Northwood Estates Community Association in Irvine California. This lawsuit alleges actions by board members and the management company of the Northwood Estates Community Association, formerly known as Northwood II, or Northwood Estates HOA (Northwood Estates Homeowners Association). The management company is PMP management, also called Property Management Professionals.
GENERAL ALLEGATIONS
- The Northwood Estates community has been taken hostage by a group of activist residents who began to act as a gang of thugs terrorizing other residents through mafia-style intimidation techniques, arbitrary fines, public shaming through various community forums, threats of unspecified retribution (physical and otherwise), video and audio surveillance, and other forms of psychological abuse. This group of gangsters has hijacked the HOA board of directors and the PMP Management company in order to intimidate and abuse residents that do not submit to the street rules and whims of the gang. Resident and Defendant Dan Choe is at the helm of this gang. Dan Choe has plagued his neighborhood by the ravaging and manic delusions of grandeur together with his Codefendants, each of them.
- Defendant Dan Choe, his entity Codefendants, and individual Codefendants have orchestrated a grotesque, Orwellian reign of terror on the residents and owners of Northwood Estates that has led to owners and residents being fearful for their personal and family safety, and terrified of financial and personal retaliation and brutal harassment of their families – and particularly their children. Defendants Dan Choe, Tina Smith, Susan Okuno, William Chu, and others, with the assistance of Defendant PMP, have engaged in a gross abuse of power akin to that of a criminal gang that controls its turf under the threat of physical retribution. They have weaponized the HOA Board procedures, disregarded state laws governing HOA practices and procedures, city ordinances and social norms, and abused their board duties and responsibilities in order to control all aspects of community living for the residents. This has included excessive and unjustifiable surveillance of residents, excessive fines and fees, fearmongering, financial malfeasance/misappropriation, and harassment of residents which has created a culture of fear, terror and divisiveness where residents are terrified to speak out and even walk outside their homes.
- The surreal, dystopian community nightmare began few years ago when Defendant Dan Choe and his spouse purchased a home in Northwood Estates. Soon, thereafter, Dan Choe ran for election to the HOA Board of Directors (“Board”) using gross misinformation and fearmongering, manipulated election procedures, forced out existing Board members, and was “elected” to the Board of the HOA. Upon securing his position on the Board, Defendant Dan Choe established what became a de facto criminal organization, aiming to extort payments from residents with threatening and malicious behavior, establish a reign of terror and control over the neighborhood, and intimidate the homeowners and residents in order to ultimately become a vendor of the HOA and derive grotesque gratification from spying on his neighbors and their children to dominate and abuse them not much different from human traffickers and serial abusers and vicious gangsters. Defendant Dan Choe’s subsequent actions have led to multiple lawsuits. The racketeering group that Defendant Dan Choe organized, engaged in, inter alia, excessive, arbitrary, oppressive and grossly punitive fines and fees which are disproportionate to the violation and not provided for the in the HOA’s Governing Documents, including the Covenants, Conditions, and Restrictions.
- In his bid for election to Defendant HOA’s Board, Defendant Dan Choe adopted the charisma and puffery emblematic of a fascist dictator’s rise to power. In his pitch to become elected to the HOA Board, Dan Choe wrote the following message to the community:
Successful companies, winning sports teams, top schools and thriving non-profit organizations all have these things in common. The willingness to ask questions, challenge the status quo and encourage competition and new ideas. In running for the board, I have been criticized for calling out improvement opportunities and suggesting change by some connected to the board and the subcommittee.
Should I be elected [,] I will fight to change our culture to embrace community feedback and always be looking for new ways to elevate Northwood Estates.
I will personally discourage levying negative messages against community members critical of the HOA board. We must listen to criticism versus making personal attacks. I will also continually encourage new candidates for HOA positions and subcommittees to keep our board invigorated and increase neighborhood engagement. Getting involved in our community should be embraced and celebrated as selfless rather than labeled “selfish”.
This needs to change and if I am elected [,] I will welcome “all criticism”. (And I have been heavily criticized by the HOA). I will have a fiduciary responsibility to the HOA, and this is why I’m the only candidate who has openly left my contact info and address. Let’s move towards transparency and positivity which will in turn lead more volunteers to run in the future.
This is how we are held accountable. This is how we improve.
- Defendant Dan Choe, upon being elected to the HOA Board, unequivocally and abjectly reneged on every promise and assurance he made to the Northwood Estates community. His platform was deliberately deceitful and a pretext concealing his sociopathic and criminal agenda to take absolute control over not just the board of the HOA, but the residents of Northwood Estates. Upon his election to the HOA Board, Defendant Dan Choe, along with other Board members, enacted multiple policies without input or approval from residents or owners of the community, including the policy of installing cameras and microphones in the community. Defendant Dan Choe surreptitiously and without consent or notice installed over 70 cameras and recording devices without including a disclosure in the HOA’s policy, governing documents, or other meetings, or posting signage of video surveillance and conversation and audio recording. Defendant Dan Choe engaged in this conduct with the ratification and active assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Plaintiffs allege on information and good faith belief that the video footage and photographs are directly and systemically accessed by Defendant Dan Choe, are routed to his personal residence for 24/7 viewing, and Defendant Choe, and Co-Defendants, improperly utilize the footage to create personal dossiers and “hit-lists” on the residents and owners, to monitor their whereabouts within the community in order to harass them and stalk them as a form of psychological warfare in order to browbeat and demean them for the Defendants’ pecuniary benefits and personal, sadistic gratification.
- Plaintiffs allege on information and good faith belief that Defendants, and each of them, have obtained improper access to photos of their minor children and Defendant Dan Choe has posted such photos on community forums, exposing their children to potential predators and unjust ridicule, and endangering their physical welfare and safety. Plaintiffs further allege that these photos of their children include photos at the community pool.
