As mentioned earlier, an affidavit of facts and a professional opinion rendered on public source documents was requested from the writer of the ill-fated 1993 determination letter. It's ready to be signed and notarized before being filed, along with other items, with the court. My neighbors' bad faith, seventeen year, dark cover is about to blown sky-high.
After reviewing original sources, it is a no-brainer to see that the letter from the City of Manteca was obtained by deceit (or complete idiocy) on the part of the defendants, which is why the BDGs are recalcitrant* and nonresponsive. Their so-called defense attorney has supported them in using their vast no-brain capacity to ignore, stall, misdirect, and screw off during a full year of discovery, producing exactly... nothing. There have been NO affirmative defenses mounted substantiating their grandfather claim because there are none - no permits, no documents, no evidence whatsoever proving that what Lynda (it's always Lynda) says is true.
Or, to state the case in Lynda's own public words:
Ms. Allen: Just one last thing? I'm not here [at city council meeting] to cause any problems with him. I just thought... it obviously didn't... I didn't think anything was gonna come to this because I just kept overlooking him... uh, just thinking it would go away, because I don't cause any problems, I don't give any problems.
(Please pardon me while I careen off the Angry wall - bounce off the Fall-Down-Laughing wall - and trip headfirst into the big, stinking She's-Full-Of-Shit pile.)
A month later I filed suit. So, in fulfillment of their jokes-passed-off-as-lives, another month later Lynda mounted the radio speaker aimed at my house. She thinks that adding radio noise on top of business noise is going to make me go away?
She "didn't think anything was gonna come to this..."? She "don't cause any problems"? (that's really bad grammar; in Pinole-speak it's, "... don't cause no problems.") Will she also claim to have "overlook[ed] him" (again? still?) and the fact that I live mere feet from where she mounted the radio speaker in the unused corner of her yard? So I recently charged her with a misdmeanor action.
p.s. By the way, "TLC" stands for Theresa, Lynda, and Corky, or, Three Lying Cuxxnxxxxs (and, yes, the C-word is ten letters long!) Their perversion of the acronym is the absolute opposite of any images engendered by Tender or Loving or Care - or flags, moms, and apple pies - or law-abiding citizens - or (name anything virtuous, lovely, or of good report). I'll never again think of "TLC" the same way I used to.
p.p.s. No, the affidavit does not go public yet; the court gets first crack at it.
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* recalcitrant (adj) marked by a stubborn unwillingness to obey figures of authority; hard to deal with.