HomeMy WebLinkAbout1001-2000 Emails1
From:Symens, Sadie
Sent:Tuesday, July 8, 2025 3:58 PM
To:Tway, Timothea (Timmi); Mezzapesa, John
Cc:Szentesi, Whit; Harnett, Natalie
Subject:RE: Mobile Home Park Code Violations
From: Tway, Timothea (Timmi) <TTway@slocity.org>
Sent: Tuesday, July 8, 2025 3:56 PM
To: Symens, Sadie <ssymens@slocity.org>; Mezzapesa, John <JMezzape@slocity.org>
Cc: Szentesi, Whit <wszentes@slocity.org>; Harnett, Natalie <nharnett@slocity.org>
Subject: RE: Mobile Home Park Code Violations
John,
Since this is a code enforcement issue, let me know if you have anything else to add or changes, otherwise we will
send these answers over.
Sadie – thank you!
From: Symens, Sadie <ssymens@slocity.org>
Sent: Tuesday, July 8, 2025 3:26 PM
To: Tway, Timothea (Timmi) <TTway@slocity.org>; Mezzapesa, John <JMezzape@slocity.org>
Cc: Szentesi, Whit <wszentes@slocity.org>; Harnett, Natalie <nharnett@slocity.org>
Subject: RE: Mobile Home Park Code Violations
My recommended responses are in purple below
From: Tway, Timothea (Timmi) <TTway@slocity.org>
Sent: Tuesday, July 8, 2025 3:04 PM
To: Symens, Sadie <ssymens@slocity.org>; Mezzapesa, John <JMezzape@slocity.org>
Cc: Szentesi, Whit <wszentes@slocity.org>; Harnett, Natalie <nharnett@slocity.org>
Subject: Fw: Mobile Home Park Code Violations
Hi team,
I received this email from Joan. Since this is potentially legal related things, wanted to get input about how we
should respond. Sadie let me know if you have concerns.
John can you craft some draft answers ready in case we want to send?
Thanks! Timmi
From: Lynch, Joan <jlynch@thetribunenews.com>
Sent: Tuesday, July 8, 2025 1:48:26 PM
To: Szentesi, Whit <wszentes@slocity.org>; Tway, Timothea (Timmi) <TTway@slocity.org>
Subject: Mobile Home Park Code Violations
2
Hello all,
I hope you're doing well! I'm reaching out because I'm working on a new story on a code violation filed against
South Peak Mobile Home Park due to a rent raise that may have violated the city's space rent ordinance, and
wanted to get the city's perspective.
A couple weeks ago, I was contacted by a South Peak Mobile Home Park owner who was
dealing with a potentially unlawful rent increase on her trailer home in South Peak. daughter was evicted
by South Peak management a couple months ago, though contested the validity of the reasons provided
for the eviction. enlisted California Rural Legal Association attorney Evan Harris to help her with the
eviction, which ended in a settlement. With her daughter no longer living at the park, she said she now has to
sell her home to a new tenant who will start a new $1,600 lease on a space that was previously leased for under
$800 or forfeit her mobile home's title to park management.
Harris told me that the city's code enforcement team was looking into this potential violation of the civil code,
and I was hoping to get the city's comment on these questions:
Harris shared a copy of the notice to correct a code violation that the city sent South Peak on June 24,
and said the next step of this process is a director's review of the violation. When will that review be held,
and how will that review be conducted?
South Peak park management has justified the rent increase by saying that home is an RV and not
a parked trailer home, claiming that this means it isn't covered by the city's space rent ordinance. Would
the city classify home as an RV, and is the park's reason for raising the rent this much valid under
the city's space rent ordinance?
Has the city received similar code enforcement violations notices from any other South Peak park
residents?
Any other comments the city has on this subject not covered by my questions is of course welcome. If you'd
prefer to have an off-record conversation about this story, feel free to reach out at the contact information
below. If you can reply by the end of the week, that would be great.
Thank you,
3
Joan Lynch
She/her/hers
Housing Reporter
P 805-781-7812
E jlynch@thetribunenews.com
W www.sanluisobispo.com
T @WritesLynch
10
From:Mezzapesa, John
Sent:Tuesday, July 8, 2025 2:52 PM
To:Tway, Timothea (Timmi); Symens, Sadie; Salem, Rami; Sheats, Steven
Subject:RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent
Stabilization Ordinance
Please review the draft of the Director’s Review for 145 South Street. The sooner we get this reviewed, the sooner it
can go out.
145 South Director's Decision.docx
Thank you,
John Mezzapesa
Interim Deputy Building Official
Community Development
Building and Safety
919 Palm Street, San Luis Obispo, CA 93401-3668
E jmezzapesa@slocity.org
T 805.781.7179
From: Tway, Timothea (Timmi) <TTway@slocity.org>
Sent: Wednesday, July 2, 2025 2:01 PM
To: Mezzapesa, John <JMezzape@slocity.org>; Symens, Sadie <ssymens@slocity.org>
Cc: Sheats, Steven <ssheats@slocity.org>
Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Perfect, thanks!
From: Mezzapesa, John <JMezzape@slocity.org>
Sent: Wednesday, July 2, 2025 1:31 PM
To: Tway, Timothea (Timmi) <TTway@slocity.org>; Symens, Sadie <ssymens@slocity.org>
Cc: Sheats, Steven <ssheats@slocity.org>
Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Your schedule looks pretty tight to fit in a meeting before then. Maybe our team can just get a draft response written
up by mid next week and we can share for review to be ready for mail by end of next week.
Does that work for both of you?
-John
From: Tway, Timothea (Timmi) <TTway@slocity.org>
Sent: Wednesday, July 2, 2025 1:09 PM
11
To: Symens, Sadie <ssymens@slocity.org>; Mezzapesa, John <JMezzape@slocity.org>
Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
John,
Can we look at this together before then? I do not see a need to wait.
thanks,
Timmi
From: Symens, Sadie <ssymens@slocity.org>
Sent: Wednesday, July 2, 2025 11:02 AM
To: Tway, Timothea (Timmi) <TTway@slocity.org>; Mezzapesa, John <JMezzape@slocity.org>
Subject: FW: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
From: Symens, Sadie
Sent: Wednesday, July 2, 2025 10:57 AM
To: Evan Harris <eharris@crla.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 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
12
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 over email (attached) there was “nothing
to correct” after 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,
13
I received the below from Harmony Communities regarding s space. Yesterday, I communicated the
City’s intent to proceed with administrative enforcement after June 25th absent information that 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
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 s RV at
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).
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, 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
14
mobile home.” The RV is required to remain vacant until sold, meaning 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 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 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
15
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.
16
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. ’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.
17
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 as reflected in the
Information for Prospective Homeowners document dated May 1, 2025, and that all statements
of space rent for 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
18
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 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>
19
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>
20
From:Lynch, Joan <jlynch@thetribunenews.com>
Sent:Tuesday, July 8, 2025 1:48 PM
To:Szentesi, Whit; Tway, Timothea (Timmi)
Subject:Mobile Home Park Code Violations
Hello all,
I hope you're doing well! I'm reaching out because I'm working on a new story on a code violation filed against
South Peak Mobile Home Park due to a rent raise that may have violated the city's space rent ordinance, and
wanted to get the city's perspective.
A couple weeks ago, I was contacted by a South Peak Mobile Home Park owner who was
dealing with a potentially unlawful rent increase on her trailer home in South Peak. daughter was evicted
by South Peak management a couple months ago, though contested the validity of the reasons provided
for the eviction. enlisted California Rural Legal Association attorney Evan Harris to help her with the
eviction, which ended in a settlement. With her daughter no longer living at the park, she said she now has to
sell her home to a new tenant who will start a new $1,600 lease on a space that was previously leased for under
$800 or forfeit her mobile home's title to park management.
Harris told me that the city's code enforcement team was looking into this potential violation of the civil code,
and I was hoping to get the city's comment on these questions:
Harris shared a copy of the notice to correct a code violation that the city sent South Peak on June 24,
and said the next step of this process is a director's review of the violation. When will that review be held,
and how will that review be conducted?
South Peak park management has justified the rent increase by saying that home is an RV and not
a parked trailer home, claiming that this means it isn't covered by the city's space rent ordinance. Would
the city classify home as an RV, and is the park's reason for raising the rent this much valid under
the city's space rent ordinance?
Has the city received similar code enforcement violations notices from any other South Peak park
residents?
Any other comments the city has on this subject not covered by my questions is of course welcome. If you'd
prefer to have an off-record conversation about this story, feel free to reach out at the contact information
below. If you can reply by the end of the week, that would be great.
Thank you,
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Joan Lynch
She/her/hers
Housing Reporter
P 805-781-7812
E jlynch@thetribunenews.com
W www.sanluisobispo.com
T @WritesLynch
31
From:Salem, Rami
Sent:Wednesday, July 2, 2025 2:20 PM
To:Sheats, Steven
Subject:RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent
Stabilization Ordinance
Got it! Thank you, Steve. I will suspend any further enforcement until directed to do otherwise.
From: Sheats, Steven <ssheats@slocity.org>
Sent: Wednesday, July 2, 2025 2:18 PM
To: Salem, Rami <RSalem@slocity.org>
Subject: FW: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hey Rami,
Just as a heads up, please see below. John is working on getting some responses together for me to draft the
Director’s Response. Until then please suspend any further enforcement.
Thanks,
Steve Sheats
Code Enforcement Officer
Interim Code Enforcement Supervisor
Community Development
Building and Safety
919 Palm Street, San Luis Obispo, CA 93401-3218
E ssheats@slocity.org
T 805.783.7841
slocity.org
Stay connected with the City by signing up for e-notifications
From: Tway, Timothea (Timmi) <TTway@slocity.org>
Sent: Wednesday, July 2, 2025 2:01 PM
To: Mezzapesa, John <JMezzape@slocity.org>; Symens, Sadie <ssymens@slocity.org>
Cc: Sheats, Steven <ssheats@slocity.org>
Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Perfect, thanks!
From: Mezzapesa, John <JMezzape@slocity.org>
Sent: Wednesday, July 2, 2025 1:31 PM
To: Tway, Timothea (Timmi) <TTway@slocity.org>; Symens, Sadie <ssymens@slocity.org>
32
Cc: Sheats, Steven <ssheats@slocity.org>
Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Your schedule looks pretty tight to fit in a meeting before then. Maybe our team can just get a draft response written
up by mid next week and we can share for review to be ready for mail by end of next week.
Does that work for both of you?
-John
From: Tway, Timothea (Timmi) <TTway@slocity.org>
Sent: Wednesday, July 2, 2025 1:09 PM
To: Symens, Sadie <ssymens@slocity.org>; Mezzapesa, John <JMezzape@slocity.org>
Subject: RE: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
John,
Can we look at this together before then? I do not see a need to wait.
thanks,
Timmi
From: Symens, Sadie <ssymens@slocity.org>
Sent: Wednesday, July 2, 2025 11:02 AM
To: Tway, Timothea (Timmi) <TTway@slocity.org>; Mezzapesa, John <JMezzape@slocity.org>
Subject: FW: [EXTERNAL] FW: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
From: Symens, Sadie
Sent: Wednesday, July 2, 2025 10:57 AM
To: Evan Harris <eharris@crla.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 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
33
City Attorney's Office
E ssymens@slocity.org
slocity.org
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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 over email (attached) there was “nothing
to correct” after 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.
34
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 space. Yesterday, I communicated the
City’s intent to proceed with administrative enforcement after June 25th absent information that
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
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
35
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. ’s RV at
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).
