Motion for Injunctive and Declaratory Relief — Alvarado v. CUIAB

Record facts

U.S. District Court for the Eastern District of California · No. 2:23-cv-03041-TLN-CSK · Doc. 18 · 2024-08-07 · Docket on CourtListener

Summary

A pro se motion for injunctive and declaratory relief by Lance Delon Alvarado, filed August 7, 2024 as Document 18 in No. 2:23-cv-03041-TLN-CSK in the U.S. District Court for the Eastern District of California, and also captioned with Ninth Circuit Docket No. 24-2049. Written on an interpleader complaint form, it names as defendants a property manager, Sunset Valley Mercy Housing California 63, L.P., a tenant and a landlord. The motion states that the property manager and the housing company demanded that he sign a lease or move out of the tenant's home while he pursues a Pandemic Unemployment Assistance complaint against the State of California, EDD and CUIAB seeking damages in excess of $75,000. It cites the First Amendment and 15 USC 9021(a)(3)(A) for jurisdiction and 28 U.S.C. § 1397 for venue. It asks that the costs of a new lease be awarded to his new landlord.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Case 2:23-cv-03041-TLN-CSK Documenti18_ Filed 08/07/24 Page 1 of 13

UNITED STATES NINTH CIRCUIT COURT OF APPEAL
MARITIME JURISDICTION

Docket No.24-2049
Case No. 2:23-cv-03041-TLN-KJN

Plaintiff(s) )
(Write the full name of each plaintiff who is filing this complaint. )
THE UNITED STATES OF AMERICA
AND
LANCE DELON ALVARADO
~v- )
ANGELIQUE RODRIGUEZ
SUNSET VALLEY
MERCY HOUSING
CALIFORNIA 63, L.P
VIRGINIA BLACK
CECILLIA BREDESON
)
)
)
) Defendant(s)

(Write the full name of each defendant who is being sued. If the ) names

of all the defendants cannot fit in the space above, please _) write “see
attached” in the space and attach an additional page )
with the full list of names.)

MOTION FOR INJUNCTIVE AND DECLARATORY RELIEF

The Parties to This motion A. The APPELLANT(s) requesting
Provide the information below for each APPELLANT named in the complaint. Attach additional pages

if needed.
Name. THE UNITED STATES OF AMERICA
AND
LANCE DELON ALVARADO

Street Address. 1553 CATALPA ST
City and County. Olivehurst County of Yuba

State and Zip Code. California 95961 REC EIV E D

Telephone Number. (775) 899-2632 AUG 07 2024

E-mail Address.
CLERK, U.S. DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA
fa

BY 4.
DEPUTY We Page | of 17

B.The Defendant(s) in INJUNCTIVE RELIEF

Provide the information below for each DEFENDANT named in the complaint, whether the defendant is
an individual, a government agency, an organization, or a corporation. For an individual defendant,
include the person’s job or title (known). Attach additional pages if needed.

Defendant No. |

Name. ANGELIQUE RODRIGUEZ

Job or title PROPERTY MANAGER

Street Address. 512 SPRUCE AVE

City and County. WHEATLAND County of YUBA
State and Zip Code. CALIFORNIA 95692
Telephone Number E-mail Address (if known)

Defendant No. 2.

Name SUNSET VALLEY MERCY HOUSING CALIFORNIA 63. LP (“LANDLORD”)
Job or Title (if known) LANDLORD FOR VIRGINIA BLACK

Street Address 512 SPRUCE AVE

City and County WHEATLAND COUNTY YUBA

State and Zip Code CALIFORNIA 95692

Telephone Number E-mail Address (if known)

Defendant No. 3

Name VIRGINIA BLACK

Job or Tithe TENANT)

Address 803 EVERGREEN #A

City and County WHEATLAND COUNTY OF YUBA

State and Zip Code CALIFORNIA 95692

Telephone Number E-mail Address (530) 641-7202 virginiasonestopbeauty.com

Page 2 of 17

Case 2:23-cv-03041-TLN-CSK Documenti18_ Filed 08/07/24 Page 3 of 13

olaint for Internleader and Declaratory Relie
a Oe eee An aor nl

Defendant No. 4
Name CECILLIA BREDESON
Job or Title (if known) LANDLORD FOR LANCE ALVARADO
Street Address 1553 CATALPA
City and County OLIVEHURST County YUBA
State and Zip Code CALIFORNIA 95691
Telephone Number (530) 315-4680
E-mail Address (if known)

Basis for Jurisdiction and Venue

There are two types of interpleader actions, each brought under a different provision. Which type of
interpleader action are you bringing? (check one)

’1 am bringing this interpleader action under Federal Rule of Civil Procedure 22. (Fill out Section
A below.)