- Plaintiffs believe on information and good faith belief that this is inaccurate and Defendant Choe, Defendant HOA, and other involved Defendants store this footage on their personal devices and accounts indefinitely as part of their dossiers to be used to browbeat, demean, and emotionally torment and subdue residents that do not submit to their “street rule” in the community. Plaintiffs know that Defendant Choe and Defendant HOA utilize the footage for purposes other than investigative and legal purposes for legitimate investigations within the realm of the HOA mandate.
- Defendants Dan Choe, Chu, Okuno, and Smith subjected residents to extreme surveillance, intimidation, extortion, harassment, and threats in order to control every aspect of community living. Defendant Dan Choe’s racketeering group engaged in, inter alia, excessive, arbitrary, oppressive, and grossly punitive fines and fees which are disproportionate to the alleged and often pretextual “violations” many of which are fabricated and/or not provided for in the HOA’s Governing Documents, including the CC&R’s. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendants Dan Choe, Chu, Okuno, Smith, Sabbagh, Keon, and Wagner enacted multiple policies without input from community residents or owners of the community, including the policy of installing a multitude of video cameras, microphones, other gate surveillance systems, electronic log systems, and flying drones in the community. Defendant Dan Choe surreptitiously and without consent or notice installed over 70 cameras and recording devices without including disclosure in the HOA’s policy, governing documents, or other meetings, or posting signage of video surveillance and conversation and audio recording. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendant Dan Choe directly monitors the cameras and audio recordings, which Plaintiffs believe upon information and good faith are all routed to his residence as a central location to allow ease of access and viewing. Defendant Dan Choe monitors these cameras and audio recordings to issue violations against residents (usually minors) rather than utilizing the cameras for actual safety measures or monitoring of criminal activity. Defendant Dan Choe monitors these cameras and audio recordings to eavesdrop on residents, intimidate and scare residents, and issue fines for grossly exaggerated or completely fabricated violations against residents and their children (usually minors) rather than utilizing the cameras for actual safety measures or monitoring of potential criminal activity. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendant Dan Choe engages in gross and baseless fear mongering to justify the need for dozens of surveillance cameras and high-tech security systems. He frequently cites false claims of high rates of crime in the community to justify and satisfy his need for him to closely monitor community activities. The real reason for Dan Choe’s surveillance of his neighbors is to control those that may disobey his reign by monitoring their every move and recording their children. Defendant Dan Choe tells residents exaggerated tales of drug houses, prostitution rings, and home invasions in order to create fear despite Irvine being consistently rated as the safest city in America. Defendant Dan Choe encourages residents to call him if they see criminal activity and often posts self-aggrandizing statements about how he is fighting crime and keeping residents safe. In reality, Defendant Dan Choe seeks solely to entrench himself and his gang of sycophants to financially benefit from the HOA as a vendor.
- Defendant Dan Choe has engaged in gross violations of the privacy of Plaintiffs and their minor children. Plaintiffs and residents have reported their children being followed and filmed in the community which are then used to issue violations and fines. Plaintiffs and residents who are issued violations are then forced to attend “disciplinary hearings” where Defendant Dan Choe, Okuno, and berate, curse and yell at them to coerce them into admitting they are wrong and to write an apology to the Board. If residents refuse to admit wrongdoing or pay the fine/charge, Plaintiffs and their minors are targeted for more fines and publicly defamed. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendant Dan Choe has “dossiers” of Plaintiffs’ and residents’ children as he knows specific details such as their age, names, faces, where they attend school, who their friends are, etc., and records them at the community swimming pool and elsewhere. Defendant Dan Choe sends photographs and descriptions of Plaintiffs’ children which are included in violation letters sent to Plaintiffs. He also posts this information to community forums and text groups, often viciously attacking and shaming his targets.
- Dozens of surveillance cameras were installed inside and outside the pool and common areas and are used to target minors for violating the rules such as not signing the pool log, or not signing in “correctly” because their children are under the age of 14 (even if the minor is with an adult), staying past pool hours, rough playing, or throwing a pinecone into the pool etc. Defendant Dan Choe is known by neighborhood teenagers to conduct nightly patrols around the pool and common areas to kick them out at closing time. Plaintiffs are greatly disturbed and afraid to allow their children, especially their teenage daughters to use the pool for fear of them being monitored and filmed. Even the doors to the pool bathrooms are monitored by cameras. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendant Dan Choe and Defendant HOA are known for targeting the children of residents in order to selectively issue violations and fines. Defendant Dan Choe, Susan Okuno, Tina Smith, Grace Lee routinely follow and film children in the neighborhood in order to issue violations. Photos of children are posted to community forums and social media asking residents to identify who they are for minor incidents such as using skateboards/scooters, leaving a bike helmet outside, or ringing doorbells. Plaintiffs’ children are falsely accused of vandalism, bullies, being a nuisance and branded as being “problem children” and pose safety threats to the community. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Plaintiffs and residents report that their teenagers and college aged children are especially targeted. Teens are “pulled over” or ed followed and directly confronted and for not stopping at stop signs for “3 seconds” or speeding. Plaintiffs are greatly disturbed and afraid to allow their children to use the pool for fear of their children and especially teenage daughters being monitored and filmed. Even the access to the pool bathrooms is monitored by cameras. Plaintiffs’ children are accused of “drinking”, loitering, damaging community property, reckless driving, or being a nuisance.
- Defendant Dan Choe angrily confronted and threatened a Plaintiff’s college age daughter because he claimed she did not stop “appropriately”. He approached her and scolded her which was captured on Plaintiff’s camera and then later pounded on Plaintiff’s door demanding to “talk”. On another occasion, Plaintiff’s daughter and her friends were confronted by Defendant Dan Choe for alleged loitering in their car while parked on the street. They were accused of creating a disturbance. Plaintiff’s daughter is terrified of Defendant Dan Choe.
- Plaintiffs and residents are then sent violation letters with photographs of their children from surveillance cameras stating their children’s age and their friends. The surveillance videos, audio recordings and pictures of children are relentlessly posted without parental consent or knowledge to community-wide websites, community group texts, and shown to other residents in order to defame the minors and their parents. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendant Dan Choe and HOA board routinely target landlords and their tenants in order to rid the neighborhood of renters “because they [renters] bring down property values”. Multiple renters have reported being followed, harassed, and intimidated by Defendant Dan Choe and felt they were being forced out.
