1
00:00:00,400 --> 00:00:02,233
You say that you purchased
this mobile home?

2
00:00:02,300 --> 00:00:02,967
Yes.

3
00:00:03,033 --> 00:00:05,900
I don't understand why you would pay
double the amount of money.

4
00:00:05,967 --> 00:00:09,000
I felt threatened that she was
gonna take the mobile home back.

5
00:00:09,066 --> 00:00:10,033
No.

6
00:00:10,100 --> 00:00:13,300
With all this, I was just
so, like, out of it. Like, um...

7
00:00:14,433 --> 00:00:16,767
We're gonna be really clear
about some of the key facts,

8
00:00:16,834 --> 00:00:18,166
because I don't believe you.

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00:00:18,233 --> 00:00:21,200
[announcer]
Today on Tribunal Justice.

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00:00:21,266 --> 00:00:22,834
[theme music playing]

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[announcer] This case was filed
in Moreno Valley, California.

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Your Honor, this is case number 1139
on the calendar

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00:00:48,500 --> 00:00:51,934
in the matter of
De La Rosa versus Herrera.

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Parties have been sworn in.
You may be seated.

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00:00:54,400 --> 00:00:55,533
Thank you, Byrd.

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00:00:55,600 --> 00:00:58,567
We're here today because of a dispute
over a mobile home.

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00:00:58,633 --> 00:01:03,734
Ms. De La Rosa, you maintain that
the defendant sold you her mobile home

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in 2014 for $5,000.

19
00:01:06,567 --> 00:01:07,233
Yes.

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00:01:07,300 --> 00:01:09,800
You then claim
that she improperly demanded

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00:01:09,867 --> 00:01:13,033
additional money from you,
which you paid for a bit.

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00:01:13,100 --> 00:01:15,900
But then at some point you said,
"I'm done paying you extra money."

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00:01:15,967 --> 00:01:16,633
[Nery] Yes.

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00:01:16,700 --> 00:01:20,834
You then allege that the defendant
started eviction proceedings against you.

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00:01:20,900 --> 00:01:24,100
You were able to get
the eviction tossed out,

26
00:01:24,166 --> 00:01:27,033
and she dismissed
her eviction case against you.

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00:01:27,100 --> 00:01:29,934
And you're now suing her
for $10,000 dollars.

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$1,000 in legal fees
for fighting the eviction,

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$800 for your lost wages,

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00:01:36,467 --> 00:01:39,866
and the bulk of your damage claim
is for punitive damages.

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00:01:39,934 --> 00:01:42,600
You're suing for over $8,000
in punitive damages.

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00:01:42,667 --> 00:01:46,767
And just so we're clear, punitive damages
aren't your out-of-pocket damages.

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00:01:46,834 --> 00:01:49,967
Punitive damages are assessed
against a defendant

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00:01:50,033 --> 00:01:52,366
for conduct that is grossly negligent,

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00:01:52,433 --> 00:01:55,767
malicious,
not just making an honest mistake.

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00:01:55,834 --> 00:01:59,033
It's for conduct
that's intentionally nasty.

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00:01:59,100 --> 00:02:02,333
That's the layperson's way
of describing it.

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00:02:02,400 --> 00:02:05,333
So that's your $10,000 case
against the defendant.

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00:02:05,400 --> 00:02:06,633
Ms. Herrera,

40
00:02:06,700 --> 00:02:10,600
you maintain that you did not sell
the plaintiff the mobile home

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00:02:10,667 --> 00:02:13,266
in 2014 for $5,000.

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00:02:13,333 --> 00:02:18,867
You say you sold it to her
in 2015 for $13,000.

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00:02:18,934 --> 00:02:23,133
You point out that you did try
to serve her with the eviction papers.

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00:02:23,200 --> 00:02:25,867
You couldn't evict her for a while
because of the pandemic.

45
00:02:25,934 --> 00:02:29,734
She stopped paying you the balance
of the amount you say was owed.

46
00:02:29,800 --> 00:02:33,000
The eviction was tossed out
because, apparently,

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00:02:33,066 --> 00:02:36,734
while she was served at the right address,
her name was misspelled.

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00:02:36,800 --> 00:02:39,233
When you went back to court,
you dropped the case

49
00:02:39,300 --> 00:02:43,900
because, according to you, she presented
falsified evidence to the court.

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00:02:43,966 --> 00:02:46,800
It became your word against hers.

51
00:02:46,867 --> 00:02:49,567
She shorted you
thousands of dollars,

52
00:02:49,633 --> 00:02:52,600
and you maintain
that you do not owe her a dime.

53
00:02:52,667 --> 00:02:53,333
That's correct.

54
00:02:53,400 --> 00:02:56,266
Now, you've got
the burden of proof in this case.

55
00:02:56,333 --> 00:02:59,767
And so, first things first,
I wanna prove the sale.

56
00:02:59,834 --> 00:03:04,100
Show me the contract that you claim
is evidence of the sale in 2014.

57
00:03:04,166 --> 00:03:06,600
Okay, well, let's look at exhibit one.

58
00:03:06,667 --> 00:03:07,667
-Is that it?
-[Nery] Yes.

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00:03:07,734 --> 00:03:12,867
[Acker] "I, Marina Herrera, at space 87
have received $800 cash

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00:03:12,934 --> 00:03:17,200
by Nery De La Rosa
on July 28th, 2014,

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00:03:17,266 --> 00:03:19,633
a payment toward the $5,000,

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00:03:19,700 --> 00:03:23,667
leaving a balance of $4200
for the sale of the mobile home."

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00:03:23,734 --> 00:03:24,400
Who wrote that?

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00:03:24,466 --> 00:03:25,466
Marina Herrera.

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00:03:25,533 --> 00:03:26,367
[Acker]
Did you write that?

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00:03:26,433 --> 00:03:30,166
Everything looks like it's my writing,
but the year is incorrect.

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00:03:30,233 --> 00:03:34,867
So it should be $5,000 in 2015?

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00:03:34,934 --> 00:03:36,600
'Cause you said $13,000.

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00:03:36,667 --> 00:03:40,433
Yes, I sold it to her.
The agreement was for 13,000.

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00:03:40,500 --> 00:03:42,333
So where did this agreement come from?

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00:03:42,400 --> 00:03:43,700
I do recognize my writing.

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00:03:43,767 --> 00:03:47,066
If this is your writing,
tell me, other than the date,

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00:03:47,133 --> 00:03:49,033
what you contend is falsified.

