Stay Out of Wisconsin
False Court Filing to Support Client's Fraud, Disregard of Process
New Paragraph
Unethical lawyer writes a mountain of lies upon misrepresentations with a cherry picked fact on top to put a few extra dollars in his scofflaw client’s pocket
What is fraud?
Fraud is generally defined in the law as an intentional misrepresentation of material existing fact made by one person to another with knowledge of its falsity and for the purpose of inducing the other person to act,
and upon which the other person relies with resulting injury or damage. Fraud may also be made by an omission or purposeful failure to state material facts, which nondisclosure makes other statements misleading.
To constitute fraud, a misrepresentation or omission must also relate to an 'existing fact', not a promise to do something in the future, unless the person who made the promise did so without any present intent to perform it or with a positive intent not to perform it. The false statement or omission must be material, meaning that it was significant to the decision to be made. For injury or damage to be the result of fraud, it must be shown that, except for the fraud, the injury or damage would not have occurred.
To constitute fraud the misrepresentation or omission must be made knowingly and intentionally, not as a result of mistake or accident, or in negligent disregard of its truth or falsity.
Also, the plaintiff must prove that the defendant intended for the plaintiff to rely upon the misrepresentation and/or omission; that the plaintiff did in fact rely upon the misrepresentation and/or omission;
and that the plaintiff suffered injury or damage as a result of the fraud. Damages may include punitive damages as a punishment or public example due to the malicious nature of the fraud.
On my initial viewing of the unit on 3/27, Nick Kedrowski told me that the well water was “clean & good.”
On that same day, he also claimed that the unit’s pipes were being replaced to improve the water pressure and the job would be completed by “mid-May” though he wrote the lease to say May.
Nowhere in any of the emails exchanged between 3/24-4/26
did Nick provide any information re the gross problem with iron in the water.
It was only after I moved in on 4/27 that I discovered the enormous quantity of iron in the water when I viewed the two toilet bowls for the first time and drew water from each of the taps.
After several visits over the next 10 days, Spectrum finally achieved a stable internet connection and I was finally able to write to Nick on 5/10:
"I’m also quite concerned re the water as it continues to be orange rather than the usual clear as seen in the picture of the toilet bowl. It is particularly disconcerting that the orange watermorphs into particles that land on the bottom of the glass. An explanation and rectification of this situation is necessary." and"I do think functioning doors, windows & screens, clear water, etc., are rather reasonable expectations."
Nick wrote that he was unaware of the unit's condition on 5/10. Perhaps he thinks that makes him immune to the legal requirements of WI §704. Note: It doesn't.
It's extremely unlikely that Nick was unaware of the unit's condition given the document he submitted to the court on 3/16 describing the damages incurred as a result of the tenant evicted 2/01.
Nick evinced no surprise that the amount of iron in the unit's water was a problem as shown in his response:
“The water issues must be related to the pipes in the trailer itself and the new lines should remedy that.” Note: "must be" & "should remedy that"
Nick omitted the iron-water issue from our conversation on 3/27 as part of the reason the pipes were being replaced and not just water pressure. Probably even the sole reason given the minimal to no
improvement in water pressure. I surmise that Nick was hoping/thinking/wishing that the "off the books" plumber's no-permit pipe replacement would correct the quantity of iron flowing from every tap.
However, whatever pipes were replaced did not resolve the problem - not even a little bit. So, what did Nick do about the problem? Did he ask for an appointment to assess or evaluate the cause of the
problem? No. That was never done because he had already defined the problem as he writes in his email of 7/01:
"If the water remains unimproved, it may be necessary to replace lines below ground. We will determine how best to approach that situation if the need arises but if that is the case,we may have to terminate your lease because we would not continue to rent the unit until that issue is remedied and it may take a considerable amount of time to remedy."
That's their solution: kick out the old lady who had signed a one-year lease 63 days earlier & had moved herself & two cats two hundred miles to expand her insurance brokerage.
Any requests to evaluate the problem? No.
They had already defined the cause of the problem but chose not to share that information with me anytime from the initial email of 3/24 to the 4/12 email which provided the one year lease.
I signed the lease on 4/16 without the information necessary to make an informed decision. Had I known the problem AND the fact that they had no intention whatsoever of correcting the problem(s),
I would have made a different decision & moved instead to one of the other locations I was considering. The icing on this fraudulent cake was their expectation of full rent without doing anything
about
the water or any of the other repairs necessary for a habitable unit with full & normal ue of the premises.
