This November 2024 letter provides three specific recommendations to SHOA based on documented inconsistencies between the official Lane County plat maps and the claims made in the SHOA CC&Rs. It highlights the origin and perpetuation of the “99-lot” myth and explains how the actual subdivision contains only 98 platted lots, with one unplatted parcel (34622 Devonshire Drive) that has been improperly treated as a SHOA member lot.
The letter includes:
- Annotated copies of official subdivision plats (Phases I and II)
- Analysis of the 2012 “Resident Locator Map” that created the 99-lot illusion
- Summary recommendations for correcting SHOA’s internal records and public representations
📚 Related Document: Clarifying the Lot Count
🔎 Does Staffordshire Subdivision Have 99 or 98 Platted Lots?
This supplemental research memo explores the origins of the “99-lot myth” and provides visual and textual evidence from Lane County plat maps to show that only 98 lots were ever legally platted.
The memo addresses:
- The misleading 2012 “Resident Locator Map” that introduced the 99th-lot error.
- Why recorded plat maps, not internal SHOA documents, determine subdivision boundaries under Oregon law.
- How this error affects SHOA’s claims of membership, voting thresholds, and assessments.
📄 Click here to read the full memo (PDF)
For legal implications, visit:
👉 Legal Findings on the 99-Lot Myth
📌 Sidebar Note:
This document is critical for understanding SHOA’s dual statutory obligations under ORS 65 (as a nonprofit) and ORS 94 (as a planned community). However, the official plat maps—not the CC&Rs—legally define the number of lots in the subdivision. This fact is confirmed in detail in the Legal Findings on the Staffordshire 99 Lot Myth analysis prepared using Oregon statutes and legal precedent.
👉 Click here to view Exhibit 110c (PDF)
📘 Read Legal Findings on the Staffordshire 99 Lot Myth
🔙 Return to Defendant Exhibit Archive