’T am bringing this interpleader action under 28 U.S.C. § 1335. (Fill out Section B below.)

A. Interpleader Action Under Rule 22

1. Jurisdiction is proper because the action (check all that apply):

, arises under a federal statute, a federal treaty, and/or a provision of the United States

Constitution (specify the relevant statutory, treaty, and/or constitutional provisions): FIRST
AMENDMENT, PANDEMIC UNEMPLOYMENT ASSISTANCE CER 625.12, [15

USC 9021(a)(3)(A)

, meets the jurisdictional requirements of 28 U.S.C. § 1332, under which no plaintiff
may be a citizen of the same State as any defendant, and the amount at stake must
exceed the sum or value of $75,000:

a. The APPELLANT(s) is an individual named LANCE DELON ALVARADO and is a citizen of the
State of NEVADA.

If the APPELLANT(S) is a corporation LANCE DELON ALVARADO, is incorporated under the laws
of the State of. NEVADA , and have TEMPORARY Business in the State of CALIIFORNIA

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Case 2:23-cv-03041-TLN-CSK Documenti8_ Filed 08/07/24 Page 4 of 13

(If more than one plaintiff is named in the complaint, attach an additional page
providing the same information for each additional plaintiff.)

b. The Defendant(s)

i. Ifthe defendant is an individual

The defendant, ANGELIQUE RODRIGUEZ, is a citizen of the State of CALIFORNIA

Or is a citizen of (foreign nation)

i. Ifthe defendant is a
corporation The defendant is
SUNSET VALLEY MERCY
HOUSING CALIFORNIA 63, L..P.
incorporated under the laws of the
UNITED STATES OF AMERICA
and has its principal place of
business in the State of CALIFORNIA.
Or is incorporated under the laws of
California , and has its principal

place of business in California

(If more than one defendant is named in the complaint, attach an additional page
providing the same information for each additional defendant.)

b. The Amount in Controversy The amount in controversy—the amount the plaintiff claims the
defendant owes or the amount at stake—is more than $75,000, not counting interest and costs of

court, because (explain): APPELLANT HAS GIVEN NOTICE TO THE PROPERTY

Page 4 of 17

Case 2:23-cv-03041-TLN-CSK Documenti18_ Filed 08/07/24 Page 5 of 13

plaint for Internpleader and Declaratory R

MANAGER NAMED ANGELIQUE RODRIGUEZ ON NUMEROUS OCCASSIONS OF
THE JUDICIAL PRIVILAGED INFORMATION CONTAINED REGARDING
APPELLANT'S BUISNESS WITHIN THE US DISTRICT COURT AND NINTH CIRCUIT
COURT OF APPEALS AND A PUA COMPLAINT IN PROCESS WHERE
PLAINTIFF/APPELLANT IS SEEKING DAMAGES IN EXCESS OF $75,000 FROM THE
STATE OF CALIFORNIA, EDD, AND CUIAB

c. THAT THE APPELLANT HAD INFORMED MS. RODRIGUEZ WHO IS FULLY AWARE
THAT MR ALVARADO IS THE BIOLOGICAL SON OF THE TENANT VIRGINIA BLACK
WHOSE UNDER A LEASE LOCATED AT 803 EVERGREEN # A WHEATLAND CA 95692
AND IS THE LOCATION WHERE THE PLAINTIFF/APPELLANT WAS DIRECTLY
AFFECTED BY THE PANDEMIC KNOWN AS COVID AND WHERE MR. ALVARADO IS
CURRENTLY WORKING ON PLAINTIFF/APPELLANT’S COMPLAINT AND APPEAL
AFTER YET AGAIN RETURNING TO CALIFORNIA FROM NEVADA REGARDING
THIS PUA COMPLAINT

d. THE PLAINTIFF/APPELLANT’S WHEREABOUTS AND TIME SENSITIVE
COMMUNICATION WITH COURT ARE PERTINENT TO THE PLAINTIFF’S
COMPLAINT IN PROCESS.