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00:03:49,100 --> 00:03:50,300
For right now, just the date.

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00:03:50,367 --> 00:03:56,233
So in 2014, you did agree to sell her
this mobile home for $5,000?

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00:03:56,300 --> 00:03:56,966
No.

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00:03:57,033 --> 00:03:58,633
[Acker] She's saying that
this is your agreement.

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00:03:58,700 --> 00:04:00,233
Can we put up the second agreement?

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00:04:00,300 --> 00:04:03,367
Because you, Ms. Herrera,
have submitted another contract

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00:04:03,433 --> 00:04:05,700
that you say is evidence of the sale.

81
00:04:05,767 --> 00:04:09,066
Now, this contract is dated
about a year later.

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00:04:09,133 --> 00:04:11,967
It's for a $13,000 purchase price.

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00:04:12,033 --> 00:04:13,767
And who wrote this contract?

84
00:04:13,834 --> 00:04:16,966
I wrote that one.
That's the first contract for 13,000.

85
00:04:17,033 --> 00:04:19,100
So where did the other contract come from?

86
00:04:19,166 --> 00:04:21,500
That's the one you say she falsified.

87
00:04:21,567 --> 00:04:23,266
-Yeah, this one--
-But it's your writing.

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00:04:23,332 --> 00:04:24,900
[Marina]
This is exactly what I'm talking about.

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00:04:24,967 --> 00:04:28,500
This is where I feel it's falsified
because it is my writing,

90
00:04:28,567 --> 00:04:30,166
but the date is just incorrect

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00:04:30,233 --> 00:04:33,000
because I was still living
in that home in 2014.

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00:04:33,066 --> 00:04:34,700
-I have pictures.
-[Acker] Okay, so if I--

93
00:04:34,767 --> 00:04:38,900
Again, if the data is incorrect,
but everything else is correct,

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00:04:38,967 --> 00:04:43,100
does that mean that you agreed
to sell her the house for $5,000?

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00:04:43,166 --> 00:04:47,233
It's important because
if she stopped paying you money

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00:04:47,300 --> 00:04:49,066
that she didn't owe you
in the first place,

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00:04:49,133 --> 00:04:50,567
or if you were demanding money

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00:04:50,633 --> 00:04:52,332
that she didn't owe you
in the first place,

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00:04:52,400 --> 00:04:54,667
she's got a great claim
for punitive damages.

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00:04:54,734 --> 00:04:56,133
I'm gonna go back to you,
Ms. De La Rosa.

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00:04:56,200 --> 00:04:59,500
For this sale to be valid,
I need to see a bill of sale,

102
00:04:59,567 --> 00:05:00,600
I need to see the title,

103
00:05:00,667 --> 00:05:03,667
I need to see
the tax clearance certificate,

104
00:05:03,734 --> 00:05:06,834
and there's also
a multipurpose transfer form.

105
00:05:06,900 --> 00:05:09,867
These are all elements
of selling a mobile home

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00:05:09,934 --> 00:05:11,400
to a consumer in California.

107
00:05:11,467 --> 00:05:14,367
So show me what you have.
I didn't see any of those things.

108
00:05:14,433 --> 00:05:19,266
I only saw two versions of a contract
and no original agreement.

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00:05:19,332 --> 00:05:21,633
No, there's not. The only thing that I--

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00:05:21,700 --> 00:05:22,767
[Acker] No title?

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00:05:22,834 --> 00:05:24,100
No, she never gave me the title. Sorry.

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00:05:24,166 --> 00:05:27,834
Okay, so no title,
no multipurpose transfer form,

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00:05:27,900 --> 00:05:29,500
no tax clearance certificate.

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00:05:29,567 --> 00:05:30,233
[Nery] No.

115
00:05:30,300 --> 00:05:34,433
And you didn't get those in 2014
and you didn't get those in 2015?

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00:05:34,500 --> 00:05:36,400
No. I went to the housing authority,

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00:05:36,467 --> 00:05:38,266
and they told me that
she had to be present for me

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00:05:38,332 --> 00:05:39,734
to get any kind of information
about that mobile home.

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00:05:39,800 --> 00:05:42,233
Where's the communication
from you to her

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00:05:42,300 --> 00:05:44,800
where you say, "I need
the rest of these documents

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00:05:44,867 --> 00:05:48,100
in order to perfect
the sale of this property"?

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00:05:48,166 --> 00:05:52,967
When we had made a transaction
in 2019, and that's when she goes--

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00:05:53,033 --> 00:05:54,567
-[Acker] Oh, wait, stick with me.
-[Nery] Mm-hmm.

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00:05:54,633 --> 00:05:58,166
What is still missing are a number
of documents that are necessary

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00:05:58,233 --> 00:05:59,967
in order to make this a valid sale.

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00:06:00,100 --> 00:06:01,400
-You have none of those things?
-No, I don't.

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00:06:01,467 --> 00:06:03,600
And you say that
when you tried to get these items,

128
00:06:03,667 --> 00:06:06,467
you were advised that you had to get
the defendant's cooperation.

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00:06:06,533 --> 00:06:07,200
Yes.

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00:06:07,266 --> 00:06:09,633
[Acker] Yet I have nothing from you,
not one bit of evidence,

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00:06:09,700 --> 00:06:14,300
in which you say to her,
"I need you to cooperate

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00:06:14,367 --> 00:06:17,900
in getting these documents
so we can make this a proper sale."

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00:06:17,967 --> 00:06:19,633
There's nothing on the record about that,
so I'm gonna move on.

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00:06:19,700 --> 00:06:20,367
[Nery] Mm-hmm.

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00:06:20,433 --> 00:06:24,233
2014 is when you say
the sale took place

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00:06:24,300 --> 00:06:25,367
for $5,000.

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00:06:25,433 --> 00:06:27,834
How much money
did you pay her in total?

138
00:06:27,900 --> 00:06:32,834
I can honestly say that I paid her
at least 12,000 altogether.

139
00:06:32,900 --> 00:06:36,266
Now, if it is your position,
and I'm gonna want to see evidence

140
00:06:36,332 --> 00:06:38,133
of those $12,000 payments.

141
00:06:38,200 --> 00:06:42,867
If it's your position that you purchased
this mobile home for $5,000,

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00:06:42,933 --> 00:06:45,734
and not $13,000, as she suggests,

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00:06:45,800 --> 00:06:48,533
why on earth would you give her
more than twice that amount of money?