- CC&R rules appear to discriminate against renters by requiring monthly lease fees which is purportedly to pay for “property monitoring and administering rental activity requires the Association to conduct routine occupancy auditing of the community, maintain and update tenant contact information, obtain and review individual lease agreements, and maintain a separate set of records of each rental unit.” Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Landlords are required to immediately provide the HOA with a copy of the lease which contains personal information of their tenants (driver’s license, Social Security Numbers, VIN numbers, income). Many landlords have reported being charged excessive fees for failing to “register their tenants” within the prescribed 7 days which they consider an unreasonable deadline. Failure to provide a lease within 7 days of lease start date results in huge fines of $1000 for each arbitrary failure. Multiple landlords have reported being charged tens of thousands of dollars due to such fines. One landlord accrued a bill for over $60,000 in spurious fees and fines and was told to apologize in writing in order to have the bill reduced. Other similar communities in Irvine have no such fees/fines aimed at renters and landlords. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Landlords have reported being fined for multiple spurious violations their tenants allegedly committed and have been told by the Defendants to evict their tenants. Tenants have been reported for “acting suspicious” or “wearing a black hoodie”. Landlords have reported being coerced into using “recommended property managers”. Several landlords have previously filed suits over these discriminatory practices which have hindered their ability to rent their properties and or has affected their income. These fees and fines are not charged in similar, nearby HOA communities. In fact, Defendant Dan Choe’s fines and threats or retribution are nothing more than his way of terrorizing the community to exact obedience through fear and avail Dan Choe of sociopathic gratification from tormenting his neighbors using HOA as a pretextual cover. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendant Dan Choe and the Defendant HOA have engaged in violations of fair housing federal regulations by discriminating against renters on the basis of their disabilities, race and gender. Plaintiffs and residents have been called racist slurs such as skin head or neo-Nazis or been insulted because of their accents. These actions and behavior were ratified and aided by their entity Codefendants and individual Codefendants.
- The harassment of renters and their landlords has been documented in several YouTube videos which show Defendants Dan Choe, Chu, Sabbagh, and Wagner confronting tenants and landlords.
- Plaintiffs allege on information and good faith belief that Defendant Dan Choe has utilized his position on the HOA Board, and then as a vendor of the HOA, for personal gain. Defendant Dan Choe imposed his company, Defendant Citadl, to act as “project manager” to provide services previously provided by PMP management. He negotiated highly favorable terms for himself including having his liability insurance paid in order to exact more money from homeowners. Plaintiffs assert that being a paid vendor represents a clear conflict of interest. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- In addition to apparently deriving sadistic gratification from tormenting his neighbors and the community where he lives, Defendant Dan Choe had a plan to gain pecuniary benefits from his role as HOA Board Member. Defendant Dan Choe in coordination with his cohorts, Defendant PMP, Defendant HOA, secured a vendor and consultant position for himself, getting the HOA to pay him purportedly for “security, technical, special services ($125/hour) and “legal” services ($175/hour), a significant benefit for a stay at home, unemployed individual. The brazen conflict of interest and criminal behavior exhibited by the Defendants is no different from that of mobsters who gain control of communities that they live in. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Plaintiffs allege on information and good faith belief that Defendant Dan Choe has utilized his position on the HOA Board to control residents’ ability to efficiently use community access gates as intended. Defendant Dan Choe, with support of the Board and PMP, is the only person who can provide transponder stickers, and he is the sole “installer” of all vehicle entry gate transponder stickers on private vehicles for all residents of Northwood Estates. Defendant Dan Choe charges residents $50-$100 to “install” stickers on cars. Previously, residents obtained a car transponder sticker directly from the property manager with no “installer fee”. Now residents are required to use Defendant Dan Choe’ “installation service” and submit personal information such as car registration and automobile leases directly to Defendant Dan Choe under his alias of the “access committee,” and later as the “Project Manager”. Defendant Dan Choe selectively delays sticker installation to some residents, including Plaintiffs, by weeks or months in order to force them to use the keypad to enter their own community. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Plaintiffs allege on information and good faith belief that Defendant Dan Choe has utilized his position as car transponder sticker “installer”, to stalk and abuse Plaintiffs and other residents. Plaintiffs are fearful of allowing Defendant Dan Choe access to their vehicles because they believe he will monitor their whereabouts. Plaintiffs’ have caught Defendant Choe snooping around their cars in a small claims court parking lot and have seen Defendant Dan Choe taking photographs of their cars on their streets. Defendant Dan Choe is known to go to great lengths to cyberstalk Plaintiffs and obtains VIN numbers for purposes of looking up automobile history of Plaintiffs and their family members. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Plaintiffs allege on information and good faith belief that Defendant Dan Choe is utilizing cash and reserves targeted for community maintenance to fund his monitoring/surveillance projects, his business expenses, and personal expenses. Inspection of a few credit card statements revealed purchases for personal items such as Starbucks, Costco, groceries, sporting goods, etc. There are also many purchases for electronic, software, technology related services and products which seem more in line for running a technology business, and unnecessary for managing a 400-home community and which previous boards did not require. Defendants Dan Choe and Susan Okuno have used community funds to make private donations to their schools and charities. Defendant Dan Choe engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Plaintiffs further allege on information and good faith belief that Defendants Dan Choe and William Chu have used HOA assets to fund a technology software consultancy company in which they are both co-owners.