The kicker, of course, was that they secured the services of an attorney, Patrick Arendt, who was willing & able to help them succeed in this fraudulent endeavor despite:
ABA Rule 1.2(d) "A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is criminal or fraudulent"
Believes needs repair? Believes? Facts do not require belief & pictures don't lie. Repairs necessary were documented with photos on 5/10.Nick agreed with me and "believed" ALL the repairs needed to be done on 5/10.Is Arendt also unaware of 704.07(2)(a)5 and 704.07(2)(a)3 requiring structural repairs to be completed & to comply with housing codes?Why did Arendt choose to enable Five Skies in their flagrant disregard of WI 704, Uniform Dwelling Code, and DSPS codes & regulations by filing a false court claim for my eviction?FIVE SKIES MADE THE FOLLOWING CHOICES THAT WERE SUPPORTED BY ARENDT:
◘ Back Stairs - metal original were not to code with no rail & >24" high - see Stairs◘ Back Stairs - replacement 9/11: were not to code & installed with no permit - seeStairs; injured on 9/16◘ Front Stairs - not to code - 33" wide, unequal riser heights - see Stairs◘ Front Stairs - repaired, not to code - 33" wide, unequal riser heights >3/8" - see Stairs◘ Plumbing pipe replacement by an off the books plumber with no permit; actually completed? to code?No way to know because there is no inspection when no permit was obtained - see Cash Job Plumber & confirmation of no permit=no inspection from DSPSReplacement was to be completed by mid-May. Still texting plumber re finishing on June 17. Not finished but informed that plumber wouldn't return on 7/01.Nick wrote "If the water remains unimproved..." - how was it going to improve without some sort of intervention? A sprinkle of pixie dust?◊ Outdoor tap 9/8. Laundry connected? Never informed (excerpt 9/03 letter). All other pipes replaced? Don't know. No inspection.◘ Windows: informed Nick 7/01 indoor temp was 90° - no a/c in unit; 16 days later, Delbert drilled 1 window open; then it couldn't be closed;◘ Door: Plate fell off bottom 5/10; informed Nick 5/10 that door jams & sticks. Nick said the door had to be replaced on 5/11. Joey allegedly looked at doors 5/26,mid-August, & 9/12; 9/16 back-ordered door, wait a couple more weeks. Deterioration continued throughout tenancy: cannot open a door without◘ When structural repairs are NOT remedied, WI 704.07(4) allows tenant to "abate rent to the extent the tenant is deprived of the full normal use of the premises.""...tenant is not liable for rent after the premises become untenantable and the landlord must repay any rent paid in advance apportioned to the period after the
premises become untenantable." That'd be day one to the last day unless the landlord hires an attorney who doesn't give a flying fig about what the law says.
◘ Water as described by WI Codes SPS 325.15 &325.25 & full normal use of §704.07(04). Notified Nick in my email of 5/10:
◊ See Water on this site & 8 of 9 above.◊ Not able to take a bath or shower, drink the water, make coffee, brush my teeth, cook with the water, fill the cats' water bowl, wash my hands, etc etc
► They advertised the unit as "available now" on 3/24.► They knew there was a problem with iron in the water. The toilet bowls and the water from every tap I discovered when I moved in belie anypossibility that they didn't know.
► They never told me about the iron water problem. I discovered it only when I moved in.► They never requested an appointment to determine the cause of the problem after I notified them 5/10 requesting explanation & rectfication.► On 5/10, Nick showed no surprise at all that there was a problem with the water. He wrote: "The water issues must be related to the pipes in thetrailer itself and the new lines should remedy that. "► Mid-June & 7/16 Joey & Delbert looked at the water mid-June & 7/16. They said nothing, walked away. Did nothing.► From 7/17 - 9/11, there was not one email, not one text, not one phone call to arrange appointment to assess or make any repair. 56 days.► Five Skies demanded & received full rent for August on the 15th (as agreed to in writing) - 0 balance, no late fees► Five Skies chose not to reply (9/3 letter) to my written request of 8/05 for a date of completion for repairs.► The alleged reason for replacing the pipes was "water pressure." There was minimal to no improvement and I'm sure they were, indeed, wishing & hopingthat replacing the unit's pipes would correct the problem. On 5/10, Nick said the new lines "should remedy that." But it didn't.