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00:06:48,600 --> 00:06:51,066
The reason why, 'cause I felt threatened
because she would always--

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00:06:51,133 --> 00:06:54,667
I mean, she would always say that
she was gonna take the mobile home back,

146
00:06:54,734 --> 00:06:57,433
that her family
was telling her that she needed--

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00:06:57,500 --> 00:06:58,700
[Acker]
Where is all of this?

148
00:06:58,767 --> 00:07:02,166
I mean, she just said these things
verbally to you?

149
00:07:02,233 --> 00:07:03,600
Yeah, when we spoke.

150
00:07:03,667 --> 00:07:06,367
So you say that you had a valid--
whoa, wait.

151
00:07:06,433 --> 00:07:09,233
You had a valid sale agreement
for $5,000,

152
00:07:09,300 --> 00:07:12,400
but for some reason,
because she was threatening you,

153
00:07:12,467 --> 00:07:14,700
you just gave her more than twice
that amount of money.

154
00:07:14,767 --> 00:07:17,500
Well, if we look at exhibit,
um, the other agreement,

155
00:07:17,567 --> 00:07:19,567
it shows right there
that she changed the price on me

156
00:07:19,633 --> 00:07:21,834
and then how much money
I had gave her after that.

157
00:07:21,900 --> 00:07:23,967
Well, you say she changed the price.

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00:07:24,033 --> 00:07:24,700
[Nery] Mm-hmm.

159
00:07:24,767 --> 00:07:27,300
She says you submitted
a falsified agreement.

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00:07:27,367 --> 00:07:30,200
So right now,
I'm sticking with your position.

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00:07:30,266 --> 00:07:32,734
-Your position is that it was $5,000.
-[Nery] Mm-hmm.

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00:07:32,800 --> 00:07:35,900
And what is confounding to me is why,

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00:07:35,967 --> 00:07:40,200
if you legitimately believed
you were buying this property for $5,000,

164
00:07:40,266 --> 00:07:42,734
you would then give her
almost $12,000.

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00:07:42,800 --> 00:07:44,066
[theme music playing]

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00:07:44,133 --> 00:07:46,400
[announcer]
Coming up on Tribunal Justice.

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00:07:46,467 --> 00:07:47,400
Where's your stuff?

168
00:07:47,467 --> 00:07:49,033
I think you're both full of it.

169
00:07:49,100 --> 00:07:52,600
I mean, you're both standing there like,
"I can't believe this is all happening.

170
00:07:52,667 --> 00:07:54,967
I thought I bought a home
and I thought I sold it,

171
00:07:55,033 --> 00:07:56,967
and I don't have anything
to prove it either way."

172
00:08:02,133 --> 00:08:03,967
[theme music playing]

173
00:08:04,033 --> 00:08:08,800
[announcer] Nery De La Rosa is suing
her former friend, Marina Herrera,

174
00:08:08,867 --> 00:08:13,000
for lost wages, legal fees,
and punitive damages

175
00:08:13,066 --> 00:08:16,567
after Marina tried to illegally evict her.

176
00:08:16,633 --> 00:08:19,767
Marina claims she sold Nery
her mobile home,

177
00:08:19,834 --> 00:08:22,834
but she only paid the down payment.

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00:08:22,900 --> 00:08:25,233
You knew how to get help
when you needed help.

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00:08:25,300 --> 00:08:28,734
She tried to evict you
and you went to a legal aid lawyer.

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00:08:28,800 --> 00:08:29,467
-Right?
-[Nery] Mm-hmm.

181
00:08:29,533 --> 00:08:31,834
[Acker] Who showed you
how to challenge the eviction.

182
00:08:31,900 --> 00:08:34,600
Now, when you evicted her,
when you served her the eviction papers,

183
00:08:34,667 --> 00:08:36,533
you served her papers
at the correct address,

184
00:08:36,600 --> 00:08:38,866
but her name was misspelled.

185
00:08:38,933 --> 00:08:42,200
Her name is Nery De La Rosa,
with an "N."

186
00:08:42,265 --> 00:08:42,933
Right.

187
00:08:43,000 --> 00:08:44,667
[Acker] And the papers--
you hired a paralegal.

188
00:08:44,734 --> 00:08:45,400
Right.

189
00:08:45,467 --> 00:08:49,400
And the paralegal sent the papers
to Mary instead of--

190
00:08:49,467 --> 00:08:50,834
Mary instead of Nery.

191
00:08:50,900 --> 00:08:53,967
So people can say
it's just a procedural technicality,

192
00:08:54,033 --> 00:08:57,367
maybe you did have actual notice,
but you weren't properly served.

193
00:08:57,433 --> 00:09:00,467
So then when she reserved you,
you went to court

194
00:09:00,533 --> 00:09:03,900
with your 2014 document,
which she says is fake,

195
00:09:03,967 --> 00:09:04,867
and then she just gave up.

196
00:09:04,934 --> 00:09:07,567
And now you're saying that
what she did is so horrible

197
00:09:07,633 --> 00:09:10,734
that you're entitled to $8,000
in punitive damages.

198
00:09:10,800 --> 00:09:12,633
But my question for you

199
00:09:12,700 --> 00:09:16,333
goes back to your
initial understanding of the agreement,

200
00:09:16,400 --> 00:09:20,433
and if you understood this to be
an agreement for $5,000,

201
00:09:20,500 --> 00:09:22,800
and you're somebody who knows
how to protect your legal rights

202
00:09:22,867 --> 00:09:26,767
because when they tried to serve you
papers with your name misspelled,

203
00:09:26,834 --> 00:09:29,400
you knew to go to legal aid
and you got legal advice

204
00:09:29,467 --> 00:09:33,133
and you got legal help,
which is your right, and I am glad.

205
00:09:33,200 --> 00:09:34,367
God bless legal aid.

206
00:09:34,433 --> 00:09:37,867
But what I'm saying to you is that
with that amount of knowledge,

207
00:09:37,934 --> 00:09:39,800
I am just curious
as to why you didn't have

208
00:09:39,867 --> 00:09:41,567
the wherewithal
and presence of mind,

209
00:09:41,633 --> 00:09:46,233
if you really legitimately believed
that you were only buying this for $5,000,

210
00:09:46,300 --> 00:09:47,734
I don't know why you'd keep paying her

211
00:09:47,800 --> 00:09:49,500
instead of going
to the legal aid lawyer then

212
00:09:49,567 --> 00:09:51,300
and say, "You know what,
I'm being extorted."

