The complaint was filed by Jill Mann against the HOA. The cross-complaint was filed by the HOA against Jill Mann. Together, these documents define the claims and defenses in this case. Both are public court records.
The Complaint
Jill Mann v. Las Brisas Pacificas, Inc. · Filed September 23, 2024
Jill's lawsuit against the HOA alleging breach of equitable servitudes, breach of fiduciary duties, negligence, and seeking declaratory relief. The complaint details the HOA's 35-year control over slopes, the French drain installation without engineering oversight, and the resulting slope failure.
"The Association installed the water drainage system at the slopes at its sole discretion, selecting the specific locations for any drainage, as well as the size, method and manner of drainage. The individual homeowners, including Plaintiff, have no control over the water drainage system at the slopes."
Paragraph 11
The Cross-Complaint
Las Brisas Pacificas, Inc. v. Jill Mann · Filed by the HOA
The HOA's counter-lawsuit against Jill Mann, seeking reimbursement of $65,434.81 for the slope repair performed by Mountain Movers Engineering. The HOA claims the slope is the homeowner's responsibility and is pursuing judicial foreclosure against Jill's home.
"The Association seeks reimbursement of $65,434.81 for slope repair costs and seeks to impose an assessment lien against Plaintiff's property, enforceable through judicial foreclosure."
Prayer for Relief