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Memorandum of Points & Authorities

10 Pages

Ex Parte Application for Emergency Stay of Judgment of Writ of Possession. Filed by Jesse Lucus, Defendant in Pro Per, requesting the Court stay execution of a Writ of Possession issued January 26, 2026, and permit presentation of meritorious defenses.

1 Fraudulent misrepresentation — Plaintiff's case manager Roynelle Mayfield destroyed accurate financial disclosures and forced Defendant to sign materially false documents submitted to HUD-VASH officials.
2 Public corruption — Evidence of coordination between Plaintiff, Oakland city employees, and VA housing officials involving potential ethics violations.
3 Breach of habitability — 96+ documented complaints over 11 months: broken security gates, human waste on property, repeated thefts, and refusal to remediate.
4 Retaliatory eviction — Official VA complaint filed January 4, 2026; unlawful detainer summons served just 4 days later on January 8, triggering Civil Code § 1942.5 presumption of retaliation.

Download Full Memorandum (PDF)

POA.pdf · 106 KB · 10 pages

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Insight Housing — SSVF Approval Letter

Exhibit

Official approval letter from Insight Housing dated December 2, 2024, signed by Roynelle Mayfield (Roads Home Case Manager). This letter confirmed Jesse Lucus was approved for SSVF (Supportive Services for Veteran Families) financial assistance including deposit assistance, rental assistance, and other financial support. The same case manager who signed this promise later destroyed accurate financial disclosures and forced the signing of fraudulent documents.

Roads Home Financial Support Approval Letter

Dated 12/2/2024 · Signed by Roynelle Mayfield, Roads Home Case Manager · Approved: Deposit Assistance, Rental Assistance, Other Financial Assistance · This written commitment was made to the landlord — the same Roynelle Mayfield who, on February 18, 2025, destroyed accurate financial disclosures and coerced the signing of false documents.

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Audio Evidence — Veterans Hotline Recordings

2 Recordings

Recorded calls to the National Homeless Veterans Hotline documenting complaints about habitability violations, security failures, and retaliatory eviction. These calls are referenced as exhibits in the court filing.

Jan 4, 2026

National Homeless Veterans Hotline — Initial Complaint

The official complaint that triggered retaliation. Filed after months of ignored habitability complaints, this call documented security failures, unsanitary conditions, and demanded accountability from Elizabeth Ann Williams Rentals. Four days later, on January 8, the unlawful detainer summons was served.

↓ 43 days later ↓

Feb 16, 2026

National Homeless Veterans Hotline — Follow-up

Follow-up call to the Veterans Hotline after the retaliatory eviction action was filed and the Writ of Possession issued. Documents the ongoing situation and continued efforts to seek accountability through official VA channels.

Additional evidence referenced in court filings — View original evidence document →

Defamation & Retaliation — Public Official Misconduct

Lateefa Simon — Town Hall Meeting: Unlawful Exclusion & Security Threat

Audio documentation of a public official's staff directing security to bar attendance and making false threats allegations — a documented act of defamation used to destroy character and credibility.

Documented Defamation & Civil Rights Violation

Staff acting on behalf of Lateefa Simon instructed on-site security personnel to prevent attendance at a public town hall meeting. Those staff members falsely claimed to security that the tenant was making threats — an allegation with no factual basis. This false statement constitutes libel and slander intended to destroy the character and credibility of a justice-involved tenant who sought accountability. The security guard on site then proceeded to directly threaten both the tenant and his girlfriend. This audio recording captures that encounter.

1 Unlawful exclusion from public town hall — Staff directed security to bar attendance at a public meeting, denying the right to participate in a public forum and hold an official accountable.
2 False allegation of threatening behavior — Simon's staff falsely characterized the tenant to security as threatening, with no factual basis. The fabricated allegation was designed to discredit and silence a critic — a textbook defamation tactic.
3 Security guard threat — On-site security, acting on the false information provided by Simon's staff, proceeded to make direct verbal threats against the tenant and his girlfriend.
4 Pattern of retaliation — This incident is consistent with a documented pattern in which Lateefa Simon refused to assist a justice-involved tenant facing illegal eviction, and now used her position to suppress public accountability.

Lateefa Simon Town Hall

Town Hall Exclusion & Security Threat — Audio Record

This recording documents the encounter at Lateefa Simon's town hall meeting in which staff instructed security to bar attendance using the false claim of threatening behavior. The recording captures the security guard's threats made against the tenant and his girlfriend. This audio serves as direct evidence of defamation by a public official's staff and a witnessed threat by security personnel.

Lateefa Simon — previously documented refusing to assist a justice-involved tenant during an illegal eviction; now documented suppressing public accountability through false allegations and endorsed threats. — Download recording →

Elizabeth Ann Williams v. Jesse Lucus

Memorandum of Points & Authorities

Insight Housing — SSVF Approval Letter

Audio Evidence — Veterans Hotline Recordings

Lateefa Simon — Town Hall Meeting: Unlawful Exclusion & Security Threat