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[ABOVE] Photo looking north, taken 9/30/2014, of the interior side of plaintiff’s
masonry wall, showing that the defendant continued her aggressive enclosure activities
& use of our wall, during the grace period of Aug. Sept. 2014, when her wall-grown–
bougainvillea (also pictured in Attachment 5) invaded our garden by several feet and
damaged the wall’s plaster.
As of the end of Dec. 2014, when this lawsuit was filed, the defendant’s greenery
encroached even more into my back garden, littering the area, including my swimming
pool, with debris, all of which adds to our maintenance costs.
Also visible here is the section of wall (marked by a red circle) on which the
adolescent, who accessed our private property from the defendant’s garden on
5/28/2014, was standing: i.e., on top of our wall’s northwest corner, only 9 ft. from our
swimming pool, and only 66 in. above the dirt floor of our planter box. (Also visible, to
the left of the red circle, is one of the defendant’s home improvements: i.e., the
shingled roof, with light blue fascia boards, of the small house-like structure she had
built in her back garden in April 2014, after removing a mature palm tree to make
room.)
[ABOVE] Exchangeable Image File Format
(EXIF) information proving that this digital photo
was taken on 9/30/2014. Taylor-Pearce v. Lewis, Trustee / 37-2014-00312813-SC-SC-CTL
Memo to Small Claims Judge
ATTACHMENT 6
Photo Taken on Cut-Off Date for Defendant’s
Rent-Free Use of Plaintiff’s Wall