► Nick wrote on 7/03 that they would terminate my lease because they "would not continue to rent the unit until that issue is remedied." 63 days after I moved in.They should have done that before they advertised the unit as 'available now." Correcting the problem was required by §704.07(2)(a)2."Prompt" remedy of the problem was required by 704.07(4).Five Skies chose not to abide by that law and Arendt supported them in that decision.► They never had any intention of correcting the problem, i.e., fraud, but would terminate my lease instead.► No correction even suggested until 9/12 (voicemail below) to apply "a filter" that would "hopefully hopefully help" & provide a "temporary" solution (also 9/16)"
4 1/2 MONTHS AFTER I MOVED IN:Joey's voicemail: "hopefully hopefully" of 9/12. This Youtube video will play on this page.
Arendt then took it a step further in his falsely concocted claim filed in the court for my eviction. He misrepresented (lied) about the rent money received and when it was due
(not late) as he wrote. He also falsely claimed that the next month's rent was late (it wasn't) and wanted late fees for both months though rent had been paid on time in September
in accor dance with §704.07(4) and wasn't due until 10/15.
Let's assume that, at least, Arendt should have known that WI Stat 704.44 provides abatement for repairs not completed as he claimed residential real estate expertise on his website.
He knew that my letter of 9/15 specified that abatement and that that abatement also was in accord with previous abatement for Five Skies failure not to repair & maintain. Instead, he
chose to support Five Skies in breaking laws and ignoring Uniform Dwelling Codes and DSPS regulations.New Paragraph
MOVE TO FALSE CLAIM PAGE
The document is dated & filed 10/14 the day before rent was due Oct 15 misrepresents (lies) about rent due for September. AND Oct with late fees based on due date of 9/1 & 10/1 AND with no adjustment
for "after 5 days" = late per lease. IF I had filed such a document, it would undoubtedly be called fraud. Is it called something else when an attorney does it? Just an "oops"?
Once again, arithmetic appears to be as hard as legal and honesty for Arendt. See Arendt Conspires w/Five Skies to Defraud Court et al
Fraud on the court occurs when the judicial machinery itself has been tainted, such as when an attorney, who is an officer of the court, is involved in the perpetration of a fraud or makes
material misrepresentations to the court.
Arendt is fine with doing all of that as well as the lies he lies & misrepresents in his response to DATCP & his email of 9/16 to Joey supporting the slumlord's actions & failures to act in violation of
Wisconsin's laws. Whatever it takes, just get the old lady out and, for a bonus pad that fraudulent claim for eviction with a chunk of extra money ($615.00), right?
Fraud on the court occurs when the judicial machinery itself has been tainted, such as when an attorney, who is an officer of the court, is involved in the perpetration of a fraud or makes material misrepresentations to the court.
Arendt claims knowledge of events prior to my move-in date in his duplicitous DATCP reply.Arendt had read my complaint to DATCP & letter of 9/03 which described the only two repairs that had been made.Arendt participated in the 9/20 bogus appointment by phone or in person.Arendt knew & Five Skies knew that the water was full of iron & correction was not made on 9/20 & Five Skies made no request after 9/20 for rescheduling by phone, text or email.
Are facts, truth, and law relevant to the practice of law in Wisconsin? I don't see anything to support that notion.Can landlords and attorneys just do & say whatever they want to get what they want? Based on my experience, yes.Egregious actions of landlord aided & abetted by attorney at law --- fraud, statute & code violations are okay in Wood County, Wisconsin? Definitely.
This is the water the day before the sham appointment
of 9/20 @ 10am
coerced by the threats of Patrick Arendt
Would
YOU
be okay paying full rent
after 5 months with absolutely no
action to correct except
"terminate your lease" 63 days after you moved in?
