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HOA DIVISION Joel M. Kriger, APC Important Legislation Affecting Homeowners News Fourth Quarter Newsletter, 2004 Legislation for 2005 Takes Effect January 1 BY KENNETH H. DILLINGHAM, ESQ. detailed in his letter to the Members A s yet another legislative new procedure, the new law provides year draws to a close, of the California State Assembly (see one for your association. California law again page 4). The new procedure must be changes for common inter- However, watch carefully for more adopted by the association following est subdivisions. From such of the same next year, as the bill’s sup- the new rule adoption procedures diverse areas as dispute porters have indicated that they will from last year (30-day prior notice to resolution to financial be reintroducing similar legislation in owners, owners have veto rights). disclosures, California a specific attempt to curb the use of It must include the following homeowner associations foreclosures to collect assessments. requirements: are facing a slew of new AB 1836, Dispute Resolution Changes • Either party may invoke the requirements that can for Communities procedure. prove a trap for the The California Law Revision • Such notice shall be in writing. unwary. Directors and Commission, after working several • There must be prompt deadlines, managers should years on the Davis-Stirling Common with a maximum time for the review the governing Interest Development Act, produced association to act. documents for their com- several pieces of enacted and pro- • Associations must participate if an munities to ensure that any posed new law. One of these took owner invokes the procedure. required changes are made. effect in 2004, and deals with proce- • Owners may participate, but are not AB 2598, Restrictions on dural fairness in rule and decision required to. Assessment Collection making, allowing owners to veto • Both parties must have the means Vetoed by Governor unpopular rules. The first of two by which they may explain their Probably the most stun- separate pieces of new legislation, positions. ning, surprising and sweet- Assembly Bill 1836, changes the way • Owners have the right to appeal any est victory for homeowner disputes are handled in common decision directly to the board. associations in many years was interest subdivisions. AB 1836 adds another layer of • Any resolution that is not in conflict the veto of Assembly Bill 2598. with law or the governing docu- If passed, the law would have rules dealing with disputes and viola- ments binds the parties, and may prevented associations from using tions in community associations. The be judicially enforced. foreclosure to collect delinquent new law will require hearing proce- dure mandated upon homeowner • Owners may not be charged any fee assessments under $2,500, and to participate in the process. restricted collection remedies for associations addressing disputes and violations in their communities. These If you do not adopt a new policy, amounts over that. For many commu- new procedures do not replace any the new Civil Code §1363.840 applies. nities this could have meant years of existing procedure (e.g. Civil Code It contains a procedure specifically nonpayment, by one or more owners, requirements of alternative dispute including the above requirements. creating a budgeting shortfall that remaining owners would have had to resolution), but add another layer of CONTINUED ON PAGE 3 pay more to address. Through the dispute resolution procedures — efforts of many groups, including the specifically at no cost to the home- California Legislative Action Committee for the Community owner. And while owners may choose not to participate, homeowner associ- Inside ations are forced to participate. 2005 Legislation .................................. 1-4 Associations Institute, a truly massive 1999 No-Pet Rule Enforced .................. 5 campaign of letter writing, faxing, Fair, Reasonable and Expeditious calling and e-mailing from thousands Dispute Resolution Procedures CID Oversight Agency Proposed ............ 6 of people throughout the state con- Associations and boards must now Lunch & Learns .................................... 6 vinced Governor Schwarzenegger provide “... a fair, reasonable, and Meet the Staff ........................................ 7 that this bill was not good. The expeditious procedure ...” for resolv- Joel Kriger Recognition .......................... 7 Governor’s reason for the veto was ing disputes in their communities. Education Schedule ................................ 