- Plaintiffs have cited multiple reports of harassment by Defendant Dan Choe. Plaintiffs and their families and many other residents have been followed, filmed, recorded, verbally attacked, bullied and threatened, and experienced physical confrontations with Defendant Dan Choe. Plaintiffs and residents have reported that Defendant Dan Choe has instigated confrontations, verbally taunting Plaintiffs to “hit me” in order to provoke physical fights. Plaintiffs allege on information and good faith belief that Defendant Dan Choe intentionally goads Plaintiffs and residents into physical assaults for the purpose of having them arrested and sued, while ironically assaulting Plaintiffs and routinely stalking them
- Defendant Dan Choe has verbally attacked residents in the common areas, insulting their families and, for instance, calling a resident “a bad father to his son”, filmed, and followed the homeowner to his home and followed children. Plaintiffs were physically confronted in the Orange County Courthouse where Defendant Dan Choe aggressively approached Plaintiffs, repeatedly demanded they leave, grabbed their coffee and threw it away in front of multiple witnesses and law enforcement. Courthouse Sheriffs had to physically restrain Defendant Dan Choe from assaulting one of the Plaintiffs. Based on multiple incidents such as these, Plaintiffs and residents truly believe that it is only a matter of time before Defendant Dan Choe further escalates his abuse and does physical harm to Plaintiffs or others.
- Defendants Dan Choe and William Chu repeatedly called police based on false reports about Plaintiffs in order to stage photo opportunities for purposes of defamation. The incident greatly traumatized Plaintiffs’ minor son who thought they were going to be arrested over Defendants’ false allegations of vandalism.
- Despite being told not to trespass onto Plaintiffs and resident’s properties, Defendant Dan Choe has repeatedly ignored these requests. Defendant has trespassed onto Plaintiffs property at least twice, posting pictures of their front door (which is not visible or accessible from the street) and stealing Plaintiffs security camera from their yard.
- Defendant Dan Choe and William Chu cyberstalked Plaintiffs on Yelp, Nextdoor, Instagram, Google, LinkedIn to find out where Plaintiffs’ children attended school, their activities and distributed the information on the community forums and large community chat administered by Defendant Alex Yang. Defendant Dan Choe boasted on community forums and texts that he called every business in which Plaintiff wrote a bad review to give the businesses the Plaintiff’s name and picture.
- Defendants Dan Choe and William Chu also impersonated Plaintiffs in order to hurt the businesses of other Plaintiffs by writing derogatory reviews of Plaintiff’s businesses. These machinations greatly disturbed and alarmed Plaintiffs and demonstrated a pattern of retaliation and scheming by Defendant Dan Choe and Defendant William Chu.
- Plaintiffs allege on information and good faith belief that Defendant Dan Choe has utilized his position on the HOA Board, to physically stalk Plaintiffs. Defendant Dan Choe has complete access to pool cameras and electronic pool key logs and frequently monitors access to the pool and common areas. On multiple occasions, Defendant Dan Choe pursued Plaintiffs late at night in the pool. On at least 6 consecutive occasions, Defendant Dan Choe showed up at the pool shortly after Plaintiffs entered the pool area. These incidents occurred late in the evening when there were few people at the pool. These experiences greatly disturbed and alarmed Plaintiffs to the point where they no longer felt comfortable to use the pool.
- Defendant Dan Choe has even gone beyond the bounds of Northwood Estates community into neighboring communities to harass and stalk other residents. Residents in adjoining communities have reported being followed to their homes and verbally confronted and have felt intimidated to the point where they are unable to enjoy using the adjoining public park located outside Northwood Estates.
- Plaintiffs and residents have filed multiple incident reports with the Irvine Police department regarding the harassment of Defendants Dan Choe and William Chu. Several lawsuits and restraining orders have been filed against Defendant Dan Choe. Plaintiffs have engaged attorneys to write multiple cease and desist letters to Defendants Dan Choe, William Chu. Despite these efforts, Defendants continue to blatantly disregard the advice of law enforcement and ignore the admonitions of Orange County Superior Court Judges and continue to harass and torment Plaintiffs.
- Defendants Dan Choe, Grace Lee, William Chu, Tina Smith, Susan Okuno, Luciana Chang, Alex (Yinyang) Yang, Vicky Chu, Hoafan Chang, Robert Jin, Jinghue (Judy) Li, Samuel Sukwoo Choe, Zi Jie Liu engaged in defamation and incitement of hate towards Plaintiffs. Alex Yang enabled and collaborated with Defendants Dan Choe and William Chu to create a large community text group (over 120 participants) primarily composed of Chinese speaking residents. The aforementioned Defendants posted hundreds of defamatory messages about Plaintiffs and their children on community group texts and online community forums in order to create a hostile environment for Plaintiffs and their families. Defendants have called Plaintiffs “crazy”, “sociopaths”, “drunks”, “racists”, “liars”, “vandals” and accused Plaintiffs of numerous false violations.
- Defendants also targeted and defamed Plaintiffs’ children and spouses. Defendant Dan Choe routinely attempts to pit neighbors against neighbors by planting false stories to foment division and hate. He has shown videos of Plaintiffs children to their neighbors and friends and impersonated Plaintiffs identity on social media in order to defame Plaintiffs and their children. Defendants have also posted Plaintiffs’ names, pictures, and home addresses on these forums and text groups which has caused Plaintiffs to fear for their safety and that of family members.
- Defendants Dan Choe, Grace Lee, William Chu, Tina Smith, Susan Okuno, Luciana Chang, Alex (Yinyang) Yang, Vicky Chu, Hoafan Chang, Robert Jin, Jinghue (Judy) Li, Samuel Sukwoo Choe, Zi Jie Liu conspired to create a culture of fear and divisiveness within the community. Defendant Dan Choe exhorts a policy of “if you see something, say something” and encourages residents to report all incidents (including criminal activities) to him directly. Under the direction of Defendant Dan Choe, Codefendants spied on Plaintiffs and their families to report information to him. In short, Plaintiffs feel they are constantly being watched and unable to freely enjoy their community – walking in the neighborhood or using the pool without fear of being confronted by Defendant Dan Choe and co-defendants.
- Defendant Dan Choe created a dictatorial environment where residents are fearful of retaliation if they speak out against him. He demands loyalty from residents and seeks to identify “traitors” to his cause. He has repeatedly threatened residents in the group WeChat administered by Alex Yang with lawsuits if they help Plaintiffs in any way.