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. 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 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 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 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>
36
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
<image002.png>
<image003.png>
<image004.png>
<image005.png>
<image006.png>
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37
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. ’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>
38
<image003.png>
<image004.png>
<image005.png>
<image006.png>
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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 as reflected in the
Information for Prospective Homeowners document dated May 1, 2025, and that all statements
of space rent for Space 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>
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39
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 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,
40
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
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>
125
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.Linda .City'sViolationNotice(2).pdf;
6.24.25.Linda .City'sViolationNotice(1).pdf;
7.01.2 .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. over email (attached) there was “nothing
to correct” after Ms. 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
126
Hello all,
I received the below from Harmony Communities regarding Ms. ’s space. Yesterday, I communicated the
City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. ’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.
’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. ’s RV at Space .
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. ’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.
127
Even if the RV were considered a mobile home, Ms. 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. 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. ’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. ’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
128
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>
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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
129
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. ’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
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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,
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130
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 as reflected in the
Information for Prospective Homeowners document dated May 1, 2025, and that all statements
of space rent for Space 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
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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.
131
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 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>
132
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,
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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>
136
From:Symens, Sadie
Sent:Monday, June 30, 2025 10:18 AM
To:McClish, Teresa; Amini, David
Cc:Dietrick, Christine; Tway, Timothea (Timmi); Corey, Tyler
Subject:Privileged/Confidential RE: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5,
Chapter 5.44
Attachments:Re: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
Hello all,
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: McClish, Teresa <tmcclish@slocity.org>
Sent: Wednesday, April 16, 2025 3:11 PM
137
To: Symens, Sadie <ssymens@slocity.org>
Cc: Dietrick, Christine <cdietric@slocity.org>; Tway, Timothea (Timmi) <TTway@slocity.org>; Amini, David
<DAmini@slocity.org>; Corey, Tyler <tcorey@slocity.org>
Subject: RE: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
From: Symens, Sadie <ssymens@slocity.org>
Sent: Tuesday, April 15, 2025 10:46 PM
To: McClish, Teresa <tmcclish@slocity.org>; Tway, Timothea (Timmi) <TTway@slocity.org>; Corey, Tyler <tcorey@slocity.org>;
Amini, David <DAmini@slocity.org>
Cc: Dietrick, Christine <cdietric@slocity.org>
Subject: RE: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
From: McClish, Teresa <tmcclish@slocity.org>
Sent: Monday, April 14, 2025 4:32 PM
To: Tway, Timothea (Timmi) <TTway@slocity.org>; Corey, Tyler <tcorey@slocity.org>; Amini, David <DAmini@slocity.org>;
Symens, Sadie <ssymens@slocity.org>
Subject: RE: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
We will take a look – also I think we can use Sadie weigh-in too.
From: Tway, Timothea (Timmi) <TTway@slocity.org>
Sent: Monday, April 14, 2025 4:30 PM
To: McClish, Teresa <tmcclish@slocity.org>; Corey, Tyler <tcorey@slocity.org>; Amini, David <DAmini@slocity.org>
Subject: FW: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
Hi all,
We will need to provide information to council on this one, can you please take a look?
Thanks!
From: CityClerk <CityClerk@slocity.org>
Sent: Monday, April 14, 2025 4:08 PM
To: Nick Pardo <
Cc: Tway, Timothea (Timmi) <TTway@slocity.org>; City_Attorney <City_Attorney@slocity.org>
Subject: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
BCC: Council All
Nick Pardo,
Thank you for taking the time to contact City Council on this topic. This is a policy related issue for the City Council’s
consideration and your message has been provided directly to them. By copy on this email, it is also being shared with
staff in our City Attorney’s Office and Community Development Department for their awareness.
138
City Clerk’s Office
City Administration
City Clerk's Office
990 Palm Street, San Luis Obispo, CA 93401-3218
From: Nick Pardo <
Sent: Monday, April 14, 2025 3:17 PM
To: E-mail Council Website <emailcouncil@slocity.org>
Subject: Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
This message is from an External Source. Use caution when deciding to open attachments, click links, or respond.
Dear Mayor Stewart and City Council Members,
Please find attached a formal petition to amend San Luis Obispo Municipal Code Title 5 Chapter 5.44, which
pertains to rent control within the city, specifically as it relates to mobilehome park tenancies.
The attached letter details how the current application of Section 5.44.030(E) creates an inequity for
mobilehome owners and conflicts with current California state law, specifically Assembly Bill 2782 (2020),
which amended California Civil Code Section 798.17.
I urge the City Council to consider this petition and take swift action to amend the ordinance. Thank you for your
time and consideration of this important matter.
Sincerely,
Nick Pardo
1
From:Nick Pardo <
Sent:Monday, June 23, 2025 4:48 PM
To:CityClerk
Cc:Tway, Timothea (Timmi); City_Attorney
Subject:Re: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
Attachments:Petition to revise Municipal Code 5.44.pdf
Dear Mayor Stewart, City Council Members, City Attorney, and City Clerk,
In April of this year, I submitted the attached petition regarding a conflict between our mobilehome rent control
ordinance and state law (attached for context).
I am writing to follow up, as I believe state law may have already resolved this matter. The exemption in our city's
ordinance, Section 5.44.030(E), was required by a former state law (CA Civil Code § 798.17) that has since been
repealed by AB 2782. Because of this, our local exemption may no longer be legally valid.
To clarify this for everyone, I believe it would be worthwhile for the City Attorney to weigh in on this. If the city's
exemption is indeed unenforceable, simply removing the defunct section from the ordinance would eliminate
significant confusion for both residents and park owners.
Thank you for your continued consideration of this important issue.
Sincerely,
Nick Pardo
On Mon, Apr 14, 2025 at 4:08 PM CityClerk <CityClerk@slocity.org> wrote:
BCC: Council All
Nick Pardo,
Thank you for taking the time to contact City Council on this topic. This is a policy related issue for the City Council’s
consideration and your message has been provided directly to them. By copy on this email, it is also being shared
with staff in our City Attorney’s Office and Community Development Department for their awareness.
2
City Clerk’s Office
City Administration
City Clerk's Office
990 Palm Street, San Luis Obispo, CA 93401-3218
From: Nick Pardo <
Sent: Monday, April 14, 2025 3:17 PM
To: E-mail Council Website <emailcouncil@slocity.org>
Subject: Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
This message is from an External Source. Use caution when deciding to open attachments, click links, or respond.
Dear Mayor Stewart and City Council Members,
Please find attached a formal petition to amend San Luis Obispo Municipal Code Title 5 Chapter 5.44, which
pertains to rent control within the city, specifically as it relates to mobilehome park tenancies.
The attached letter details how the current application of Section 5.44.030(E) creates an inequity for
mobilehome owners and conflicts with current California state law, specifically Assembly Bill 2782 (2020),
which amended California Civil Code Section 798.17.
I urge the City Council to consider this petition and take swift action to amend the ordinance. Thank you for
your time and consideration of this important matter.
Sincerely,
Nick Pardo
Nick Pardo
April 14, 2025
Honorable Mayor Erica A. Stewart and City Council Members
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
Subject: Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44 Regarding Rent Control in
Mobilehome Parks
Dear Mayor Stewart and City Council Members,
I am writing to petition for an amendment to San Luis Obispo Municipal Code Title 5 Chapter 5.44, which pertains
to rent control within the city, speciflcally as it relates to mobilehome park tenancies.
The current application of Chapter 5.44.030(E) creates a severe inequity for mobilehome owners in San Luis
Obispo and necessitates immediate corrective action. The ordinance's exemption from rent control for 'tenancies
covered by leases or contracts which provide for a tenancy of more than a year' confiicts with current California
state law, causing signiflcant flnancial hardship and inequity for residents.
Assembly Bill 2782 (2020) amended California Civil Code Section 798.17. This amendment removed the automatic
exemption from local rent stabilization ordinances for long-term leases signed on or after February 13, 2020
(effective January 1, 2021) and also removed the exemption for leases signed before February 13, 2020 (Effective
January 2025). This legislative change affirms that local rent control ordinances should take precedence over
confiicting terms in these leases.
There is a signiflcant loophole within the Mobilehome Residency Law (MRL) that allows park owners to exploit the
vulnerability of individuals purchasing a home within the park. The MRL deflnes a "homeowner" as "a person who
has a tenancy in a mobilehome park under a rental agreement" [§798.9]. This deflnition leaves buyers in a
precarious position, as they do not yet qualify as "homeowners" until they sign the park's required lease. Park
owners can leverage this gap in protection to force buyers into accepting unfavorable long-term lease agreements
as a condition of residency approval, effectively circumventing the intent of the MRL to protect homeowners.
Mobilehome owners, often facing limited housing options, are frequently compelled to accept "take it or leave it"
long-term leases that impose rent increases far exceeding the protections afforded by Municipal Code Section
5.44.
The consequences of these issues can be flnancially crippling. To illustrate the potential for harm, consider the
following 20-year rent increase projections, calculated using historical Consumer Price Index (CPI) data from 2004
to 2024, and comparing San Luis Obispo city and county’s rent control scenarios to an actual long-term lease
offered by a San Luis Obispo mobilehome park. For these simulations, we will assume a starting monthly space
rent of $1000 (typical starting rent in 2025):
• Scenario 1: SLO City Rent Control - Section 5.44 (CPI with a 5% annual cap):
o Ending Monthly Rent: $1666.91
o Total Rent Paid: $314,378.88
• Scenario 2: SLO County Rent Control - Title 25 (60% of CPI):
o Ending Monthly Rent: $1385.01
o Total Rent Paid: $281,702.28
• Scenario 3: Actual Offered 20-Year Lease (CPI + 2% with a 3.9% minimum and 9% annual cap):
o Ending Monthly Rent: $2624.52
o Total Rent Paid: $402,801.00
The data clearly demonstrates that even under recent CPI conditions, long-term leases lead to a dramatic
escalation of housing costs. Residents who have no viable alternative but to sign these leases face signiflcant long
term flnancial impact, jeopardizing their housing stability and overall well-being. The signiflcant difference in both
total rent paid and the flnal monthly rent underscores the urgent need for reform. Over 20 years, a typical long -term
lease in this scenario would result in residents paying $88,422.12 more than under the cities actual rent control
ordinance, with a flnal monthly rent that is 57.4% higher. This is the flrst opportunity under the current ordinance,
for residents to gain the beneflt of San Luis Obispo's rent control provisions. By this time, the damage is done.
Crucially, the fundamental problem lies in the transfer of authority over rent increases from local government to
private corporations. San Luis Obispo's existing rent control ordinance in Chapter 5.44 refiects a balance between
ensuring fair returns for property owners and protecting residents from excessive rent hikes. This balance is
achieved through local oversight and a structure that is publicly accountable. In contrast, long -term leases
empower park owners, whose primary motivation is proflt maximization, to unilaterally determine rent increases,
often with formulas that far outpace the ability of residents on flxed incomes to keep pace.
Furthermore, these long-term leases frequently include provisions that go beyond traditional rent increases. Park
owners may pass through the costs of capital improvements or replacements to residents, often with an added
interest factor. This means residents are not only paying for the improvements but also flnancing them at a rate
determined by the park owner, further infiating their housing costs. While the scenarios presented illustrate
potential flnancial harm, the core issue is about local control. The allowable rent increases and any additional
charges should be determined by the City of San Luis Obispo, as it is for those under short-term leases under
Chapter 5.44, and not by private entities. It is not necessarily that the flnal rent under Scenario 1 is the only
acceptable outcome, but that the mechanism for determining fair and reasonable rent increases and related
charges should reside with the city, ensuring a more equitable and sustainable outcome for residents.
