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three-day notice, and proof of service of the notice), in addition to the testimony of Joublin
Manoochehri and defendant, who was called pursuant to Evidence Code section 776.
Defendant was the only defense witness.
In 2013, when defendant signed the lease agreement, the property was owned by Edith
Newman and managed by K & B Property Management. JNM Realty took over as the property
manager at least five years before the trial. Manoochehri is the assigned property manager.
Newman died a few years before the trial and her children inherited ownership of the property.
In 2023, ownership of the property was transferred to plaintiff, an LLC. Manoochehri
confirmed that a written notice of change of ownership “was given” to defendant “within the
last 12 months,” “towards the end of 2023,” but he did not bring the notice to court. The notice
was posted on defendant’s door and in the common area of the complex near the mailboxes,
and it was separately mailed to defendant. According to Manoochehri, the document contained
“all the information pertaining to the new ownership” and “anything else I [sic] needed to know
. . . where to pay rent and everything like that.” Manoochehri could not recall whether the
notice contained any information other than notification of the change of ownership and where
to pay rent. Manoochehri believed he also called defendant to notify him of the changes.
Manoochehri testified that defendant accumulated a minimum of $7,236 in past-due rent
between June 2023 and April 2024, as reflected in the rent ledger.3 He reviewed the three-day
notice prepared by plaintiff’s counsel and confirmed the information on the notice was
accurate. The rent ledger reflected defendant was charged $50 late fees multiple times during
his tenancy, but the statement of rent due in the three-day notice did not include late fees.
Defendant failed to pay the rent owed or quit possession of the premises after the three-day
notice period expired.
In his testimony, defendant did not dispute that his monthly rent was $1,831 or that he
received a copy of the three-day notice to pay rent or quit. When asked if he attempted to pay
the rent owed, defendant replied, “I believe I mailed a check or communicated with the office at