Formal Complaint: Habitability Violation & Gray Water/Mold Contamination
Formal Complaint: Habitability Violation & Gray Water/Mold Contamination
(It's worth noting that Ms. Dunne was given 24 hours to respond, 27+ hrs. have passed with not so much as a "Your Concern Was Received")
To Whom It May Concern,
I am submitting this formal complaint regarding a serious and ongoing habitability violation at my residence, located at:
5965 E Shields Ave.
Unit #[Redacted for Public Posting]
Fresno, CA 93727
On Sunday, May 4, 2025, water (presumed gray) from an unknown source surfaced in a non-functioning bathroom sink. This fixture has no active water line and has remained sealed - confirming the contamination originated from a shared or common plumbing line. The incident persisted for over 24 hours, draining slowly and leaving visible residue. Two days later, on May 6, additional gray water, foam, and toxic backflow emerged again.
Attached is a PDF document containing timestamped photographic evidence of the ongoing sewage exposure. The conditions within my unit are currently:
- In direct violation of California Civil Code 1941.1
- In violation of Health & Safety Codes related to sewage exposure and mold
- A breach of minimum habitability standards under California law
- A public health hazard with potential long-term medical risk
I have notified RLJ Property Management - specifically Rachelle Dunne, named Agent for Service on corporate filings - yet no investigation or remediation has been initiated. This negligence places both residents and the HOA itself at severe legal and financial risk.
I am requesting immediate action:
1. A full inspection of shared plumbing systems in my block of units (109-116)
2. Remediation of all biohazards present in the unit
3. Relocation assistance during necessary repairs
4. A formal response within 3 business days
Please consider this complaint a matter of legal record and pending litigation. This letter, along with attachments and agency response (or lack thereof), is being logged for escalation to media outlets, legal counsel, and additional state and federal agencies if needed.
Sincerely,
Kristen C Snow-White
kcsnowhite7@gmail.com
(559) 912-4606
cc: CA DRE, Fresno City Code Enforcement, Fresno City Attorney's Office, CA AG Mr. Rob Bonta, CA SoS
Legal Addendum: Applicable CA Health & Safety Code Violations
California Health & Safety Code 17920.3 Substandard Building Violations (Relevant Sections)
Based on observed conditions and documented evidence, the following violations apply:
- (a)(1) Improper lavatory/sink (gray/brown water backflow)
- (a)(5) Unsafe water conditions
- (a)(11) Dampness of habitable rooms
- (a)(13) Visible mold growth
- (a)(14) General dilapidation or improper maintenance
- (a)(15) Lack of sewage system connection
- (c) General nuisance
- (e) Faulty plumbing
- (g)(2) Deteriorated waterproofing/foundation
- (j) Hazardous debris or water accumulation
- (k) Unsafe due to inadequate maintenance
Source: https://leginfo.legislature.ca.gov (HSC 17920.3 as amended by SB 1465, effective Jan 1, 2025)
To: Rachelle Dunne, RLJ "RENTAL" Management
Rachelle,
The attached photo documents a backflow incident that occurred in my unit [redacted for public posting] on 4 May 2025 at approximately 647 PM. This water surfaced in a non-functioning sink—a fixture with no active water line—which confirms the issue originates from shared or common plumbing infrastructure.
This is not an isolated incident. The City of Fresno has a documented history of plumbing failures and flooding events tied to this property. The conditions in my unit are now actively hazardous—toxic mold, sewer gas, and contaminated water—both violate health codes and minimum habitability standards under California law.
Rachelle, by naming yourself as Agent of Service in the Statement of Information, you are now the direct point of accountability for these conditions and their legal consequences.
Unless immediate action is taken, this will be escalated to:
- Fresno Code Enforcement
- California Department of Real Estate
- Environmental Health Services
- The HOA’s Insurance Carrier
- And all relevant legal authorities.
You are on notice. This photo is already being circulated and archived for litigation. I strongly advise halting any foreclosure activity or property sale involving my unit until a full inspection and remediation plan is in place.
I am requesting a formal response within 24 hours outlining:
1. Immediate steps to investigate and repair this sewer issue;
2. Temporary relocation options during remediation;
3. Full disclosure of past plumbing complaints logged for this address (5965 E. Shields, complete);
This is now a matter of public health, legal liability, and public record.
Sincerely,
Kristen C Snow-White
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