EVIDENCE PRESERVATION CHECKLIST
Jose Segura — Unit 208, 15516 Nordhoff St, North Hills, CA
COMPLETE THESE ITEMS THIS WEEK. Do not delay.
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PHOTOGRAPHS & VIDEO (Day 1)
☐ Photograph EVERY visible mold spot — close-up with ruler for scale
☐ Photograph EVERY water stain on ceiling, walls, floors
☐ Photograph the HVAC closet and insulation
☐ Photograph any peeling paint, bubbling drywall, discoloration
☐ Photograph the exterior roof area above Unit 208 (if accessible)
☐ Photograph any damage to personal property
☐ Photograph the unit overall — showing it's uninhabitable
☐ Shoot a 5-10 minute VIDEO walkthrough narrating every issue
☐ Ensure ALL photos/videos have timestamps enabled
☐ Back up everything to cloud storage (Google Drive, iCloud, Dropbox)
☐ Email copies to Vince Caruso as a dated record
Target: 100+ photos minimum
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DOCUMENTS TO PRESERVE (Day 1-2)
☐ Air quality test results (EMSL Order #322508477)
☐ Mold remediation estimate #337 ($1,862.30)
☐ Updated remediation estimate (February 9, 2026)
☐ CC&Rs / Governing Documents (received from Josh Ochoa January 16, 2026)
☐ Maintenance request email to Josh Ochoa (October 14, 2025)
☐ ALL emails with Joshua Ochoa / California HOA Solutions
☐ ALL emails with Cristina Martinez / Mold & Water Damage Specialist
☐ ALL HOA meeting notices, agendas, and minutes
☐ The special assessment vote results (20-9)
☐ Your lease agreement with the former tenant
☐ Tenant's written notice to vacate (if any)
☐ Mortgage statements showing ongoing payments
☐ HOA assessment receipts showing you're current on dues
☐ Insurance policy (your HO-6 condo policy)
☐ Any prior maintenance requests or correspondence with HOA
☐ Asbestos testing invoice ($330)
Make 3 copies of everything: physical, digital (cloud), and with Vince
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HOA RECORDS REQUEST (Day 2-3)
Under California Civil Code §5200-5210, you have the RIGHT to inspect these records. Send a written request (certified mail) for:
☐ Current CC&Rs, Bylaws, and Rules
☐ Minutes from the meeting where the 20-9 vote occurred
☐ ALL maintenance request logs for Unit 208 and the building
☐ Most recent reserve study
☐ Financial statements (last 3 years)
☐ Master insurance policy declarations page
☐ Any roof inspection reports, bids, or engineering assessments
☐ Board meeting minutes for the past 2 years
☐ Any correspondence regarding the roof leak issue
☐ Current vendor/contractor list for building maintenance
The HOA must provide these within 10 business days (Civil Code §5210)
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MEDICAL DOCUMENTATION (Day 1-3)
☐ Schedule doctor appointment THIS WEEK
☐ Report ALL symptoms: respiratory issues, coughing, headaches, fatigue, allergies, eye irritation, sore throat
☐ Tell the doctor about mold exposure at confirmed elevated levels
☐ Ask the doctor to document the visit and note mold exposure as a potential cause
☐ Keep copies of all medical bills and records
☐ If the former tenant had health issues, ask them to document as well
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ASBESTOS TESTING (Day 2-5)
☐ DO NOT touch or disturb the HVAC insulation
☐ Hire a CA DOSH-certified asbestos inspector
☐ Get a written report regardless of results (positive or negative)
☐ If POSITIVE: remediation scope and cost increase dramatically — this strengthens the case significantly
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FINANCIAL DOCUMENTATION (Day 3-5)
Create a spreadsheet tracking ALL financial losses:
☐ Monthly mortgage payment amount
☐ Date tenant vacated
☐ Monthly rent you were receiving
☐ Total lost rental income (monthly rent × months vacant)
☐ HOA assessments paid during this period
☐ Insurance premiums paid
☐ Air quality testing cost
☐ Asbestos testing cost ($330)
☐ Any repair or mitigation costs you've paid
☐ Medical costs
☐ Travel costs to/from property for inspections
☐ Any other out-of-pocket expenses related to this issue
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CONTACT OTHER AFFECTED OWNERS (Day 3-7)
☐ Identify all 9 affected unit owners
☐ Get their names, unit numbers, email addresses, phone numbers
☐ Ask each one for a brief written statement of their damages
☐ Determine if any of them have filed complaints, hired attorneys, or have their own mold testing
☐ Propose a group meeting to discuss joint action
☐ Discuss joint representation by an HOA litigation attorney
9 owners together = much stronger case than 1 alone
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REGULATORY PREPARATION (Day 5-7)
Prepare (but do NOT file yet — save as leverage) complaints to:
☐ LA County Department of Public Health — mold contamination
☐ Los Angeles Department of Building and Safety — roof failure, water intrusion
☐ File these AFTER the 30-day demand letter deadline expires, unless conditions worsen
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INSURANCE CLAIMS (Day 3-5)
☐ File a claim under YOUR HO-6 condo insurance policy for:
- Interior water damage
- Mold damage
- Loss of use / loss of rental income
- Personal property damage (if any)
☐ The insurance company may then pursue subrogation against the HOA
☐ Demand (in writing) that the HOA file a claim under their master policy
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ONGOING DOCUMENTATION
☐ After EVERY rain: photograph any new water intrusion immediately
☐ Log every communication with the HOA (date, time, who, what was said)
☐ Save every email, letter, and text message
☐ Note any worsening of mold or conditions
☐ Note any health symptoms — date, type, severity
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Remember: The HOA's 20-9 vote against repairs is actually EVIDENCE FOR YOUR CASE. It proves they knew about the problem and chose not to fix it. Document, document, document.