8 If the association does not adopt a News New 2005 Legislation mail, facsimile transmission, or “other means reasonably calculated Fair, Reasonable, and Expeditious Procedures, Again CONTINUED FROM PAGE 1 to provide” notice. Remember “fair, reasonable, and New ADR Requirements The parties still have thirty days to expeditious” procedures for dispute Associations and community owners respond to an ADR notice, and ninety resolution? The same factors now have been required to participate in days to complete the process once the apply to architectural applications. alternative dispute resolution as a pre- notice is accepted. Now, specific provi- Associations are required to provide lude to litigation since Civil Code sions of the California Evidence Code fair, reasonable, and expeditious pro- §1354 was enacted. AB 1836 makes are applicable to the proceedings, and cedures for making architectural deci- some changes to this law. any statute of limitation problem may sions. These procedures must provide Civil Code §1354 is now modified to be “tolled,” or extended, by participat- prompt deadlines, and must state a only refer to enforcement of the decla- ing in the ADR process. maximum time for responses by the ration and governing documents. The Finally, the new law still provides board or committee. Also, these proce- ADR provisions are now contained in that the cost of the ADR process dures must be included in the com- Civil Code §1369.510, et. seq. These “...shall be borne by the parties.” munity’s “governing documents,” which is defined in the Civil Code to mean the CC&Rs, bylaws, and rules, among other documents. Any decision made on an architec- tural application must be in accor- dance with applicable law, including California’s Fair Employment and Housing law, and must not be unrea- sonable, arbitrary, or capricious. Decisions must be in writing (no more talking to the owner on the sidewalk!), and if the application is disapproved, the written notice must contain the reasons why it was disapproved, and the procedures needed for reconsideration. Owners’ Right to Appeal If an application is disapproved, the owner is entitled to reconsideration by the board of directors. This reconsid- eration of the denied application does new provisions for ADR are slightly dif- Changes to Annual Notices to Owners not need to be made at an open meet- ferent from the §1354 provisions, but The new ADR statute still requires ing, but it does not qualify as the first ADR is still required for disputes for an annual notice to owners summariz- step in the internal dispute resolution declaratory, injunctive, or writ relief, or ing the law, with a specific paragraph process. Thus, an owner whose applica- that relief in connection with a claim included. Additionally, the notice to tion is denied may first appeal to the for monetary damages not exceeding owners must now include the internal board for reconsideration, then, if $5,000. dispute resolution procedures adopted denied again, may start the dispute res- Matters subject to the prior ADR pursuant to §1363.850. olution procedures required by the requirement have been expanded and AB 2376, New Requirements for new law. clarified. “Enforcement Action” is Architectural Reviews defined in the new law as civil actions Long a function of the board or a or proceedings, other than cross com- committee, the review of architectural plaints, to enforce provisions of the changes in common interest subdivi- Civil and Corporations Code govern- sions has been one of the more impor- ing homeowner associations, and the tant aspects to preserving the flavor governing documents for the com- and feel of a community. It has also munity. Both small claims actions and been a source of friction between assessment disputes are excluded from owners and associations. this pre-litigation requirement. A new Section 1378 is added to the The ADR notice must still be served Civil Code affecting the way associa- on the parties to the dispute. However, tions review and approve or disapprove the new law allows for service by per- architectural applications for changes sonal delivery, first-class mail, express by owners. 