213
00:09:51,367 --> 00:09:54,467
And I'm making that point
because I don't believe you.

214
00:09:54,533 --> 00:09:56,200
I'm having problems with your credibility.

215
00:09:56,266 --> 00:09:56,934
[Nery] Mm-hmm.

216
00:09:57,000 --> 00:09:59,165
[Acker] I don't know
that it was a $5,000 sale,

217
00:09:59,233 --> 00:10:00,533
and you haven't convinced me of that.

218
00:10:00,600 --> 00:10:01,266
[Nery] Mm-hmm.

219
00:10:01,333 --> 00:10:02,934
So you've got two more judges.

220
00:10:03,000 --> 00:10:04,300
Judge DiMango.

221
00:10:04,367 --> 00:10:06,667
I'm noticing in here
a document that seems to say

222
00:10:06,734 --> 00:10:11,633
the title to this trailer
was transferred on May 27th, 2014.

223
00:10:11,700 --> 00:10:13,100
-Yes.
-[DiMango] Can you explain that?

224
00:10:13,166 --> 00:10:16,800
My mom transferred it over to me,
uh, as a gift.

225
00:10:16,867 --> 00:10:18,300
Okay, you get it in May,

226
00:10:18,367 --> 00:10:22,500
and then in July,
the 2014 note is written.

227
00:10:22,567 --> 00:10:24,066
-Yeah, it--
-That's what it says here.

228
00:10:24,133 --> 00:10:27,800
Now, I know you keep saying the date,
the date, but it goes beyond the date.

229
00:10:27,867 --> 00:10:30,066
To me, this almost looks
like a down payment.

230
00:10:30,133 --> 00:10:35,266
It doesn't say specifically that the home
was being sold for $5,000.

231
00:10:35,333 --> 00:10:38,734
It just says that that money
was being paid towards that home.

232
00:10:38,800 --> 00:10:39,834
So that helps you,

233
00:10:39,900 --> 00:10:42,934
except your position
is that this note's a forgery.

234
00:10:43,000 --> 00:10:46,000
So it either helps you,
or it's a forgery.

235
00:10:46,066 --> 00:10:48,600
If it's a forgery, then we disregard it.

236
00:10:48,667 --> 00:10:52,700
So your position is that this
is a forgery. Is that correct?

237
00:10:52,767 --> 00:10:54,100
Now you don't want it to be a forgery

238
00:10:54,165 --> 00:10:56,233
'cause you think it supports
your position, don't you?

239
00:10:56,300 --> 00:10:58,934
I was gonna say it was just a date.

240
00:10:59,000 --> 00:11:01,567
I did say in the first place
that is my writing.

241
00:11:01,633 --> 00:11:03,700
I did recognize that
that is my writing.

242
00:11:03,767 --> 00:11:04,700
With the date,

243
00:11:04,767 --> 00:11:07,533
it just didn't add up
to when I sold the mobile home.

244
00:11:07,600 --> 00:11:10,066
But you got the place in May,
the end of May.

245
00:11:10,133 --> 00:11:12,700
How long did you have it
before you decided to sell it?

246
00:11:12,767 --> 00:11:15,633
So I lived in that mobile home
since 2007,

247
00:11:15,700 --> 00:11:18,200
and I moved out, like,
in the summer of 2015.

248
00:11:18,266 --> 00:11:19,266
That's when I sold it.

249
00:11:19,333 --> 00:11:21,200
So you just don't give over property.

250
00:11:21,266 --> 00:11:24,266
You have other documents.
That's already been pointed out.

251
00:11:24,333 --> 00:11:26,867
It's like a car.
You just don't give cars away.

252
00:11:26,934 --> 00:11:29,467
You have to have title,
you've gotta have registration,

253
00:11:29,533 --> 00:11:31,166
you've gotta have tax documents.

254
00:11:31,233 --> 00:11:33,165
You've gotta have all of these things.

255
00:11:33,233 --> 00:11:36,233
Where are they in this case, ladies,
from each of you?

256
00:11:36,300 --> 00:11:39,734
Because the bottom line here is,
you have the burden of proof,

257
00:11:39,800 --> 00:11:44,200
but neither one of you has been able
to establish anything, anything at all.

258
00:11:44,266 --> 00:11:47,367
We don't have a value. I don't know
what that mobile home is worth.

259
00:11:47,433 --> 00:11:51,500
We looked into it to some extent,
and it seems that the value today

260
00:11:51,567 --> 00:11:55,400
for a sale of a mobile home
might be over 100,000,

261
00:11:55,467 --> 00:11:57,967
but we certainly don't have
any evidence of that here,

262
00:11:58,033 --> 00:12:01,700
and who sells a $100,000 home
for $5,000?

263
00:12:01,767 --> 00:12:04,000
So there's home and there's land.

264
00:12:04,066 --> 00:12:05,667
When and if you were to sell that,

265
00:12:05,734 --> 00:12:08,500
did you sell it as one,
the land and the home?

266
00:12:08,567 --> 00:12:09,667
Just the mobile home.

267
00:12:09,734 --> 00:12:12,300
How do you sell only the home
but not the land with it?

268
00:12:12,367 --> 00:12:13,667
-So the land--
-[DiMango] The land is leased?

269
00:12:13,734 --> 00:12:16,633
The land belongs to the owner
of the property.

270
00:12:16,700 --> 00:12:19,333
Were you paying rent
to the landlord of the property?

271
00:12:19,400 --> 00:12:20,066
Yes.

272
00:12:20,133 --> 00:12:22,834
From what point
were you paying that person?

273
00:12:22,900 --> 00:12:24,567
From 2014 to now, present.

274
00:12:24,633 --> 00:12:27,533
[DiMango] I wanna see
that first check from 2014

275
00:12:27,600 --> 00:12:32,066
'cause that's the issue here
that's in debate: 2014, 2015.

276
00:12:32,133 --> 00:12:37,133
All you need to do
is hand up one document that says,

277
00:12:37,200 --> 00:12:40,734
"Here I am paying a mortgage,
paying rent, paying you,

278
00:12:40,800 --> 00:12:45,033
paying somebody on this date
on 2014."

279
00:12:45,100 --> 00:12:46,400
Where is it?

280
00:12:46,467 --> 00:12:47,367
What are you looking at him for?

281
00:12:47,433 --> 00:12:51,333
No, because my envelope
is right there.

282
00:12:51,400 --> 00:12:52,600
You think it's in there?

