SHALOM BEN LEVY:

1. I purchased the fifty-three unit apartment building located at 671 S. Coronado St., Los Angeles approximately in 1981 and sold it in 1989 to Beyond Shelter, a non-profit housing corporation located at 4032 Wilshire Blvd. in the City of Los Angeles. During the period of my ownership I maintained the building in an above-average condition for the neighborhood.
   
2. During the period of my ownership approximately fifteen tenants resided in this building whom I discovered were selling narcotics. I immediately contacted the police and began eviction proceedings against these tenants.
   
3. An activist/attorney named MARK T. JOHNSON who was connected with the People's University located at 660 Bonne Brai St. in Los Angeles represented these drug dealers in criminal court and also defended them in the unlawful detainer (eviction) action that I had initiated in L.A. Municipal Court. Johnson was also an affiliate of the non-profit housing corporation, LATINOS UNIDOS,
   
4. During this same time period the L..A. Department of Building and Safety, Health Department and Fire Department began citing me with a multitude of code violations, many of which consisted of damage or unsanitary conditions inside the apartments of the same group of tenants mentioned earlier in this declaration. For example, the tenants created holes in the walls, which appeared to be for the purpose of passing narcotics back and forth between individual units to protect themselves in the case of a search by the police. I repaired these holes after being cited but immediately after the repair the tenants created these holes again. Since the Department of Building and Safety inspectors were coming on almost a daily basis, they repeatedly cited me for the same violation.
   
5. During this period of time I applied for rehabilitation loans through HUD and various other government-sponsored loan programs. My applications were repeatedly denied although the building conformed to the eligibility requirements specified in the various loan programs.
   
6. Since my loan applications were denied I began rehabilitation work utilizing my own funds both before and after the city citations were issued. I spent approximately $500 thousand dollars in this effort before I was eventually forced by the city to sell this building.
   
7. Before my sentencing date in criminal court, I was approached with an offer to buy the property by the non-profit housing corporation, BEYOND SHELTER, located at 4032 Wilshire Blvd. Suite 502 in Los Angeles. The purchase price agreed to was $2.1million although Beyond Shelter defaulted on $100,000 and therefore ended up spending $2 million for the property. The market value of the property at the time was approximately $2.3 million.
   
8. Beyond Shelter was able to obtain the same government sponsored loans which had been denied to me earlier, thereby creating a situation that afforded them a large positive case flow.
   
9. Mark. T. Johnson, the attorney who was instrumental in this abuse of my civil rights is now the director if the City of West Hollywood Rent Stabilization Division.
   
10. I ultimately lost everything that I owned as well as my family because of the abuse that I sustained by the City of Los Angeles, including JAMES HAHN.
    

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SHALOM BEN LEVY:

1. I purchased the fifty-three unit apartment building located at 671 S. Coronado St., Los Angeles approximately in 1981 and sold it in 1989 to Beyond Shelter, a non-profit housing corporation located at 4032 Wilshire Blvd. in the City of Los Angeles. During the period of my ownership I maintained the building in an above-average condition for the neighborhood.
   
2. During the period of my ownership approximately fifteen tenants resided in this building whom I discovered were selling narcotics. I immediately contacted the police and began eviction proceedings against these tenants.
   
3. An activist/attorney named MARK T. JOHNSON who was connected with the People's University located at 660 Bonne Brai St. in Los Angeles represented these drug dealers in criminal court and also defended them in the unlawful detainer (eviction) action that I had initiated in L.A. Municipal Court. Johnson was also an affiliate of the non-profit housing corporation, LATINOS UNIDOS,
   
4. During this same time period the L..A. Department of Building and Safety, Health Department and Fire Department began citing me with a multitude of code violations, many of which consisted of damage or unsanitary conditions inside the apartments of the same group of tenants mentioned earlier in this declaration. For example, the tenants created holes in the walls, which appeared to be for the purpose of passing narcotics back and forth between individual units to protect themselves in the case of a search by the police. I repaired these holes after being cited but immediately after the repair the tenants created these holes again. Since the Department of Building and Safety inspectors were coming on almost a daily basis, they repeatedly cited me for the same violation.
   
5. During this period of time I applied for rehabilitation loans through HUD and various other government-sponsored loan programs. My applications were repeatedly denied although the building conformed to the eligibility requirements specified in the various loan programs.
   
6. Since my loan applications were denied I began rehabilitation work utilizing my own funds both before and after the city citations were issued. I spent approximately $500 thousand dollars in this effort before I was eventually forced by the city to sell this building.
   
7. Before my sentencing date in criminal court, I was approached with an offer to buy the property by the non-profit housing corporation, BEYOND SHELTER, located at 4032 Wilshire Blvd. Suite 502 in Los Angeles. The purchase price agreed to was $2.1million although Beyond Shelter defaulted on $100,000 and therefore ended up spending $2 million for the property. The market value of the property at the time was approximately $2.3 million.
   
8. Beyond Shelter was able to obtain the same government sponsored loans which had been denied to me earlier, thereby creating a situation that afforded them a large positive case flow.
   
9. Mark. T. Johnson, the attorney who was instrumental in this abuse of my civil rights is now the director if the City of West Hollywood Rent Stabilization Division.
   
10. I ultimately lost everything that I owned as well as my family because of the abuse that I sustained by the City of Los Angeles, including JAMES HAHN.
    

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