e. THAT MS.RODRIGUEZ MERCY HOUSING CALIFORNIA 63, L.P. CONSTANT
INTERFERENCE AND INTRUSION INCLUDING ATTACKS AGAINST HIS
CHARACTOR SEEM TO WISH TO DESTROY AND DISCREDIT
PLAINTIFF/APPELLANT’S COMPLAINT WHILE EXERCISING HIS FIRST
AMENDMENT RIGHT FOR REDRESS.

f. THAT PLAINTIFF’S COMPLAINT BRINGS QUESTIONS OF CONCERN REGARDING
FEDERAL ALOTTED FUNDING UNDER INCLUDING BUT NOT LIMITED TO 20 CFR
625.6 AND THOSE WHOM PRY, THREATEN AND EXTORT INFORMATION FROM
LITIGANTS AND WITNESSES INVOLVED IN CIVIL MATTERS THAT DO NOT
CONCERN THEM 18 CFR 1501-1512, 18 USC 878, INCLUDING CA CIVIL CODE SEC
789.3

g. THAT UPON EXAMINATION OF THE EXECUTIVE PROCESS ON RECORD IN THIS
MATTER THE COURT WILL FIND THAT IN FACT MS. RODRIGUEZ WAS LISTED AS
A WITNESS AFTER VERBALLY AGREEING TO GIVE TESTIMONY FOLLOWING A

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Case 2:23-cv-03041-TLN-CSK Documenti8_ Filed 08/07/24 Page 6 of 13

Declarator,

REQUEST FROM HER TENANT VIRGINIA BLACK AND WAS GIVEN PRIOR NOTICE
OF THE DATE AND TIME OF THE HEARING CONDUCTED BETWEEN MR
ALVARADO AND THE CUIAB BUT FAILED TO GIVE TESTIMONY AFTER
NUMEROUS ATTEMPTS TO CONTACT HER BY TELEPHONE DURING BUISNESS
HOURS.

MR ALVARADO’S CUIAB HEARING CONTINUED WHERE MS. BLACK GAVE
TESTIMONY CONFIRMING THE APPELLANT’S LOCATION ALONG WITH CECILLIA
BREDESON. BOTH WERE DEPOSED BY THE MAGISTRATE CONDUCTING THE
HEARING.

MR. ALVARADO HAS VIDEO FOOTAGE OF HIM WARNING MS. RODRIGUEZ

WHOM OBVIOUSLY FAILED TO CONSIDER HER PRIOR INVOLVMENT REGARDING
THE CUIAB HEARINGS WHERE SHE FAILED TO GIVE TESTIMONY THEN SENT
NOTICE TO MS BLACK REGARDING A LEASE VIOLATION. STATING “WE NEED
HIM TO MOVE OUT”. |

PLACING MS BLACK ON PROBATION FOR MR. ALVARADO BEING LOCATED ON
THE PROPERTY WHERE HE WAS DIRECTLY AFFECTED BY THE PANDEMIC AND
RETURNED NEVADA. RETURNED TO PETITION THE CUIAB THEN RETURNED TO
NEVADA. RETURNED FOR THE CUIAB HEARING THEN RETURNED TO NEVADA.
NOW HAS RETURNED TO PETITON HIS REDRESS IN THE US DISTRICT COURTS
WHERE MR ALVARADO IS UNABLE TO AFFORD THE COSTS OF TRAVELLING
BACK AND FORTH NOR THE COSTS OF CALIFORNIA’S SERVICE TO PARTIES AND
SUMMONS COSTS WHILE PETIONING FOR REDRESS.