- Defendant Dan Choe and his individual Codefendants have demonstrated a pattern of willful targeting and retaliating against Plaintiffs who air their grievances on social media. They obsessively monitor residents and owners on social media platforms such as Nextdoor.com to root out anyone who they believe is making critical comments about himself or the board. Within minutes, Defendants and Codefendants will delete comments made by Plaintiffs and have repeatedly suspended their accounts. Plaintiffs and residents are then sent multiple violations and fines in retaliation.
- Defendants Dan Choe, Grace Lee, William Chu, Tina Smith, Susan Okuno, Luciana Chang, Alex (Yinyang) Yang, Vicky Chu, Hoafan Chang, Robert Jin, Jinghue (Judy) Li, Samuel Sukwoo Choe, Zi Jie Liu engaged in election interference to unduly influence HOA elections. Plaintiffs who were running for the HOA board were called “morons”, “crazy”, “sociopaths”, “drunks”, “racists”, “stupid”, “criminals”, “threatening” among other insults. Defendants also engaged in defamation campaigns going door to door in the community to malign Plaintiffs (and their families) who were running for election to the HOA boards.
- Defendants Dan Choe, Grace Lee, William Chu, Tina Smith, Susan Okuno, Luciana Chang, Alex (Yinyang) Yang, Vicky Chu, Hoafan Chang, Robert Jin, Jinghue (Judy) Li, Samuel Sukwoo Choe, Zi Jie Liu, and Lia Dalhover have used community board meetings not for the intended purposes of discussing legitimate community business, but to conduct orchestrated angry mob hate rallies against Plaintiffs. During board meetings, Plaintiffs are defamed, yelled at, cursed at, and often ejected from meetings. Defendants demanded to release the names and personal home address of Plaintiff to the community. Plaintiffs are concerned for their safety and feel intimidated and attacked during community meetings and fear being confronted by the Defendants within their own neighborhood. Defendant Dan Choe engaged in this conduct and behavior with the ratification, coordination and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- The HOA has revised the community “Standards and Guidelines” at least four times since 2020, imposing new rules and significantly increase the fines multiple times. The original rules in 2004 were less than eight pages; now, they are close to 25 or more pages. Defendants Dan Choe, and HOA board have increased the schedule of fines far in excess of those imposed by similar communities in order to extort more money for CCR “violations”, many of which are frivolous, arbitrary, or fabricated. The HOA now plans to approve additional rules and exorbitant fines-$500 for first infractions up to $5000 per month to extort even more money from residents. Defendant Dan Choe engaged in this conduct and behavior with the ratification, coordination and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Throughout his tenure on the Board, Defendant Dan Choe systematically and deliberately failed to enforce city safety codes and comply with state HOA laws, including the Davis-Stirling Act. Defendant Dan Choe has engaged in this conduct with the ratification and active assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendant Dan Choe and HOA board failed to conduct the proper inquiries and obtain Irvine city permits before investing in costly, unapproved neighborhood “security and surveillance projects.” Defendants also and failed to gain approval from community residents as required by community bylaws regarding large capital expenses of surveillance equipment. Defendant Dan Choe engaged in this conduct and behavior with the ratification, coordination and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Throughout his tenure on the HOA Board, Defendant Dan Choe systematically and deliberately failed to obey city safety codes which has resulted in multiple citations from the City of Irvine. Due to Defendant Dan Choe’s harassment of city officials, the City must use police escorts for city officials when doing inspections in the community. This failure to follow City planning, permitting, and safety codes has resulted in municipal violations and fines against the HOA. Rather than comply with the laws, rules and regulations of the City of Irvine, Defendant Dan Choe and the Board have used community resources to litigate against the City of Irvine and file complaints about officials for doing their jobs. Defendant Dan Choe engaged in this conduct and behavior with the ratification, coordination and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendants Dan Choe, William Chu, Susan Okuno, Tina Smith and the board failed to comply with multiple sections of the Davis-Stirling Act which governs HOA procedures and conduct. Most egregiously, aforementioned Defendants have repeatedly engaged in financial opaqueness and stonewalling and perversion of board election procedures. Defendant Dan Choe has engaged in this conduct with the ratification and active assistance of Defendant HOA, Defendant PMP, and his individual Codefendants, all acting in coordinated and systemic unison.
- Defendants Dan Choe, HOA board, and PMP management have intentionally failed to maintain financial transparency of expenses and records as required by Davis Stirling laws regarding the release of Association financial records. Despite multiple requests from Plaintiffs and residents, Defendant Dan Choe and the HOA, have refused to release all requested financial records for over a year which prompted Plaintiffs to file a small claims suit to release the records. Plaintiffs won the small claims suit and Defendant Dan Choe has appealed the case. Per the vendor contract, Defendant Dan Choe has been charging the community $175 per hour for his “legal services” to attend court and defend the multiple lawsuits which he has caused, a clear instance of self-dealing. These fees are in addition to attorney fees and PMP legal representative fees, all of which have been borne by the community. Defendant Dan Choe engaged in this conduct and behavior with the ratification, coordination and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Plaintiff, who is a board member of the HOA, has been repeatedly stonewalled from accessing financial records and information regarding other lawsuits against the HOA and Defendant Dan Choe. Defendant Dan Choe orchestrated a campaign with Defendants William Chu, Susan Okuno, Tina Smith, Robert Jin, Vicky Chu, Haofan Chang, Luciana Chang, Grace Lee to compel Plaintiff to resign because Plaintiff participated in the small claims lawsuit to release financial records. Without presenting evidence or cause, Defendants used community meetings to harass and demand Plaintiff resign from the board. Defendant Dan Choe engaged in this conduct and behavior with the ratification, coordination and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendant Dan Choe has taken on the role of a traffic cop vigilante, conducting patrols of the neighborhood multiple times a day. He frequently waits in hiding near stop signs to monitor residents and then confronts them for not stopping fully. Defendant Dan Choe has frequently approached or “jumped in front” of moving vehicles in order to stop them from alleged “speeding” which is a nuisance and safety hazard and may result in accidents and his own personal injury.
