Legal Docs
Legal Docs
Complaints
Original Complaint (25 pages) gDoc
First Amended Complaint (Draft) (100 pages) gDoc (updated 11/11/2024) --
First Amended Complaint - db style reference gSheet (details over 50 false statements or misrepresentations)
First Amended Complaint - Conspiracy/Comparative Fault gSheet
Second Amended Complaint (36 pages) gDoc SERVED 2/23/2025
Second Amended Complaint Declaration (8 pages) gDoc DRAFT as of 2/23/2025
Second Amended Complaint - exhibits Group 1 pdf DRAFT as of 2/23/2025
Second Amended Complaint - exhibits Group 2 (quotes) pdf DRAFT as of 2/23/2025
Declaration to Court pdf Filed 3/25/2025
Third Amended Complaint (DRAFT) gDoc PDF as of 4/14/2025, sent to Vierras for review
NOTE We started discovery w/o getting complaint through pleadings process and answered. Judge Panetta wasn't aware that was an option but the Attorneys knew it.
First Discovery Responses
Response to Plaintiffs RFA (183 pages) pdf
Response to Plaintiffs RFP (10 Pages) pdf
Photos*
VIE000005-100, Brannon VIE0000101-202, robert photos in the report?
Docs
WIN Order System (VIE000266-VIE000271)
Docs other (not linked)
(signed pre-inspection agreement, call log, proof of payment, emails)
Second Discovery Requests - Canary to Vierra
Robert Vierra
RFA - Robert ( x pages ) pdf gDoc
RFA - Robert - DEC ( x pages ) pdf gDoc
RFD - Robert ( x pages ) pdf gDoc
RFI - Robert ( x pages ) pdf gDoc
Form Interog - (x pages) pdf
Brannon Vierra
RFA - Brannon ( x pages ) pdf gDoc
RFD - Brannon ( x pages ) pdf gDoc
RFI - Brannon ( x pages ) pdf gDoc
Form Interog - (x pages) pdf
Discovery Request to B and H
Brandon to B Response
FROGs view gDoc pdf
SROGs view gDoc pdf
RFP view gDoc pdf
Robert to B
FROGs view gDoc pdf
SROGs view gDoc pdf
RFP view gDoc pdf
Brandon to H
FROGs view gDoc pdf
SROGs view gDoc pdf
RFP view gDoc pdf
Robert to H
FROGs view gDoc pdf
SROGs view gDoc pdf
RFP view gDoc pdf
Documents
2015 Report - 2015/04/14 - (38 pgs) view
Vierra report - 2021/01/28 - (52 pgs) view
Murrer Report - 2021/04/07 - (99 pgs) view
EnviroTemp report - 2021/04/15 (1 page) view
HI 1 - HI 7 Composite docs
HI 1- 2nd floor attic defects (33, 10k) view
HI 2 - Gas Furnace Combustion Hazard (14, 8k) view
HI 3 - Gas Water Heater Combustion Hazard (15, 2k) view
HI 4a - Crawl Structural Defects (40, 5k) view
HI 4b - Crawl Insl - upside down/away from heated
HI 5 - Drainage Defect - Concrete Seizing (19, 3,5k) view
HI 6 - North Yard Flooding (23, 7k) view
HI 7 - Water supply - No Hot Water view
Email w/ Vierra report before offer view
Counter Offer Acceptance view
Request for repairs view folder
Close of Escrow view
Attestation of Contractor Dave Nelson view
Witnesses to Discovery of Misrepresentation and Valuation of Misrepresentation
Bryan Canary, Plaintiff (Licensed Contractor and Real Estate Agent from Maryland)
Home Inspector, Paul Murrer, Murruer Home Inspections, identified all defects (HI1-HI7) on 4/7/2021
HVAC Inspector, Jason Martin, Enviro Temp, identified HI 1 and HI2 on 4/15/2021.
Contractor, Dave Nelson (can make statement about crawl and others. , has not yet)
Two Contractors who did Estimates ( assessed damage from quote worksheets and HI1 through HI7. )
Exhibits - Home Inspection Reports
Vierra report - 2021/01/28 - (52 pgs) view
Murrer Report - 2021/04/05 - (99 pgs) view
EnviroTemp report - 2021/04/15 (1 page) view
2015 Report - 2015/04/14 - (38 pgs) view
Exhibits - HI 1 through HI 9 Quotes to Rectify
HI 1 - 2nd Floor Attic Racoon Invasion ( 16 pgs) view [ 7950+2485 // 8500+1850 ]
HI 2- Gas Furnace - Explosion Hazard (12 pgs) view [ 10,000 // 10,000 ]
HI 3 - Gas Water Heater - Explosion Hazzard (13 pgs) view [ 3000 // 2000 ]
HI 4a - Crawl Space - Structural Defects - (19 pgs) view [ 4358 // 4600 ]
HI 4b - Crawl Space - Insulation Defects [ 5000 // 2000 ]
HI 5 - Concrete Slab Seizing (9 pgs) view [ 3500 // 3500 ]
HI 6 - North Yard Grade - East French Drain (18 pgs) view [ 10,000 // 6500 ]
HI 7 - No Hot Water (12 pgs) view [ 25,000 // 17,000 ]
HI 8 - Other Plumbing deceit (5 pgs) view [ 0 // 0 ]
HI 9 - Moss on Roof (10 pgs) view [ 3000// 2000 ]
Total $74,293 // $57,950
Other
There a a few hundred page of emails with the Defense Attorney that expose a Legal Document Service Fraud Scheme engaged in by he and his paralegal to attempt to throw the plaintiffs off the tracks procedurally.
There is a Bar Complaint filed against the Attorney (and his paralegal) for the legal document service fraud scheme view
NOTE: A dead man filed a Motion that was not properly served ...
In a bizarre twist we can get into later, when they had problems getting the motion to set aside default on file, after having run the motion to strtike document service fraud, it appears someone else got involved and assisted with their filing. The problem? The computer account used to make that filing seems to have belonged to a young attorney who died a few months prior...
We are going to hold back on this material for now. We need help with the primary investigation content first. If we get that help , we'll then share the information about the Deadman's filing to see who that can be pinned on as well.