*The following story (DO NOT COPY OR DISTRIBUTE) is based in part, on Complaints/Records recently received from the Oregon Department of Safety Standards and Training (DPSST) pursuant to an ORDER issued by the Oregon Department of Justice (DOJ). The DOJ’s ORDER was regarding complaints submitted in 2020 against Ranch Matters John Stevens’ private investigators license that were submitted by Ranch Officials and later dismissed by DPSST as “FALSE/UNFOUNDED.”
“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
.
WHAT COMPLAINT?
CROOKED RIVER RANCH CLUB AND MAINTENANCE ASSOCIATION, an Oregon nonprofit corporations,
Plaintiff
V.
JOHN STEVENS, an individual, TERRY NAPIER, an individual, CHRIS ALLSMEN, an individual, LINDA ANDYKE, an individual, and SUNRAY HENDERSON, an individual,
Defendants
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