283
00:12:52,667 --> 00:12:54,266
I mean, wouldn't you know
if it was in there?

284
00:12:54,333 --> 00:12:55,967
You came to court to present a case.

285
00:12:56,033 --> 00:12:57,533
You think you're not gonna--
I'm not gonna stand here

286
00:12:57,600 --> 00:12:59,100
while you make believe
you're looking for something.

287
00:12:59,165 --> 00:13:00,834
Don't play that game with us.

288
00:13:00,900 --> 00:13:03,700
"Oh, I... I can't find it, Judge.
I can't find it."

289
00:13:03,767 --> 00:13:05,667
It's not there.
You don't have anything.

290
00:13:05,734 --> 00:13:07,133
You have nothing to show.

291
00:13:07,200 --> 00:13:10,200
And you have nothing to show.
You claim you did sell it to her.

292
00:13:10,266 --> 00:13:12,400
It's not like you're saying,
"I never sold it to her."

293
00:13:12,467 --> 00:13:15,734
You're just saying you sold it to her
for 13,000 in 2015.

294
00:13:15,800 --> 00:13:17,266
Where's your stuff?

295
00:13:17,333 --> 00:13:18,633
I think you're both full of it.

296
00:13:18,700 --> 00:13:22,467
I mean, you're both standing there like,
"I can't believe this is all happening.

297
00:13:22,533 --> 00:13:24,600
I thought I bought a home
and I thought I sold it,

298
00:13:24,667 --> 00:13:26,433
and I don't have anything
to prove it either way."

299
00:13:26,500 --> 00:13:29,934
Sir, who are you
in relation to the plaintiff?

300
00:13:30,000 --> 00:13:31,233
Good afternoon, Your Honor.

301
00:13:31,300 --> 00:13:32,400
[DiMango] Good afternoon, sir.
Who are you?

302
00:13:32,467 --> 00:13:34,000
My name is Vito,
Vito D'Angelo.

303
00:13:34,066 --> 00:13:35,834
I'm a legal assistant.

304
00:13:35,900 --> 00:13:39,000
She wandered into my office
after the court,

305
00:13:39,066 --> 00:13:44,333
uh, rejected her request for documents
regarding the eviction case.

306
00:13:44,400 --> 00:13:48,100
They said she wasn't entitled to it
because she wasn't named in the case.

307
00:13:48,165 --> 00:13:50,867
Okay, wait, so pause
'cause you're beyond where I'm asking.

308
00:13:50,934 --> 00:13:53,066
I just wanted to know who you are,
Mr. D'Angelo,

309
00:13:53,133 --> 00:13:55,266
and who you were
in relation to the plaintiff.

310
00:13:55,333 --> 00:13:57,667
And what you are is a legal assistant.

311
00:13:57,734 --> 00:13:59,233
And you're not a witness to anything.

312
00:13:59,300 --> 00:13:59,967
Yes, Your Honor.

313
00:14:00,100 --> 00:14:02,500
[DiMango] Okay, I'm gonna ask you
to sit, sir. Thank you.

314
00:14:02,567 --> 00:14:05,934
So the other note
that we go back to is the main one.

315
00:14:06,000 --> 00:14:08,533
Which says you're selling it for 13,000.

316
00:14:08,600 --> 00:14:10,100
You say you paid 12.

317
00:14:10,166 --> 00:14:11,800
You're not disputing that, are you?

318
00:14:11,867 --> 00:14:13,533
You see, I got a problem
with the two of you.

319
00:14:13,600 --> 00:14:16,233
You both keep looking at me
like I'm talking another language.

320
00:14:16,300 --> 00:14:18,266
You have nothing,
and you have nothing,

321
00:14:18,333 --> 00:14:20,266
and I don't think
I could strain myself anymore.

322
00:14:20,333 --> 00:14:22,500
I'm looking at two women
who have come to court

323
00:14:22,567 --> 00:14:26,166
either not being honest with us
or totally unprepared.

324
00:14:26,233 --> 00:14:28,000
But either way, the burden is with you.

325
00:14:28,066 --> 00:14:28,734
Judge Levy.

326
00:14:28,800 --> 00:14:33,834
Ms. Herrera, if Ms. De La Rosa today
right now wrote you a check, a good check,

327
00:14:33,900 --> 00:14:36,066
for $13,000
for the purchase of the home,

328
00:14:36,133 --> 00:14:36,800
you'd take it, right?

329
00:14:36,867 --> 00:14:37,600
Yes.

330
00:14:37,667 --> 00:14:39,500
[Levy] Right.
And so, therefore, if, in fact,

331
00:14:39,567 --> 00:14:42,200
the mobile home
was actually worth $100,000,

332
00:14:42,266 --> 00:14:43,967
it really doesn't make any difference

333
00:14:44,033 --> 00:14:47,934
because we're not talking
$100,000 and $5,000,

334
00:14:48,000 --> 00:14:50,633
we're talking $5,000
and $13,000.

335
00:14:50,700 --> 00:14:54,567
So for whatever reason,
back in 2014 or 2015,

336
00:14:54,633 --> 00:14:57,533
in your mind's eye,
you were happy to get 13,000,

337
00:14:57,600 --> 00:15:01,867
or you at least wrote up a contract,
whether the date was wrong or not,

338
00:15:01,934 --> 00:15:04,400
whether or not you just got the wrong date
when you wrote it,

339
00:15:04,467 --> 00:15:06,200
for $5,000, right?

340
00:15:06,266 --> 00:15:08,567
So between 5,000 and 13,000,

341
00:15:08,633 --> 00:15:11,433
you would have been happy with
for that mobile home, right?

342
00:15:11,500 --> 00:15:12,333
-No.
-[Levy] No.

343
00:15:12,400 --> 00:15:14,700
So it's only 13,000.
Is that what you're saying?

344
00:15:14,767 --> 00:15:16,934
I'm saying that was a down payment
towards the 13,000.

345
00:15:17,000 --> 00:15:18,734
Down payment.
So nothing prevented--

346
00:15:18,800 --> 00:15:19,867
And this is your handwriting, right?

347
00:15:19,934 --> 00:15:20,600
Yes.

348
00:15:20,667 --> 00:15:21,900
[Levy] So if, in fact,
it was a down payment,

349
00:15:21,967 --> 00:15:23,867
you would've wrote "down payment"
and not "sale," right?

350
00:15:23,934 --> 00:15:24,767
-Of course.
-[Marina] That's true.