2 Anderson & Kriger Quarterly Newsletter News No Right to Change the membership. Previously this summary Changes to Reporting Timeframes Common Areas needed only be in a certain type-face. The time for distributing the The new law specifically does not Now, this summary must be in the budget, reserve summary, and other authorize any owner to propose or same type-face, and must also be based notices to owners has been length- make any physical change to the com- only on assets held in cash or cash ened. The new timeframe is thirty mon area that is inconsistent with the equivalents. Additionally, the summary to ninety days before the fiscal year governing documents for the com- must include, in addition to existing (formerly forty-five to sixty days before munity or applicable law. Nor is the requirements and statements, a state- the fiscal year). This change applies to association, board or committee ment as to the mechanism by which distribution of (a) the budget and required to approve such a change. the board will fund the reserves, reserve summary, (b) the lien enforce- ment statement, and (c) the insurance disclosures. New Mandatory Assessment and Reserve Funding Disclosure Summary Form A new Civil Code §1365.2.5 contains a new form required in disclosing to owners the assessment and reserve funding summary. This new form must accompany each budget or budget summary distributed to owners. While the form may be supplemented or modified to “...clar- ify the information delivered,” the minimum information set out in the form must be provided. New Notice Before Borrowing from Reserves Associations have been able to bor- row from reserves to fund short-term New Annual Notices to Owners including assessments, borrowing, use of other assets, deferral of repairs, or cash flow issues in their operating The new Civil Code §1378 requires other alternatives. Also, in any reserve accounts, subject to certain require- associations to provide a notice to summary statement or report, reserve ments. There is now an additional owners each year. This disclosure must funding calculations may not assume a requirement that before any such bor- contain notice of any requirements for rate of return on cash reserves in rowing, or before delaying any repay- approval of architectural applications excess of two percent above the ment, the board must provide notice and describe the types of changes that rediscount rate published by to the owners of the meeting at which require approval. Additionally, the dis- the Federal Reserve Bank of the action will be discussed. closure must include a copy of the procedure used to review and approve San Francisco. CONTINUED ON PAGE 4 or disapprove a proposed change. AB 2718, New Financial Disclosures and Reserve Requirements As many communities mature, the issue of reserve funding becomes cru- cial to associations and owners alike. In response to concerns raised by Realtors and others, this new law was enacted to revise the provisions gov- erning the distribution of financial and other documents to owners, and requiring a specific format for assess- ment and reserve funding disclosures. It is required for reports and disclo- sures made after July 1, 2005. Changes to Reserve Disclosures Associations have been required to include a summary of their reserves with the budget distributed to the Anderson & Kriger Quarterly Newsletter 3 News mbly: New 2005 Legislation e California State Asse To the Members of th signature. CONTINUED FROM PAGE 1 ly Bill 2598 without my I am returning Assemb rn Common s to the laws that gove New Method of Delivery of Escrow This bill ma kes sweeping change for failure the foreclosure process Documents Interest De velopments (CID) and the intent of rs’ assessments. While delinquent homeowne Owners have been obligated pur- to pay homeowners suant to Civil Code §1368 to provide d intended to protect this leg islation is laudable an linquent assess- certain documents to prospective pur- on for small sums of de fro m being foreclosed up gatively impact all chasers. This obligation normally is sat- y broad and could ne isfied in an escrow for sale, when the ments, this bill is overl CIDs. association is requested to provide the homeowners living in ssments for other result in increased asse documents, which associations are This bill could unfairly ssments in a timely ma nner and obligated to provide. This new law homeowne rs who pay their asse lien perty in CIDs due to the allows those associations who maintain may delay the transfer of real pro the bill. the documents in an electronic format procedures set forth in against a to provide them via an electronic t course of action taken Forec losure should be the las ion betw een home- transmission or machine readable elec- re more open discuss tronic storage media (e.g. CD-ROM) if homeowner. If there we ny conflicts could be resolved. ciations, ma owners and their asso 36 (C hapter 754, 2004) the parties agree. signed into law AB 18 That is why I recently 04). These bills establish methods to and AB 2718 (Chapter 766, 20 tween tter communication be encourage more disclosure and be associations. homeowners and their ure statutes is rification in the foreclos I recog nize that additional cla incrementally