How did that coerced appointment go?
no show
no call to cancel
no request to reschedule
See full chronology under Arendt:
Bogus 9/20 App't
The Kedrowskis did NOT like the fact that I abated September's rent
and adjusted August rent in accordance with Wisc §704.07(4)! On 7/01, they will choose to terminate my lease 63 days after I moved in but they're all good as long as I pay full rent and they can continue to do nothing to perform the necessary repairs as they did 7/17-9/10. However,
Arendt's email of 9/16 threatened me sufficiently to accept the 9/20 appointment (on right)
Arendt failed to grasp or, more likely, chose to ignore the fact that it was coming up on five
months that the original issues of water, door, and windows still were not repaired/remedied & they had done NOTHING since 7/16. His email to the DATCP claims knowledge of events prior to my move-in on 4/27:
Arendt wrote that they would "...be within its rights to immediately enter the premises...with or without her consent and without 24 hour notice..."Arendt wrote they "...could initiate eviction..."Arendt wrote they "...may have to consider terminating her water supply..."
Arendt wrote
that my time frame to remedy the water issue was "arbitrary." Wisconsin laws requires that repairs are to be made promptly. I moved in 4/27; Five Skies chose to ignore my written request of 8/5
for a date to expect repairs would be completed. The situation described on this website & very briefly abridged below, results in a reasonable even generous, not arbitrary, decision to establish a deadline for them given my experience from 4/27-9/02:
► Five Skies was informed about the water quality 11 times: in writing: 5/10, 5/20, 6/30, 8/5, 9/3 & verbally by plumber: 5/19, 5/31, 6/17; in person (Joey & Delbert) mid-June & 7/16, Joey on 9/11► Five Skies requested three (3) appointments May 20 through Sept 11: 5/21, mid-June, 7/16. All 3 were accepted.► 5/10 Nick replied to my email: the new pipes in the unit "should remedy that." Unfortunately, their cash-job plumber's no-permit incomplete replacement of the unit's pipes did not correct the iron problem.► 5/10, 7/01, 7/03 Nick promises to address "as soon as possible" "soon" "on schedule" which he claimed to forward to Delbert & or Joey.► 7/01 Nick writes "If the water remain unimproved, it may be necessary to replace lines below ground....may have to terminate (my) lease if underground lines are cause of problem. " As they did NOTHING to assess the problem after I moved in, it is logical to conclude that they knew or, at least, thought they had defined the problem.I moved myself, my business & 2 cats 200 miles in good faith that landlord was providing & maintaining a habitable residence. But, 63 days after I moved in, I should just pack up & get out to accommodate their fraud?► 7/03 Five Skies did nothing to correct the water. According to Nick on 7/03, "water quality" was their "primary concern” & considered other repairs “moot."Note: Considering other repairs "moot" because you don't want to do a particular repair is in violation of Wisconsin §704.44(8)
► 8/05 Five Skies chose not to reply to my written request for the date they intended to complete repairs.
► 8/15 Demonstrating their positive intention to collect full rent while doing nothing to perform the necessary repairs,Five Skies cashed my check for FULL August rent while doing nothing - absolutely nothing from 7/17-9/10:no requested assessments, no requested appointments, not oneemail, phone call, or text.► 9/08 Five Skies Plumber connects outdoor water tap for garden/lawn he 'promised' for 6/6; never learned whether laundry was connected although it couldn't be used unless I wanted an all orange wardrobe.Would water pressure be sufficient? Don't know. Have to assume not; wouldn't they, at least, have said it was connected if it was as I described laundry hook-ups as one of my very few requirements in my initial email of 3/24?► 9/11 Joey declined the mug of water I offered him when I happened to see him on the property. He said they were having money problems and he was "looking at doors."► 9/12 Five Skies couldn't even be bothered to contact me before the deadline specified in my letter of 9/03 they received on 9/6.► 9/16 Joey was seeking a 'temporary' solution for water that "hopefully hopefully" will "help" (voicemail) a few days short of 5 months since I moved in 4/27 & they were notified eleven times that water was full of iron.Now he's out there looking for a "temporary" fix that "hopefully" will "help." I guess that other "temporary" fix of 9/12 wasn't going to 'help' after all.► 5/10-6/17 Five Skies hired plumber for a no permit-cash job to replace the unit's pipes. Plumber promises to show up again & again, but doesn't show up over 39 days - one full month AFTER their stated completiondate of mid-May - resulting in the expiration of my temporary insurance license so now I can't work in MN or WI.To be totally fair, he couldn't show up after he was arrested 6/05 (mugshot here) for felony stalking a woman in Stevens Point & was in jail on 6/13 when he texted me that he wouldn't show up because he had a "bad back."► Sewage pipe at back of neighbor's unit breaks 8/22 spewing sewage onto my lawn a few feet from my office window & remains there 8/22 - 9/08. 2 days after Five Skies receive my letter on 9/06, plumber hoses sewage into grass; no bleach applied as required by DSPS. Neither Kedrowski nor plumber contacted Health Dept as required re sewage spill. After I contacted Wood Co Health Dept 10/04, plumber puts correct to code cap on pipe 47 days later (8/22-10/07).► The Kedrowskis chose to ignore Uniform Dwelling Code in re metal back stairs, replacement back stairsBuilding permits for replacement stairs and plumbing from Town of Saratoga were not obtained.Were all pipes replaced? Did replaced pipes meet code? No inspection with no permit.