351
00:15:24,834 --> 00:15:25,800
Don't even answer that.

352
00:15:25,867 --> 00:15:27,600
[theme music playing]

353
00:15:27,667 --> 00:15:30,033
[announcer]
Coming up on Tribunal Justice.

354
00:15:30,100 --> 00:15:33,734
Who did the judge rule in favor of
regarding this document?

355
00:15:33,800 --> 00:15:34,467
The plaintiff.

356
00:15:34,533 --> 00:15:37,066
And so what the law
prohibits you from doing now

357
00:15:37,133 --> 00:15:38,767
is to relitigate that issue.

358
00:15:38,834 --> 00:15:40,300
That issue is over.

359
00:15:40,367 --> 00:15:41,934
This is not a forgery.

360
00:15:46,800 --> 00:15:50,300
[theme music playing]

361
00:15:50,367 --> 00:15:53,266
So here's the thing, though,
that I wanna make crystal clear.

362
00:15:53,333 --> 00:15:57,800
In your answer, Ms. Herrera,
you say that at the eviction proceeding,

363
00:15:57,867 --> 00:15:59,834
-which you participated in, right?
-Correct.

364
00:15:59,900 --> 00:16:02,066
[Levy] And Ms. De La Rosa
participated in, right?

365
00:16:02,133 --> 00:16:02,800
Correct.

366
00:16:02,867 --> 00:16:05,734
That she presented the judge
in the eviction proceeding

367
00:16:05,800 --> 00:16:07,834
with this document, right?

368
00:16:07,900 --> 00:16:08,567
Yes.

369
00:16:08,633 --> 00:16:11,900
And in your answer,
you say that you classify this

370
00:16:11,967 --> 00:16:15,166
as a falsified document
claiming that you sold her

371
00:16:15,233 --> 00:16:19,033
the mobile home for 5,000
instead of 13,000.

372
00:16:19,100 --> 00:16:20,166
So first of all, in your answer,

373
00:16:20,233 --> 00:16:22,533
at no time do you say
it was a down payment, right?

374
00:16:22,600 --> 00:16:24,000
You never say it was a down payment.

375
00:16:24,066 --> 00:16:27,700
So the point is, you went to court,
you went before a judge,

376
00:16:27,767 --> 00:16:29,000
you argued your point.

377
00:16:29,066 --> 00:16:31,500
The point that you argued
was that this was a forgery.

378
00:16:31,567 --> 00:16:35,600
Who did the judge rule in favor of
regarding this document?

379
00:16:35,667 --> 00:16:37,266
You or the plaintiff?

380
00:16:37,333 --> 00:16:38,467
The plaintiff.

381
00:16:38,533 --> 00:16:40,667
And so what the law prohibits you
from doing now,

382
00:16:40,734 --> 00:16:42,767
because you were a participant,

383
00:16:42,834 --> 00:16:45,900
had a full and fair opportunity
to be heard in that proceeding,

384
00:16:45,967 --> 00:16:48,367
is to relitigate that issue.

385
00:16:48,433 --> 00:16:50,000
That issue is over.

386
00:16:50,066 --> 00:16:51,567
This is not a forgery.

387
00:16:51,633 --> 00:16:53,567
The doctrine of collateral estoppel

388
00:16:53,633 --> 00:16:56,100
prohibits you from arguing
that right now.

389
00:16:56,165 --> 00:16:57,600
Period.
You follow that?

390
00:16:57,667 --> 00:16:58,567
-Yes.
-[Levy] Good.

391
00:16:58,633 --> 00:17:01,033
Now, Ms. De La Rosa,
you were asked a bunch of questions.

392
00:17:01,100 --> 00:17:03,133
You were savvy enough
to find someone to help you.

393
00:17:03,200 --> 00:17:04,233
The question was asked:

394
00:17:04,300 --> 00:17:08,367
Well, why didn't you feel it necessary
to do that back in 2014?

395
00:17:08,433 --> 00:17:10,700
Honestly, I didn't know
what kind of help I could get.

396
00:17:10,767 --> 00:17:12,834
And I did go to legal services.

397
00:17:12,900 --> 00:17:15,834
They explained to me that it was too late,
that there was no way that

398
00:17:15,900 --> 00:17:20,165
I could've gotten the mobile home,
and then thank God that Vito was--

399
00:17:20,233 --> 00:17:23,599
He has a building next to the courthouse,

400
00:17:23,666 --> 00:17:25,500
and that's when I was able
to get the help from him.

401
00:17:25,567 --> 00:17:28,900
[Levy] And so why didn't you do that
back in 2014, or 2015?

402
00:17:28,967 --> 00:17:31,867
Because I didn't think that this
was even gonna come to this point.

403
00:17:31,934 --> 00:17:35,667
In 2022 here,
when you're facing eviction,

404
00:17:35,734 --> 00:17:36,967
you got all your stuff packed up

405
00:17:37,033 --> 00:17:39,133
like you're waiting for the sheriff
to throw you out.

406
00:17:39,200 --> 00:17:40,066
-Right?
-Yes.

407
00:17:40,133 --> 00:17:41,300
[Levy]
That's what your paper said.

408
00:17:41,367 --> 00:17:45,233
But in 2014, you weren't afraid
of getting thrown out, right?

409
00:17:45,300 --> 00:17:48,467
According to your papers,
you said in 2014,

410
00:17:48,533 --> 00:17:52,233
Marina sent you a certified letter
stating that you paid her 5,000

411
00:17:52,300 --> 00:17:55,900
and you simply needed to pay her
an additional 8,000

412
00:17:55,967 --> 00:17:58,667
for a total of $13,000
to get the motor home.

413
00:17:58,734 --> 00:18:00,734
She said that she would not
give you the title

414
00:18:00,800 --> 00:18:02,734
until you paid off the remaining balance.

415
00:18:02,800 --> 00:18:04,400
And you felt like you didn't
have any other option.

416
00:18:04,467 --> 00:18:06,367
-That's what you wrote.
-Yes, I did.

417
00:18:06,433 --> 00:18:08,333
[Levy] So there's a difference
between those two things.

418
00:18:08,400 --> 00:18:10,934
One thing is like,
"How am I gonna fight this lady?" Right?

419
00:18:11,000 --> 00:18:14,166
Back in 2014,
at least it makes sense to me,

420
00:18:14,233 --> 00:18:16,133
that she's really--
she's got you over the barrel.