ange should be made nece ssary. However, this ch fore, I am directing impacted parties. There wo rking together with all siness, Transportation er Services and the Bu the State and Consum interested stakehold- s to work with all of the and Housing Agencie for collecting CID sure that the process ers to develop and en ined so that all homeow ners are homeowne rs’ assessments is ref ery reason- ure only occurs after ev treated equitably and foreclos usted. able alternative is exha Schwarzenegger AB 224, Fire Retardant Roofing Sincerely, Gov. Arnold Materials In response to the October wildfires in Southern California, Assembly Member Christine Kehoe introduced, and the Governor signed, a bill Skip Daum is the CLAC Liaison to CAI National and works for CIDs in making sure legislators know “both sides of the story” when it comes restricting the ability of associations to to passing or vetoing new laws. require replacement roofing that poses Skip led a massive letter-writing a fire danger. This new law is applica- and phone-calling campaign ble to those communities located in along with grassroots California very high fire severity zones, and was CLAC members to help veto AB designed to address a common cause 2598 in the best interest of of massive destruction during a wild- California homeowner associa- fire — wood-shake roofing materials. tions and those members that Once again, associations, board customarily pay their assessments members and managers are faced on time. Be on watch on this with a new set of regulations that topic of foreclosure in homes they must follow. If you have any where assessments were ignored questions on these or any other issues, for seemingly small amounts of please feel free to contact our office money. for assistance. It may resurface with better Attorney Ken Dillingham is the current alternatives and new language Legislative Action Committee Roundtable but “It will be back” as Governor Chair and CLAC Delegate for San Diego Arnold Schwarzenegger would CAI. say! 4 Anderson & Kriger Quarterly Newsletter News California Supreme Court Remains Consistent with Trial & Appellate Court she purchased the property and, there- 1999 No-Pet Rule Enforced fore, it could not be enforced against her. Again, the California Supreme BY LAURI CROCE, ESQ. Court rejected these arguments based on the Davis-Stirling Act. I n Villa de las Palmas restriction. The Association thereafter Terifaj proffered a third argument Homeowners Association v. filed an amended complaint alleging by which she averred, in effect, that Terifaj (June 14, 2004) 33 the same causes of action and seeking amended CC&Rs are not enforceable Cal.4th 73, the California the same relief as the original com- as equitable servitudes like original Supreme Court addressed plaint, this time based upon the CC&Rs are. The California Supreme several procedural and CC&Rs rather than the Rules & Court rejected this argument for being substantive issues pertaining to the Regulations for the community. The as destabilizing as the first argument. enforceability of CC&Rs in general, judge in a bench trial (i.e., a trial with- Fourth and finally, Terifaj argued and pet restrictions in particular. The out a jury) ruled in favor of the that the no-pet restriction in the questions addressed were (a) whether Association. They found the covenants CC&Rs did not meet the Court’s own use restrictions added to the CC&Rs and restrictions in the Amended Nahrstedt standards, in that it was sub- through an amendment and recorded CC&Rs were enforceable equitable after a homeowner had purchased an stantively arbitrary and imposed a bur- servitudes, and granted a Judgment individual unit were binding on such den on Terifaj that far outweighed any against Terifaj permanently enjoining an owner, and (b) whether the benefit to the community from the any further violation of the no-pet California Supreme Court’s rule set rule. Here, the California Supreme restriction. forth in Nahrstedt v. Lakeside Village Court first explained that the Nahrstedt Supreme Court rejects arguments rule applies to subsequently adopted Condominium Association (1994) 8 Terifaj made several arguments to and recorded use restrictions incorpo- Cal.4th 361 (“ Nahrstedt”) – that restric- the California Supreme Court in seek- rated into a development’s CC&Rs as it tions in a common interest develop- ment’s declaration are presumed to be ing to overturn the Judgment. First she does to original CC&Rs. (Interestingly, reasonable and enforceable – applied argued that the restriction in the the Nahrstedt case also involved a pet with equal force to CC&R amend- CC&Rs banning pets was added after