On Sept. 29, 2006, plaintiff Alla Koudriavtseva, 31, a Russian-born limousine business owner, and adult entertainment model and actress professionally known as “Linda Glam,” moved into Versailles on the Lake, an upscale apartment complex in Santa Ana. Koudriavtseva claimed that shortly thereafter, water intruded into her apartment, causing mold contamination and all of her personal property to be destroyed. She also claimed she suffered mold poisoning as a result of the multiple water intrusions. As a result, Koudriavtseva terminated her tenancy on Nov. 11, 2009. Koudriavtseva sued the owner of the complex, Versailles Lake Investors Ltd., L.P., which was doing business as Versailles on the Lake; and the property manager, Domino Realty Management Co. Inc. She alleged that the defendants’ failure to act upon her complaints of water intrusion constituted a breach of implied warranty of habitability, private nuisance, negligence and a breach of implied covenant of quiet enjoyment. Koudriavtseva contended that there were a series of water intrusions into her bathroom area starting in 2008 and that the complex’s management did nothing other than clean up the water, allowing the leak and moisture to continue. She claimed that as a result, the water intrusion continued and got progressively worse between February 2008 and October 2009, causing, according to her mold and fungal expert, the moisture to germinate into toxic mold. Koudriavtseva claimed that after complaining to the defendants for 21 months, and becoming increasingly sick and frustrated with their failure to respond, she got a referral for a mold remediation company. However, she alleged that when she told the defendants that she had arranged for a mold inspection company to inspect her unit, the defendants immediately responded by locking her out of her apartment for three days and hiring their own mold remediation company to work on the unit. She claimed that as a result, any evidence of mold in the unit was destroyed. Thus, Koudriavtseva contended that the timing of the remediation, as well as the total exclusion from her apartment, distinguishes the defendants conduct from fixing a problem to spoliation of evidence. Versailles Lake Investors and Domino Realty Management claimed that they promptly responded to Koudriavtseva’s complaints on multiple occasions during her tenancy and determined that there was no evidence of a water leak. They also claimed that they responded to Koudriavtseva’s complaints in a timely manner, fully investigated the issue, and adequately responded. They further claimed they retained a mold remediation and inspection company during Koudriavtseva’s tenancy, and were advised there was no evidence of mold in the apartment. Thus, defense counsel contended that plaintiff’s counsel offered no evidence at trial to support Koudriavtseva’s claims of mold existing in the apartment during her tenancy. In addition, Versailles Lake Investors and Domino Realty Management rejected Koudriavtseva’s contention that she was “locked out” of her apartment or that they destroyed evidence of mold. Defense counsel submitted evidence showing that Versailles Lake Investors and Domino Realty Management responded to Koudriavtseva’s complaints regarding “alleged water leaks” and obtained Koudriavtseva’s consent to further investigate the claims. Counsel also submitted evidence of Versailles Lake Investors and Domino Realty Management requesting that Koudriavtseva be relocated during the time the investigation was being performed and that she was reimbursed for the time she was out of her apartment., Koudriavtseva claimed symptoms of watering eyes, open sores, rashes, hearing loss, nose bleeds, migraine headaches, dehydration, fatigue, joint pain, weight loss, breathing problems, irregular menstrual periods, hormonal imbalance, weakened immune system, cold sores, mold colonies in her blood, ear infections, urinary tract infections, and kidney, liver and bladder problems. Her treating physician ultimately diagnosed her with mold poisoning. She subsequently received extensive medical attention, including frequent trips to hospitals and urgent care centers, and takes oxygen and numerous medications regularly. She alleged that some of her physical symptoms have gotten better with treatment and clean air, but that other symptoms have persisted. In addition to her alleged physical , Koudriavtseva claimed emotional distress from the ordeal, as well as a fear of developing cancer. She also claimed $125,000 in property damage, consisting of damage to photos, furniture, clothing and costumes she obtained from various photo shoots. Koudriavtseva further claimed $1,139,721 in total lost earnings due to her inability to model and update her Web site, as well as her inability to operate her limousine business. In addition, she claimed $26,000 in past medical costs and up to $214,765 in future medical costs, and sought a refund of rental payments from February 2008 through November 2009. Defense counsel argued that Koudriavtseva did not suffer as a result of living at the apartment and relied on comprehensive medical expert testimony, including, but not limited to, an independent medical exam that allegedly revealed that Koudriavtseva did not have any injury related to “mold exposure.” Defense counsel contended that Koudriavtseva appeared in several provocative photographs after she terminated her tenancy. Counsel argued that these photos, which were revealed at trial, directly contradicted Koudriavtseva’s claim that she was ill and unable to model or work during or after her tenancy. Defense counsel also offered photographs of Koudriavtseva working as a model/spokesperson at various adult entertainment events during the period of when she was allegedly unable to work. In addition, the jury was shown photographs of personal items that Koudriavtseva claimed were damaged and had to be thrown away. However, defense counsel claimed that these items were undamaged.