421
00:18:16,200 --> 00:18:17,834
She's not gonna give you
the title to the home

422
00:18:17,900 --> 00:18:19,934
unless you give her the $8,000.

423
00:18:20,000 --> 00:18:21,467
You don't understand the legal process.

424
00:18:21,533 --> 00:18:22,567
In your mind's eye,

425
00:18:22,633 --> 00:18:25,000
at least from what I could see
and what I read,

426
00:18:25,066 --> 00:18:27,233
is that you figured, "I might as well
pay her the eight grand,

427
00:18:27,300 --> 00:18:28,600
even though I don't owe her
the eight grand,

428
00:18:28,667 --> 00:18:30,500
because this is the contract."

429
00:18:30,567 --> 00:18:33,233
You know,
she cannot say with a straight face,

430
00:18:33,300 --> 00:18:34,233
as my mother would say,

431
00:18:34,300 --> 00:18:36,333
that it was not her intent to sell this

432
00:18:36,400 --> 00:18:39,233
'cause that's the word that she used,
her handwriting, not yours.

433
00:18:39,300 --> 00:18:41,734
It wasn't a down payment.
It was nothing else but the sale.

434
00:18:41,800 --> 00:18:42,467
-Right?
-[Nery] Mm-hmm.

435
00:18:42,533 --> 00:18:44,433
[Levy]
So she says it's a forgery.

436
00:18:44,500 --> 00:18:48,100
Forgery is that you wrote it out without
her permission, that you signed her name.

437
00:18:48,166 --> 00:18:50,033
But that's not what she's saying here.

438
00:18:50,100 --> 00:18:53,934
And if what she said in eviction court
is the same thing that she said here,

439
00:18:54,000 --> 00:18:56,367
which is that it was just the date,
the date's wrong.

440
00:18:56,433 --> 00:18:58,967
So? People put
the wrong date down all the time.

441
00:18:59,033 --> 00:19:01,166
But the details are important.

442
00:19:01,233 --> 00:19:04,433
A sale for $5,000, 800 down,

443
00:19:04,500 --> 00:19:06,900
$4200 to be paid later.

444
00:19:06,967 --> 00:19:07,967
-[Nery] Mm-hmm.
-Period.

445
00:19:08,033 --> 00:19:09,200
-Makes sense?
-Yes.

446
00:19:09,266 --> 00:19:11,166
-Your Honor, if I may?
-[Levy] Yeah. Yeah. Please step up.

447
00:19:11,233 --> 00:19:12,667
Did I get anything about that wrong?

448
00:19:12,734 --> 00:19:14,600
There is an educational issue

449
00:19:14,667 --> 00:19:18,433
where Judge Acker
raised some issues that--

450
00:19:18,500 --> 00:19:22,000
I've been in this business 46 years,
typing legal documents.

451
00:19:22,066 --> 00:19:24,433
I wasn't even aware
of all the transfer documents

452
00:19:24,500 --> 00:19:25,500
that she described.

453
00:19:25,567 --> 00:19:29,300
So for a layperson
that has no legal background at all--

454
00:19:29,367 --> 00:19:31,867
Now it sort of sounds like
you're arguing on her behalf,

455
00:19:31,934 --> 00:19:33,433
more like a lawyer
than you are a legal advisor.

456
00:19:33,500 --> 00:19:34,967
-[Vito] Okay, I'm sorry.
-That's all right.

457
00:19:35,033 --> 00:19:37,000
Now, let me ask you
this last question

458
00:19:37,066 --> 00:19:40,533
'cause you also have
a claim for $1700 for legal fees.

459
00:19:40,600 --> 00:19:42,600
Were those legal fees pay to you?

460
00:19:42,667 --> 00:19:44,667
Well, to my company.
Yes, Your Honor.

461
00:19:44,734 --> 00:19:46,633
-And you were assisting her with--
-Just the paperwork.

462
00:19:46,700 --> 00:19:49,633
Yeah, just the paper-- I got it.
I have nothing further. Thanks.

463
00:19:49,700 --> 00:19:51,033
Where are you living now?

464
00:19:51,100 --> 00:19:52,333
-In the mobile home?
-[Nery] Yes.

465
00:19:52,400 --> 00:19:56,500
And you've made no further payments
to the defendant?

466
00:19:56,567 --> 00:19:57,233
No.

467
00:19:57,300 --> 00:19:59,100
-[Acker] You said you paid about 12?
-Yes.

468
00:19:59,166 --> 00:20:01,133
[DiMango] Okay. Thank you.
We're gonna retire to deliberate.

469
00:20:01,200 --> 00:20:03,834
Court now stands in recess.
Parties are excused.

470
00:20:03,900 --> 00:20:05,934
[theme music playing]

471
00:20:06,000 --> 00:20:07,266
Here's how I see it.

472
00:20:07,333 --> 00:20:10,700
For the plaintiff to prevail,
she has to demonstrate that the defendant

473
00:20:10,767 --> 00:20:15,700
had no good-faith basis for believing
she was entitled to more money

474
00:20:15,767 --> 00:20:20,100
and that the defendant set about
these eviction proceedings maliciously.

475
00:20:20,166 --> 00:20:20,834
Exactly.

476
00:20:20,900 --> 00:20:25,100
And I don't see that because the plaintiff
is continuing to pay her.

477
00:20:25,166 --> 00:20:27,900
She pays her almost twice
the amount of money.

478
00:20:27,967 --> 00:20:30,867
We're getting nearer the amount
that the defendant says

479
00:20:30,934 --> 00:20:33,567
the property is worth
than we are what the plaintiff says.

480
00:20:33,633 --> 00:20:36,133
So the plaintiff is continuing to go along

481
00:20:36,200 --> 00:20:38,333
with what the defendant sees
as a $13,000 sale,

482
00:20:38,400 --> 00:20:39,700
until she doesn't.

483
00:20:39,767 --> 00:20:42,667
COVID hits, she stops paying,
the defendant tries to evict her,

484
00:20:42,734 --> 00:20:45,567
the eviction's thrown out
for all the reasons that we know,

485
00:20:45,633 --> 00:20:48,133
plaintiff is in the house
and now wants punitive damages,

486
00:20:48,200 --> 00:20:49,200
and I just don't see it.

487
00:20:49,266 --> 00:20:54,233
I think that if anything, the defendant,
also unsophisticated, confused,

488
00:20:54,300 --> 00:20:56,867
and maybe thought she had
more of an entitlement to money

489
00:20:56,934 --> 00:21:00,333
based on the second document,
not aware of collateral estoppel

490
00:21:00,400 --> 00:21:04,200
or the controlling element,
the controlling nature of that agreement.