To align the city ordinance with current state law, I propose the following amendment to San Luis Obispo Municipal
Code Title 5, Chapter 5.44.030(E):
• Proposed Amendment: removal of Chapter 5.44.030(E).
This amendment aligns with Assembly Bill 2782 and Civil Code 798.17, ensuring that all mobilehome park
residents are afforded the protections of the city's rent control ordinance, preventing the exploitation of residents
through mandatory, long-term leases and addressing the vulnerability of new homeowners during the purchase
process.
I urge the City Council to take swift action on this critical issue. Thank you for your time and consideration.
Sincerely,
Nick Pardo
139
From:Symens, Sadie
Sent:Friday, June 27, 2025 5:05 PM
To:Matt Davies; Jason Dilday
Subject:RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance
Hello,
1. I am referring to the unit as a mobilehome because it is a mobilehome under the San Luis Obispo Mobile
Home Rent Stabilization Ordinance, for the reasons I have previously stated.
2. The phrase “In the event of change of ownership resulting from vacation of the space, then the space rent may
be adjusted to fair market rent in the community” in SLOMC 5.44.060 refers to the occasion in which the
mobilehome is removed from the space, the space is vacant (vacation of the space), and the new unit that
moves into the space is owned by a new owner. The change in ownership relevant here is described in this
part of that section: “The maximum monthly space rent of a tenant may be increased by the owner when there
is a change of ownership affecting a mobile home. However, such increase shall not exceed ten percent of the
then existing space rent and may not be relied upon any more often than once in any thirty-six-month period as
the basis to increase rent.” Again, if I am wrong that the mobilehome is remaining in Space , please
correct me.
3. The City’s position has been consistent on this point since May 30th. Ms. has rights afforded to
tenants under the SLO MHPRSO.
Since the City’s position has remained consistent and, I hope, clear since May 30th, I am open to continuing this
conversation in a meeting rather than continued email exchanges. If you wish to schedule that, please let me know.
Otherwise, I will defer to the director’s review process currently in motion.
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.
140
From: Matt Davies <matt@harmonycom.com>
Sent: Thursday, June 26, 2025 3:58 PM
To: Symens, Sadie <ssymens@slocity.org>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hi Sadie,
Still not following.
1) You keep referring to this as a mobile home when you have seen incontrovertible evidence this is a park model
RV. This is not semantics. Why do you refer to the RV as a Mobilehome?
2) There would never be a change of ownership if the unit was removed from the space. That sentence makes zero
sense based on your interpretation. It is impossible to have a change of ownership if the unit is removed. The
ordinance as drafted is clear. There is a “vacation”. Do you not see a “vacation”? Is she not trying to facilitate a
change in ownership?
3) The legislative intent language includes reference to “tenants.” Is she a tenant or isn’t she?
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: Thursday, June 26, 2025 3:34 PM
To: Matt Davies <matt@harmonycom.com>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
I see that you have already submitted your request for director’s review. However, I will still respond to your question.
It is my understanding that the mobilehome is staying in space ; please correct me if I am wrong about that. If the
mobilehome is remaining in place, I do not believe the portion you have highlighted is applicable to this situation.
“Vacation of space” refers to the mobile home vacating the space. Ms. ’s right to occupy has apparently been
terminated, but she is permitted to “conduct on onsite sale of Defendant’s mobilehome in accordance with the
Mobilehome Residency Law to a park approved buyer to and through November 30 th, 2025.” I would direct you again
to the legislative intent of the MHPRSO which states, as a reason for the limitation of space rent increase upon sale,
that “tenants in mobile home parks desiring to sell their mobile homes may have difficulty finding buyers because,
upon a change of ownership, the park is able to rent without regard to the city’s mobile home rent stabilization
ordinance.” The City Council would not have included this statement of intent if the Ordinance did not attempt to
address that stated harm. The harm caused upon Ms. by Harmony Communities’ unlawful space rent
increase is the type of harm the City Council attempted to mitigate by enacting 5.44.060(C).
Thank you,
Sadie Symens
pronouns she/her/hers
Deputy City Attorney
141
City Attorney's Office
E ssymens@slocity.org
slocity.org
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IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you.
From: Matt Davies <matt@harmonycom.com>
Sent: Wednesday, June 25, 2025 8:26 AM
To: Symens, Sadie <ssymens@slocity.org>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello Sadie,
I would like to call your attention to 5.44.060 C. I believe our disagreement related to RV’s to be a moot point. The 10%
change of ownership limitation is of no effect when the change of ownership results from a “vacation of the space”(see
below). Attached is an email from ’s attorney confirming she vacated the unit in early June. She was then paid
$2,000 in exchange for vacating the unit. She and her attorney bargained for this agreement and cannot now change their
position as to what they legally agreed to. Please review and advise at your convenience.
C. The maximum monthly space rent of a tenant may be increased by the owner when there is a change of
ownership affecting a mobile home. However, such increase shall not exceed ten percent of the then
existing space rent and may not be relied upon any more often than once in any thirty-six-month period as
the basis to increase rent. In the event of change of ownership resulting from subletting of the mobile home
space as may be allowed by state law, should such become state law, then upon any such subletting the
space rent may be increased up to ten percent of the then existing space rent. In the event of change of
ownership resulting from vacation of the space, then the space rent may be adjusted to fair market rent in
the community. Nothing in this paragraph shall preclude an adjustment as may otherwise be provided for in
this chapter.
Regards,
Matt Davies
Harmony Communities
6653 Embarcadero Dr. Ste. C
Stockton, CA 95219
Cell: (209) 601-4538
Main: (209) 932-8747
142
Matt@HarmonyCom.com
From: Symens, Sadie <ssymens@slocity.org>
Sent: Tuesday, June 24, 2025 5:01 PM
To: Matt Davies <matt@harmonycom.com>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
I apologize that the director’s review document was not enclosed. I have included it here.
The City provided the basis for enforcement on May 30, 2025. Additionally, Harmony Communities has recognized the
unit as a mobilehome consistently throughout Ms. ’s tenancy and as recently as May 1, 2025, including the
rental agreement, the unlawful detainer action and settlement, and the Information for Prospective Homeowners
document. The Mobile Home Park Rent Stabilization Ordinance is not as narrowly applicable as Harmony
Communities appears to believe. Further, Ms. was entitled to occupy the mobilehome under her lease until
her tenancy was terminated, and the unlawful detainer action has no effect on the applicability of SLOMC 5.44.060(C),
which prohibits increases in excess of 10% upon change in ownership; that is, the protection contemplated by that
section is as to the space (for continuity of affordability) and not to the existing/former resident. SLOMC 5.44.010(E)
clarifies the legislative intent. Again, please refer to my letter dated May 30, 2025, attached again here. The
applicability of H&S 18009.3 and 18010 on a mobilehome unit that has been in place as a primary residence since,
according to the records you have provided, at least 2018 is unclear to me, so I cannot respond to that particular
argument.
Thank you,
Sadie Symens
pronouns she/her/hers
Deputy City Attorney
City Attorney's Office
E ssymens@slocity.org
slocity.org
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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
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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: Tuesday, June 24, 2025 3:41 PM
143
To: Symens, Sadie <ssymens@slocity.org>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello Sadie,
That’s unfortunate. Your characterization of our characterization is inaccurate. We don’t characterize it in any
manner. It’s not up to us. We simply follow state law. State law defines what an RV is. See H&S 18009.3 and 18010. A
park model is a type of RV.
https://www.aamva.org/policy/policy-positions/recreational-park-
trailer#:~:text=A%20park%20model%20recreational%20vehicle,feet%20in%20the%20setup%20mode .
https://www.gorving.com/explore-rvs/park-model-
rvs#:~:text=The%20Seasonal%20RV,the%20possible%20features%20and%20amenities .
https://www.championhomes.com/our-homes/park-model-
rv#:~:text=What%20is%20a%20Park%20Model,U.S.%20and%20most%20Canadian%20provinces.\
It seems that you are having an issue based on what you see visually. The above links will help you understand that this is
indeed an Rvand will give you more insight on the product type. It still has its wheels and axels attached, and the hitch is
located underneath the unit.
The NOV does not have an enclosure. Please email me the enclosure and we will file with the director.
Further, please respond to the points made in Jason’s email so we may understand the city’s position related to
recreational vehicles and tenancies.
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: Tuesday, June 24, 2025 3:28 PM
To: Matt Davies <matt@harmonycom.com>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
Thank you for confirming receipt of the notice of violation. We do not intend to rescind the Notice. Information on
requesting a director’s review is on page 2 of the Notice of Violation.
So that I am clear, can you confirm that the unit Harmony Communities is characterizing as an RV is the unit depicted
in the photo attached?
Thank you,
Sadie Symens
pronouns she/her/hers
Deputy City Attorney
144
City Attorney's Office
E ssymens@slocity.org
slocity.org
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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: Tuesday, June 24, 2025 3:03 PM
To: Symens, Sadie <ssymens@slocity.org>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello Sadie,
Please see the attached registration for the 23/24 year. Since this is an RV(vehicle), you only get one pink slip on
purchase. It is attached. The DMV issued a new pink slip to after she purchased it. The attached was also
posted on the door of her unit today. Please advise if you will be rescinding in light of Jason’s email. Otherwise, we
dispute the violation and request a hearing. Please advise as to the process to dispute this violation.
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: Tuesday, June 24, 2025 1:57 PM
To: Jason Dilday <jason@harmonycom.com>
Cc: Matt Davies <matt@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
Thank you for that information. Could you please provide registration and title for the year you sold the unit to
? The one you attached was from 2018.
Thank you,
145
Sadie Symens
pronouns she/her/hers
Deputy City Attorney
City Attorney's Office
E ssymens@slocity.org
slocity.org
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designated addressee named above. The information transmitted is subject to the attorney-client privilege
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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. ’s RV at Space .
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. ’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. 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. 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
146
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. ’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. ’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:
147
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>
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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,
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YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY
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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
148
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. ’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>
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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,
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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>
149
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 as reflected in the
Information for Prospective Homeowners document dated May 1, 2025, and that all statements
of space rent for Space 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>
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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
150
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 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,
151
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>
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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,
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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>
152
From:Symens, Sadie
Sent:Friday, June 27, 2025 11:32 AM
To:
Subject:RE: South Peak MHP, #A66, San Luis Obispo, CA
Hello,
I have been made aware that you contacted the City’s Code Enforcement staff about this issue. As I stated in my
email dated June 10th, if your home is a mobilehome subject to the Mobile Home Park Rent Stabilization Ordinance
and that the Park has violated that ordinance, please send that information to me. As a reminder, the City cannot
represent you in an action against your landlord. You may want to consider contacting CRLA.
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:
Sent: Wednesday, June 11, 2025 8:40 AM
To: Symens, Sadie <ssymens@slocity.org>
Subject: Re: South Peak MHP, #A66, San Luis Obispo, CA
Thank you.
Sent from my iPhone
On Jun 10, 2025, at 1:43 PM, Symens, Sadie <ssymens@slocity.org> wrote:
153
The City Attorney’s office cannot represent you in a dispute with the mobile home park owner, but if you
or your attorney believe that you are protected by the Mobile Home Park Rent Stabilization Ordinance
(which you can view online here), and that the mobile home park owner is unlawfully increasing your
space rent, you may provide that information to our office. Our office may investigate the park for
violations of the City’s municipal code.
