Small Claims Archive – Defendant Exhibits (July 21, 2025)


  • 📄 Exhibit 101 – Legal and Factual Response

    A detailed written response to the plaintiff’s claims, outlining factual rebuttals, legal arguments, and supporting documents.


  • 👉 📄 View Exhibit 101

  • 🧾 Exhibit 102 – Statement of Principle Challenging Resolution 5
    A concise one-page document submitted by the defendants summarizing their objections to SHOA’s Resolution 5. It highlights concerns about the process, legality, and impact of the fines policy, and frames the dispute as a matter of fairness, transparency, and member rights.

  • 👉 View Exhibit 102

  • 📜 Exhibit 103 – SHOA Certificate of Incorporation (1983)
    SHOA’s original founding document, establishing it as a nonprofit under Oregon law (ORS 65). Provides the legal basis for board structure, amendment procedures, and member control.

    👉 View Exhibit 103

  • Exhibit 104 – SHOA CC&Rs (1999)
    The 1999 “Declaration of Protective Covenants, Conditions, and Restrictions” formally brings SHOA under the Oregon Planned Community Act (ORS 94). These CC&Rs govern land use, membership rights, architectural control, assessments, and enforcement. This document mentions the existence of 99 lots (and conflicts with the official Staffordshire plats which show 98 platted lots, with additional lots designated “Future Phase”; note: see Exhibit 110c for further explanation), defines the common areas, and outlines SHOA’s powers and obligations under both ORS 65 and ORS 94.

    👉 View Exhibit 104

  • 📄 Exhibit 105 – Registered Agent Correspondence

    Letters sent to and from the official registered agent addresses for SHOA and SWS regarding compliance questions.

    👉 View Exhibit 105

  • 📄 Exhibit 106 – Letter to SHOA Re: Transfer Fee

    A formal letter disputing the validity of the 1% transfer fee amendment, with references to ORS statutes and procedural flaws.

    👉 View Exhibit 106

  • 📄 Exhibit 107 – Mediation Request & Response

    Evidence of a formal mediation attempt, including the defendant’s proposal and the SHOA Board’s refusal to participate.

    👉 View Exhibit 107

  • 📄 Exhibit 108 – SHOA Newsletters & Communications

    Selected excerpts from SHOA newsletters and public messages, cited as evidence of shifting policies and inconsistent enforcement.

    👉 View Exhibit 108

  • 📄 Exhibit 109 – Map of Property Boundaries

    Diagrams and official plat maps showing Staffordshire’s lot layout, boundaries, and utility easements.

    👉 View Exhibit 109

  • 📄 Exhibit 110 – Video Evidence (Composite)

    A multi-part exhibit containing video clips used to document interactions and property conditions. Split into:

    A. Driveway Video

    B. Gate Interaction

    C. Yard Walkthrough

    D. Community Meeting Snippet

    👉 View Exhibit 110

  • 📄 Exhibit 111 – ORS and Legal Basis Summary

    Compiled references to Oregon statutes (ORS 65, ORS 94, etc.) that support the defense’s claim of unlawful enforcement or board action.

    👉 View Exhibit 111