THE NOTICE MS. BLACK RECEIVED HAS NAMED SUNSET VALLEY MERCY
HOUSING CALIFORNIA 63, L.P’S AS WELL AS THE PROPERTY MANAGER
ANGELUQUE RODRIGUEZ ARE DEMANDING THAT MR. ALVARADO MOVE OUT
FOR REFUSING TO SIGN A LEASE IN ORDER TO CONTINUE TO REMAIN AT MS.
BLACK’S WHERE PLAINTIFF/APPELLANT IS AIDING MS BLACK WHOM IS
DISABLED WITH HER DAILY NEEDS AND UPKEEP OF HER HOME UNDER LEASE.
WHILE LITIGATING THIS CASE

RATHER THAN MAKING AN EXCEPTION TO THEIR RULES AND ACCOMIDATE MS.
BLACK BY MODIFYING THE GUEST RESTRICTION MS. RODRIGUEZ CLAIMS

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Case 2:23-cv-03041-TLN-CSK Documenti8_ Filed 08/07/24 Page 7 of 13
THAT SHE JUST RECENTLY NOTICED MR. ALVARADO AS BEING ON THE
PROPERTY.

m. THAT MS. RODRIGUEZ IS EITHER TAKING MATTERS INTO HER OWN HANDS
REGARDING THE NOTICE SERVED TO MS. BLACK OR THAT SUNSET VALLEY
MERCY HOUSING CALIFORNIA 63, L.P ARE CONSPIRING TOGETHER AND ARE
THREATENING AND COERISING MS. BLACK UNDER FALSE PRETENSES THAT
THEY NEED THE PLAINTIFF/APPELLANT TO MOVE FOR REFUSING TO BE MS.
BLACK'S LIVE IN AID?

n. PLAINTIFF/APPELLANT IN COMPLIANCE WITH THE THREATENING DEMANDS OF
ANGELIQUE RODRIGUEZ SUNSET VALLEY MERCY HOUSING CALIFORNIA 63,
LL.P. AND THE DURESS MS. BLACK IS UNDER IS AWAITING A LEASE TO BE
SIGNED WITH CECILLIA BREDESON WHOM AGREED TO HELP.

o. MS RODRIGUEZ HAS FAILED TO CONSIDER THE DAMAGES SHE IS CAUSING
INCLUDING BUT NOT LIMITED TO LOSS OF CONSORTIUM, AND MONITARY
DAMAGES IF PLAI TIFF/APPELLANT SIGNS A LEASE WHILE PETITIONING THE
COURTS.

p. AFAIR ESTIMATION OF THE COSTS ASSOCIATED WOULD BE THE AVERAGE
PRICE OF A SECURITY DEPOSIT OF FIRST AND LAST RENT COMBINED AND THE
MONTHLY RENT OF A FULLY FURNISHED ONE BEDROOM RENTAL INCLUDING
THE PLAINTIFF/APPELLANT’S OWN CHOICE OF RENTERS AND HOME
APPLIANCE INSURANCE WITHIN YUBA COUNTY TO INSURE THE RENTAL
PROPERTY OF ANY DAMAGES OR LOSS. (LE. AAA RENTERS AND AMERICAN
HOME SHIELD COMBINED POLICIES).

q. THAT THOSE COSTS BE CONSIDERED AND AWARDED TO CECILLIA BREDESON
FOR THE NEW LANDLORD’S NEED AND ASSURANCES UNDER A LEGAL BINDING
LEASE AGREEMENT AND COSTS THAT MS. BREDESON SHOULD HAVE THE
LEGAL RIGHT TO BE INSURED AND PAID IN FULL AGAINST THE DEFENDANT(S)
ANGELIQUE RODRIGUEZ SUNSET VALLEY MERCY HOUSING CALIFORNIA 63, L.P
FOR THEIR NEED THAT THE PLAINTIFF/APPELLANT BE UNDER A LEASE,MOVE
OUT AND PROVIDE PROOF OF WHERE HE MOVED TO.

Page 7 of 17

t.

WHERE PLAINTIFF/APPELLANT MOVED IS NONE OF MS. RODRIGUEZ OR
SUNSET VALLEY MERCY HOUSING CALIFORNIA, L.P'S BUISNESS. ARE THEY
STALKING MR. ALVARADO? DO THEY WISH TO CAUSE MORE HARM OTHER
THAN THE FINANCIAL HARM A LEASE AND THE COSTS ASSOCIATED ARE
CAUSING?

