrant protection against unreasonable rent increases: “high cost and impracticability of moving mobile homes, the potential for damage resulting therefrom, the requirements relating to the installation of mobile homes, including permits, landscaping and site preparation, the lack of alternative homesites for mobile home residents, and the substantial investment of mobile home owners in such homes[.]” (SLOMC 5.44.010). Homes typically considered “mobile homes” and any other structure described by the above are subject to the protections of the Ordinance. Additionally, Section 798.3 of the Mobilehome Residency Law includes in the definition of a mobile home within a mobile home park, trailers and other recreational vehicles of all types defined in Section 18010 of the Health and Safety Code, other than motor homes, truck campers, and camping trailers, which are used for human habitation if the occupancy criteria of either paragraph (1) or (2), as follows, are met: (1) The trailer or other recreational vehicle occupies a mobilehome site in the park, on November 15, 1992, under a rental agreement with a term of one month or longer, and the trailer or other recreational vehicle occupied a mobilehome site in the park prior to January 1, 1991. (2) The trailer or other recreational vehicle occupies a mobilehome site in the park for nine or more continuous months commencing on or after November 15, 1992. (Ca. Civ. Code § 798.3.) “Mobilehome” does not include a trailer or other recreational vehicle located in a recreational vehicle park subject to the Recreational Vehicle Park Occupancy Law. It is the City’s understanding that Ms. Valentine’s trailer is used for human habitation and has occupied a mobile home site in South Peak Mobile Home Park for nine or more continuous months and therefore meets the definition of a mobile home. Finally, SLOMC §5.44.060(C) states that monthly space rent may, upon change of ownership affecting a mobile home, be increased by no more than ten percent of the space rent existing at the time of such change when the change of ownership does not result in vacation of the space. This limitation is intended to be absolute; in adopting Section 5.44.060(C), the City Council recognized that, prior to the limitation, “Tenants in mobile home parks desiring to sell their mobile homes may have difficulty finding buyers because, upon a change of ownership, the park owner is able to raise the rent without regard to the city’s mobile home rent stabilization ordinance.” (see Ordinance No. 1226 (1992) Series) and SLOMC §5.44.010(E).) It is the City’s position that this section governs the permissible rent increases for spaces upon change in ownership in place, including Space A28, notwithstanding the unlawful detainer filed against Ms. Valentine and subsequent stipulated judgment executed by the parties. Please consider this letter the City’s notice that management’s proposed increase in the space rent for space A28 at South Peak Mobile Home Park by 108% upon change in ownership would constitute a violation of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. Sincerely, Sadie Symens Deputy City Attorney 1 From:Symens, Sadie Sent:Wednesday, June 18, 2025 3:48 PM To:Judy Tsai; Evan Harris Subject:RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello, Thank you for your reply. Can you please provide me with the contact information for your client or their counsel, if they are represented in this matter? Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Wednesday, June 18, 2025 3:43 PM To: Symens, Sadie <ssymens@slocity.org>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi. I am not the attorney that will be handling this issue. I have forwarded your email to my client. From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, 2 It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 3 Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org 4 Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Symens, Sadie Sent:Wednesday, June 18, 2025 3:39 PM To:Judy Tsai; Evan Harris Subject:RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> 2 Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. 3 Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Symens, Sadie Sent:Wednesday, June 18, 2025 6:05 PM To:Matt Davies Cc:melissa@harmonycom.com; eharris@crla.org Subject:Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance:High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, 2 It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 3 Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org 4 Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Evan Harris <eharris@crla.org> Sent:Wednesday, June 18, 2025 2:55 PM To:Symens, Sadie Subject:Re: [EXTERNAL] Email from Linda Valentine Attachments:Communications between South Peaks and CRLA concerning Rent Increase (1).pdf Hello Sadie, 1. The form was provided to my client by Melissa Lawley, Senior Regional Manager of Harmony Communities, via email on May 1 in response to my client’s inquiry about whether any forms need to be completed by a new owner to be accepted into South Peak MHP. My client reports that several prospective buyers have expressed serious interest in purchasing her unit at the current space rent of $767.91, but ultimately declined after learning the rent would increase to $1,595 for a new owner. One such couple is Sherry and Norm Enns (SherryeEnns@icloud.com), current residents of South Peak. They were hoping to move into my client’s larger unit but were shocked by the rent hike and declined to proceed. Notably, the Ennses are also trying to sell their own unit, which carries a current space rent of $730. However, Harmony Communities raised their space rent to $1,350 when they listed it for sale. They too have been unable to secure a buyer at the inflated price. 2. On May 23, I provided you with an email exchange between me and Judy Tsai, in which she maintains that my client’s RV is not subject to mobile home ordinance protections. I’ve attached that email thread here for your convenience. Beyond that statement, to my knowledge, the Park has not provided any documentation or other materials that would preserve this claim. 3. At this time, CRLA is not pursuing any claims against South Peak MHP or Harmony Communities. That said, I believe the Park's conduct is creeping and systematic and may ultimately justify a public claim of this nature by the City. Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 9:33 AM To: Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Email from Linda Valentine Hi Evan, A few follow-up questions, if you are able to answer them: 2 1. How is the attached being used by the Park? To whom has this been provided? Have any prospective buyers actually declined to pursue the home because of this notice (to your knowledge)? 2. The attached notice and the lease, among other documents, seem to assume that your client’s home is a mobile home. Has the Park provided your client with anything preserving their claim that the “RV” is not subject to mobile home ordinance protections? 3. Are you/CRLA pursuing a private action unfair competition law claim against the Park? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Monday, June 16, 2025 2:21 PM To: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Email from Linda Valentine Hello Sadie, Thank you for bringing this to my attention. Yes, this email is from my client. I’ll follow up with her and make the appropriate clarifications. Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. 3 From: Symens, Sadie <ssymens@slocity.org> Sent: Monday, June 16, 2025 2:11 PM To: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Email from Linda Valentine Hello Evan, I received the attached email from, purportedly, Linda Valentine. I am not sure the email is legitimate (see sender’s email address), but in any case, I do not intend to respond since you represent Linda Valentine. Please clarify with your client that I cannot speak with her directly, nor do I work for the DA. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. Rural Roots, Justice for All 1880 Santa Barbara Avenue, Suite 240 • San Luis Obispo, CA 93401• Tel: 805-544-7994• Fax: 805-544-3904• crla.org Evan Harris California Rural Legal Assistance 1880 Santa Barbara Ave #240 San Luis Obispo, CA 93401 April 28, 2025 Judy Tsai Law Office of Judy Tsai 710 Lakeway Dr Ste 180 Sunnyvale, CA 94085-4048 Subject: Invalid Rent Increase – Space A28, 145 South Street, San Luis Obispo Dear Ms. Tsai, As you are aware, I represent Linda Valentine, the owner of the mobile home located at Space A28 in your client’s park at 145 South Street, San Luis Obispo, CA 93401. I am writing regarding the unlawful rent increase recently imposed by your client. You are already familiar with the relevant facts, as you represented Harmony Communities in its settlement with Ms. Valentine and were copied on the email correspondence between Ms. Valentine and your client’s property management team regarding the rent increase. Ms. Melissa Lawley, Senior Regional Manager for Harmony Communities, appears to misunderstand both the terms of the settlement agreement and the applicable local rent control ordinance. The agreement filed by your office on March 12 does not preserve or continue the prior lease—it replaces it. A valid 60-day notice terminates the tenancy upon expiration of that period. The agreement contains no lease terms and does not incorporate the prior lease by reference. Instead, it grants a temporary right to occupy and complete an on-site sale, with rent deducted from sale proceeds—not paid by the occupants as tenants, and explicitly replaces all prior agreements. Additionally, nothing in the agreement requires Ms. Valentine to assign her lease to a buyer. She is free to sell her mobile home to any buyer lawfully approved by the park, and the park may then enter into a new lease directly with that buyer. Accordingly, the long-term lease exemption under San Luis Obispo Municipal Code § 5.44.030(E) that Ms. Lawley referenced does not apply. The governing provision is instead § 5.44.060(C), which prohibits rent increases exceeding “ten percent of the then-existing space rent” when a mobile home is sold in place and the space is not vacated. The proposed rent Rural Roots, Justice for All 1880 Santa Barbara Avenue, Suite 240 • San Luis Obispo, CA 93401• Tel: 805-544-7994• Fax: 805-544-3904• crla.org increase from Ms. Vale ntine’s current $767.91 space rent to $1,595 constitutes a 108% increase and is therefore plainly unlawful. Please confirm receipt of this letter within seven (7) business days and advise whether Harmony Communities intends to comply with the terms of the settlement agreement and the local rent control ordinance. Sincerely, Evan Harris 1 From:Symens, Sadie Sent:Wednesday, June 18, 2025 9:34 AM To:Evan Harris Subject:RE: [EXTERNAL] Email from Linda Valentine Attachments:Western Manufactured Housing Communities Association Rent Increase Form.pdf Hi Evan, A few follow-up questions, if you are able to answer them: 1. How is the attached being used by the Park? To whom has this been provided? Have any prospective buyers actually declined to pursue the home because of this notice (to your knowledge)? 2. The attached notice and the lease, among other documents, seem to assume that your client’s home is a mobile home. Has the Park provided your client with anything preserving their claim that the “RV” is not subject to mobile home ordinance protections? 3. Are you/CRLA pursuing a private action unfair competition law claim against the Park? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Monday, June 16, 2025 2:21 PM To: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Email from Linda Valentine Hello Sadie, 2 Thank you for bringing this to my attention. Yes, this email is from my client. I’ll follow up with her and make the appropriate clarifications. Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Monday, June 16, 2025 2:11 PM To: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Email from Linda Valentine Hello Evan, I received the attached email from, purportedly, Linda Valentine. I am not sure the email is legitimate (see sender’s email address), but in any case, I do not intend to respond since you represent Linda Valentine. Please clarify with your client that I cannot speak with her directly, nor do I work for the DA. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 1 From:Symens, Sadie Sent:Thursday, June 19, 2025 3:36 PM To:eharris@crla.org Cc:pvandyke@crla.org; mthompson@crla.org Subject:FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Attachments:Space A28.pdf Hello all, I received the below from Harmony Communities regarding Ms. Valentine’s space. Yesterday, I communicated the City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. Valentine’s residence is not subject to the Ordinance. Can you please provide a response to the statements I have highlighted below so that my office can evaluate next steps? Thank you very much. In addition, could you please clarify when Ms. Valentine’s tenancy was terminated? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Jason Dilday <jason@harmonycom.com> Sent: Thursday, June 19, 2025 3:25 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Matt Davies <matt@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Symens, 2 As Matt mentioned and explained more fully below, we disagree that the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance”) applies to Ms. Valentine’s RV at Space A28. The Ordinance’s protections apply to “mobile homes,” a term undefined in the text but clearly tied to structures with “high cost and impracticability of moving” and “requirements relating to installation” (SLOMC §5.44.010). Ms. Valentine’s RV, as a vehicle registered with the DMV and designed for mobility, does not meet these criteria . Unlike mobile homes, which are structures registered with HCD, RVs are built for easy relocation and lack the burdens of cost, damage, or site preparation that the Ordinance addresses. The Ordinance’s focus on these unique challenges does not extend to RVs. Even if the RV were considered a mobile home, Ms. Valentine does not qualify as a “tenant” under SLOMC §5.44.020(D), which defines a “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” The RV is required to remain vacant until sold, meaning Ms. Valentine is not currently “entitled to occupy” it, as the Ordinance requires for tenant status. The Ordinance does not incorporate Cal. Civ. Code §798.3(b), which extends certain Mobilehome Residency Law (MRL) protections to RVs meeting specific occupancy criteria. Enacted after the Ordinance’s last amendment in 1988 (Ord. 1117), §798.3(b) is irrelevant unless explicitly adopted, which the Ordinance does not do. The City cannot retroactively apply a modern state law definition to a 1988 ordinance without legislative action. Using the MRL’s 1988 definition undermines the City’s position: Mobilehome is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the Vehicle Code. Mobilehome includes a manufactured home, as defined in Section 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a recreational vehicle, as defined in Section 799.24 of this code and Section 18010 of the Health and Safety Code or a commercial coach as defined in Section 18001.8 of the Health and Safety Code. Moreover, under the MRL, an RV is not a mobilehome. While §798.3(b) may grant RV tenants certain protections after nine months of occupancy, it does not classify RVs as mobilehomes. Unlike actual mobilehomes, section 798.73 explicitly permits parks to require RV removal upon sale. In summary, the Ordinance’s protections do not extend to Ms. Valentine’s RV, which is neither a mobile home nor occupied by a qualifying tenant. We remain committed to complying with all applicable laws and invite further discussion if the City believes additional facts warrant a different conclusion. Attached is the 2018-2019 DMV registration card for the RV that we had in the file as well as Ms. Valentine’s purchase agreement. Thank you. Jason Dilday 949-891-1627 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:25 PM To: Sadie Symens <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: Re: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie 3 Yes we received it. We disagree for numerous reasons. Jason will respond to you tomorrow. I’ll also reforward you my email to the other tenant you were on so you have it. In my opinion this is the same scenario, however Jason will provide a much more robust response. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com On Jun 18, 2025, at 6:20 PM, Symens, Sadie <ssymens@slocity.org> wrote: Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, 4 you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Did you receive my prior email? You never responded. This is an RV as well. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> 5 Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- 6 client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. <image007.png> eharris@crla.org 7 <image008.png> (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. <Letter to South Peak Mobile Home Park 053025.pdf> 1 From:Evan Harris <eharris@crla.org> Sent:Wednesday, July 2, 2025 10:50 AM To:Symens, Sadie; Salem, Rami Cc:Patsy Van Dyke; Mariah Thompson Subject:Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Attachments:6.24.25.LindaValentine.City'sViolationNotice(2).pdf; 6.24.25.LindaValentine.City'sViolationNotice(1).pdf; 7.01.25.LindaValentine.ManagmentEmailDenyingRentChange.pdf Hello Sadie and Rami, Thank you for issuing the attached violation notice to South Peaks MHP. The notice directs South Peaks to present the “Information for Prospective Homeowners” form to the City of San Luis Obispo with the adjusted monthly rent increase of no more than ten percent. It also states that failure to correct the violation(s) will result in an Administrative Citation and fines under SLOMC Chapter 1.24, and that continued noncompliance may subject the park to additional civil or criminal enforcement. However, I did not see a specific deadline in the notice for when South Peaks must complete this corrective action. Can you clarify how much time the park has before fines or further enforcement steps will be taken? Unfortunately, park management does not appear willing to comply voluntarily. Yesterday, Melissa Lawley, Senior Regional Manager of Harmony Communities, told Ms. Valentine over email (attached) there was “nothing to correct” after Ms. Valentine requested that the space rent amount be revised and the new owner paperwork be resent. Please let me know when the City intends to escalate enforcement in line with the notice. Thank you again for your continued support on this matter. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Thursday, June 19, 2025 3:36 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 2 Hello all, I received the below from Harmony Communities regarding Ms. Valentine’s space. Yesterday, I communicated the City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. Valentine’s residence is not subject to the Ordinance. Can you please provide a response to the statements I have highlighted below so that my office can evaluate next steps? Thank you very much. In addition, could you please clarify when Ms. Valentine’s tenancy was terminated? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Jason Dilday <jason@harmonycom.com> Sent: Thursday, June 19, 2025 3:25 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Matt Davies <matt@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Symens, As Matt mentioned and explained more fully below, we disagree that the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance”) applies to Ms. Valentine’s RV at Space A28. The Ordinance’s protections apply to “mobile homes,” a term undefined in the text but clearly tied to structures with “high cost and impracticability of moving” and “requirements relating to installation” (SLOMC §5.44.010). Ms. Valentine’s RV, as a vehicle registered with the DMV and designed for mobility, does not meet these criteria . Unlike mobile homes, which are structures registered with HCD, RVs are built for easy relocation and lack the burdens of cost, damage, or site preparation that the Ordinance addresses. The Ordinance’s focus on these unique challenges does not extend to RVs. 3 Even if the RV were considered a mobile home, Ms. Valentine does not qualify as a “tenant” under SLOMC §5.44.020(D), which defines a “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” The RV is required to remain vacant until sold, meaning Ms. Valentine is not currently “entitled to occupy” it, as the Ordinance requires for tenant status. The Ordinance does not incorporate Cal. Civ. Code §798.3(b), which extends certain Mobilehome Residency Law (MRL) protections to RVs meeting specific occupancy criteria. Enacted after the Ordinance’s last amendment in 1988 (Ord. 1117), §798.3(b) is irrelevant unless explicitly adopted, which the Ordinance does not do. The City cannot retroactively apply a modern state law definition to a 1988 ordinance without legislative action. Using the MRL’s 1988 definition undermines the City’s position: Mobilehome is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the Vehicle Code. Mobilehome includes a manufactured home, as defined in Section 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a recreational vehicle, as defined in Section 799.24 of this code and Section 18010 of the Health and Safety Code or a commercial coach as defined in Section 18001.8 of the Health and Safety Code. Moreover, under the MRL, an RV is not a mobilehome. While §798.3(b) may grant RV tenants certain protections after nine months of occupancy, it does not classify RVs as mobilehomes. Unlike actual mobilehomes, section 798.73 explicitly permits parks to require RV removal upon sale. In summary, the Ordinance’s protections do not extend to Ms. Valentine’s RV, which is neither a mobile home nor occupied by a qualifying tenant. We remain committed to complying with all applicable laws and invite further discussion if the City believes additional facts warrant a different conclusion. Attached is the 2018-2019 DMV registration card for the RV that we had in the file as well as Ms. Valentine’s purchase agreement. Thank you. Jason Dilday 949-891-1627 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:25 PM To: Sadie Symens <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: Re: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie Yes we received it. We disagree for numerous reasons. Jason will respond to you tomorrow. I’ll also reforward you my email to the other tenant you were on so you have it. In my opinion this is the same scenario, however Jason will provide a much more robust response. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 4 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com On Jun 18, 2025, at 6:20 PM, Symens, Sadie <ssymens@slocity.org> wrote: Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 5 Did you receive my prior email? You never responded. This is an RV as well. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF 6 YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 7 From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. <image007.png> eharris@crla.org <image008.png> (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> 8 Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. <Letter to South Peak Mobile Home Park 053025.pdf> 1 From:Symens, Sadie Sent:Wednesday, July 2, 2025 10:57 AM To:Evan Harris; Salem, Rami Cc:Patsy Van Dyke; Mariah Thompson Subject:RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, You are correct that the NOV did not state a date for compliance; however, South Peak had 5 days to request a director’s review of the NOV prior to any administrative citations being issued. They have requested a director’s review, and that process is currently underway. There is no timeline set for a director’s review. I understand the time sensitivity of this issue, and staff are diligently pursuing this review. I will let you know of any further updates. Please let me know if CRLA has reconsidered pursuing private enforcement as well. Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 2, 2025 10:50 AM To: Symens, Sadie <ssymens@slocity.org>; Salem, Rami <RSalem@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie and Rami, 2 Thank you for issuing the attached violation notice to South Peaks MHP. The notice directs South Peaks to present the “Information for Prospective Homeowners” form to the City of San Luis Obispo with the adjusted monthly rent increase of no more than ten percent. It also states that failure to correct the violation(s) will result in an Administrative Citation and fines under SLOMC Chapter 1.24, and that continued noncompliance may subject the park to additional civil or criminal enforcement. However, I did not see a specific deadline in the notice for when South Peaks must complete this corrective action. Can you clarify how much time the park has before fines or further enforcement steps will be taken? Unfortunately, park management does not appear willing to comply voluntarily. Yesterday, Melissa Lawley, Senior Regional Manager of Harmony Communities, told Ms. Valentine over email (attached) there was “nothing to correct” after Ms. Valentine requested that the space rent amount be revised and the new owner paperwork be resent. Please let me know when the City intends to escalate enforcement in line with the notice. Thank you again for your continued support on this matter. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Thursday, June 19, 2025 3:36 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello all, I received the below from Harmony Communities regarding Ms. Valentine’s space. Yesterday, I communicated the City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. Valentine’s residence is not subject to the Ordinance. Can you please provide a response to the statements I have highlighted below so that my office can evaluate next steps? Thank you very much. In addition, could you please clarify when Ms. Valentine’s tenancy was terminated? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney 3 City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Jason Dilday <jason@harmonycom.com> Sent: Thursday, June 19, 2025 3:25 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Matt Davies <matt@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Symens, As Matt mentioned and explained more fully below, we disagree that the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance”) applies to Ms. Valentine’s RV at Space A28. The Ordinance’s protections apply to “mobile homes,” a term undefined in the text but clearly tied to structures with “high cost and impracticability of moving” and “requirements relating to installation” (SLOMC §5.44.010). Ms. Valentine’s RV, as a vehicle registered with the DMV and designed for mobility, does not meet these criteria . Unlike mobile homes, which are structures registered with HCD, RVs are built for easy relocation and lack the burdens of cost, damage, or site preparation that the Ordinance addresses. The Ordinance’s focus on these unique challenges does not extend to RVs. Even if the RV were considered a mobile home, Ms. Valentine does not qualify as a “tenant” under SLOMC §5.44.020(D), which defines a “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” The RV is required to remain vacant until sold, meaning Ms. Valentine is not currently “entitled to occupy” it, as the Ordinance requires for tenant status. The Ordinance does not incorporate Cal. Civ. Code §798.3(b), which extends certain Mobilehome Residency Law (MRL) protections to RVs meeting specific occupancy criteria. Enacted after the Ordinance’s last amendment in 1988 (Ord. 1117), §798.3(b) is irrelevant unless explicitly adopted, which the Ordinance does not do. The City cannot retroactively apply a modern state law definition to a 1988 ordinance without legislative action. Using the MRL’s 1988 definition undermines the City’s position: 4 Mobilehome is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the Vehicle Code. Mobilehome includes a manufactured home, as defined in Section 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a recreational vehicle, as defined in Section 799.24 of this code and Section 18010 of the Health and Safety Code or a commercial coach as defined in Section 18001.8 of the Health and Safety Code. Moreover, under the MRL, an RV is not a mobilehome. While §798.3(b) may grant RV tenants certain protections after nine months of occupancy, it does not classify RVs as mobilehomes. Unlike actual mobilehomes, section 798.73 explicitly permits parks to require RV removal upon sale. In summary, the Ordinance’s protections do not extend to Ms. Valentine’s RV, which is neither a mobile home nor occupied by a qualifying tenant. We remain committed to complying with all applicable laws and invite further discussion if the City believes additional facts warrant a different conclusion. Attached is the 2018-2019 DMV registration card for the RV that we had in the file as well as Ms. Valentine’s purchase agreement. Thank you. Jason Dilday 949-891-1627 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:25 PM To: Sadie Symens <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: Re: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie Yes we received it. We disagree for numerous reasons. Jason will respond to you tomorrow. I’ll also reforward you my email to the other tenant you were on so you have it. In my opinion this is the same scenario, however Jason will provide a much more robust response. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com On Jun 18, 2025, at 6:20 PM, Symens, Sadie <ssymens@slocity.org> wrote: Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will 5 also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Did you receive my prior email? You never responded. This is an RV as well. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com 6 From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, 7 It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. 8 From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. <image007.png> eharris@crla.org <image008.png> (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, 9 Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. <Letter to South Peak Mobile Home Park 053025.pdf> 1 From:Evan Harris <eharris@crla.org> Sent:Wednesday, July 16, 2025 5:08 PM To:Symens, Sadie Cc:Patsy Van Dyke; Mariah Thompson Subject:Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, Thank you for the clear update and timeline—it’s very helpful. Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, July 16, 2025 4:41 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, As Code Enforcement proceeds with administrative enforcement, I wanted to clarify with you the timelines for this process. Once an administrative citation is issued, the cited party has ten days to file an appeal. The appeal must be heard within 60 days, and we are currently scheduling those hearings in September for appeals filed now. If the appeal is overturned (and the citation is upheld), the cited party may seek judicial review by trial de novo (must be filed within 20 days of the appeal decision) or by writ (must be filed within 90 days of the appeal decision.) Either of those proceedings could take months or longer. All that to say, if Harmony Communities exhausts these available procedures, it seems unlikely that this administrative enforcement matter will be resolved by November 30 th. Please let me know if you have any questions about this. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney 2 City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 2, 2025 10:50 AM To: Symens, Sadie <ssymens@slocity.org>; Salem, Rami <RSalem@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie and Rami, Thank you for issuing the attached violation notice to South Peaks MHP. The notice directs South Peaks to present the “Information for Prospective Homeowners” form to the City of San Luis Obispo with the adjusted monthly rent increase of no more than ten percent. It also states that failure to correct the violation(s) will result in an Administrative Citation and fines under SLOMC Chapter 1.24, and that continued noncompliance may subject the park to additional civil or criminal enforcement. However, I did not see a specific deadline in the notice for when South Peaks must complete this corrective action. Can you clarify how much time the park has before fines or further enforcement steps will be taken? Unfortunately, park management does not appear willing to comply voluntarily. Yesterday, Melissa Lawley, Senior Regional Manager of Harmony Communities, told Ms. Valentine over email (attached) there was “nothing to correct” after Ms. Valentine requested that the space rent amount be revised and the new owner paperwork be resent. Please let me know when the City intends to escalate enforcement in line with the notice. Thank you again for your continued support on this matter. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org 3 (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Thursday, June 19, 2025 3:36 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello all, I received the below from Harmony Communities regarding Ms. Valentine’s space. Yesterday, I communicated the City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. Valentine’s residence is not subject to the Ordinance. Can you please provide a response to the statements I have highlighted below so that my office can evaluate next steps? Thank you very much. In addition, could you please clarify when Ms. Valentine’s tenancy was terminated? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Jason Dilday <jason@harmonycom.com> Sent: Thursday, June 19, 2025 3:25 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Matt Davies <matt@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 4 Ms. Symens, As Matt mentioned and explained more fully below, we disagree that the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance”) applies to Ms. Valentine’s RV at Space A28. The Ordinance’s protections apply to “mobile homes,” a term undefined in the text but clearly tied to structures with “high cost and impracticability of moving” and “requirements relating to installation” (SLOMC §5.44.010). Ms. Valentine’s RV, as a vehicle registered with the DMV and designed for mobility, does not meet these criteria . Unlike mobile homes, which are structures registered with HCD, RVs are built for easy relocation and lack the burdens of cost, damage, or site preparation that the Ordinance addresses. The Ordinance’s focus on these unique challenges does not extend to RVs. Even if the RV were considered a mobile home, Ms. Valentine does not qualify as a “tenant” under SLOMC §5.44.020(D), which defines a “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” The RV is required to remain vacant until sold, meaning Ms. Valentine is not currently “entitled to occupy” it, as the Ordinance requires for tenant status. The Ordinance does not incorporate Cal. Civ. Code §798.3(b), which extends certain Mobilehome Residency Law (MRL) protections to RVs meeting specific occupancy criteria. Enacted after the Ordinance’s last amendment in 1988 (Ord. 1117), §798.3(b) is irrelevant unless explicitly adopted, which the Ordinance does not do. The City cannot retroactively apply a modern state law definition to a 1988 ordinance without legislative action. Using the MRL’s 1988 definition undermines the City’s position: Mobilehome is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the Vehicle Code. Mobilehome includes a manufactured home, as defined in Section 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a recreational vehicle, as defined in Section 799.24 of this code and Section 18010 of the Health and Safety Code or a commercial coach as defined in Section 18001.8 of the Health and Safety Code. Moreover, under the MRL, an RV is not a mobilehome. While §798.3(b) may grant RV tenants certain protections after nine months of occupancy, it does not classify RVs as mobilehomes. Unlike actual mobilehomes, section 798.73 explicitly permits parks to require RV removal upon sale. In summary, the Ordinance’s protections do not extend to Ms. Valentine’s RV, which is neither a mobile home nor occupied by a qualifying tenant. We remain committed to complying with all applicable laws and invite further discussion if the City believes additional facts warrant a different conclusion. Attached is the 2018-2019 DMV registration card for the RV that we had in the file as well as Ms. Valentine’s purchase agreement. Thank you. Jason Dilday 949-891-1627 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:25 PM To: Sadie Symens <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: Re: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 5 Hello Sadie Yes we received it. We disagree for numerous reasons. Jason will respond to you tomorrow. I’ll also reforward you my email to the other tenant you were on so you have it. In my opinion this is the same scenario, however Jason will provide a much more robust response. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com On Jun 18, 2025, at 6:20 PM, Symens, Sadie <ssymens@slocity.org> wrote: Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file 6 copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Did you receive my prior email? You never responded. This is an RV as well. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> 7 <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications 8 The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney 9 California Rural Legal Assistance, Inc. <image007.png> eharris@crla.org <image008.png> (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. <Letter to South Peak Mobile Home Park 053025.pdf> 1 From:Symens, Sadie Sent:Wednesday, July 16, 2025 4:40 PM To:Evan Harris Cc:Patsy Van Dyke; Mariah Thompson Subject:RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, As Code Enforcement proceeds with administrative enforcement, I wanted to clarify with you the timelines for this process. Once an administrative citation is issued, the cited party has ten days to file an appeal. The appeal must be heard within 60 days, and we are currently scheduling those hearings in September for appeals filed now. If the appeal is overturned (and the citation is upheld), the cited party may seek judicial review by trial de novo (must be filed within 20 days of the appeal decision) or by writ (must be filed within 90 days of the appeal decision.) Either of those proceedings could take months or longer. All that to say, if Harmony Communities exhausts these available procedures, it seems unlikely that this administrative enforcement matter will be resolved by November 30 th. Please let me know if you have any questions about this. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 2, 2025 10:50 AM To: Symens, Sadie <ssymens@slocity.org>; Salem, Rami <RSalem@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 2 Hello Sadie and Rami, Thank you for issuing the attached violation notice to South Peaks MHP. The notice directs South Peaks to present the “Information for Prospective Homeowners” form to the City of San Luis Obispo with the adjusted monthly rent increase of no more than ten percent. It also states that failure to correct the violation(s) will result in an Administrative Citation and fines under SLOMC Chapter 1.24, and that continued noncompliance may subject the park to additional civil or criminal enforcement. However, I did not see a specific deadline in the notice for when South Peaks must complete this corrective action. Can you clarify how much time the park has before fines or further enforcement steps will be taken? Unfortunately, park management does not appear willing to comply voluntarily. Yesterday, Melissa Lawley, Senior Regional Manager of Harmony Communities, told Ms. Valentine over email (attached) there was “nothing to correct” after Ms. Valentine requested that the space rent amount be revised and the new owner paperwork be resent. Please let me know when the City intends to escalate enforcement in line with the notice. Thank you again for your continued support on this matter. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Thursday, June 19, 2025 3:36 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello all, I received the below from Harmony Communities regarding Ms. Valentine’s space. Yesterday, I communicated the City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. Valentine’s residence is not subject to the Ordinance. Can you please provide a response to the statements I have highlighted below so that my office can evaluate next steps? Thank you very much. In addition, could you please clarify when Ms. Valentine’s tenancy was terminated? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney 3 City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Jason Dilday <jason@harmonycom.com> Sent: Thursday, June 19, 2025 3:25 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Matt Davies <matt@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Symens, As Matt mentioned and explained more fully below, we disagree that the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance”) applies to Ms. Valentine’s RV at Space A28. The Ordinance’s protections apply to “mobile homes,” a term undefined in the text but clearly tied to structures with “high cost and impracticability of moving” and “requirements relating to installation” (SLOMC §5.44.010). Ms. Valentine’s RV, as a vehicle registered with the DMV and designed for mobility, does not meet these criteria . Unlike mobile homes, which are structures registered with HCD, RVs are built for easy relocation and lack the burdens of cost, damage, or site preparation that the Ordinance addresses. The Ordinance’s focus on these unique challenges does not extend to RVs. Even if the RV were considered a mobile home, Ms. Valentine does not qualify as a “tenant” under SLOMC §5.44.020(D), which defines a “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” The RV is required to remain vacant until sold, meaning Ms. Valentine is not currently “entitled to occupy” it, as the Ordinance requires for tenant status. The Ordinance does not incorporate Cal. Civ. Code §798.3(b), which extends certain Mobilehome Residency Law (MRL) protections to RVs meeting specific occupancy criteria. Enacted after the Ordinance’s last amendment in 1988 (Ord. 1117), §798.3(b) is irrelevant unless explicitly adopted, which the Ordinance does not do. The City cannot retroactively apply a modern state law definition to a 1988 ordinance without legislative action. Using the MRL’s 1988 definition undermines the City’s position: 4 Mobilehome is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the Vehicle Code. Mobilehome includes a manufactured home, as defined in Section 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a recreational vehicle, as defined in Section 799.24 of this code and Section 18010 of the Health and Safety Code or a commercial coach as defined in Section 18001.8 of the Health and Safety Code. Moreover, under the MRL, an RV is not a mobilehome. While §798.3(b) may grant RV tenants certain protections after nine months of occupancy, it does not classify RVs as mobilehomes. Unlike actual mobilehomes, section 798.73 explicitly permits parks to require RV removal upon sale. In summary, the Ordinance’s protections do not extend to Ms. Valentine’s RV, which is neither a mobile home nor occupied by a qualifying tenant. We remain committed to complying with all applicable laws and invite further discussion if the City believes additional facts warrant a different conclusion. Attached is the 2018-2019 DMV registration card for the RV that we had in the file as well as Ms. Valentine’s purchase agreement. Thank you. Jason Dilday 949-891-1627 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:25 PM To: Sadie Symens <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: Re: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie Yes we received it. We disagree for numerous reasons. Jason will respond to you tomorrow. I’ll also reforward you my email to the other tenant you were on so you have it. In my opinion this is the same scenario, however Jason will provide a much more robust response. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com On Jun 18, 2025, at 6:20 PM, Symens, Sadie <ssymens@slocity.org> wrote: Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will 5 also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Did you receive my prior email? You never responded. This is an RV as well. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com 6 From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, 7 It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. 8 From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. <image007.png> eharris@crla.org <image008.png> (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, 9 Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. <Letter to South Peak Mobile Home Park 053025.pdf> 1 From:Evan Harris <eharris@crla.org> Sent:Thursday, September 11, 2025 9:53 AM To:Symens, Sadie Subject:Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, I understand that the City issued Harmony Communities an administrative citation on July 23 for violating SLOMC § 5.44.060(C). Do you know if Harmony has appealed this citation, and if so, whether a hearing date has been set? Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 16, 2025 5:08 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, Thank you for the clear update and timeline—it’s very helpful. Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, July 16, 2025 4:41 PM 2 To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, As Code Enforcement proceeds with administrative enforcement, I wanted to clarify with you the timelines for this process. Once an administrative citation is issued, the cited party has ten days to file an appeal. The appeal must be heard within 60 days, and we are currently scheduling those hearings in September for appeals filed now. If the appeal is overturned (and the citation is upheld), the cited party may seek judicial review by trial de novo (must be filed within 20 days of the appeal decision) or by writ (must be filed within 90 days of the appeal decision.) Either of those proceedings could take months or longer. All that to say, if Harmony Communities exhausts these available procedures, it seems unlikely that this administrative enforcement matter will be resolved by November 30 th. Please let me know if you have any questions about this. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 2, 2025 10:50 AM To: Symens, Sadie <ssymens@slocity.org>; Salem, Rami <RSalem@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie and Rami, Thank you for issuing the attached violation notice to South Peaks MHP. 3 The notice directs South Peaks to present the “Information for Prospective Homeowners” form to the City of San Luis Obispo with the adjusted monthly rent increase of no more than ten percent. It also states that failure to correct the violation(s) will result in an Administrative Citation and fines under SLOMC Chapter 1.24, and that continued noncompliance may subject the park to additional civil or criminal enforcement. However, I did not see a specific deadline in the notice for when South Peaks must complete this corrective action. Can you clarify how much time the park has before fines or further enforcement steps will be taken? Unfortunately, park management does not appear willing to comply voluntarily. Yesterday, Melissa Lawley, Senior Regional Manager of Harmony Communities, told Ms. Valentine over email (attached) there was “nothing to correct” after Ms. Valentine requested that the space rent amount be revised and the new owner paperwork be resent. Please let me know when the City intends to escalate enforcement in line with the notice. Thank you again for your continued support on this matter. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Thursday, June 19, 2025 3:36 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello all, I received the below from Harmony Communities regarding Ms. Valentine’s space. Yesterday, I communicated the City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. Valentine’s residence is not subject to the Ordinance. Can you please provide a response to the statements I have highlighted below so that my office can evaluate next steps? Thank you very much. In addition, could you please clarify when Ms. Valentine’s tenancy was terminated? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office 4 E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Jason Dilday <jason@harmonycom.com> Sent: Thursday, June 19, 2025 3:25 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Matt Davies <matt@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Symens, As Matt mentioned and explained more fully below, we disagree that the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance”) applies to Ms. Valentine’s RV at Space A28. The Ordinance’s protections apply to “mobile homes,” a term undefined in the text but clearly tied to structures with “high cost and impracticability of moving” and “requirements relating to installation” (SLOMC §5.44.010). Ms. Valentine’s RV, as a vehicle registered with the DMV and designed for mobility, does not meet these criteria . Unlike mobile homes, which are structures registered with HCD, RVs are built for easy relocation and lack the burdens of cost, damage, or site preparation that the Ordinance addresses. The Ordinance’s focus on these unique challenges does not extend to RVs. Even if the RV were considered a mobile home, Ms. Valentine does not qualify as a “tenant” under SLOMC §5.44.020(D), which defines a “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” The RV is required to remain vacant until sold, meaning Ms. Valentine is not currently “entitled to occupy” it, as the Ordinance requires for tenant status. The Ordinance does not incorporate Cal. Civ. Code §798.3(b), which extends certain Mobilehome Residency Law (MRL) protections to RVs meeting specific occupancy criteria. Enacted after the Ordinance’s last amendment in 1988 (Ord. 1117), §798.3(b) is irrelevant unless explicitly adopted, which the Ordinance does not do. The City cannot retroactively apply a modern state law definition to a 1988 ordinance without legislative action. Using the MRL’s 1988 definition undermines the City’s position: Mobilehome is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the Vehicle Code. Mobilehome includes a manufactured home, as defined in Section 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a recreational vehicle, as defined in Section 799.24 of this code and Section 18010 of the Health 5 and Safety Code or a commercial coach as defined in Section 18001.8 of the Health and Safety Code. Moreover, under the MRL, an RV is not a mobilehome. While §798.3(b) may grant RV tenants certain protections after nine months of occupancy, it does not classify RVs as mobilehomes. Unlike actual mobilehomes, section 798.73 explicitly permits parks to require RV removal upon sale. In summary, the Ordinance’s protections do not extend to Ms. Valentine’s RV, which is neither a mobile home nor occupied by a qualifying tenant. We remain committed to complying with all applicable laws and invite further discussion if the City believes additional facts warrant a different conclusion. Attached is the 2018-2019 DMV registration card for the RV that we had in the file as well as Ms. Valentine’s purchase agreement. Thank you. Jason Dilday 949-891-1627 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:25 PM To: Sadie Symens <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: Re: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie Yes we received it. We disagree for numerous reasons. Jason will respond to you tomorrow. I’ll also reforward you my email to the other tenant you were on so you have it. In my opinion this is the same scenario, however Jason will provide a much more robust response. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com On Jun 18, 2025, at 6:20 PM, Symens, Sadie <ssymens@slocity.org> wrote: Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. 6 Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Did you receive my prior email? You never responded. This is an RV as well. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High 7 Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). 8 Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> 9 Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. <image007.png> eharris@crla.org <image008.png> (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office 10 E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. <Letter to South Peak Mobile Home Park 053025.pdf> 1 From:Holcomb, Kelly Sent:Friday, September 12, 2025 11:54 AM To:Evan Harris Cc:Zion, Sarah; Symens, Sadie Subject:RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Mr. Harris, As Sadie is out of the office this week, I’ll quickly let you know that the administrative citation you refer to was appealed and the hearing officer review has been scheduled to take place on or after September 29, 2025. Sarah from our office, who coordinates the appeals process, has been copied on this reply if you have any further questions. Kelly Holcomb Senior Legal Analyst E kholcomb@slocity.org T 805.781.7060 From: Evan Harris <eharris@crla.org> Sent: Thursday, September 11, 2025 9:53 AM To: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, I understand that the City issued Harmony Communities an administrative citation on July 23 for violating SLOMC § 5.44.060(C). Do you know if Harmony has appealed this citation, and if so, whether a hearing date has been set? Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 16, 2025 5:08 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance 2 Hello Sadie, Thank you for the clear update and timeline—it’s very helpful. Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, July 16, 2025 4:41 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, As Code Enforcement proceeds with administrative enforcement, I wanted to clarify with you the timelines for this process. Once an administrative citation is issued, the cited party has ten days to file an appeal. The appeal must be heard within 60 days, and we are currently scheduling those hearings in September for appeals filed now. If the appeal is overturned (and the citation is upheld), the cited party may seek judicial review by trial de novo (must be filed within 20 days of the appeal decision) or by writ (must be filed within 90 days of the appeal decision.) Either of those proceedings could take months or longer. All that to say, if Harmony Communities exhausts these available procedures, it seems unlikely that this administrative enforcement matter will be resolved by November 30 th. Please let me know if you have any questions about this. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with 3 publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 2, 2025 10:50 AM To: Symens, Sadie <ssymens@slocity.org>; Salem, Rami <RSalem@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie and Rami, Thank you for issuing the attached violation notice to South Peaks MHP. The notice directs South Peaks to present the “Information for Prospective Homeowners” form to the City of San Luis Obispo with the adjusted monthly rent increase of no more than ten percent. It also states that failure to correct the violation(s) will result in an Administrative Citation and fines under SLOMC Chapter 1.24, and that continued noncompliance may subject the park to additional civil or criminal enforcement. However, I did not see a specific deadline in the notice for when South Peaks must complete this corrective action. Can you clarify how much time the park has before fines or further enforcement steps will be taken? Unfortunately, park management does not appear willing to comply voluntarily. Yesterday, Melissa Lawley, Senior Regional Manager of Harmony Communities, told Ms. Valentine over email (attached) there was “nothing to correct” after Ms. Valentine requested that the space rent amount be revised and the new owner paperwork be resent. Please let me know when the City intends to escalate enforcement in line with the notice. Thank you again for your continued support on this matter. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Thursday, June 19, 2025 3:36 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello all, 4 I received the below from Harmony Communities regarding Ms. Valentine’s space. Yesterday, I communicated the City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. Valentine’s residence is not subject to the Ordinance. Can you please provide a response to the statements I have highlighted below so that my office can evaluate next steps? Thank you very much. In addition, could you please clarify when Ms. Valentine’s tenancy was terminated? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Jason Dilday <jason@harmonycom.com> Sent: Thursday, June 19, 2025 3:25 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Matt Davies <matt@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Symens, As Matt mentioned and explained more fully below, we disagree that the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance”) applies to Ms. Valentine’s RV at Space A28. The Ordinance’s protections apply to “mobile homes,” a term undefined in the text but clearly tied to structures with “high cost and impracticability of moving” and “requirements relating to installation” (SLOMC §5.44.010). Ms. Valentine’s RV, as a vehicle registered with the DMV and designed for mobility, does not meet these criteria . Unlike mobile homes, which are structures registered with HCD, RVs are built for easy relocation and lack the burdens of cost, damage, or site preparation that the Ordinance addresses. The Ordinance’s focus on these unique challenges does not extend to RVs. Even if the RV were considered a mobile home, Ms. Valentine does not qualify as a “tenant” under SLOMC §5.44.020(D), which defines a “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the 5 mobile home.” The RV is required to remain vacant until sold, meaning Ms. Valentine is not currently “entitled to occupy” it, as the Ordinance requires for tenant status. The Ordinance does not incorporate Cal. Civ. Code §798.3(b), which extends certain Mobilehome Residency Law (MRL) protections to RVs meeting specific occupancy criteria. Enacted after the Ordinance’s last amendment in 1988 (Ord. 1117), §798.3(b) is irrelevant unless explicitly adopted, which the Ordinance does not do. The City cannot retroactively apply a modern state law definition to a 1988 ordinance without legislative action. Using the MRL’s 1988 definition undermines the City’s position: Mobilehome is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the Vehicle Code. Mobilehome includes a manufactured home, as defined in Section 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a recreational vehicle, as defined in Section 799.24 of this code and Section 18010 of the Health and Safety Code or a commercial coach as defined in Section 18001.8 of the Health and Safety Code. Moreover, under the MRL, an RV is not a mobilehome. While §798.3(b) may grant RV tenants certain protections after nine months of occupancy, it does not classify RVs as mobilehomes. Unlike actual mobilehomes, section 798.73 explicitly permits parks to require RV removal upon sale. In summary, the Ordinance’s protections do not extend to Ms. Valentine’s RV, which is neither a mobile home nor occupied by a qualifying tenant. We remain committed to complying with all applicable laws and invite further discussion if the City believes additional facts warrant a different conclusion. Attached is the 2018-2019 DMV registration card for the RV that we had in the file as well as Ms. Valentine’s purchase agreement. Thank you. Jason Dilday 949-891-1627 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:25 PM To: Sadie Symens <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: Re: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie Yes we received it. We disagree for numerous reasons. Jason will respond to you tomorrow. I’ll also reforward you my email to the other tenant you were on so you have it. In my opinion this is the same scenario, however Jason will provide a much more robust response. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com 6 On Jun 18, 2025, at 6:20 PM, Symens, Sadie <ssymens@slocity.org> wrote: Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Did you receive my prior email? You never responded. This is an RV as well. 7 Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 8 From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM 9 To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. <image007.png> eharris@crla.org <image008.png> (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> 10 Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. <Letter to South Peak Mobile Home Park 053025.pdf> 1 From:Evan Harris <eharris@crla.org> Sent:Monday, September 15, 2025 11:08 AM To:Holcomb, Kelly Cc:Zion, Sarah; Symens, Sadie Subject:Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Ms. Holcomb, Thank you very much. Are these hearings open to the public? If so, how might I attend? Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Holcomb, Kelly <kholcomb@slocity.org> Sent: Friday, September 12, 2025 11:53 AM To: Evan Harris <eharris@crla.org> Cc: Zion, Sarah <SZion@slocity.org>; Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Mr. Harris, As Sadie is out of the office this week, I’ll quickly let you know that the administrative citation you refer to was appealed and the hearing officer review has been scheduled to take place on or after September 29, 2025. Sarah from our office, who coordinates the appeals process, has been copied on this reply if you have any further questions. Kelly Holcomb Senior Legal Analyst E kholcomb@slocity.org T 805.781.7060 From: Evan Harris <eharris@crla.org> Sent: Thursday, September 11, 2025 9:53 AM To: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance You don't often get email from kholcomb@slocity.org. Learn why this is important 2 Hello Sadie, I understand that the City issued Harmony Communities an administrative citation on July 23 for violating SLOMC § 5.44.060(C). Do you know if Harmony has appealed this citation, and if so, whether a hearing date has been set? Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 16, 2025 5:08 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, Thank you for the clear update and timeline—it’s very helpful. Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, July 16, 2025 4:41 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, As Code Enforcement proceeds with administrative enforcement, I wanted to clarify with you the timelines for this process. Once an administrative citation is issued, the cited party has ten days to file an appeal. The appeal must be heard within 60 days, and we are currently scheduling those hearings in September for appeals filed now. If the appeal is overturned (and the citation is upheld), the cited party may seek judicial review by trial de novo (must be filed within 20 days of the appeal decision) or by writ (must be filed within 90 days of the appeal decision.) Either of those 3 proceedings could take months or longer. All that to say, if Harmony Communities exhausts these available procedures, it seems unlikely that this administrative enforcement matter will be resolved by November 30 th. Please let me know if you have any questions about this. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 2, 2025 10:50 AM To: Symens, Sadie <ssymens@slocity.org>; Salem, Rami <RSalem@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie and Rami, Thank you for issuing the attached violation notice to South Peaks MHP. The notice directs South Peaks to present the “Information for Prospective Homeowners” form to the City of San Luis Obispo with the adjusted monthly rent increase of no more than ten percent. It also states that failure to correct the violation(s) will result in an Administrative Citation and fines under SLOMC Chapter 1.24, and that continued noncompliance may subject the park to additional civil or criminal enforcement. However, I did not see a specific deadline in the notice for when South Peaks must complete this corrective action. Can you clarify how much time the park has before fines or further enforcement steps will be taken? Unfortunately, park management does not appear willing to comply voluntarily. Yesterday, Melissa Lawley, Senior Regional Manager of Harmony Communities, told Ms. Valentine over email (attached) there was “nothing 4 to correct” after Ms. Valentine requested that the space rent amount be revised and the new owner paperwork be resent. Please let me know when the City intends to escalate enforcement in line with the notice. Thank you again for your continued support on this matter. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Thursday, June 19, 2025 3:36 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello all, I received the below from Harmony Communities regarding Ms. Valentine’s space. Yesterday, I communicated the City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. Valentine’s residence is not subject to the Ordinance. Can you please provide a response to the statements I have highlighted below so that my office can evaluate next steps? Thank you very much. In addition, could you please clarify when Ms. Valentine’s tenancy was terminated? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent 5 error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Jason Dilday <jason@harmonycom.com> Sent: Thursday, June 19, 2025 3:25 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Matt Davies <matt@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Symens, As Matt mentioned and explained more fully below, we disagree that the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance”) applies to Ms. Valentine’s RV at Space A28. The Ordinance’s protections apply to “mobile homes,” a term undefined in the text but clearly tied to structures with “high cost and impracticability of moving” and “requirements relating to installation” (SLOMC §5.44.010). Ms. Valentine’s RV, as a vehicle registered with the DMV and designed for mobility, does not meet these criteria . Unlike mobile homes, which are structures registered with HCD, RVs are built for easy relocation and lack the burdens of cost, damage, or site preparation that the Ordinance addresses. The Ordinance’s focus on these unique challenges does not extend to RVs. Even if the RV were considered a mobile home, Ms. Valentine does not qualify as a “tenant” under SLOMC §5.44.020(D), which defines a “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” The RV is required to remain vacant until sold, meaning Ms. Valentine is not currently “entitled to occupy” it, as the Ordinance requires for tenant status. The Ordinance does not incorporate Cal. Civ. Code §798.3(b), which extends certain Mobilehome Residency Law (MRL) protections to RVs meeting specific occupancy criteria. Enacted after the Ordinance’s last amendment in 1988 (Ord. 1117), §798.3(b) is irrelevant unless explicitly adopted, which the Ordinance does not do. The City cannot retroactively apply a modern state law definition to a 1988 ordinance without legislative action. Using the MRL’s 1988 definition undermines the City’s position: Mobilehome is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the Vehicle Code. Mobilehome includes a manufactured home, as defined in Section 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a recreational vehicle, as defined in Section 799.24 of this code and Section 18010 of the Health and Safety Code or a commercial coach as defined in Section 18001.8 of the Health and Safety Code. Moreover, under the MRL, an RV is not a mobilehome. While §798.3(b) may grant RV tenants certain protections after nine months of occupancy, it does not classify RVs as mobilehomes. Unlike actual mobilehomes, section 798.73 explicitly permits parks to require RV removal upon sale. In summary, the Ordinance’s protections do not extend to Ms. Valentine’s RV, which is neither a mobile home nor occupied by a qualifying tenant. We remain committed to complying with all applicable laws and invite further discussion if the City believes additional facts warrant a different conclusion. Attached is the 2018-2019 DMV registration card for the RV that we had in the file as well as Ms. Valentine’s purchase agreement. 6 Thank you. Jason Dilday 949-891-1627 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:25 PM To: Sadie Symens <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: Re: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie Yes we received it. We disagree for numerous reasons. Jason will respond to you tomorrow. I’ll also reforward you my email to the other tenant you were on so you have it. In my opinion this is the same scenario, however Jason will provide a much more robust response. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com On Jun 18, 2025, at 6:20 PM, Symens, Sadie <ssymens@slocity.org> wrote: Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org 7 <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Did you receive my prior email? You never responded. This is an RV as well. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. 8 Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> 9 City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). 10 To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. <image007.png> eharris@crla.org <image008.png> (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file 11 copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. <Letter to South Peak Mobile Home Park 053025.pdf> 1 From:Evan Harris <eharris@crla.org> Sent:Monday, September 15, 2025 11:15 AM To:Symens, Sadie; Holcomb, Kelly Cc:Zion, Sarah Subject:Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, Understood, thank you very much. Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Monday, September 15, 2025 11:11 AM To: Evan Harris <eharris@crla.org>; Holcomb, Kelly <kholcomb@slocity.org> Cc: Zion, Sarah <SZion@slocity.org> Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, Generally, yes, administrative appeal hearings are open to the public, but South Peak did not request a hearing so the decision will be made “on paper.” Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with 2 publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Monday, September 15, 2025 11:08 AM To: Holcomb, Kelly <kholcomb@slocity.org> Cc: Zion, Sarah <SZion@slocity.org>; Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Ms. Holcomb, Thank you very much. Are these hearings open to the public? If so, how might I attend? Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Holcomb, Kelly <kholcomb@slocity.org> Sent: Friday, September 12, 2025 11:53 AM To: Evan Harris <eharris@crla.org> Cc: Zion, Sarah <SZion@slocity.org>; Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Mr. Harris, As Sadie is out of the office this week, I’ll quickly let you know that the administrative citation you refer to was appealed and the hearing officer review has been scheduled to take place on or after September 29, 2025. Sarah from our office, who coordinates the appeals process, has been copied on this reply if you have any further questions. Kelly Holcomb Senior Legal Analyst E kholcomb@slocity.org T 805.781.7060 From: Evan Harris <eharris@crla.org> Sent: Thursday, September 11, 2025 9:53 AM You don't often get email from kholcomb@slocity.org. Learn why this is important 3 To: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, I understand that the City issued Harmony Communities an administrative citation on July 23 for violating SLOMC § 5.44.060(C). Do you know if Harmony has appealed this citation, and if so, whether a hearing date has been set? Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 16, 2025 5:08 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, Thank you for the clear update and timeline—it’s very helpful. Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, July 16, 2025 4:41 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, As Code Enforcement proceeds with administrative enforcement, I wanted to clarify with you the timelines for this process. Once an administrative citation is issued, the cited party has ten days to file an appeal. The appeal must be 4 heard within 60 days, and we are currently scheduling those hearings in September for appeals filed now. If the appeal is overturned (and the citation is upheld), the cited party may seek judicial review by trial de novo (must be filed within 20 days of the appeal decision) or by writ (must be filed within 90 days of the appeal decision.) Either of those proceedings could take months or longer. All that to say, if Harmony Communities exhausts these available procedures, it seems unlikely that this administrative enforcement matter will be resolved by November 30 th. Please let me know if you have any questions about this. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 2, 2025 10:50 AM To: Symens, Sadie <ssymens@slocity.org>; Salem, Rami <RSalem@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie and Rami, Thank you for issuing the attached violation notice to South Peaks MHP. The notice directs South Peaks to present the “Information for Prospective Homeowners” form to the City of San Luis Obispo with the adjusted monthly rent increase of no more than ten percent. It also states that failure to correct the violation(s) will result in an Administrative Citation and fines under SLOMC Chapter 1.24, and that continued noncompliance may subject the park to additional civil or criminal enforcement. However, I did not see a specific deadline in the notice for when South Peaks must complete this corrective action. Can you clarify how much time the park has before fines or further enforcement steps will be taken? 5 Unfortunately, park management does not appear willing to comply voluntarily. Yesterday, Melissa Lawley, Senior Regional Manager of Harmony Communities, told Ms. Valentine over email (attached) there was “nothing to correct” after Ms. Valentine requested that the space rent amount be revised and the new owner paperwork be resent. Please let me know when the City intends to escalate enforcement in line with the notice. Thank you again for your continued support on this matter. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Thursday, June 19, 2025 3:36 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello all, I received the below from Harmony Communities regarding Ms. Valentine’s space. Yesterday, I communicated the City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. Valentine’s residence is not subject to the Ordinance. Can you please provide a response to the statements I have highlighted below so that my office can evaluate next steps? Thank you very much. In addition, could you please clarify when Ms. Valentine’s tenancy was terminated? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with 6 publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Jason Dilday <jason@harmonycom.com> Sent: Thursday, June 19, 2025 3:25 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Matt Davies <matt@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Symens, As Matt mentioned and explained more fully below, we disagree that the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance”) applies to Ms. Valentine’s RV at Space A28. The Ordinance’s protections apply to “mobile homes,” a term undefined in the text but clearly tied to structures with “high cost and impracticability of moving” and “requirements relating to installation” (SLOMC §5.44.010). Ms. Valentine’s RV, as a vehicle registered with the DMV and designed for mobility, does not meet these criteria . Unlike mobile homes, which are structures registered with HCD, RVs are built for easy relocation and lack the burdens of cost, damage, or site preparation that the Ordinance addresses. The Ordinance’s focus on these unique challenges does not extend to RVs. Even if the RV were considered a mobile home, Ms. Valentine does not qualify as a “tenant” under SLOMC §5.44.020(D), which defines a “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” The RV is required to remain vacant until sold, meaning Ms. Valentine is not currently “entitled to occupy” it, as the Ordinance requires for tenant status. The Ordinance does not incorporate Cal. Civ. Code §798.3(b), which extends certain Mobilehome Residency Law (MRL) protections to RVs meeting specific occupancy criteria. Enacted after the Ordinance’s last amendment in 1988 (Ord. 1117), §798.3(b) is irrelevant unless explicitly adopted, which the Ordinance does not do. The City cannot retroactively apply a modern state law definition to a 1988 ordinance without legislative action. Using the MRL’s 1988 definition undermines the City’s position: Mobilehome is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the Vehicle Code. Mobilehome includes a manufactured home, as defined in Section 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a recreational vehicle, as defined in Section 799.24 of this code and Section 18010 of the Health and Safety Code or a commercial coach as defined in Section 18001.8 of the Health and Safety Code. Moreover, under the MRL, an RV is not a mobilehome. While §798.3(b) may grant RV tenants certain protections after nine months of occupancy, it does not classify RVs as mobilehomes. Unlike actual mobilehomes, section 798.73 explicitly permits parks to require RV removal upon sale. In summary, the Ordinance’s protections do not extend to Ms. Valentine’s RV, which is neither a mobile home nor occupied by a qualifying tenant. We remain committed to complying with all applicable laws and invite 7 further discussion if the City believes additional facts warrant a different conclusion. Attached is the 2018-2019 DMV registration card for the RV that we had in the file as well as Ms. Valentine’s purchase agreement. Thank you. Jason Dilday 949-891-1627 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:25 PM To: Sadie Symens <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: Re: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie Yes we received it. We disagree for numerous reasons. Jason will respond to you tomorrow. I’ll also reforward you my email to the other tenant you were on so you have it. In my opinion this is the same scenario, however Jason will provide a much more robust response. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com On Jun 18, 2025, at 6:20 PM, Symens, Sadie <ssymens@slocity.org> wrote: Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office 8 E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Did you receive my prior email? You never responded. This is an RV as well. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. 9 Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> 10 City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). 11 To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. <image007.png> eharris@crla.org <image008.png> (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file 12 copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. <Letter to South Peak Mobile Home Park 053025.pdf> 1 From:Symens, Sadie Sent:Monday, September 15, 2025 11:11 AM To:Evan Harris; Holcomb, Kelly Cc:Zion, Sarah Subject:RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, Generally, yes, administrative appeal hearings are open to the public, but South Peak did not request a hearing so the decision will be made “on paper.” Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Monday, September 15, 2025 11:08 AM To: Holcomb, Kelly <kholcomb@slocity.org> Cc: Zion, Sarah <SZion@slocity.org>; Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Ms. Holcomb, Thank you very much. Are these hearings open to the public? If so, how might I attend? Best, Evan Harris he/him | Attorney 2 California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Holcomb, Kelly <kholcomb@slocity.org> Sent: Friday, September 12, 2025 11:53 AM To: Evan Harris <eharris@crla.org> Cc: Zion, Sarah <SZion@slocity.org>; Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Mr. Harris, As Sadie is out of the office this week, I’ll quickly let you know that the administrative citation you refer to was appealed and the hearing officer review has been scheduled to take place on or after September 29, 2025. Sarah from our office, who coordinates the appeals process, has been copied on this reply if you have any further questions. Kelly Holcomb Senior Legal Analyst E kholcomb@slocity.org T 805.781.7060 From: Evan Harris <eharris@crla.org> Sent: Thursday, September 11, 2025 9:53 AM To: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, I understand that the City issued Harmony Communities an administrative citation on July 23 for violating SLOMC § 5.44.060(C). Do you know if Harmony has appealed this citation, and if so, whether a hearing date has been set? Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. You don't often get email from kholcomb@slocity.org. Learn why this is important 3 From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 16, 2025 5:08 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie, Thank you for the clear update and timeline—it’s very helpful. Best, Evan Harris he/him | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, July 16, 2025 4:41 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Evan, As Code Enforcement proceeds with administrative enforcement, I wanted to clarify with you the timelines for this process. Once an administrative citation is issued, the cited party has ten days to file an appeal. The appeal must be heard within 60 days, and we are currently scheduling those hearings in September for appeals filed now. If the appeal is overturned (and the citation is upheld), the cited party may seek judicial review by trial de novo (must be filed within 20 days of the appeal decision) or by writ (must be filed within 90 days of the appeal decision.) Either of those proceedings could take months or longer. All that to say, if Harmony Communities exhausts these available procedures, it seems unlikely that this administrative enforcement matter will be resolved by November 30 th. Please let me know if you have any questions about this. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org 4 Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Evan Harris <eharris@crla.org> Sent: Wednesday, July 2, 2025 10:50 AM To: Symens, Sadie <ssymens@slocity.org>; Salem, Rami <RSalem@slocity.