restriction.) Then it held that the Villa ments. The answer to both questions she had purchased her Villa de las de las Palmas CC&Rs provision pro- was a resounding “yes.” Palmas unit, and therefore did not hibiting pets was not unreasonable as a apply to her. The California Supreme matter of law. The Supreme Court reit- Veterinarian moves pet in – breaks rule Court rejected this argument, holding Villa de las Palmas is a small condo- erated its pronouncement in Nahrstedt that use restrictions added to CC&Rs that prohibiting pets is “rationally minium development consisting of 24 by amendment bind not only subse- mostly vacation-home units located in related to health, sanitation and noise quent purchasers, but current home- concerns legitimately held by resi- Palm Springs. Pursuant to the author- owners as well. The California ity granted in the Villa de las Palmas dents” of common interest develop- Supreme Court noted that Terifaj’s ments. And importantly, the Court CC&Rs – but not a specific provision argument ran counter to a clear read- in the CC&Rs banning pets – the held that the recently enacted Civil ing of the applicable statutes con- Code Section 1360.5 (which requires Association adopted a no-pet rule. tained in the Davis-Stirling Common Paula Terifaj, a veterinarian who pur- associations to allow at least one pet in Interest Development Act. The Court all governing documents created after chased her vacation home unit in also reasoned that her argument was 1995, did not receive a written copy of January 2001) does not contradict the untenable, stating that “to allow a dec- conclusion that a no-pet restriction the no-pet rule, but was admittedly laration to be amended but limit its aware of it at point of purchase. Yet, may be reasonable and enforceable applicability to subsequent purchasers under the circumstances. The Court she brought her boxer dog to the would make little sense,” since Terifaj’s complex in violation of the rule. explained that Section 1360.5 does not scheme would result in use restrictions mean all no-pet provisions are unrea- Terifaj attempted to have the Associ- applying to some but not all owners in ation amend the no-pet rule at the sonable – it merely demonstrates a the community at any given time – legislative preference for allowing Association’s 1996 and 2000 general leading to instability in the com- meetings, but was unsuccessful. homeowners in common interest munity, precisely what the CC&Rs are developments to keep at least one pet. Warned, Sued, and Enforced meant to avoid. It is worth noting, in conclusion, The Association repeatedly warned Second, Terifaj argued that the no- that Terifaj not only lost her case in Terifaj that she was violating the com- pet provision added to the CC&Rs was the trial court, the appellate court, munity’s no-pet rule and was eventu- procedurally unreasonable because and the California Supreme Court, ally compelled to bring suit against the provision was not contained in a but she was also required to pay Terifaj in August 1999. document recorded prior to her pur- the Association’s attorneys’ fees in During the pendency of the lawsuit chase of a unit in the development. In addition to her own. to enforce the rule, the members of other words, Terifaj argued she did the Association voted to amend their not have notice of the restriction when CC&Rs to add a specific no-pet use Anderson & Kriger Quarterly Newsletter 5 News Within Department of Consumer Affairs CID Oversight Agency Proposed BY JOEL M. KRIGER, ESQ. Mediation — The Commission and efforts through mediation are T he California Law Revision Commission, appointed by the Legisla- believes that many homeowners associ- ation disputes can be resolved inex- unsuccessful, the Bureau would have the authority to issue a corrective cita- ture to examine the laws pensively, informally and amicably tion. This citation would order abate- governing community asso- through Bureau-facilitated mediation. ment of the violation and could ciations, is proposing the The law will allow any person to include other relief. In addition, the creation of an oversight agency for request the Bureau’s assistance in Bureau will also be empowered to community associations. The Com- resolving a dispute. On receipt of such impose an administrative fine of up to mission is in the process of having $1,000 per violation against any indi- informational hearings on the pro- viduals it finds that have acted with posed law before it is finalized and The law will allow any malice, oppression or fraud. Any fines submitted to the Legislature for person to request the imposed against Board Members can- approval. Laws submitted by