- Defendant Dan Choe and HOA board intentionally removed designated public parking spaces in which Plaintiffs and their neighbors had been using for years in order to punish them for being a “problem street”. For over 6 months, Defendant Dan Choe patrolled the streets of Plaintiffs in order to fine and tow their cars. Neighbors have reported Defendant Dan Choe has had their cars’ tires deflated and towed for arbitrary infractions that even the tow company considered frivolous. Defendant Dan Choe engaged in this conduct and behavior with the ratification, coordination and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Defendant Dan Choe has appointed himself to function as security patrol and frequently interrogates guests of residents using community amenities or walking within the neighborhood.
- Defendants Dan Choe, William Chu, Susan Okuno, Tina Smith engage in selective enforcement and do not obey the community rules themselves. Plaintiffs have reported that Defendant Dan Choe has been an extreme nuisance with his constant harassment of residents, stalking and a threat to resident safety. Defendants fail to stop fully at stop signs, have installed “unsightly” television antennas, and have unmaintained lawns. Plaintiffs have reported that Defendant William Chu has frequent parking violations, installs unapproved architectural changes, and leaves recreational equipment in common areas. Plaintiffs have reported that both Defendants Susan Okuno and Tina Smith have repeatedly been nuisances by filming Plaintiffs children. Despite these breaking multiple CCR themselves, none of the Defendants have received violations or fines.
- Plaintiffs have been targeted by Defendant Dan Choe frequently. Plaintiffs feel intimidated and feel their coming and going are monitored by the license plate scanning system. As soon as Plaintiffs entered the community, Defendant Dan Choe would frequently appear on their street to make obscene gestures (middle finger) and to intimidate them by making “I’m watching you” gestures. Defendant Choe has ostentatiously filmed Plaintiffs for no purposes other than to harass and disturb them. Plaintiffs have been fined multiple times for specious frivolous incidents such as claims of following and harassing Board members, stepping onto community landscaping, or talking to vendors.
- Defendant Dan Choe, Defendant HOA, and Defendant PMP have failed to properly maintain the community assets and keep them in good condition: Landscaping has multiple divots and several sinkholes; tree maintenance is neglected; pest control is neglected, street maintenance is overdue; pedestrian gates fail to close, and the locks are not functioning on those gates; hardscape is deteriorating, streetlamps have broken glass and walkway lights are filthy. Street signs are missing and lean; stop signs are badly faded and peeling creating safety hazards.
- Defendants Dan Choe and William Chu have created hostile working conditions for postal workers. Workers have complained that the shoddy landscape maintenance – many large divots and sinkholes in the grass and poor lighting create safety hazards for postal workers in delivering the mail. Defendants revoked postal worker access to common area bathrooms forcing postal workers to leave the community to use the bathroom. This has created an undue hardship for workers and delays mail delivery. The installation and replacement of mailboxes did not get USPS approval/permit. These working conditions have caused delays in delivery of residents’ mail and create the potential for liability for injury of postal workers.
- Defendant Choe has sent at least one Plaintiff numerous phone calls, harassing text messages, including several aggressive and malevolent text messages for several hours regarding a simple public forum post that Plaintiff had made about the gates’ arms, with comments including:
“you ignore my basic question”
“i don’t need to be polite. please read and be thankful your family wasn’t affected when many have been.”
“delete the post. otherwise, the board will want to meet you” “call me or not”
“i answered but you were not answering”
“you haven’t even bothered to read these detailed posts on our forums contextualizing the pain and suffering of your neighbors”
- Defendant Choe then proceeded to scream at Plaintiff over the phone when she called him back during her son’s game. A true and correct copy of some of these messages is attached herein as Exhibit E.
- Defendant Choe sent other Plaintiffs text messages attempting to provoke marital discord between the couple including messages such as “your wife isn’t willing to share with you” and others falsely accusing several Plaintiffs and demanding them “to stop harassing my family”.
- A homeowner had a particularly disturbing encounter that was reported to Defendant PMP. In their report, they wrote
“I am reporting this to PMP and the board for investigation and action. This relates to an individual who claims to be an agent of the HOA. This incident occurred at approximately 9:40 pm on 6/12/2024. I was walking on Tea Garden near the clubhouse. I saw Dan Choe arguing with a tow truck, and after he was done, I politely asked him if he knew who the HOA uses for transponder installation (see my other service request). Then the following occurred. First, he said it was ‘A 3rd party he didn’t know.’ I asked if he was sure, and then he said, ‘It was me.’ He became increasingly belligerent and odd, and started yelling the following points at me, after he took out his camera and started videotaping. Examples of what he said follows: 1) He said he was going after me and my family and going to my employer in order to harass me and sue me[;] 2) He accused various board members and their children of odd acts, such as soliciting prostitutes[;] 3) He offered me $1000 to look at my phone accusing me of texting someone about him [I did not].[;] 4) He screamed that I need to go to therapy[;] 5) He screamed that I needed to be a better father to my son.[;] 6) He yelled about vaccinations.[;] 7) As his agitation increased, I felt unsafe with the situation and therefore I started walking back to my residence briskly and he chased after me, along with his small dog. He was screaming “Did you call the police?” [;] 8) He followed me as I walked back to my residence.
He appeared to videotape the entire episode, so perhaps there is evidence if you would like to attempt to corroborate what is above. I did not raise my voice at all during this uncomfortable and harassing encounter.
Mr. Choe claims he was acting as an agent of the HOA as an installer. This unhinged behavior towards residents is concerning and a significant liability to PMP and the HOA.
I would appreciate that PMP and the board investigate and let me know the outcome of the investigation.
- This homeowner did not receive any follow-up or feedback regarding this incident.
- Plaintiffs further believe on information and good faith, based on documented evidence, that Defendant Choe, Defendant HOA, and Codefendants utilize drone technology to surveil residents and homeowners in the community, which is not disclosed in the Camera Policy.