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>
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<image006.png>
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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:
Sent: Tuesday, June 10, 2025 11:36 AM
To: Symens, Sadie <ssymens@slocity.org>
Subject: Fwd: South Peak MHP, #A66, San Luis Obispo, CA
Sent from my iPhone
Begin forwarded message:
From:
Date: June 10, 2025 at 11:15:05 AM PDT
To:
Subject: Fwd: South Peak MHP, #A66, San Luis Obispo, CA
I have emailed Deputy District Attorney
Sent from my iPhone
154
Begin forwarded message:
From: Matt Davies <matt@harmonycom.com>
Date: June 10, 2025 at 9:24:52 AM PDT
To:
Cc: ssymens@slocity.org, Melissa Lawley
<melissa@harmonycom.com>
Subject: RE: South Peak MHP, #A66, San Luis Obispo, CA
Okay we’ll not be selling then. We like South Peak and intend to stay
at
You live in a recreational vehicle and have no rights to sell said vehicle in
place under state law(see civil code 798). In light of our disagreement, we
will not be providing any documentation and you will need to have the RV
removed upon sale. Thank you in advance for your cooperation.
Regards,
Matt Davies
Harmony Communities
6653 Embarcadero Dr. Ste. C
Stockton, CA 95219
Main: (209) 932-8747
Matt@HarmonyCom.com
From: Melissa Lawley <melissa@harmonycom.com>
Sent: Tuesday, June 10, 2025 8:46 AM
Please see below
Thank you,
Melissa Lawley
Senior Regional Manager
<image007.jpg>
6653 Embarcadero Drive, Ste. C
Stockton, CA 95219
Direct: (209) 438-7242
Main: (209) 932-8747
Fax: (209) 451-1297
Melissa@HarmonyCom.com
From: Symens, Sadie <ssymens@slocity.org>
Sent: Tuesday, June 10, 2025 7:38 AM
To: ; Melissa Lawley
155
<melissa@harmonycom.com>
Subject: RE: South Peak MHP, #A66, San Luis Obispo, CA
Thank you for reaching out. Please feel free to forward to our office any
rent increases in violation of the San Luis Obispo Municipal Home Park
Rent Stabilization Ordinance.
Sadie Symens
pronouns she/her/hers
Deputy City Attorney
<image001.png>
City Attorney's Office
E ssymens@slocity.org
slocity.org
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From:
Sent: Monday, June 9, 2025 6:39 PM
To: Symens, Sadie <ssymens@slocity.org>; Melissa Lawley
<melissa@harmonycom.com>
Subject: South Peak MHP, #A66, San Luis Obispo, CA
When we do get a buyer, please put the new land lease amount in
writing so we can mail a copy to
the City of SLO, District Attorney, Christine Dietrick who is
examining the case for land lease price gouging.
990 Palm St
156
San Luis Obispo, CA 93401
Thank you,
Sent from my iPhone
157
From:Mariah Thompson <mthompson@crla.org>
Sent:Thursday, June 26, 2025 5:26 PM
To:Patsy Van Dyke; Symens, Sadie
Subject:Re: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent
Stabilization Ordinance - South Peak/
Ms. Symens,
I came across this article today that you may be interested in. https://sanjosespotlight.com/san-jose-tightens-
mobile-home-park-rent-control-policy/
It demonstrates that a good approach to this debate is to amend RSOs to clearly include RVs in MHPs.
Cheers,
Mariah
Mariah Thompson she/her/ella | Senior Litigator
California Rural Legal Assistance, Inc.
mthompson@crla.org
(559) 441-8721
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: Patsy Van Dyke <pvandyke@crla.org>
Sent: Thursday, June 26, 2025 1:48:50 PM
To: Symens, Sadie <ssymens@slocity.org>; Mariah Thompson <mthompson@crla.org>
Subject: Re: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance -
South Peak/
Dear Ms. Symens:
Unfortunately, it appears that we do not have a complete copy of the Park Rules for South Peak-- only the odd
numbered pages. I will work on getting a complete copy.
Thanks,
Patsy Van Dyke | Senior Litigator
California Rural Legal Assistance, Inc.
pvandyke@crla.org
(831) 757-5221
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.
158
From: Symens, Sadie <ssymens@slocity.org>
Sent: Wednesday, June 25, 2025 5:37 PM
To: Mariah Thompson <mthompson@crla.org>
Cc: Patsy Van Dyke <pvandyke@crla.org>
Subject: RE: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance -
South Peak/
Hello,
Thank you for that additional information and for your continued assistance. By way of update, the City has issued a
Notice of Violation against the property owner, requiring them to present an updated Information for Prospective
Homeowners document which reflects a space rent in lawful compliance with the Mobile Home Park Rent Stabilization
Ordinance. The owners have 5 days to request a director’s review. If they do not, or if the director upholds the NOV,
the City may begin to issue administrative citations, including daily accruing citations for each day the Park remains in
violation. The park owner may appeal an administrative citation within 10 days of issuance, to either a hearing officer
or Administrative Review Board.
Evan sent over the South Peak Park rules, but it looks like the even-numbered pages are missing; would either of you
be able to send me the complete Rules?
Thank you,
Sadie Symens
pronouns she/her/hers
Deputy City Attorney
City Attorney's Office
E ssymens@slocity.org
slocity.org
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IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you.
From: Mariah Thompson <mthompson@crla.org>
Sent: Tuesday, June 24, 2025 1:47 PM
To: Symens, Sadie <ssymens@slocity.org>
Cc: Patsy Van Dyke <pvandyke@crla.org>
159
Subject: Re: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance -
South Peak/
I have not been to the park and our local attorney on this case, Evan, is currently out of office. But that looks like a
park model unit and has the same address so I don't see any reason that wouldn't be the correct unit.
Attached is the title search for the unit. I have sent additional questions to the registration/titling department because of
discrepancies between the title and the sales contract. I am specifically asking HCD whether titling should currently be
going through HCD or DMV. I am wondering if Harmony failed to follow the appropriate process when it acquired the
unit and then sold the unit. It looks like the unit HCD registration has not been updated in a long time and was never
updated with CA MHP Investors 3, LLC (Bruce Davies/Harmony company) as the legal owner. Notably, Harmony also
did not produce to you a recent registration-- they produced a DMV registration from 2018. If I were you, I would ask
Harmony for the registration and title for the year that they sold the unit to CRLA's client.
Mariah Thompson she/her/ella | Senior Litigator
California Rural Legal Assistance, Inc.
mthompson@crla.org
(559) 441-8721
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communication in error, please notify us immediately.
From: Symens, Sadie <ssymens@slocity.org>
Sent: Tuesday, June 24, 2025 11:04 AM
To: Mariah Thompson <mthompson@crla.org>
Cc: Patsy Van Dyke <pvandyke@crla.org>
Subject: Re: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance - South Peak/
Thank you. I drove by Space . Could you confirm that this is your client’s unit?
60
161
On Jun 24, 2025, at 9:54 AM, Mariah Thompson <mthompson@crla.org> wrote:
Good morning,
I can actually ask my contact at HCD's registration department about this. I will do this now. I would
think that it would have been but let me confirm.
Thanks,
Mariah Thompson she/her/ella | Senior Litigator
California Rural Legal Assistance, Inc.
<C2_signature_msg_60437b2c-1a55-4bd4-933f-6012a97256b3.png>
mthompson@crla.org
<C2_signature_phone_f1f87ccc-6c1e-43c4-9096-0c070108fb9e.png>
(559) 441-8721
162
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: Patsy Van Dyke <pvandyke@crla.org>
Sent: Tuesday, June 24, 2025 10:52 AM
To: Symens, Sadie <ssymens@slocity.org>
Cc: Mariah Thompson <mthompson@crla.org>
Subject: Re: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance - South Peak/
Not to our knowledge.
Patsy Van Dyke | Senior Litigator
California Rural Legal Assistance, Inc.
<Image.png>
pvandyke@crla.org
<Image.png>
(831) 757-5221
NOTICE: If the reader of this message is not the intended recipient, you are hereby notified that any
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communication in error, please notify us immediately.
From: Symens, Sadie <ssymens@slocity.org>
Sent: Monday, June 23, 2025 5:26:07 PM
To: Patsy Van Dyke <pvandyke@crla.org>
Cc: Mariah Thompson <mthompson@crla.org>
Subject: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance - South Peak/
You don't often get email from ssymens@slocity.org. Learn why this is important
Hello,
Thank you for that additional information. Do you know if the unit has ever been registered with HCD? I
agree that the DMV registration is not determinative, but I just want to make sure I have all the
information. Thank you again.
Sadie Symens
pronouns she/her/hers
Deputy City Attorney
<image001.png>
City Attorney's Office
E ssymens@slocity.org
slocity.org
<image002.png>
163
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you received this document through inadvertent error and any further review, dissemination,
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YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY
TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you.
From: Patsy Van Dyke <pvandyke@crla.org>
Sent: Friday, June 20, 2025 4:04 PM
To: Symens, Sadie <ssymens@slocity.org>
Cc: Mariah Thompson <mthompson@crla.org>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance -
South Peak/
Dear Ms. Symens:
Thank you for following up on this matter. Evan Harris is on vacation, so I will be the point
person on the matter (with assistance from Mariah Thompson) until at least July 7, 2025.
With respect to Mr. Dilday's arguments about Ms. 's home being a recreational
vehicle that is not subject to the City's Rent Stabilization Ordinance (RSO), I refer you to our earlier
submissions and communications. Moreover, the type of registration is not relevant for the
purpose of determining whether the RSO applies. It is not one of the criteria raised in the RSO.
Further, Mr. Dilday ignores that this unit is permanently installed, including the utility installation.
It is not "readily moved" simply attaching it to a pickup truck with a trailer hitch. It is undisputed
that this unit has been occupied as a permanent residence with the full knowledge and consent of
Harmony.
Indeed, this argument that Ms. 's home is a recreational vehicle and not a
"mobilehome" is belied by the very documents Mr. Dilday relies upon to try to deny Ms.
's ownership and legal occupancy of the site. For example, the stipulation itself refers to
the unit as a "mobilehome" in multiple places, See, e.g. Paragraphs 2, 7, and 8. Paragraph 8 also
makes clear that Harmony will continue to collect rent for the space occupied by Ms. 's
mobilehome through the time of sale. Thus, although the unit may be vacant, Ms. is the
owner of the mobilehome that legally occupies that space, and pursuant to which Harmony still
seeks to collect rent. Thus, any argument that she is not a "tenant" based on the stipulation is
unfounded. Mr. Dilday is manufacturing arguments after the fact out of thin air in a brazen attempt
to avoid application of the RSO.
164
The parties' course of conduct further confirms that the parties consider Ms. 's unit to
be a mobilehome and not a recreational vehicle for purposes of the applicability of the RSO. For
example, Harmony required Ms. to sign a 30-year lease. A long-term lease would not
have been necessary if the unit was considered a recreational vehicle that was exempt from the
RSO. Further, the information sheet distributed by Harmony for prospective purchasers also
refers to the unit as a "home" as does the sales contract or home purchase agreement signed by
Ms. when she initially purchased the unit from Harmony.
Please contact me if you require any additional information. Thank you for your prompt
consideration of this matter.
Sincerely,
Patsy Van Dyke | Senior Litigator
California Rural Legal Assistance, Inc.
<image007.png>
pvandyke@crla.org
<image008.png>
(831) 757-5221
<image009.png>
3 Williams Road, Salinas, CA 93905
<image010.jpg>
<image011.png><image012.png><image013.png><image014.png>
CRLA.org
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immediately.
193
From:Symens, Sadie
Sent:Wednesday, June 25, 2025 3:25 PM
To:
Subject:RE: South Peak Rent increase violations
Hello
The City has issued a Notice of Violation against the park for the unlawful space increase for Space in violation of
the City’s Mobile Home Park Rent Stabilization Ordinance. If you believe your tenancy is subject to that ordinance,
and that the Park management is violating the ordinance, you are free to forward that information to our office for our
possible investigation. Please note that our office can not represent you in any action against management.
