Copeland

I. FACTUAL AND PROCEDURAL BACKGROUND

The alleged witness, Wagner, owns two horse properties in north San Diego county. The properties are side-by-side, in viewing distance of one another. Wagner lives on one of the properties and has four horses that she keeps there. In October 2011, Wagner began leasing the adjacent property to Copeland. Wagner charged Copeland $1,500 per month at first, and later increased the rent to $1,650 per month. Rent was due on the 15th of the month. For nearly 10 years, from October 2011 through June 2021, Copeland paid his rent each month in a timely manner.

2 Copeland and Wagner grew to be close friends. Copeland referred to Wagner as family and had dinner at her house once a week. Wagner was also close friends with West and had been for approximately 20 years. West owned a pony named Cooper that she purchased in 2008, as part of a pony ride business that she operated with her daughters. West closed the business in 2015. Her daughters were grown, and no one was riding Cooper anymore, so West was open to the idea of someone else taking care of him. Wagner knew that Copeland wanted horses and suggested to West

that Copeland might be interested in a…