- Defendant Dan Choe has posted in WeChats goading to the residents and owners about his infallibility and threatening, posting messages such as “Jama Icanese = fake name = Eileen Hoshino”, “When I last posted this she called the police on me”, “Irvine PD couldn’t do anything” with a laughing emoji, “If you take screenshots and there is a legal matter, I will personally file a lawsuit against you.”, and “Just enjoy the community. Follow the rules. Be nice to each other.” A true and correct copy of this message chain is attached herein as Exhibit D.
- Defendant Choe has also stalked an employee of a Plaintiff who was running for election to the HOA Board, unlawfully and intentionally interfering with the ability of Plaintiff to effectively run for election.
- Defendant Dan Choe’s actions and behavior, with the ratification and assistance of Defendant HOA, Defendant PMP, and individual Codefendants, have led to multiple legal actions and lawsuits that have dramatically increased legal costs for the Northwood Estates community, including but not limited to failure to install equipment and follow safety codes which has resulted in city fines and litigation due to Defendant Dan Choe’s harassment of city officials.
- Other lawsuits against Defendant Choe and Defendant HOA include Big Star Enterprises, Inc. and Guido Campellone v. Jason Oh, et al., filed in the Superior Court of the State of California County of Orange on December 18, 2023 (Case No. 30-2023-01369166-CU-CR-NJC), Jinping Wan v. Northwood II Community Association, et al., filed in the Superior Court of the State of California County of Orange on December 10, 2023 (Case No. 30-2023-01324853-CU-BC-CJC), and Timothy Cross v. Daniel Choe, filed in the Superior Court of the State of California County of Orange (Case No. 30-2023-01335027-CU-HR-CJC).
- There have been multiple Irvine Police incident reports documenting Plaintiffs’ harassment from Defendants Dan Choe and William Chu. Incident report numbers: 24-0610140, 24-08695, 24-04680, 230900336, 24-0501333, 230900332, 220508378, 230506594, 221203189, 23-10641, T21001764, T24000993.
- Defendants, each of them, stalk, harass, and bully renters who lease properties in the community to prevent landlords from leasing their properties.
- Defendants, each of them, are attempting to coerce landlords into ceasing all rental activity, in violation of state law.
- Defendant HOA requires that landlords complete an application in order to be able to lease their residence.
- Defendants, each of them, engage in targeted harassment in efforts to pit landlords against tenants and vice versa.
- Defendant HOA and Defendant Choe have required landlords to send all of a renter’s personal and lease information to the HOA.
- On at least one occasion, Plaintiffs and/or other homeowners have requested information and details regarding the citations issued to the Northwood Estates community by the City of Irvine, including the nature of the violations and any associated documentation. However, their requests have been ignored and they’ve simply been told to address at HOA Board meetings. However, at these meetings, individuals who raise these questions and issues are attacked, mocked, denigrated, and bullied by Defendant Choe and his gang of vigilantes.
- Defendant Dan Choe failed to conduct proper inquiries before investing in costly projects and failed to gain approval from community residents. He engaged in this conduct and behavior with the ratification and assistance of Defendant HOA, Defendant PMP, and his individual Codefendants.
- Plaintiffs allege on information and good faith belief that Defendant Dan Choe is utilizing cash reserves targeted for community maintenance to fund his monitoring/surveillance projects.
- Plaintiffs allege on information and good faith belief that Defendant Dan Choe has utilized his position the first as a member of the HOA Board and then as a vendor of the HOA for personal gain. As a member of the HOA Board, Dan Choe suggested his company as a vendor for the desired contract, a clear conflict of interest.
- Plaintiffs further allege on information and good faith belief that Defendant Dan Choe is utilizing HOA assets for his own personal benefit. There are many purchases for electronic, software, technology related services and products which seem excessive and unsuitable for a 400-home community. They are more in line for a technology business. Some of this technology includes cloud services (Google, Amazon, Microsoft), IT equipment, marketing services, etc. It is well-known that Dan Choe has launched multiple IT start-ups and has even tried to solicit business from residents, including Plaintiff Sood for his products.
- Defendant Dan Choe and his individual Codefendants monitor residents and owners on social media platforms, Nextdoor.com, and community forums. The Codefendants will target and retaliate against residents and owners who air their grievances on social media.
- Defendant Dan Choe, Defendant HOA, and Defendant PMP have failed to properly maintain the community assets and keep them in good condition.
- The previous retired postal worker (Sharon) also complained that the shoddy landscape maintenance – lots of large divots in the grass, poor lighting created safety hazards for her in delivering the mail. She said she almost fell a few times. I think she said when she brought this up to Dan/William, they began to treat her badly – accused her of speeding, revoking her access to bathrooms which created a hardship for her because she had to go to Starbucks several times a day, verbally scolding her, etc. She also said replacement of mailboxes did not get USPS approval/permit.
- Plaintiffs have been subjected to a pattern of aggressive, hostile, intimidating, and threatening behavior by Defendant Choe, his gang of vigilantes, Defendant PMP, and Defendant HOA.
- A particular group of Plaintiffs have been particularly victimized by Defendant Choe and his gang of vigilantes. Since approximately June 2023, Defendant Choe has engaged in a pattern of increasing intimidation and harassment towards Plaintiffs. She has reported his behavior to the police, and they advised her to file a civil harassment restraining order as soon as possible.
- Defendant Choe is extremely angry at Plaintiff because she and her husband attempted to help a neighbor who was afraid of him. Her and her husband questioned Defendant Choe’s accusations, and she voiced concerns about him filming minors and posting their pictures to community forums and group texts.
- Because of this, Defendant Choe began to target Plaintiff and her son by repeatedly falsely accusing her 11-year-old son of vandalism. He forced her and her husband to attend a “discipline hearing” where Defendant Choe became very hostile and continued to berate and threaten them.
- Both Plaintiff and her husband filed Temporary Restraining Orders against Defendant Choe in August 2023 because Choe had been repeatedly targeting their children and taking photos and filming them despite Plaintiffs telling him to refrain from doing so. Unfortunately, they had to withdraw the Temporary Restraining Orders due to their neighbor’s life-threatening illness.