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
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IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you.
From:
Sent: Wednesday, June 25, 2025 3:20 PM
To: Symens, Sadie <ssymens@slocity.org>
Subject: Re: South Peak Rent increase violations
Hi Sadie,
Is there any way I can follow the progress of this? I just renewed my intent to sell form (they make us do it every
60 days, this is when they adjust the future owner's space rent) and they are still making the space rent double
for the next owner. I am unable to sell my home and am in dire straits.
Thanks,
194
On Fri, Jun 13, 2025 at 9:01 AM Symens, Sadie <ssymens@slocity.org> wrote:
Hello,
The Park has disagreed with the City’s interpretation and has not yet accepted the City’s invitation for further
discussion. Should the Park violate the municipal code, the City will certainly explore enforcement options.
Sadie Symens
pronouns she/her/hers
Deputy City Attorney
City Attorney's Office
E ssymens@slocity.org
slocity.org
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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
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publicly accessible records. If you are not the designated addressee named above or the authorized agent
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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:
Sent: Thursday, June 12, 2025 1:33 PM
To: Symens, Sadie <ssymens@slocity.org>
Subject: Re: South Peak Rent increase violations
Do you know if they are planning on complying with the regulation? If they don't, is the city planning on pressing
charges?
195
Thanks for responding,
On Thu, Jun 12, 2025 at 1:15 PM Symens, Sadie <ssymens@slocity.org> wrote:
Hello,
Can you clarify what information you are looking for? The extent of our office’s involvement at this point has been to
notify South Peak Mobile Home Park management (Harmony Properties) that their proposal to increase mobile
home space rent upon sale by more than 10% would be considered a violation of the San Luis Obispo Mobile
Home Park Rent Stabilization Ordinance.
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
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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:
Sent: Thursday, June 12, 2025 12:49 PM
196
To: Symens, Sadie <ssymens@slocity.org>
Subject: Re: South Peak Rent increase violations
Hi Sadie,
Any chance you have any info for me? We are about to drop the price to well below what it's worth just to
escape the monthly rent payments.
Thanks,
On Wed, Jun 4, 2025 at 4:23 PM wrote:
Hi Sadie,
My name is and both me and my girlfriend are trying to sell our mobile homes in the South
Peak mobile home park, but we are having some difficulties due to the fact that they are raising the space
rent nearly double for the next owner, no one wants to buy the house and we are in a bad situation. We heard
through the grapevine that the city may be cracking down on them doing this, and that it is against the city
ordinances, is there any information you might be able to provide about that? We would be grateful.
Thanks,
201
From:Matt Davies <matt@harmonycom.com>
Sent:Wednesday, June 25, 2025 8:26 AM
To:Symens, Sadie; Jason Dilday
Subject:RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance
Attachments:Re: [EXTERNAL] South Peak v.
Hello Sadie,
I would like to call your attention to 5.44.060 C. I believe our disagreement related to RV’s to be a moot point. The 10%
change of ownership limitation is of no effect when the change of ownership results from a “vacation of the space”(see
below). Attached is an email from ’s attorney confirming she vacated the unit in early June. She was then paid
$2,000 in exchange for vacating the unit. She and her attorney bargained for this agreement and cannot now change their
position as to what they legally agreed to. Please review and advise at your convenience.
C. The maximum monthly space rent of a tenant may be increased by the owner when there is a change of
ownership affecting a mobile home. However, such increase shall not exceed ten percent of the then
existing space rent and may not be relied upon any more often than once in any thirty-six-month period as
the basis to increase rent. In the event of change of ownership resulting from subletting of the mobile home
space as may be allowed by state law, should such become state law, then upon any such subletting the
space rent may be increased up to ten percent of the then existing space rent. In the event of change of
ownership resulting from vacation of the space, then the space rent may be adjusted to fair market rent in
the community. Nothing in this paragraph shall preclude an adjustment as may otherwise be provided for in
this chapter.
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: Tuesday, June 24, 2025 5:01 PM
To: Matt Davies <matt@harmonycom.com>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
I apologize that the director’s review document was not enclosed. I have included it here.
The City provided the basis for enforcement on May 30, 2025. Additionally, Harmony Communities has recognized the
unit as a mobilehome consistently throughout Ms. ’s tenancy and as recently as May 1, 2025, including the
rental agreement, the unlawful detainer action and settlement, and the Information for Prospective Homeowners
document. The Mobile Home Park Rent Stabilization Ordinance is not as narrowly applicable as Harmony
Communities appears to believe. Further, Ms. was entitled to occupy the mobilehome under her lease until
her tenancy was terminated, and the unlawful detainer action has no effect on the applicability of SLOMC 5.44.060(C),
202
which prohibits increases in excess of 10% upon change in ownership; that is, the protection contemplated by that
section is as to the space (for continuity of affordability) and not to the existing/former resident. SLOMC 5.44.010(E)
clarifies the legislative intent. Again, please refer to my letter dated May 30, 2025, attached again here. The
applicability of H&S 18009.3 and 18010 on a mobilehome unit that has been in place as a primary residence since,
according to the records you have provided, at least 2018 is unclear to me, so I cannot respond to that particular
argument.
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: Tuesday, June 24, 2025 3:41 PM
To: Symens, Sadie <ssymens@slocity.org>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello Sadie,
That’s unfortunate. Your characterization of our characterization is inaccurate. We don’t characterize it in any
manner. It’s not up to us. We simply follow state law. State law defines what an RV is. See H&S 18009.3 and 18010. A
park model is a type of RV.
https://www.aamva.org/policy/policy-positions/recreational-park-
trailer#:~:text=A%20park%20model%20recreational%20vehicle,feet%20in%20the%20setup%20mode .
https://www.gorving.com/explore-rvs/park-model-
rvs#:~:text=The%20Seasonal%20RV,the%20possible%20features%20and%20amenities .
https://www.championhomes.com/our-homes/park-model-
rv#:~:text=What%20is%20a%20Park%20Model,U.S.%20and%20most%20Canadian%20provinces.\
203
It seems that you are having an issue based on what you see visually. The above links will help you understand that this is
indeed an Rvand will give you more insight on the product type. It still has its wheels and axels attached, and the hitch is
located underneath the unit.
The NOV does not have an enclosure. Please email me the enclosure and we will file with the director.
Further, please respond to the points made in Jason’s email so we may understand the city’s position related to
recreational vehicles and tenancies.
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: Tuesday, June 24, 2025 3:28 PM
To: Matt Davies <matt@harmonycom.com>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
Thank you for confirming receipt of the notice of violation. We do not intend to rescind the Notice. Information on
requesting a director’s review is on page 2 of the Notice of Violation.
So that I am clear, can you confirm that the unit Harmony Communities is characterizing as an RV is the unit depicted
in the photo attached?
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
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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
204
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: Tuesday, June 24, 2025 3:03 PM
To: Symens, Sadie <ssymens@slocity.org>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello Sadie,
Please see the attached registration for the 23/24 year. Since this is an RV(vehicle), you only get one pink slip on
purchase. It is attached. The DMV issued a new pink slip to after she purchased it. The attached was also
posted on the door of her unit today. Please advise if you will be rescinding in light of Jason’s email. Otherwise, we
dispute the violation and request a hearing. Please advise as to the process to dispute this violation.
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: Tuesday, June 24, 2025 1:57 PM
To: Jason Dilday <jason@harmonycom.com>
Cc: Matt Davies <matt@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
Thank you for that information. Could you please provide registration and title for the year you sold the unit to
? The one you attached was from 2018.
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
205
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. ’s RV at Space .
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. ’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. 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. 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.
206
In summary, the Ordinance’s protections do not extend to Ms. ’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. ’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>
207
City Attorney's Office
E ssymens@slocity.org
slocity.org
<image002.png>
<image003.png>
<image004.png>
<image005.png>
<image006.png>
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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.
208
The City reiterates its invitation to discuss this matter and/or Ms. ’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>
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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 as reflected in the
Information for Prospective Homeowners document dated May 1, 2025, and that all statements
of space rent for Space 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.
209
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>
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 at
South Peak Mobile Home Park.
210
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
E ssymens@slocity.org
slocity.org
<image002.png>
<image003.png>
<image004.png>
<image005.png>
<image006.png>
211
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-
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copies of this email with publicly accessible records. If you are not the designated addressee
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you received this document through inadvertent error and any further review, dissemination,
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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>
212
From:Symens, Sadie
Sent:Tuesday, June 24, 2025 5:01 PM
To:Matt Davies; Jason Dilday
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 (1).pdf; Request for Director's Review.pdf
Hello,
I apologize that the director’s review document was not enclosed. I have included it here.
The City provided the basis for enforcement on May 30, 2025. Additionally, Harmony Communities has recognized the
unit as a mobilehome consistently throughout Ms. ’s tenancy and as recently as May 1, 2025, including the
rental agreement, the unlawful detainer action and settlement, and the Information for Prospective Homeowners
document. The Mobile Home Park Rent Stabilization Ordinance is not as narrowly applicable as Harmony
Communities appears to believe. Further, Ms. was entitled to occupy the mobilehome under her lease until
her tenancy was terminated, and the unlawful detainer action has no effect on the applicability of SLOMC 5.44.060(C),
which prohibits increases in excess of 10% upon change in ownership; that is, the protection contemplated by that
section is as to the space (for continuity of affordability) and not to the existing/former resident. SLOMC 5.44.010(E)
clarifies the legislative intent. Again, please refer to my letter dated May 30, 2025, attached again here. The
applicability of H&S 18009.3 and 18010 on a mobilehome unit that has been in place as a primary residence since,
according to the records you have provided, at least 2018 is unclear to me, so I cannot respond to that particular
argument.
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.
213
From: Matt Davies <matt@harmonycom.com>
Sent: Tuesday, June 24, 2025 3:41 PM
To: Symens, Sadie <ssymens@slocity.org>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello Sadie,
That’s unfortunate. Your characterization of our characterization is inaccurate. We don’t characterize it in any
manner. It’s not up to us. We simply follow state law. State law defines what an RV is. See H&S 18009.3 and 18010. A
park model is a type of RV.
https://www.aamva.org/policy/policy-positions/recreational-park-
trailer#:~:text=A%20park%20model%20recreational%20vehicle,feet%20in%20the%20setup%20mode .
https://www.gorving.com/explore-rvs/park-model-
rvs#:~:text=The%20Seasonal%20RV,the%20possible%20features%20and%20amenities .
https://www.championhomes.com/our-homes/park-model-
rv#:~:text=What%20is%20a%20Park%20Model,U.S.%20and%20most%20Canadian%20provinces.\
It seems that you are having an issue based on what you see visually. The above links will help you understand that this is
indeed an Rvand will give you more insight on the product type. It still has its wheels and axels attached, and the hitch is
located underneath the unit.
The NOV does not have an enclosure. Please email me the enclosure and we will file with the director.
Further, please respond to the points made in Jason’s email so we may understand the city’s position related to
recreational vehicles and tenancies.
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: Tuesday, June 24, 2025 3:28 PM
To: Matt Davies <matt@harmonycom.com>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
Thank you for confirming receipt of the notice of violation. We do not intend to rescind the Notice. Information on
requesting a director’s review is on page 2 of the Notice of Violation.
So that I am clear, can you confirm that the unit Harmony Communities is characterizing as an RV is the unit depicted
in the photo attached?