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: Re: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie and Rami, Thank you for issuing the attached violation notice to South Peaks MHP. The notice directs South Peaks to present the “Information for Prospective Homeowners” form to the City of San Luis Obispo with the adjusted monthly rent increase of no more than ten percent. It also states that failure to correct the violation(s) will result in an Administrative Citation and fines under SLOMC Chapter 1.24, and that continued noncompliance may subject the park to additional civil or criminal enforcement. However, I did not see a specific deadline in the notice for when South Peaks must complete this corrective action. Can you clarify how much time the park has before fines or further enforcement steps will be taken? Unfortunately, park management does not appear willing to comply voluntarily. Yesterday, Melissa Lawley, Senior Regional Manager of Harmony Communities, told Ms. Valentine over email (attached) there was “nothing to correct” after Ms. Valentine requested that the space rent amount be revised and the new owner paperwork be resent. Please let me know when the City intends to escalate enforcement in line with the notice. Thank you again for your continued support on this matter. Best, Evan Harris (he/him) | Attorney California Rural Legal Assistance, Inc. eharris@crla.org (805) 544-7994 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. 5 From: Symens, Sadie <ssymens@slocity.org> Sent: Thursday, June 19, 2025 3:36 PM To: Evan Harris <eharris@crla.org> Cc: Patsy Van Dyke <pvandyke@crla.org>; Mariah Thompson <mthompson@crla.org> Subject: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello all, I received the below from Harmony Communities regarding Ms. Valentine’s space. Yesterday, I communicated the City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. Valentine’s residence is not subject to the Ordinance. Can you please provide a response to the statements I have highlighted below so that my office can evaluate next steps? Thank you very much. In addition, could you please clarify when Ms. Valentine’s tenancy was terminated? Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney City Attorney's Office E ssymens@slocity.org slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Jason Dilday <jason@harmonycom.com> Sent: Thursday, June 19, 2025 3:25 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Matt Davies <matt@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Symens, As Matt mentioned and explained more fully below, we disagree that the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance (the “Ordinance”) applies to Ms. Valentine’s RV at Space A28. The Ordinance’s protections apply to “mobile homes,” a term undefined in the text but clearly tied to structures with “high cost and impracticability of moving” and “requirements relating to installation” (SLOMC §5.44.010). 6 Ms. Valentine’s RV, as a vehicle registered with the DMV and designed for mobility, does not meet these criteria . Unlike mobile homes, which are structures registered with HCD, RVs are built for easy relocation and lack the burdens of cost, damage, or site preparation that the Ordinance addresses. The Ordinance’s focus on these unique challenges does not extend to RVs. Even if the RV were considered a mobile home, Ms. Valentine does not qualify as a “tenant” under SLOMC §5.44.020(D), which defines a “tenant” as “any person entitled to occupy a mobile home within a mobile home park pursuant to ownership of the mobile home or under a rental or lease agreement with the owner of the mobile home.” The RV is required to remain vacant until sold, meaning Ms. Valentine is not currently “entitled to occupy” it, as the Ordinance requires for tenant status. The Ordinance does not incorporate Cal. Civ. Code §798.3(b), which extends certain Mobilehome Residency Law (MRL) protections to RVs meeting specific occupancy criteria. Enacted after the Ordinance’s last amendment in 1988 (Ord. 1117), §798.3(b) is irrelevant unless explicitly adopted, which the Ordinance does not do. The City cannot retroactively apply a modern state law definition to a 1988 ordinance without legislative action. Using the MRL’s 1988 definition undermines the City’s position: Mobilehome is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the Vehicle Code. Mobilehome includes a manufactured home, as defined in Section 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a recreational vehicle, as defined in Section 799.24 of this code and Section 18010 of the Health and Safety Code or a commercial coach as defined in Section 18001.8 of the Health and Safety Code. Moreover, under the MRL, an RV is not a mobilehome. While §798.3(b) may grant RV tenants certain protections after nine months of occupancy, it does not classify RVs as mobilehomes. Unlike actual mobilehomes, section 798.73 explicitly permits parks to require RV removal upon sale. In summary, the Ordinance’s protections do not extend to Ms. Valentine’s RV, which is neither a mobile home nor occupied by a qualifying tenant. We remain committed to complying with all applicable laws and invite further discussion if the City believes additional facts warrant a different conclusion. Attached is the 2018-2019 DMV registration card for the RV that we had in the file as well as Ms. Valentine’s purchase agreement. Thank you. Jason Dilday 949-891-1627 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:25 PM To: Sadie Symens <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: Re: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hello Sadie Yes we received it. We disagree for numerous reasons. Jason will respond to you tomorrow. I’ll also reforward you my email to the other tenant you were on so you have it. In my opinion this is the same scenario, however Jason will provide a much more robust response. 7 Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com On Jun 18, 2025, at 6:20 PM, Symens, Sadie <ssymens@slocity.org> wrote: Hello Mr. Davies, The last I received from you was an email on June 10th saying you would get back to me, but I do not believe you have done so until today. I apologize if I missed an email. Does South Peak have a response to the arguments I set forth in the letter from May 30th? I have attached it again here. I will also note that South Peak has referred to the mobile home as such in at least two documents, including the lease agreement and the Information for Prospective Homeowners dated May 1, 2025. Absent information from South Peak that this structure is not subject to the Mobile Home Park Rent Stabilization Ordinance (beyond the stated assertion that the structure is a recreational vehicle, which, for the reasons set forth in my letter, is not determinative), the City intends to pursue enforcement as stated below. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. 8 From: Matt Davies <matt@harmonycom.com> Sent: Wednesday, June 18, 2025 6:11 PM To: Symens, Sadie <ssymens@slocity.org> Cc: Jason Dilday <jason@harmonycom.com> Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Did you receive my prior email? You never responded. This is an RV as well. Regards, Matt Davies Harmony Communities 6653 Embarcadero Dr. Ste. C Stockton, CA 95219 Cell: (209) 601-4538 Main: (209) 932-8747 Matt@HarmonyCom.com From: Symens, Sadie <ssymens@slocity.org> Sent: Wednesday, June 18, 2025 6:05 PM To: Matt Davies <matt@harmonycom.com> Cc: Melissa Lawley <melissa@harmonycom.com>; eharris@crla.org Subject: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Importance: High Hello Mr. Davies, I sent the below message to Judy Tsai earlier today and was informed that she is no longer representing South Peak in this matter. Please see the below, and please let me know if South Peak has retained alternate legal counsel. The City reiterates its invitation to discuss this matter and/or Ms. Valentine’s specific situation and otherwise appreciates your anticipated cooperation. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of 9 the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Symens, Sadie Sent: Wednesday, June 18, 2025 3:39 PM To: Judy Tsai <judy@judytsai.com>; Evan Harris <eharris@crla.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Ms. Tsai, It has been two weeks since your last email, so I am following up. Please confirm by June 25, 2025, that South Peak has rescinded the unlawful rental amount for Space A28 as reflected in the Information for Prospective Homeowners document dated May 1, 2025, and that all statements of space rent for Space A28 and similarly situated spaces are compliant with SLO Municipal Code 5.44.060(C). Should South Peak fail to do so, the City will proceed with enforcement of its municipal code, including but not limited to issuance of Notices of Violation (for each unlawful increase), Administrative Citations (for each unlawful increase), escalating and daily accruing fines (for each unlawful increase), and/or civil action for collection of unpaid fines and injunctive relief. Thank you. Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF 10 YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. From: Judy Tsai <judy@judytsai.com> Sent: Tuesday, June 3, 2025 3:56 PM To: Evan Harris <eharris@crla.org> Cc: Symens, Sadie <ssymens@slocity.org> Subject: RE: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance This will be reviewed and no, the City’s letter is not dispositive on the issue. This is an RV, and not necessarily covered. The City is stretching to make that definition “fit” into the ordinance. But again, I only received the letter on Friday, and have just returned from court in Fresno so that is my preliminary assessment. From: Evan Harris <eharris@crla.org> Sent: Tuesday, June 3, 2025 3:44 PM To: Judy Tsai <judy@judytsai.com> Cc: Symens, Sadie <ssymens@slocity.org> Subject: Re: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance Hi Judy, I’m following up on the City’s letter regarding the proposed 108% rent increase for Space A28 at South Peak Mobile Home Park. As the City made clear, such an increase would violate the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance. I trust Harmony Communities will therefore withdraw the proposed increase and instead apply the lawful 10% cap permitted under SLOMC § 5.44.060(C). To avoid any further confusion or delay in the sale process, I’d appreciate it if you could confirm in writing that Harmony is no longer pursuing the 108% increase and provide an updated notice reflecting the correct space rent. Please let me know your client’s position as soon as possible so we can move forward appropriately. Best, Evan Harris (he/him) | Staff Attorney California Rural Legal Assistance, Inc. <image007.png> eharris@crla.org <image008.png> (805) 544-7994 11 NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly forbidden. If you have received this communication in error, please notify us immediately. From: Symens, Sadie <ssymens@slocity.org> Sent: Friday, May 30, 2025 3:35 PM To: judy@judytsai.com <judy@judytsai.com> Cc: Evan Harris <eharris@crla.org> Subject: [EXTERNAL] Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance To Judy Tsai as Counsel for Harmony Properties/South Peak Mobile Home Park, Please find attached a letter regarding reported potential violations of the San Luis Obispo Mobile Home Park Rent Stabilization Ordinance by South Peak Mobile Home Park. Thank you, Sadie Symens pronouns she/her/hers Deputy City Attorney <image001.png> City Attorney's Office E ssymens@slocity.org slocity.org <image002.png> <image003.png> <image004.png> <image005.png> <image006.png> Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney- client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. <Letter to South Peak Mobile Home Park 053025.pdf>