BEING HOW MS. RODRIGUEZ NEEDS HIM TO SIGN A LEASE THAT COSTS MONEY
AND SUNSET VALLEY MERCY HOUSING CALIFORNIA 63, L.-P MUST BELIEVE
MONEY GROWS ON TREES KNOWING THAT THE PLAINTIFF/APPELLANT IS A
NEVADA RESIDENT AND CANT RETURN HOME BECAUSE HE DOESN’T HAVE ANY
MONEY AND STILL AWAITS HIS PUA SETTLEMENT.

DEMANDING A LEASE ON TOP OF AND INCLUDING A LEASE THAT IS IN GOOD
STANDING AND RENT IS CURRENT AND WHERE MR. ALVARADO IS NOT BEING
ANY NUISANCE OR CAUSING ANY TYPE OF TROUBLE.

WHILE MS. RODRIGUEZ CONTINUES THREATENING A LITIGANT AND COERCING
AN EXECUTIVE PROCESS WITNESS THAT WILL BE CALLED TO TESTIFY IN THIS
US DISTRICT COURT COMPLAINT/APPEAL THAT IS PENDING STATING “WE NEED
HIM TO MOVE OUT” IS CRIMINAL AS CRIMINAL CAN GET TO SAY THE LEAST.

AS WELL AS ANOTHER EXAMPLE OF THE CONTINUED DISCRIMINATION OF THE
PLAINTIFF/APPELLANT'S CHARACTER AND OBVIOUS ADMITION OF
ANGELUQUE RODRIGUEZ BY SENDING MS. BLACK A NOTICE OF LEASE
VIOLATION INCLUDING A VICTIMS OF DOMESTIC VIOLENCE INFORMATION
PACKET ATTACHED. AFTER PLAINTIFF/APPELLANT VIDEO RECORDED HIM NOT
GIVING CONSENT TO A BACKGROUND CHECK FOR HIS OWN PROTECTION
WHILE BEING COERCED TO SIGN SAID RELEASE OF PRIVATE INFORMATION.

THAT THE VIDEO WILL SHOW THE PLAINTIFF/APPELLANT PERFORMING AS A
LITIGANT OFFICER OF THE COURT INFORMING MS. RODRIGUEZ THAT HE DID
NOT CONSENT TO SIGNING AND THAT WHOMEVER PROCESSED THAT
PAPERWORK WOULD DO SO AT THEIR OWN DETRIMENT. A VIDEO THAT THE
PLAINTIFF/APPELLANT WILL BE HAPPY TO PROVIDE AS EVIDENCE. .

Page 8 of 17

x.

aa.

bb.

cc.

SUNSET VALLEY MERCY HOUSING CALIFORNIA 63, L.P CONSTANT
HARRASSMENT TOWARD THEIR TENANT WHOM HAS BEEN IN GOOD STANDING
NEARLY 10YRS AND THE DISCRIMINATION OF MR. ALVARADO WHILE
PETIONING FOR HIS PUA BENEFITS HAS FORCED PLAINTIFF_APPELLANT TO
SEEK OUT A CHANGE OF ADDRESS AND DRAFT A LEASE AGREEMENT THAT IS
READY TO BE SIGNED.

MR. ALVARADO HAS INFORMED CECILLIA BREDESON OF HIS AND MS. BLACK
BEING HARRASSED AND INTIMIDATED. WHEREAS MS. BREDESON THEN GAVE
MR. ALVARADO PERMISSION TO TEMPORARILY UTILIZE HER ADDRESS TO
CONTINUE TO RECEIVE HIS MAIL REGARDING THE PLAINTIFF/APPELLANT’S
COMPLAINT IN APPEAL WHILE HE AND HIS MOTHER ARE UNDER THREAT.

MR ALVARADO HAS DRAFTED A LEASE BETWEEN MS. BREDESON AND MR.
ALVARADO IN COMPLIANCE TO THE DEMANDS OF MS. RODRIGUEZ SUNSET
VALLEY MERCY HOUSING CALIFORNIA 63, L.P.