Thank you,
214
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: Tuesday, June 24, 2025 3:03 PM
To: Symens, Sadie <ssymens@slocity.org>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello Sadie,
Please see the attached registration for the 23/24 year. Since this is an RV(vehicle), you only get one pink slip on
purchase. It is attached. The DMV issued a new pink slip to after she purchased it. The attached was also
posted on the door of her unit today. Please advise if you will be rescinding in light of Jason’s email. Otherwise, we
dispute the violation and request a hearing. Please advise as to the process to dispute this violation.
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: Tuesday, June 24, 2025 1:57 PM
To: Jason Dilday <jason@harmonycom.com>
Cc: Matt Davies <matt@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
215
Thank you for that information. Could you please provide registration and title for the year you sold the unit to
? The one you attached was from 2018.
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. ’s RV at Space .
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. ’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. 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
216
mobile home.” The RV is required to remain vacant until sold, meaning Ms. 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. ’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. ’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
217
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>
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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,
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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.
218
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. ’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
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<image003.png>
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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.
219
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 as reflected in the
Information for Prospective Homeowners document dated May 1, 2025, and that all statements
of space rent for Space 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>
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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
220
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 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>
221
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
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<Letter to South Peak Mobile Home Park 053025.pdf>
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 ’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 .
Ms. ’s counsel reports that South Peak declines to recognize Ms. 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. 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. ’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 , notwithstanding the unlawful detainer filed against Ms.
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 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
REQUEST FOR DIRECTOR’S REVIEW
Person Requesting Review: __________________________________ Phone: ________________
Address: _____________________________________Email: ______________________________
Property Owner: ______ Tenant: _____ Case #: ______________________
Address of alleged violation: _________________________________________________________
Date of Notice to Correct/Violation: ____________________________________________________
Please identify the code violation or interpretation you are contesting. Please provide relevant
information and explain why the alleged violation or interpretation should be reconsidered. You
may attach additional pages, if necessary.
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
I hereby request a review of alleged violation or interpretation by the Community Development Director.
Signature of Appellant: _______________________________________ Date: ______________
Please return form to: City of San Luis Obispo,
Community Development Department
919 Palm Street
San Luis Obispo, CA 93401
or
Email: code@slocity.org
COMPLETED FORM MUST BE RECEIVED BY THE COMMUNITY DEVELOPMENT
DEPARTMENT WITHIN 5 DAYS OF THE DATE OF THE NOTICE TO CORRECT/VIOLATION.
232
From:Symens, Sadie
Sent:Tuesday, June 24, 2025 3:28 PM
To:Matt Davies; Jason Dilday
Subject:RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance
Attachments:Image (1).jpg
Hello,
Thank you for confirming receipt of the notice of violation. We do not intend to rescind the Notice. Information on
requesting a director’s review is on page 2 of the Notice of Violation.
So that I am clear, can you confirm that the unit Harmony Communities is characterizing as an RV is the unit depicted
in the photo attached?
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: Tuesday, June 24, 2025 3:03 PM
To: Symens, Sadie <ssymens@slocity.org>; Jason Dilday <jason@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello Sadie,
Please see the attached registration for the 23/24 year. Since this is an RV(vehicle), you only get one pink slip on
purchase. It is attached. The DMV issued a new pink slip to after she purchased it. The attached was also
233
posted on the door of her unit today. Please advise if you will be rescinding in light of Jason’s email. Otherwise, we
dispute the violation and request a hearing. Please advise as to the process to dispute this violation.
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: Tuesday, June 24, 2025 1:57 PM
To: Jason Dilday <jason@harmonycom.com>
Cc: Matt Davies <matt@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
Thank you for that information. Could you please provide registration and title for the year you sold the unit to
? The one you attached was from 2018.
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>
234
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. ’s RV at Space .
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. ’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. 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. 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. ’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. ’s purchase agreement.
Thank you.
Jason Dilday
949-891-1627
235
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
<image002.png>
<image003.png>
<image004.png>
<image005.png>
<image006.png>
Stay connected with the City by signing up for e-notifications
236
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. ’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
237
E ssymens@slocity.org
slocity.org
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<image003.png>
<image004.png>
<image005.png>
<image006.png>
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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 as reflected in the
Information for Prospective Homeowners document dated May 1, 2025, and that all statements
of space rent for Space 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>
238
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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 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.
239
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
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you received this document through inadvertent error and any further review, dissemination,
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240
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>
241
From:Matt Davies <matt@harmonycom.com>
Sent:Tuesday, June 24, 2025 3:03 PM
To:Symens, Sadie; Jason Dilday
Subject:RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance
Attachments: .pdf; IMG_7853.jpeg
Hello Sadie,
Please see the attached registration for the 23/24 year. Since this is an RV(vehicle), you only get one pink slip on
purchase. It is attached. The DMV issued a new pink slip to after she purchased it. The attached was also
posted on the door of her unit today. Please advise if you will be rescinding in light of Jason’s email. Otherwise, we
dispute the violation and request a hearing. Please advise as to the process to dispute this violation.
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: Tuesday, June 24, 2025 1:57 PM
To: Jason Dilday <jason@harmonycom.com>
Cc: Matt Davies <matt@harmonycom.com>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance
Hello,
Thank you for that information. Could you please provide registration and title for the year you sold the unit to
? The one you attached was from 2018.
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
242
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. ’s RV at Space .
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. ’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. 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. 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.
243
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. ’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. ’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.
244
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
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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,
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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,
245
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. ’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>
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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,
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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 as reflected in the
Information for Prospective Homeowners document dated May 1, 2025, and that all statements
of space rent for Space 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.
246
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>
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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,
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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
247
Hi Judy,
I’m following up on the City’s letter regarding the proposed 108% rent increase for Space 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
E ssymens@slocity.org
slocity.org
<image002.png>
248
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you received this document through inadvertent error and any further review, dissemination,
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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>
249
From:Mariah Thompson <mthompson@crla.org>
Sent:Tuesday, June 24, 2025 1:47 PM
To:Symens, Sadie
Cc:Patsy Van Dyke
Subject:Re: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent
Stabilization Ordinance - South Peak/
Attachments:RT_ESCROW_AND_TITLE_SEARCHES_run_on_24-Jun-2025.pdf
I have not been to the park and our local attorney on this case, Evan, is currently out of office. But that looks like a
park model unit and has the same address so I don't see any reason that wouldn't be the correct unit.
Attached is the title search for the unit. I have sent additional questions to the registration/titling department because of
discrepancies between the title and the sales contract. I am specifically asking HCD whether titling should currently be
going through HCD or DMV. I am wondering if Harmony failed to follow the appropriate process when it acquired the
unit and then sold the unit. It looks like the unit HCD registration has not been updated in a long time and was never
updated with CA MHP Investors 3, LLC (Bruce Davies/Harmony company) as the legal owner. Notably, Harmony also
did not produce to you a recent registration-- they produced a DMV registration from 2018. If I were you, I would ask
Harmony for the registration and title for the year that they sold the unit to CRLA's client.
Mariah Thompson she/her/ella | Senior Litigator
California Rural Legal Assistance, Inc.
mthompson@crla.org
(559) 441-8721
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: Tuesday, June 24, 2025 11:04 AM
To: Mariah Thompson <mthompson@crla.org>
Cc: Patsy Van Dyke <pvandyke@crla.org>
Subject: Re: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance - South Peak/
Thank you. I drove by Space . Could you confirm that this is your client’s unit?
250
251
On Jun 24, 2025, at 9:54 AM, Mariah Thompson <mthompson@crla.org> wrote:
Good morning,
I can actually ask my contact at HCD's registration department about this. I will do this now. I would
think that it would have been but let me confirm.
Thanks,
Mariah Thompson she/her/ella | Senior Litigator
California Rural Legal Assistance, Inc.
<C2_signature_msg_60437b2c-1a55-4bd4-933f-6012a97256b3.png>
mthompson@crla.org
<C2_signature_phone_f1f87ccc-6c1e-43c4-9096-0c070108fb9e.png>
(559) 441-8721
252
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: Patsy Van Dyke <pvandyke@crla.org>
Sent: Tuesday, June 24, 2025 10:52 AM
To: Symens, Sadie <ssymens@slocity.org>
Cc: Mariah Thompson <mthompson@crla.org>
Subject: Re: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance - South Peak/
Not to our knowledge.
Patsy Van Dyke | Senior Litigator
California Rural Legal Assistance, Inc.
<Image.png>
pvandyke@crla.org
<Image.png>
(831) 757-5221
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 23, 2025 5:26:07 PM
To: Patsy Van Dyke <pvandyke@crla.org>
Cc: Mariah Thompson <mthompson@crla.org>
Subject: [EXTERNAL] RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance - South Peak/
You don't often get email from ssymens@slocity.org. Learn why this is important
Hello,
Thank you for that additional information. Do you know if the unit has ever been registered with HCD? I
agree that the DMV registration is not determinative, but I just want to make sure I have all the
information. Thank you again.
Sadie Symens
pronouns she/her/hers
Deputy City Attorney
<image001.png>
City Attorney's Office
E ssymens@slocity.org
slocity.org
<image002.png>
253
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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: Patsy Van Dyke <pvandyke@crla.org>
Sent: Friday, June 20, 2025 4:04 PM
To: Symens, Sadie <ssymens@slocity.org>
Cc: Mariah Thompson <mthompson@crla.org>
Subject: RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization Ordinance -
South Peak/
Dear Ms. Symens:
Thank you for following up on this matter. Evan Harris is on vacation, so I will be the point
person on the matter (with assistance from Mariah Thompson) until at least July 7, 2025.
With respect to Mr. Dilday's arguments about Ms. 's home being a recreational
vehicle that is not subject to the City's Rent Stabilization Ordinance (RSO), I refer you to our earlier
submissions and communications. Moreover, the type of registration is not relevant for the
purpose of determining whether the RSO applies. It is not one of the criteria raised in the RSO.
Further, Mr. Dilday ignores that this unit is permanently installed, including the utility installation.
It is not "readily moved" simply attaching it to a pickup truck with a trailer hitch. It is undisputed
that this unit has been occupied as a permanent residence with the full knowledge and consent of
Harmony.
Indeed, this argument that Ms. 's home is a recreational vehicle and not a
"mobilehome" is belied by the very documents Mr. Dilday relies upon to try to deny Ms.
's ownership and legal occupancy of the site. For example, the stipulation itself refers to
the unit as a "mobilehome" in multiple places, See, e.g. Paragraphs 2, 7, and 8. Paragraph 8 also
makes clear that Harmony will continue to collect rent for the space occupied by Ms. 's
mobilehome through the time of sale. Thus, although the unit may be vacant, Ms. is the
owner of the mobilehome that legally occupies that space, and pursuant to which Harmony still
seeks to collect rent. Thus, any argument that she is not a "tenant" based on the stipulation is
unfounded. Mr. Dilday is manufacturing arguments after the fact out of thin air in a brazen attempt
to avoid application of the RSO.
254
The parties' course of conduct further confirms that the parties consider Ms. 's unit to
be a mobilehome and not a recreational vehicle for purposes of the applicability of the RSO. For
example, Harmony required Ms. to sign a 30-year lease. A long-term lease would not
have been necessary if the unit was considered a recreational vehicle that was exempt from the
RSO. Further, the information sheet distributed by Harmony for prospective purchasers also
refers to the unit as a "home" as does the sales contract or home purchase agreement signed by
Ms. when she initially purchased the unit from Harmony.
Please contact me if you require any additional information. Thank you for your prompt
consideration of this matter.
Sincerely,
Patsy Van Dyke | Senior Litigator
California Rural Legal Assistance, Inc.