- Defendant Choe has repeatedly harassed, intimidated, and threatened Plaintiff to the point where she no longer feels safe in her own neighborhood. She no longer walks around the neighborhood or uses the pool and other amenities. She is constantly looking over her shoulder and is afraid to allow her son to ride his bike around the neighborhood. Sometimes, when her husband is out of town, she will stay with a friend. Her and her husband have installed cameras around their home and their cars because of Defendant Choe.
- Defendant Choe’s actions towards Plaintiffs have been increasingly aggressive over the past year. They have had legal cease and desist letters sent to him and the police have attempted to intervene, but Defendant Choe’s harassment has only gotten more hostile and extreme. Therefore, Plaintiffs intend to file another restraining order because Defendant Choe has shown no signs of stopping his harassment. Plaintiffs fear for their safety and are under constant emotional distress.
- On or around August 10, 2023, Defendant Choe physically confronted Plaintiffs in the courthouse for the Superior Court of Orange County. He was angry that Plaintiffs agreed to be a character witnesses for a former resident who was filing a restraining order against him. Defendant Choe followed and filmed Plaintiffs in the courthouse cafeteria. He got very close to their faces and repeatedly demanded that they leave. Defendant Choe grabbed Plaintiff’s coffee and threw it away. Two sheriffs had to physically separate Defendant Choe from Plaintiffs. Defendant Dan Choe then posted to the pictures of Plaintiffs to the community page and viciously defamed them.
- Defendant Choe has incited a campaign of hate against Plaintiffs. Several neighbors have voiced concerns for their safety. Defendant Choe obsessively writes hundreds and hundreds of online defamatory posts and text messages about Plaintiffs and their family, which he then sends to the neighborhood on an almost daily basis. He repeatedly makes false accusations that Plaintiffs’ son vandalized community property and repeatedly defames Plaintiff, calling her a sociopath, a criminal, crazy, and other derogatory terms.
- Since November 2023, Defendant Choe has turned monthly community board meetings into hate rallies against Plaintiff. Plaintiff feels that Defendant Choe intentionally organizes these hate rallies with his gang of vigilantes. Defendant Choe has verbally attacked Plaintiff and screamed at her, repeatedly defaming her and accusing her of fake charges and allegations. He repeatedly talks disparagingly about her even when she is not in attendance and encourages his gang of vigilantes to verbally attack her. Plaintiff no longer attends these meetings out of fear.
- Plaintiffs, on information and good faith belief, allege that Defendant HOA, Defendant Choe, and Defendant Choe’s crew of miscreants utilize surveillance audio collected throughout the neighborhood to randomly and arbitrarily penalize and fine residents and homeowners, including resorting to diversionary tactics, extortion, and blackmail.
- On September 21, 2024, Defendant Choe sent Plaintiffs a peculiar email contrived to on the one hand, deflect from his own misdeeds and unlawful acts, and on the other, threaten Plaintiffs with public humiliation and degradation if they did not acquiesce to his machinations, demands, and unruly fines. A true and correct copy of this email is attached herein as Exhibit E.
- Defendant Choe disclosed an unidentified audio recording in the email, citing that it was an “audio recording from a resident living far away from Torrey Pine, who was considerably upset due to disturbances to their sleep after 11 pm. One can only imagine the intensity of the experience firsthand.” While Defendant Choe failed to corroborate the origin or true nature of the recording, as Plaintiff believes on information and good faith belief that he could not because he was lying, he made a point to tell Plaintiffs that “I would like to clarify that this recording did not originate from my residence nor anyone on the board.”
- Defendant Choe assured Plaintiffs that the HOA had been unaware of these occurrences until informed by residents; however, Defendant Choe then later claims that “[t]he board also lacked prior knowledge and proceeded to confirm the events through surveillance footage, dedicating considerable time to authenticate the details.” On the one hand, Defendant Choe claimed that the HOA had been unaware of these occurrences until informed by residents and on the other hand, claims that the HOA was able to verify the events through surveillance footage, which is interesting as Plaintiffs knows that Defendant Choe is consistently monitoring surveillance footage and even runs out to harass Defendants when they come home from work because he is watching the surveillance footage from inside his home.
- Plaintiffs allege that Defendant Choe lied in this email to frame Plaintiffs for the disturbances that he is unable to verify are coming from Plaintiffs’ residence or property and hasn’t even confirmed what the alarm is in the audio recording.
- Further, in this email, to deflect from his perverse and Machiavellian machinations, he raises an alleged message that Plaintiff sent Defendant HOA on January 21, 2024, to the HOA’s community manager, stating that “[i]t appears that this HOA is gender discriminating, and called me owner’s wife not the owner. If this HOA does not have access to the Deed of property, I’m attaching the copy of deed for immediate correction.”
- Any claims from Defendant HOA that Plaintiff are not the owner of the residence belonging to both Plaintiffs is nothing more than a sinister, calculated, and lowly attempt to belittle Plaintiff and wrongfully absolve itself of addressing Plaintiffs’ concerns.
- Despite the fact that this claim was made in January 2024, Defendant Choe shamelessly and gallingly demanded that Plaintiffs demand this allegation to avoid the necessity of legal action.
- As a final gaslighting tactic in what can be described as nothing more than an abusive maneuver to coerce Plaintiffs into silence and submission, Defendant Choe brought up Plaintiffs’ license plate stating that “[i]t’s important to remember that these issues handled with confidentiality, which means our families are not informed about the violations. However, should you decide to pursue legal action, it would bring this matter into the public domain, a decision that rests solely with you…In light of this, I trust that the fine related to the violation will be resolved without protect. It’s important that we know that moving forward.”
- Defendant Choe has amassed and organized a group of sycophants and submissive enablers to act at his direction to wreak havoc on the Northwood Estates community and has elected himself as de facto totalitarian ruler of the community, placing the residents in a state of constant fear, torturing them psychologically, and endangering the welfare of their children.