the non- not be indemnified by their com- partisan commission have an 80-90 Bureau’s assistance in munity association, but must be paid percent rate of passage. by the Board Member individually. The proposed law would create the resolving a dispute Financial support for the Bureau Common Interest Development through bureau will come entirely from the residents Bureau within the Department of of community associations. The Consumer Affairs. Primarily, the func- facilitated mediation. required fee would be paid by the tions of the Bureau would be three- community association when it regis- fold. request, the Bureau shall, within its ters with the Secretary of State every Education — The Commission found resources, investigate the dispute, con- two years. The initial funding would that homeowners do not fully under- fer with the interested parties and be set between $5 to $10 per unit stand their rights or obligations in assist in efforts to resolve the dispute per year. communicating with their associations. by mutual agreement of the parties. The Commission is now holding Mistakes and misunderstandings are Law Enforcement Powers — informational hearings regarding this inevitable and may lead to serious, The Commission believes there will proposed law. If it decides to proceed, costly and divisive problems. The be some disputes that cannot be a statute will be drafted and submitted Bureau’s purpose in educating officers resolved through appeals to reason to the Legislature. and homeowners is to reduce or pre- and goodwill. When the Bureau finds a vent the severity of these unforeseen violation of community association law, conflicts. LEGISLATIVE LEGAL LUNCH & LEARNS — Community Managers Only – Laws in Effect January 1, 2005 New laws will take effect on January 1, 2005 and the following management companies have reserved their dates for a “Legislative Legal Lunch & Learn” — call Patee at (800)425-6397 ext. 322 to reserve your date. 1. November 9, 2004 – Haven Management in Ontario 2. November 12, 2004 – Mega Management in San Diego 3. November 18, 2004 – Euclid Management in Upland 4. December 8, 2004 – Hudson Management in San Diego 5. December 10, 2004 – CMS in Upland Optimum Management Company in 6. December 17, 2004 – Castle Breckenridge in San Diego (La Mesa) Tustin invited Joel Kriger and Patee 7. January 21, 2005 – Mauzy Management in Temecula Barta to present a Legal Lunch & Attorney Ken Dillingham, current delegate and chairperson for the Learn on Maintenance Responsi- Legislative Action Committee of CAI San Diego, will present the new laws on bilities and CC&R Enforcement in power point with legislative handouts. Marketing Director Patee Barta, current August of 2004. liaison to the CAI-San Diego Board on the Legislative Action Committee will assist Dillingham. 6 Anderson & Kriger Quarterly Newsletter News Meet the Staff Lauren Derstine, Esq. Lauren Derstine, a resident of La Mesa, brings nine years of experience in insurance defense litigation, real estate and construction law to her position as an associate with Anderson & Kriger. She deals primarily with such matters as association and homeowner rights, contract disputes, property rights, assessments and collections, employment issues, and document review in the firm’s Homeowners Association Department. She is a member of the San Diego County Bar Association, Lawyers Club and volunteers through the San Diego Volunteer Lawyers Program assisting children to maximize their spe- cial education opportunities. She is also a registered fiduciary. Ms. Derstine was admitted to the New York and New Jersey bars in 1994 and practiced insurance defense with an emphasis on commercial and personal injury cases in Newark, New Jersey with the firm of Wilson, Elser, Moskowitz, Edelman and Dicker, LLP during the mid 1990s. In 1998, she relocated to San Diego, California where she gained extensive litigation experience representing developers and subcontractors in construction defect cases. Ms. Derstine received her Juris Doctorate at the University of Houston Law Center in Houston, Texas, and her Bachelor of Arts degree, cum laude, in Psychology with minors in Philosophy, Spanish and Art History from Rutgers College in New Brunswick, New Jersey. Legal Assistant to Attorneys Lauri Croce & Lauren Derstine Bonnie Randall Bonnie Randall joined Joel M. Kriger, APC, a division of Anderson & Kriger, as a full- time legal assistant to Attorneys Lauri Croce and Lauren Derstine in the Community Association General Counsel Division of the firm. After her hire on April 1, 2004, she began working in litigation, revision of community association governing documents (CC&Rs) and general