<image007.png>
pvandyke@crla.org
<image008.png>
(831) 757-5221
<image009.png>
3 Williams Road, Salinas, CA 93905
<image010.jpg>
<image011.png><image012.png><image013.png><image014.png>
CRLA.org
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283
From:Symens, Sadie
Sent:Monday, June 23, 2025 5:17 PM
To:Dietrick, Christine; Tway, Timothea (Timmi)
Subject:RE: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
From: Nick Pardo <nickpardo1992@gmail.com>
Sent: Monday, June 23, 2025 4:48 PM
To: CityClerk <CityClerk@slocity.org>
Cc: Tway, Timothea (Timmi) <TTway@slocity.org>; City_Attorney <City_Attorney@slocity.org>
Subject: Re: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
Dear Mayor Stewart, City Council Members, City Attorney, and City Clerk,
In April of this year, I submitted the attached petition regarding a conflict between our mobilehome rent control
ordinance and state law (attached for context).
I am writing to follow up, as I believe state law may have already resolved this matter. The exemption in our city's
ordinance, Section 5.44.030(E), was required by a former state law (CA Civil Code § 798.17) that has since been
repealed by AB 2782. Because of this, our local exemption may no longer be legally valid.
To clarify this for everyone, I believe it would be worthwhile for the City Attorney to weigh in on this. If the city's
exemption is indeed unenforceable, simply removing the defunct section from the ordinance would eliminate
significant confusion for both residents and park owners.
Thank you for your continued consideration of this important issue.
Sincerely,
Nick Pardo
nickpardo1992@gmail.com
805-915-8122
On Mon, Apr 14, 2025 at 4:08 PM CityClerk <CityClerk@slocity.org> wrote:
BCC: Council All
284
Nick Pardo,
Thank you for taking the time to contact City Council on this topic. This is a policy related issue for the City Council’s
consideration and your message has been provided directly to them. By copy on this email, it is also being shared
with staff in our City Attorney’s Office and Community Development Department for their awareness.
City Clerk’s Office
City Administration
City Clerk's Office
990 Palm Street, San Luis Obispo, CA 93401-3218
From: Nick Pardo <nickpardo1992@gmail.com>
Sent: Monday, April 14, 2025 3:17 PM
To: E-mail Council Website <emailcouncil@slocity.org>
Subject: Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
This message is from an External Source. Use caution when deciding to open attachments, click links, or respond.
Dear Mayor Stewart and City Council Members,
Please find attached a formal petition to amend San Luis Obispo Municipal Code Title 5 Chapter 5.44, which
pertains to rent control within the city, specifically as it relates to mobilehome park tenancies.
The attached letter details how the current application of Section 5.44.030(E) creates an inequity for
mobilehome owners and conflicts with current California state law, specifically Assembly Bill 2782 (2020),
which amended California Civil Code Section 798.17.
I urge the City Council to consider this petition and take swift action to amend the ordinance. Thank you for
your time and consideration of this important matter.
Sincerely,
Nick Pardo
805-915-8122
287
From:Nick Pardo <
Sent:Monday, June 23, 2025 4:48 PM
To:CityClerk
Cc:Tway, Timothea (Timmi); City_Attorney
Subject:Re: cc Pardo - Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
Attachments:Petition to revise Municipal Code 5.44.pdf
Dear Mayor Stewart, City Council Members, City Attorney, and City Clerk,
In April of this year, I submitted the attached petition regarding a conflict between our mobilehome rent control
ordinance and state law (attached for context).
I am writing to follow up, as I believe state law may have already resolved this matter. The exemption in our city's
ordinance, Section 5.44.030(E), was required by a former state law (CA Civil Code § 798.17) that has since been
repealed by AB 2782. Because of this, our local exemption may no longer be legally valid.
To clarify this for everyone, I believe it would be worthwhile for the City Attorney to weigh in on this. If the city's
exemption is indeed unenforceable, simply removing the defunct section from the ordinance would eliminate
significant confusion for both residents and park owners.
Thank you for your continued consideration of this important issue.
Sincerely,
Nick Pardo
On Mon, Apr 14, 2025 at 4:08 PM CityClerk <CityClerk@slocity.org> wrote:
BCC: Council All
Nick Pardo,
Thank you for taking the time to contact City Council on this topic. This is a policy related issue for the City Council’s
consideration and your message has been provided directly to them. By copy on this email, it is also being shared
with staff in our City Attorney’s Office and Community Development Department for their awareness.
288
City Clerk’s Office
City Administration
City Clerk's Office
990 Palm Street, San Luis Obispo, CA 93401-3218
From: Nick Pardo <
Sent: Monday, April 14, 2025 3:17 PM
To: E-mail Council Website <emailcouncil@slocity.org>
Subject: Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
This message is from an External Source. Use caution when deciding to open attachments, click links, or respond.
Dear Mayor Stewart and City Council Members,
Please find attached a formal petition to amend San Luis Obispo Municipal Code Title 5 Chapter 5.44, which
pertains to rent control within the city, specifically as it relates to mobilehome park tenancies.
The attached letter details how the current application of Section 5.44.030(E) creates an inequity for
mobilehome owners and conflicts with current California state law, specifically Assembly Bill 2782 (2020),
which amended California Civil Code Section 798.17.
I urge the City Council to consider this petition and take swift action to amend the ordinance. Thank you for
your time and consideration of this important matter.
Sincerely,
Nick Pardo
Nick Pardo
April 14, 2025
Honorable Mayor Erica A. Stewart and City Council Members
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
Subject: Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44 Regarding Rent Control in
Mobilehome Parks
Dear Mayor Stewart and City Council Members,
I am writing to petition for an amendment to San Luis Obispo Municipal Code Title 5 Chapter 5.44, which pertains
to rent control within the city, speciflcally as it relates to mobilehome park tenancies.
The current application of Chapter 5.44.030(E) creates a severe inequity for mobilehome owners in San Luis
Obispo and necessitates immediate corrective action. The ordinance's exemption from rent control for 'tenancies
covered by leases or contracts which provide for a tenancy of more than a year' confiicts with current California
state law, causing signiflcant flnancial hardship and inequity for residents.
Assembly Bill 2782 (2020) amended California Civil Code Section 798.17. This amendment removed the automatic
exemption from local rent stabilization ordinances for long-term leases signed on or after February 13, 2020
(effective January 1, 2021) and also removed the exemption for leases signed before February 13, 2020 (Effective
January 2025). This legislative change affirms that local rent control ordinances should take precedence over
confiicting terms in these leases.
There is a signiflcant loophole within the Mobilehome Residency Law (MRL) that allows park owners to exploit the
vulnerability of individuals purchasing a home within the park. The MRL deflnes a "homeowner" as "a person who
has a tenancy in a mobilehome park under a rental agreement" [§798.9]. This deflnition leaves buyers in a
precarious position, as they do not yet qualify as "homeowners" until they sign the park's required lease. Park
owners can leverage this gap in protection to force buyers into accepting unfavorable long-term lease agreements
as a condition of residency approval, effectively circumventing the intent of the MRL to protect homeowners.
Mobilehome owners, often facing limited housing options, are frequently compelled to accept "take it or leave it"
long-term leases that impose rent increases far exceeding the protections afforded by Municipal Code Section
5.44.
The consequences of these issues can be flnancially crippling. To illustrate the potential for harm, consider the
following 20-year rent increase projections, calculated using historical Consumer Price Index (CPI) data from 2004
to 2024, and comparing San Luis Obispo city and county’s rent control scenarios to an actual long-term lease
offered by a San Luis Obispo mobilehome park. For these simulations, we will assume a starting monthly space
rent of $1000 (typical starting rent in 2025):
• Scenario 1: SLO City Rent Control - Section 5.44 (CPI with a 5% annual cap):
o Ending Monthly Rent: $1666.91
o Total Rent Paid: $314,378.88
• Scenario 2: SLO County Rent Control - Title 25 (60% of CPI):
o Ending Monthly Rent: $1385.01
o Total Rent Paid: $281,702.28
• Scenario 3: Actual Offered 20-Year Lease (CPI + 2% with a 3.9% minimum and 9% annual cap):
o Ending Monthly Rent: $2624.52
o Total Rent Paid: $402,801.00
The data clearly demonstrates that even under recent CPI conditions, long-term leases lead to a dramatic
escalation of housing costs. Residents who have no viable alternative but to sign these leases face signiflcant long
term flnancial impact, jeopardizing their housing stability and overall well-being. The signiflcant difference in both
total rent paid and the flnal monthly rent underscores the urgent need for reform. Over 20 years, a typical long -term
lease in this scenario would result in residents paying $88,422.12 more than under the cities actual rent control
ordinance, with a flnal monthly rent that is 57.4% higher. This is the flrst opportunity under the current ordinance,
for residents to gain the beneflt of San Luis Obispo's rent control provisions. By this time, the damage is done.
Crucially, the fundamental problem lies in the transfer of authority over rent increases from local government to
private corporations. San Luis Obispo's existing rent control ordinance in Chapter 5.44 refiects a balance between
ensuring fair returns for property owners and protecting residents from excessive rent hikes. This balance is
achieved through local oversight and a structure that is publicly accountable. In contrast, long -term leases
empower park owners, whose primary motivation is proflt maximization, to unilaterally determine rent increases,
often with formulas that far outpace the ability of residents on flxed incomes to keep pace.
Furthermore, these long-term leases frequently include provisions that go beyond traditional rent increases. Park
owners may pass through the costs of capital improvements or replacements to residents, often with an added
interest factor. This means residents are not only paying for the improvements but also flnancing them at a rate
determined by the park owner, further infiating their housing costs. While the scenarios presented illustrate
potential flnancial harm, the core issue is about local control. The allowable rent increases and any additional
charges should be determined by the City of San Luis Obispo, as it is for those under short-term leases under
Chapter 5.44, and not by private entities. It is not necessarily that the flnal rent under Scenario 1 is the only
acceptable outcome, but that the mechanism for determining fair and reasonable rent increases and related
charges should reside with the city, ensuring a more equitable and sustainable outcome for residents.
To align the city ordinance with current state law, I propose the following amendment to San Luis Obispo Municipal
Code Title 5, Chapter 5.44.030(E):
• Proposed Amendment: removal of Chapter 5.44.030(E).
This amendment aligns with Assembly Bill 2782 and Civil Code 798.17, ensuring that all mobilehome park
residents are afforded the protections of the city's rent control ordinance, preventing the exploitation of residents
through mandatory, long-term leases and addressing the vulnerability of new homeowners during the purchase
process.
I urge the City Council to take swift action on this critical issue. Thank you for your time and consideration.
Sincerely,
Nick Pardo
291
From:Patsy Van Dyke <pvandyke@crla.org>
Sent:Friday, June 20, 2025 4:04 PM
To:Symens, Sadie
Cc:Mariah Thompson
Subject:RE: Notice of potential violation of San Luis Obispo Mobile Home Park Rent Stabilization
Ordinance - South Peak/
Attachments:March 12 UD Stipulation Agreement.pdf
Dear Ms. Symens:
Thank you for following up on this matter. Evan Harris is on vacation, so I will be the point person on the
matter (with assistance from Mariah Thompson) until at least July 7, 2025.
With respect to Mr. Dilday's arguments about Ms. 's home being a recreational vehicle that is not
subject to the City's Rent Stabilization Ordinance (RSO), I refer you to our earlier submissions and
communications. Moreover, the type of registration is not relevant for the purpose of determining whether the
RSO applies. It is not one of the criteria raised in the RSO. Further, Mr. Dilday ignores that this unit is
permanently installed, including the utility installation. It is not "readily moved" simply attaching it to a pickup
truck with a trailer hitch. It is undisputed that this unit has been occupied as a permanent residence with the full
knowledge and consent of Harmony.
