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1/10/2020, 6:44 PM “AD NAUSEAM” On October 16, 2019, defendants attorney, William Ohle submitted to the Jefferson County Circuit Court, some Motion Material/Declarations that contained statements confirming there was CONFUSION among some of the Ranch Board of Directors regarding what was a valid vote to amend the by-laws in 2016. Former Ranch Director/Secretary, Paula Bartolomei stated in her Declaration, “…some members of the CRR including myself were CONFUSED over what was a valid vote to amend the by-laws…”

Former Ranch President, Dave Palmer addressed the confusion issue in his Declaration, “some members of the Crooked River Ranch were confused over what was a valid vote to amend the Bylaws.”

Attorney Ohle, stated in his Motion, “some members of the Board, including Ms. Bartolomei, were CONFUSED over what a valid vote to amend the Bylaws…”. Note that Ohle used members, plural.

In a recently obtained document/email, dated August 29, 2016, authored by Dave Palmer, he stated in part, “So, after reading and re-reading this ad nauseam it really seems to me that the intent is not only do we need the 50% + 1 of eligible voters, but to pass a measure the total YES VOTES must that 50% + 1 also.” Note: WITH ONLY 2 DAYS LEFT FOR THE 2016 ELECTION.


In Secretary Bartolomei’s July 2016 TELEGRAPH Message/Solicitation titled, “We need you!” She stated, “Today, with 2646 eligible voting lots, in order to change the By-Laws, we need a majority of eligible voters plus one-or 1,324 votes in favor (YES)-in order to change anything.”

Since Ranch Directors were CONFUSED, and Ranch Secretary Bartolomei was CONFUSED, and so admitted in late 2019, then why were Ranch Members attacked for asking clarification questions and more importantly, why did the 3 plaintiffs have to file a lawsuit?

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