SPS 326.15 & SPS 326.25 per Jack Wortruba, Dept Safety & Professional Service.If this was the water at the place you moved into, would you find the photos & videos of the water "reasonably adequate"?
► Five Skies chose to ignore WI Statutes:
704.03(1)704.08704.44704.07704.07(4)704.45710.15(2m)
Arendt is fine with all of that as the lies he writes in response to DATCP & his email of 9/16 to Joey supporting the slumlord's actions & failures to act, Just get the old lady out and, for a bonus, pad the fraudulent claim with a chunk of extra money, right?
9/24
9/26
9/28
Visited Saratoga Building Inspector re not-to-code stairs in re injuries sustained 9/16.
One of my friends who was coming down with a truck to help me move was hospitalized as he had had a severe stroke. How many people can afford to move every few months just because their landlord chooses not to perform necessary repairs? I could not. I lost the place I'd planned on because I could not confirm a move-in date. Now I had to figure out how to borrow more money to rent a truck and, hopefully, find someone on craigslist or somewhere to help with move to "TBD" because now I had to find another place with immediate availability.....again.
Notice to vacate or pay full rent for Sept w/late fees(!) taped to the broken door (since 5/10).
Rent was due 9/15 not 9/1.
Lease specifies late fees begin after 5th day.
IF rent had been due since 9/1: Arendt's document pg 2 conflicts with lease as 9/6 to 9/28 = 23 days @ $5/day = $115 NOT $140
I know math can be hard, but this was a simple task and performed in a sloppy & deceitful manner for someone with a J.D.
09/29
09 30Called Judicare to learn that after snail mail confirmation of citizenship rec'd in Wausau & then determination of eligibility, they' usually get back to folks in a "couple weeks or so." Fill in form, mail...that doesn't look like it will help.
Rec'd a notice of certified mail from Arendt's office. There is no requirement for a certified notice for this document & it makes little sense given 5 days. I saw no reason to drive to the post office & pick up a certified copy of the same thing that had been taped to my door. Nor was I in a frame of mind to cross the street to spit on Arendt or any Five Skies agents had they been on fire. Finding a place to move & people to move me was more important.
Arendt references §704.17(1) in the notice. §704.17(1) is for "Month-to-month and week-to-week tenancies"
Arendt wrote: "....lease of one year or less or month to month tenant"
He should have referenced §704.17(2)..." Tenancies under a lease for one year or less, and year-to-year tenancies"
You'd think he could at least bother to reference the correct statute though I'm pretty sure that Judge B would tell me that it "doesn't matter" (and it does abet the slumlord which does seem to be Arendt's goal).
It's one thing to represent a client; it's another to help them avoid consequences of disregard for laws & codes by lying for them. Whatever it takes, right? Lie to DATCP, lie to the court, fudge the court documents to put a few more dollars in his scofflaw client's pocket.
Sloppy & inaccurate is how it's done in Wisconsin legal system.
Arendt knew that the 9/20 appointment re water was a no show, no cancel, and no reschedule per Joey's email to me of 9/20 (talking w/Arendt) & his own email to DATCP.Keeping in mind that I had paid abated rent on the agreed upon date, Sept 15. (See 8/15 August check). September's check was submitted with letter adjusting abatement for Aug/Sep in accordance with Wisc §704.07(4),i.e., rent abates to the extent the tenant is deprived of the full normal use of the premises (couldn't take a bath, couldn't open/close a window, couldn't use door to get in/out, couldn't drink a glass of water, couldn't fill the cats' water bowl, etc., etc., etc.)Arendt calculated rent due IN FULL with Late Charges from Sept 1.Attorneys & scofflaw landlords can just do whatever they want - make up stuff as they go along ignoring previous written agreements & Wisconsin law?That's how it's done in Wood County Wisconsin?Fraud on the court occurs when the judicial machinery itself has been tainted, such as when an attorney, who is an officer of the court, is involved in the perpetration of a fraud or makes material misrepresentations to the court.