Indeed, this argument that Ms. 's home is a recreational vehicle and not a "mobilehome" is belied
by the very documents Mr. Dilday relies upon to try to deny Ms. 's ownership and legal occupancy of
the site. For example, the stipulation itself refers to the unit as a "mobilehome" in multiple places, See, e.g.
Paragraphs 2, 7, and 8. Paragraph 8 also makes clear that Harmony will continue to collect rent for the space
occupied by Ms. 's mobilehome through the time of sale. Thus, although the unit may be vacant, Ms.
is the owner of the mobilehome that legally occupies that space, and pursuant to which Harmony still
seeks to collect rent. Thus, any argument that she is not a "tenant" based on the stipulation is unfounded. Mr.
Dilday is manufacturing arguments after the fact out of thin air in a brazen attempt to avoid application of the
RSO.
The parties' course of conduct further confirms that the parties consider Ms. 's unit to be a
mobilehome and not a recreational vehicle for purposes of the applicability of the RSO. For example, Harmony
required Ms. to sign a 30-year lease. A long-term lease would not have been necessary if the unit was
considered a recreational vehicle that was exempt from the RSO. Further, the information sheet distributed by
Harmony for prospective purchasers also refers to the unit as a "home" as does the sales contract or home
purchase agreement signed by Ms. when she initially purchased the unit from Harmony.
Please contact me if you require any additional information. Thank you for your prompt consideration of this
matter.
Sincerely,
Patsy Van Dyke | Senior Litigator
California Rural Legal Assistance, Inc.
pvandyke@crla.org
292
(831) 757-5221
3 Williams Road, Salinas, CA 93905
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.
299
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 .pdf
Hello all,
I received the below from Harmony Communities regarding Ms. ’s space. Yesterday, I communicated the
City’s intent to proceed with administrative enforcement after June 25th absent information that Ms. ’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.
’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,
300
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. ’s RV at Space .
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. ’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. 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. 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. ’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. ’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
301
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>
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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,
302
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. ’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>
303
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 as reflected in the
Information for Prospective Homeowners document dated May 1, 2025, and that all statements
of space rent for Space 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>
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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-
304
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 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
305
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(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>
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<Letter to South Peak Mobile Home Park 053025.pdf>
348
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
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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
349
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 as reflected in the Information for Prospective
Homeowners document dated May 1, 2025, and that all statements of space rent for Space 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
350
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 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
351
Deputy City Attorney
City Attorney's Office
E ssymens@slocity.org
slocity.org
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designated addressee named above. The information transmitted is subject to the attorney-client privilege
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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.
361
From:Evan Harris <eharris@crla.org>
Sent:Wednesday, June 18, 2025 2:55 PM
To:Symens, Sadie
Subject:Re: [EXTERNAL] Email from
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 , 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 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
Hi Evan,
A few follow-up questions, if you are able to answer them:
362
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
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.
363
From: Symens, Sadie <ssymens@slocity.org>
Sent: Monday, June 16, 2025 2:11 PM
To: Evan Harris <eharris@crla.org>
Subject: [EXTERNAL] Email from
Hello Evan,
I received the attached email from, purportedly, . 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 . 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 , 145 South Street, San Luis Obispo
Dear Ms. Tsai,
As you are aware, I represent , the owner of the mobile home located at Space
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.
and were copied on the email correspondence between Ms. 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. 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
364
From:Symens, Sadie
Sent:Wednesday, June 18, 2025 9:34 AM
To:Evan Harris
Subject:RE: [EXTERNAL] Email from
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
Hello Sadie,
365
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
Hello Evan,
I received the attached email from, purportedly, . 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 . 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.
414
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.
415
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.
416
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. ’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
417
Hi Judy,
I’m following up on the City’s letter regarding the proposed 108% rent increase for Space 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
418
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.
477
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
478
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.
479
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 ’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 .
Ms. ’s counsel reports that South Peak declines to recognize Ms. 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. 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. ’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 , notwithstanding the unlawful detainer filed against Ms.
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 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
483
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. ’s primary
residence since then? If not, when did the trailer become Ms. ’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. 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. authorize disclosure of details of her tenancy to South Peak?
Given Ms. ’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.
484
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 , a resident of Space 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. owns a 2018 Champion Redman Park Model RV—commonly referred to as a park trailer—located
at Space . 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. , 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. 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. 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. 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
485
under a court-approved settlement. By remaining in possession under the agreement and conducting a
sale, Ms. should still qualify for the ordinance’s protections.
2. Ms. does not own a “mobile home.” It is true that Ms. ’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. 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. ’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. 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
486
CRLA.org
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493
From:City of San Luis Obispo, CA <slocitywebmaster@enotify.visioninternet.com>
Sent:Tuesday, May 13, 2025 3:00 PM
To:Amberg, Mark
Subject:Consumer complaint
Message submitted from the <City of San Luis Obispo, CA> website.
Site Visitor Name:
I have a mobile home in a mobile home park in San Luis Obispo belonging to Harmony Communities called
South Peak Mobile Home Park @ 145 South St. has raised land leases for many potential new owners 50% in
one year instead following the city ordinance of no more than 10% per year.
499
From:Dietrick, Christine
Sent:Tuesday, April 22, 2025 8:58 AM
To:Symens, Sadie; Williams, Leanne
Subject:FW: Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
Attachments:Petition to revise Municipal Code 5.44.pdf
From: Nick Pardo <
Sent: Monday, April 14, 2025 3:17 PM
To: E-mail Council Website <emailcouncil@slocity.org>
Subject: Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44
This message is from an External Source. Use caution when deciding to open attachments, click links, or respond.
Dear Mayor Stewart and City Council Members,
Please find attached a formal petition to amend San Luis Obispo Municipal Code Title 5 Chapter 5.44, which
pertains to rent control within the city, specifically as it relates to mobilehome park tenancies.
The attached letter details how the current application of Section 5.44.030(E) creates an inequity for
mobilehome owners and conflicts with current California state law, specifically Assembly Bill 2782 (2020),
which amended California Civil Code Section 798.17.
I urge the City Council to consider this petition and take swift action to amend the ordinance. Thank you for your
time and consideration of this important matter.
Sincerely,
Nick Pardo
Nick Pardo
1255 Orcutt Road SPC B1
April 14, 2025
Honorable Mayor Erica A. Stewart and City Council Members
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
Subject: Petition to Amend San Luis Obispo Municipal Code Title 5, Chapter 5.44 Regarding Rent Control in
Mobilehome Parks
Dear Mayor Stewart and City Council Members,
I am writing to petition for an amendment to San Luis Obispo Municipal Code Title 5 Chapter 5.44, which pertains
to rent control within the city, speciflcally as it relates to mobilehome park tenancies.
The current application of Chapter 5.44.030(E) creates a severe inequity for mobilehome owners in San Luis
Obispo and necessitates immediate corrective action. The ordinance's exemption from rent control for 'tenancies
covered by leases or contracts which provide for a tenancy of more than a year' confiicts with current California
state law, causing signiflcant flnancial hardship and inequity for residents.
Assembly Bill 2782 (2020) amended California Civil Code Section 798.17. This amendment removed the automatic
exemption from local rent stabilization ordinances for long-term leases signed on or after February 13, 2020
(effective January 1, 2021) and also removed the exemption for leases signed before February 13, 2020 (Effective
January 2025). This legislative change affirms that local rent control ordinances should take precedence over
confiicting terms in these leases.
There is a signiflcant loophole within the Mobilehome Residency Law (MRL) that allows park owners to exploit the
vulnerability of individuals purchasing a home within the park. The MRL deflnes a "homeowner" as "a person who
has a tenancy in a mobilehome park under a rental agreement" [§798.9]. This deflnition leaves buyers in a
precarious position, as they do not yet qualify as "homeowners" until they sign the park's required lease. Park
owners can leverage this gap in protection to force buyers into accepting unfavorable long-term lease agreements
as a condition of residency approval, effectively circumventing the intent of the MRL to protect homeowners.
Mobilehome owners, often facing limited housing options, are frequently compelled to accept "take it or leave it"
long-term leases that impose rent increases far exceeding the protections afforded by Municipal Code Section
5.44.
The consequences of these issues can be flnancially crippling. To illustrate the potential for harm, consider the
following 20-year rent increase projections, calculated using historical Consumer Price Index (CPI) data from 2004
to 2024, and comparing San Luis Obispo city and county’s rent control scenarios to an actual long-term lease
offered by a San Luis Obispo mobilehome park. For these simulations, we will assume a starting monthly space
rent of $1000 (typical starting rent in 2025):
• Scenario 1: SLO City Rent Control - Section 5.44 (CPI with a 5% annual cap):
o Ending Monthly Rent: $1666.91
o Total Rent Paid: $314,378.88
• Scenario 2: SLO County Rent Control - Title 25 (60% of CPI):
o Ending Monthly Rent: $1385.01
o Total Rent Paid: $281,702.28
• Scenario 3: Actual Offered 20-Year Lease (CPI + 2% with a 3.9% minimum and 9% annual cap):
o Ending Monthly Rent: $2624.52
o Total Rent Paid: $402,801.00
The data clearly demonstrates that even under recent CPI conditions, long-term leases lead to a dramatic
escalation of housing costs. Residents who have no viable alternative but to sign these leases face signiflcant long
term flnancial impact, jeopardizing their housing stability and overall well-being. The signiflcant difference in both
total rent paid and the flnal monthly rent underscores the urgent need for reform. Over 20 years, a typical long -term
lease in this scenario would result in residents paying $88,422.12 more than under the cities actual rent control
ordinance, with a flnal monthly rent that is 57.4% higher. This is the flrst opportunity under the current ordinance,
for residents to gain the beneflt of San Luis Obispo's rent control provisions. By this time, the damage is done.
Crucially, the fundamental problem lies in the transfer of authority over rent increases from local government to
private corporations. San Luis Obispo's existing rent control ordinance in Chapter 5.44 refiects a balance between
ensuring fair returns for property owners and protecting residents from excessive rent hikes. This balance is
achieved through local oversight and a structure that is publicly accountable. In contrast, long -term leases
empower park owners, whose primary motivation is proflt maximization, to unilaterally determine rent increases,
often with formulas that far outpace the ability of residents on flxed incomes to keep pace.
Furthermore, these long-term leases frequently include provisions that go beyond traditional rent increases. Park
owners may pass through the costs of capital improvements or replacements to residents, often with an added
interest factor. This means residents are not only paying for the improvements but also flnancing them at a rate
determined by the park owner, further infiating their housing costs. While the scenarios presented illustrate
potential flnancial harm, the core issue is about local control. The allowable rent increases and any additional
charges should be determined by the City of San Luis Obispo, as it is for those under short-term leases under
Chapter 5.44, and not by private entities. It is not necessarily that the flnal rent under Scenario 1 is the only
acceptable outcome, but that the mechanism for determining fair and reasonable rent increases and related
charges should reside with the city, ensuring a more equitable and sustainable outcome for residents.
To align the city ordinance with current state law, I propose the following amendment to San Luis Obispo Municipal
Code Title 5, Chapter 5.44.030(E):
• Proposed Amendment: removal of Chapter 5.44.030(E).
This amendment aligns with Assembly Bill 2782 and Civil Code 798.17, ensuring that all mobilehome park
residents are afforded the protections of the city's rent control ordinance, preventing the exploitation of residents
through mandatory, long-term leases and addressing the vulnerability of new homeowners during the purchase
process.
I urge the City Council to take swift action on this critical issue. Thank you for your time and consideration.
Sincerely,
Nick Pardo