491
00:21:04,266 --> 00:21:07,800
The defendant was wrong,
but I don't see punitive damages.

492
00:21:07,867 --> 00:21:09,100
-I don't see legal fees.
-[DiMango] I agree.

493
00:21:09,166 --> 00:21:12,500
I see the same thing, and I'm also
thinking that the argument she might

494
00:21:12,567 --> 00:21:14,333
have made in front of the other judge
might have been different,

495
00:21:14,400 --> 00:21:17,066
so she thought if she changed
her argument here somewhat,

496
00:21:17,133 --> 00:21:18,233
that she was able to relitigate--

497
00:21:18,300 --> 00:21:19,467
'Cause that puts her in a better position.

498
00:21:19,533 --> 00:21:20,834
Right, that certainly didn't.

499
00:21:20,900 --> 00:21:22,533
But still I thought
the best part was when I go,

500
00:21:22,600 --> 00:21:26,133
"So if I look at this as a down payment,
is this a forgery?"

501
00:21:26,200 --> 00:21:26,867
-No.
-No.

502
00:21:26,934 --> 00:21:27,600
[both laugh]

503
00:21:27,667 --> 00:21:28,734
Exactly. Exactly.

504
00:21:28,800 --> 00:21:31,934
No, it's not, and I think that really
both of them were very confused.

505
00:21:32,000 --> 00:21:34,333
And based on that, I mean,
the plaintiff does not prevail

506
00:21:34,400 --> 00:21:35,934
in her argument
by a preponderance.

507
00:21:36,000 --> 00:21:37,367
I just can't find that she did.

508
00:21:37,433 --> 00:21:38,400
I agree.

509
00:21:38,467 --> 00:21:39,400
Great. So we're unanimous?

510
00:21:39,467 --> 00:21:40,133
-Yes.
-Yes.

511
00:21:40,200 --> 00:21:40,867
Wonderful.

512
00:21:40,934 --> 00:21:42,834
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513
00:21:42,900 --> 00:21:43,934
Court is back in session.

514
00:21:44,000 --> 00:21:45,900
Parties are reminded
you're still under oath.

515
00:21:45,967 --> 00:21:47,000
-Thank you, Byrd.
-[Byrd] Mm-hmm.

516
00:21:47,066 --> 00:21:49,967
We've deliberated
and we've reached a unanimous verdict.

517
00:21:50,033 --> 00:21:53,333
Ms. De La Rosa, in order for you
to prevail in your case,

518
00:21:53,400 --> 00:21:56,567
you would have had to have
demonstrated to us

519
00:21:56,633 --> 00:21:59,166
that the defendant
had no good-faith basis

520
00:21:59,233 --> 00:22:02,867
for acting as she did,
and we just don't find that true

521
00:22:02,934 --> 00:22:06,233
as a matter of law, and because
of the prior court proceedings,

522
00:22:06,300 --> 00:22:08,433
we have to treat that first document,

523
00:22:08,500 --> 00:22:11,000
the document that you
originally claimed was falsified

524
00:22:11,066 --> 00:22:13,934
before you said it wasn't falsified--
doesn't matter.

525
00:22:14,000 --> 00:22:15,967
Because of the findings
of the prior judge,

526
00:22:16,033 --> 00:22:18,200
we have to treat
that document as valid.

527
00:22:18,266 --> 00:22:22,367
So $5,000 sale,
however, you continued to pay her,

528
00:22:22,433 --> 00:22:24,934
and we don't see
any evidence of extortion.

529
00:22:25,000 --> 00:22:26,567
We don't see any evidence
of you saying,

530
00:22:26,633 --> 00:22:29,400
"You know what,
why are you asking me for this money?"

531
00:22:29,467 --> 00:22:32,266
You continued to pay her
in accordance with the agreement

532
00:22:32,333 --> 00:22:34,667
that she said
was the controlling agreement.

533
00:22:34,734 --> 00:22:37,867
She said it was $13,000,
you paid her nearly 12.

534
00:22:37,934 --> 00:22:40,767
But you didn't get to 13,
so she tried to evict you.

535
00:22:40,834 --> 00:22:42,033
That was thrown out.

536
00:22:42,100 --> 00:22:45,066
She lost on that substantive matter.

537
00:22:45,133 --> 00:22:49,367
But for you to get punitive damages,
you would have to show us that she had

538
00:22:49,433 --> 00:22:52,367
no good-faith basis for believing
that she had a right to do it.

539
00:22:52,433 --> 00:22:53,166
You haven't shown that.

540
00:22:53,233 --> 00:22:56,400
I mean, in fact,
as the facts have come out in this case,

541
00:22:56,467 --> 00:23:00,100
she would have been entirely justified,
frankly, in saying,

542
00:23:00,166 --> 00:23:02,100
"You know what,
I think I'm entitled to 13.

543
00:23:02,166 --> 00:23:04,967
She paid me 12. She stopped paying.
I'm going to evict her."

544
00:23:05,033 --> 00:23:07,567
So you failed to meet
your burden in this case,

545
00:23:07,633 --> 00:23:10,600
and we are dismissing your complaint
in its entirety.

546
00:23:10,667 --> 00:23:12,800
You have a home.
Good luck to you and enjoy it.

547
00:23:12,867 --> 00:23:14,033
-That's the verdict of the court.
-Thank you.

548
00:23:14,100 --> 00:23:15,800
-[gavel bangs]
-This case is now concluded.

549
00:23:15,867 --> 00:23:17,900
Parties are excused.
You may step out.

550
00:23:22,333 --> 00:23:23,266
She put me through a lot.

551
00:23:23,333 --> 00:23:24,533
I was not harassing her.

552
00:23:24,600 --> 00:23:27,266
Oh, I went through stress,
just everything,

553
00:23:27,333 --> 00:23:29,233
telling my kids
that they had to get evicted.

554
00:23:29,300 --> 00:23:30,734
I was just trying to get
in contact with her

555
00:23:30,800 --> 00:23:32,834
just to get monthly payments
like we agreed to.

556
00:23:32,900 --> 00:23:35,166
I feel like I was entitled
to what I was asking for.

557
00:23:35,233 --> 00:23:37,066
Don't trust anybody.
Get all the money up front.

558
00:23:37,133 --> 00:23:39,166
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559
00:23:39,233 --> 00:23:42,734
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560
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