10/04 Emails to/from Wood Co Dept of Health (summarized in letter to Linda Seemeyer, Director, Department of Health Services, State of Wisconsin)
10/04 4:20 pm Rec’d email from Joey: they “just learned” plumber was in Madison (gmail time stamp 9/20 11:40am)
His 10:34am 9/20 email responding to my email to him, plumber, & Delbert, Joey said: “we are here right now talking with our attorney" (see above)
10/06 Nick, Joey, and woman – arrived about 8:30am. They were standing around on my front lawn near the pipe where sewage spewed; someone knocked on the broken door.
I had no appointment with anyone so I didn't answer because I was on conference call in attempt to reinstate my insurance license (turns out: no)
I learned later from neighbor that woman was from Wood Co Health Dept making my life worse: see letter to Director Seemeyer, Wisc State Health Dept
Call from Michelle Reinen at office of Consumer Protection in response to forwarded 9/28 letter from Gov Walker. I returned call 10/6; she did not return call 10/07
Plumber put a code-compliant cap on the pipe that had spewed sewage– 2pm - 47 days after pipe broke 8/22
Spoke with Michelle Reinen, Director Consumer Protection Bureau. She had rec'd documents from Gov Walker's office & would expedite complaint.
Their department does not enforce anything. They collect data & when "enough" is accumulated....(=enough people hurt)
Keeping in mind that I'm trying to find a place to move for the 3rd time in 6 months, finding someone with a truck to move, borrowing money, attempting to secure legal help, etc.
10 11
10 14
I filed DATCP complaint: 11 emails to Michelle Reinen - w/95 pages of documentation
As an officer of the court, Arendt filed eviction summons & complaint with false information to aid & abet the scofflaw slumlord whom he knew chose not to perform repairs as required by Wisconsin Statutes 702. This is supported by Arendt's statement on the 9/28 5 day notice: It appears that you are unhappy wilh lhe manner in which my client manages its trailer park.
The document is dated & filed 10/14 the day before rent was due Oct 15 claiming rent due for Sept AND Oct with late fees based on due date of 9/1 & 10/1 AND with no adjustment for "after 5 days" = late per lease = FRAUD
IF I had filed such a document, it would undoubtedly be called fraud. Is it called something else when an attorney does it? Just an "oops"?
I reiterate: Abated rent per §704.07(4) on due date of 9/15 with letter specifying abatement adjusted for slumlord's demand for full rent & doing nothing re repair; Oct rent due 10/15I reiterate: Arendt claims knowledge of events prior to move-in date of 4/27 through 10/14
10 14
The document is dated & filed 10/14 the day before rent was due Oct 15 claiming rent due for Sept & Oct with late fees based on due date of 9/1 & 10/1 with no adjustment for "after 5 days" = late per lease.
I reiterate: Abated rent per §704.07(4) on due date of 9/15 with letter specifying abatement adjusted for slumlord's demand for full rent & doing nothing re repair; Oct rent due 10/15
Oct 20 & 24
10 25
Process server knocked on door - Oct 20 & 24. I had looked up service procedure 10/15 (see pgs 1, 3, 4): "leave copy on premises, mail" and checked immediately for the copy left both times. No copy was left. No copy was received in mail.
No affidavit of mailing filed (not posted on public website)
Email rec'd from Arendt - claim form NOT attached - NOT the process required per court documentation (attorneys can just make up what they want to do and how to do it?)
The document is dated & filed 10/14 the day before rent was due Oct 15 claiming rent due for Sept & Oct with late fees based on due date of 9/1 & 10/1 with no adjustment for "after 5 days" = late per lease.
I reiterate: Abated rent per §704.07(4) on due date of 9/15 with letter specifying abatement adjusted for slumlord's demand for full rent & doing nothing re repair; Oct rent due 10/15
Given documentation above AND his mendacious rendition of events as documented in his reply to the DATCP complaint AND the false information that Arendt knew to be false that he used to file fraudulent eviction on 10/14/16, /////