THAT DETRIMENT IS HOLDING MS. RODRIGUEZ SUNSET VALLEY MERCY
HOUSING CALIFORNIA 63, L.P. LIABLE FOR THE ALL COSTS ASSOCIATED FOR
THREATENING PLAINTIFF/APPELLANT WHOM IS ACTIVELY INVOLVED IN A
CIVIL COMPLAINT AGAINST THE STATE OF CALIFORNIA’S EDD AND CUIAB AND
DEPARTMENTS WITHIN THE STATE OF CALIFORNIA AND AGAINST PARTIES THAT
ARE STILL UNKNOWN DEFENDANT/APPELLEES AND HOLDING THE
PLAINTIFF/APPELLANT HARMLESS.

THAT UPON FURTHER INVESTIGATION MR. ALVARADO CHANGED HIS ADDRESS
AND A LEASE AGREEMENT IS AWAITING TO BE SIGNED AND THE COSTS
ASSOCIATED WITH THAT LEASE BE AWARDED TO CECILLIA BREDESON FOR
RENDERING AID TO MR. ALVARADO AND MS. BLACK DURING THEIR TIME OF
NEED.

MS. BREDESON HAS NOT THREATENED THE PLAINTIFF/APPELLANT AND THE
PLAINTIFF/APPELLANT HAS NOT THREATENED MS. BREDESON. AND IN FACT
ENCURAGED MS. BREDESON TO SEEK OUT AN ATTORNEY BEFORE DECIDING TO
SIGN THE LEASE THAT FULLY DISCLOSES THE PLAINTIFF/APPELLANT’S NEED
FOR IT ENTIRELY.

Page 9 of 17

I.

. Or is incorporated under the laws of ,

(foreign nation)

business in (name)

and has its principal place of

c. The Property in Controversy

The property in controversy is

Venue is proper under 28 U.S.C. § 1397 because at least one defendant, VIRGINIA BLACK is a
CITIZEN of Washoe County located in the State NEVADA and is residing in YUBA COUNTY Judicial district.

Statement of Interpleader Action

A.

Describe the property that is the subject of this interpleader action, and explain why you are in
possession of the property. Explain why each of the defendants claims an entitlement to the property.

DEFENDANT(S) CLAIM THAT MR. ALVARADO IS RESIDING AT MS. BLACK’S FOR REASONS
OTHER THAN EXERCISING HIS FIRST AMENDMENT RIGHT SEEKING REDRESS FOR
PANDEMIC UNEMPLOYMENT ASSISTANCE THAT PLAINTIFF/APPELLANT WAS FOUND
ELIGIBLE BENEFITS PAYABLE BY THE CUIAB AND STILL HAS NOT RECEIVED HIS
PROMICED PUA MONEY NOW IN PROCESS IN THE US 9"! CIRCUIT COURT OF APPEALS
WITH A VALUE IN EXCESS OF $75,000.00

MS BLACK IS A NEVADA CITIZEN HOLDING A LEASE IN GOOD STANDING WITH SUNSET
VALLEY/ MERCY HOUSING CALIFORNIA 63, L.P.

THE PLAINTIFF/APPELLANT(S) DO NOT HAVE POSSESION NOR CLAIM HAVING
POSSESSION OF ANY PROPERTY OF THE DEFENDANT’S.

THAT THE DEMANDS OF ANGELUQUE RODRIGUEZ SUNSET VALLEY MERCY HOUSING
CALIFORNIA 63, L.P TO SIGN OR PRODUCE PROOF OF A LEASE AGREEMENT ARE
KNOWINGLY CAUSING MONITARY DAMAGES TO THE PLAINTIFF/APPELLANT(S).THAT
THE DEFENDANT(S) CECILLIA BREDESON HAS GIVEN PERMISSION TO UTILIZE HER
ADDRESS AFTER LEARNING THAT THE PLAINTIFF/APPELLANT AND MS BLACK ARE
BEING THREATENED.

