“DO NOT COPY OR DISTRIBUTE”
“On the thumb drive provided, is a copy of ‘Crooked River Ranch Defamation Complaint-‘ Draft from our HOA attorney. Read through it, but pay special attention to complaints about John Stevens…”
FORMER Ranch Director Mark Schneider
CROOKED RIVER RANCH CLUB AND MAINTENANCE ASSOCIATION, an Oregon nonprofit corporations,
JOHN STEVENS, an individual, TERRY NAPIER, an individual, CHRIS ALLSMEN, an individual, LINDA ANDYKE, an individual, and SUNRAY HENDERSON, an individual,
Former Ranch Director Mark Schneider submitted an undated, unsigned DRAFT COMPLAINT that was never filed with the Jefferson County Circuit Court as part of his complaint package to the Department of Public Safety Standards and Training (DPSST) on March 8, 2020 against Ranch Matters John Stevens’ private investigators license.
NOTE: Schneider signed his March 8 DPSST COMPLAINT, “I certify that the information provided on or with this form is true and correct to the best of my knowledge…”
The unsigned Draft/Complaint was apparently prepared by Kevin V. Harker an attorney with the Community Association Law Group based in Portland.
The hastily prepared DRAFT/COMPLAINT, much like Schneider’s DPSST complaint, is riddled with multiple inaccuracies, false information and lacked legal formality.
Part of the Draft/Complaint refers to statements about the Board’s failure to exercise due diligence in March 2017.
WHAT HAPPENED IN MARCH 2017?
Ranch Matters attorney submitted an ORS 94.630 NOTICE regarding claims against Crooked River Ranch directors, officers and employees on March 20, 2017. The notice incorporated 16 points of concern with point number 16 stating, “Failure to exercise DUE DILIGENCE and investigate director and management actions, inactions, and conflict with loyalty to CRR.”
COPY OF MARCH 20, 2017 94 NOTICE FOR FURTHER DETAILS
Retribution best describes the Draft with an air of vindictiveness.
The Draft/Complaint’s apparent objective was to shut up and shut down Ranch Matters. It ends, “…an injunction prohibiting Defendant Stevens from interfering with the affairs and operations of the Association, Board of Directors, and Association’s employees; and an injunction prohibiting Defendants from publishing any further defamatory statements.”
What’s interesting, if they really felt that they had a case, why not file it and proceed accordingly. We can only speculate, but possible they decided to conjure up another plan of attack-DPSST.
HOW MUCH DID THIS DRAFT/COMPLAINT COST THE HOMEOWNERS?
HOW DID MARK SCHNEIDER OBTAIN A COPY OF THIS DRAFT/COMPLAINT AND WAS THE “NINE-PERSON BOARD OF DIRECTORS” INVOLVED?
The Draft states right up front, “DO NOT COPY OR DISTRIBUTE”, but that didn’t stop Schneider.
Ranch Matters Staff