TOP-05 — Mold & Habitability Knowledge (Concealment Cycle)

Executive Summary

Before and during tenancy, significant mold, rot, and structural failures were known to the owner. Photographs, emails, and LY Construction involvement confirm longstanding, unremediated habitability violations that were concealed prior to move-in.

Legal Significance

• Health & Safety Code §§17920.3, 17920.10: Mold = substandard housing.
• Failure to Disclose: Owner never provided mold disclosure form.
• Retaliation: Mold complaints preceded threats and the eviction campaign.

Why This Matters at Trial

This establishes motive and pattern: conceal defects → collect rent → retaliate when confronted → attempt eviction → flip to Airbnb. This aligns with RICO fraud patterns and real-estate concealment schemes.