Page 14 of 17
THAT MS.BLACK WHO IS BEING DENIED HER FULL USE AND ENJOYMENT OF HER
RENTAL HOME UNDER A LEASE IN GOOD STANDING WHERE THE PLAINTIFF/APPELLANT
HAS BEEN EXPOSED TO DOUBLE LITIGATION BY SUNSET VALLEY MERCY HOUSING
CALIFORNIA 63, L.P AND THEIR PROPERTY MANAGER MS. RODRIGUEZ.

APPELLANT has been approved for in forma pauper status for the Plaintiff/Appellant's COMPLAINT
AND APPEAL

deposited (the property at issue) into the registry of the court

, given a bond payable to the clerk of court in the amount of $ , Which

the court has deemed proper and which is conditioned upon compliance by the plaintiff with
the future order or judgment of the court with respect to the subject matter of the controversy.

Explain why you are in great doubt as to which defendant(s) is/are entitled to the property subject to the
interpleader action. Explain why you cannot determine which claim(s) is/are valid without exposing
yourself to potential double litigation.

THAT SUNSET VALLEY MERCY HOUSING CALIFORNIA 63, L.P AND OTHER UNKNOWN
DEFENDANT(S) OR PARTIES OR DEPARTMENTS WITHIN CALIFORNIA ARE CAUSING AND
EXPOSING THE PLAINTIFF/APPELLANT TO DOUBLE LITIGATION WHILE INFRINGING AND
CAUSING DELAY

THE PLAINTIFF/APPELLANT HAS BEEN PURSUING BECOMING A LAWYER. A PURSUIT
PLAINTIFF/APPELLANT WAS WORKING ON PRIOR TO THE PANDEMIC. THAT DURING
PLAINTIFF/APPELLANT’S EXECUTIVE PROCESS PUA LITIGATION PLAINTIFF/APPELLANT
WAS FOUND ELIGIBLE PUA BENEFITS PAYABLE.

THAT WHILE PROVIDING AID TO HIS MOTHER WHOM IS ALSO A NEVADA CITIZEN AND
RESIDES IN CALIFORNIA PLAINTIFF/APPELLANT IS UNABLE TO AQUIRE WORK OR

Page 15 of 17
Case 2:23-cv-03041-TLN-CSK Document18 Filed 08/07/24 Page 12 of 13
obro Sel (Rev.12/16) Complaint for Interpleader and Declaratory Relief ed
CONTINUE PURSUING THE CAREER OF HIS CHOICE NOR AVAILABLE FOR WORK OTHER

THAN THE AID PLAINTIFF/APPELLANT IS PROVIDING MS BLACK WHILE WORKING ON
THIS US DISTRICT COURT COMPLAINT AND APPEAL IN PROCESS.

Wl. Relief

The plaintiff requests that (check all that apply):

x Each defendant be restrained from instituting any action against the plaintiff for recovery of the
property or any part of it.
x’ The defendants be required to interplead and settle among themselves their rights to the property and

that the plaintiff be discharged from all liability.
x. The plaintiff recover all costs and attorney's fees.

x The court grant any further relief as may be just and proper under the circumstances of this case.

IV. Certification and Closing

Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge, information,
and belief that this complaint: (1) is not being presented for an improper purpose, such as to harass, cause
unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a non-
frivolous argument for extending, modifying, or reversing existing law; (3) the factual contentions have
evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable
opportunity for further investigation or discovery; and (4) the complaint otherwise complies with the
requirements of Rule 11.

A. For Parties Without an Attorney
I agree to provide the Clerk’s Office with any changes to my address where case-related papers may be

served. I understand that my failure to keep a current address on file with the Clerk’s Office may result
in the dismissal of my case.

Date of signing:

7 Bey of 45 tory

Signature of Plaintiff = -

Printed Name of Plaintiff din a Lelon 74, Merealo

B. For Attorneys

Date of signing:

Page 16 of 17
Case 2:23-cv-03041-TLN-CSK Document18 Filed 08/07/24 Page 13 of 13

ompiaint for Internleader and Declaratory R

Signature of Attorney Tn VL, Ko'“da f- whiors

Printed Name of Attorney

Bar Number

Name of Law Firm

Street Address

State and Zip Code

Telephone Number

E-mail Address

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