office procedures. Since October 1, Randall also assists Office Administrator Janet Wilcox. Randall says, “I’m pretty basic – worked as a legal secretary for a sole practitioner and two partners in law firms in Rockville, Maryland for the past 15 years primarily in civil liti- gation, general practice and family law.” The motivation to move to southern California, ultimately leading to her hire with Joel M. Kriger APC, was to be closer to her daughters, Jennifer, 29, a resident of Newport Beach, the Senior Marketing Representative for the Anaheim Angels, and Kelly, 26, a resi- dent of Pacific Beach and employed by the YMCA before and after-school program as a Site Supervisor for a junior high in La Jolla. Randall has been married to her high school sweetheart, Bill, for 35 years. The Rockville, Maryland law firms Randall spent so much time with were Sullivan, Talbott & Batt and the sole practi- tioner is Stacy J. Blondes. Rockville is a suburb of Washington, D.C. Kriger Recognized for 20 Years with CAI Joel Kriger (second from left) was recognized as a 20-year mem- ber and past president of CAI San Diego. He addressed the crowd from the podium at the September Mini Trade Show at the Del Mar Hilton Hotel. Enjoying the comradery of industry profession- als and members of his staff, Kriger “strikes a pose” at his booth with Patee Barta, Marketing & Public Relations Director, Lauren Derstine, Esq., Janet Wilcox, Office Administrator, Lauri Croce, Esq., and Ken Dillingham, Esq.. All of us at the Joel M. Kriger APC firm congratulate Joel on his long-standing relationship with San Diego CAI and his service with Greater Inland Empire and Orange County Chapters. Anderson & Kriger Quarterly Newsletter 7 Leadership in Legal Education 2004/2005 Attorneys at Law Attorneys Joel M. Kriger, Lauri Croce and Kenneth Dillingham will teach ______________ • ______________ the following courses in Homeowner Association Law: Corporate Office 8220 University Avenue, Suite 100 CACM Law Seminars — 2005 Homeowner Association Law La Mesa, CA 91941-3837 Panel on Fair Employment and Housing – for Board Members and Their (619) 589-8800 · Fax (619) 589-2680 Joel Kriger and State Department of Fair Managing Agents Offices in Temecula, Orange County, Employment and Housing Representative Riverside, Antelope Valley, Sacramento NOVEMBER 6, 2004 will discuss “What Is Fair About Fair GROSSMONT COLLEGE Housing?” 9 a.m. to Noon · Lauri Croce, Instructor This is an overview from the manager’s 8800 Grossmont College Drive, perspective of the Federal and State laws El Cajon, CA 92020 that prohibit discrimination in housing, and Room 554 – Park in Lot required accommodations in their rules for the disabled. Contact: Community Learning Manager JANUARY 14, 2005 619-660-4350; Refer to Schedule No. 4099 REGISTRATION: $35 (plus $12 payable in Certification SAN DIEGO TOWN AND COUNTRY RESORT class to instructor for optional book) 8-hour Class plus Exam & CONVENTION CENTER 8:30 - 4:30 p.m. · Self Parking $8 JANUARY 29, 2005 MARCH 5, 2005 500 Hotel Circle North, San Diego, CA 92108 UNIVERSITY OF CALIFORNIA 8 a.m. to 5:00 p.m. · Saturday RIVERSIDE EXTENSION CENTER 800-772-8527 Call hotel and ask for special CACM reduced 9 a.m. to 12 Noon · Lauri Croce, Instructor INSTRUCTORS: room rates! 1200 University Ave., Riverside, CA Contact: To use VISA or MasterCard, call Joel Kriger JANUARY 21, 2005 909-787-4105 or 800-442-4990 or e-mail AND MILLENNIUM BILTMORE HOTEL to register at: email@example.com Ken Dillingham 8:30 a.m. to 4:30 p.m. Registration: $60 (includes Condominium 506 South Grand Avenue, Los Angeles, CA 90071 Blue Book text and parking) University of California Riverside 213-624-1011 EDP 043-LPS-F67 Extension Center February 4, 2005 1200 University Ave., Riverside, CA APRIL 9, 2005 OAKLAND MARRIOTT CITRUS COLLEGE 8:30 a.m. to 4:30 p.m. Contact: To use VISA or MasterCard, 9 a.m. to 12 Noon · Joel Kriger, Instructor Joel Kriger will speak call 909-787-4105 or 1000 West Foothill Blvd. between 10:00 and 11:30 a.m. 800-442-4990 or e-mail to register at: Glendora, CA 91741-1899 1001 Broadway, Oakland, CA 94607 firstname.lastname@example.org Contact: Continuing Education 510-451-4000 626-852-8022 Registration Cost: $105 Registration: $45 (includes work binder, test, & parking) Book: Condominium Blue Book, $12.00 (to instructor) EDP 043-LPS-F68 BULK RATE News U.S. POSTAGE PAID PERMIT NO. 1 SAN DIEGO, CA Joel M. Kriger, A.P.C. 8220 University Avenue La Mesa, CA 91941-3837 (619) 589-8800 · FAX (619) 589-2680 www.a-k.com email: email@example.com If you no longer wish to receive the A&K News, please call (619) 589-8800 and let us know.
"Fourth Quarter 2004 - Kriger Law Firm"