CRITICAL EVIDENCE

The Board Never Approved the Sale

2763 White Sage Drive — The Sale Is Voidable

Core Legal Argument

The sale of 2763 White Sage Drive is voidable because the Board never authorized it in compliance with NRS 116.31083 and NRS 116.31085. No compliant agenda, no compliant minutes, no compliant vote.

No Compliant Agenda

No agenda for any Board meeting announced an intent to foreclose on 2763 White Sage Drive. NRS 116.31083 requires that meeting agendas be made available to homeowners and that actions taken must be within the scope of the agenda.

If it wasn't on the agenda, the Board cannot legally authorize it.

No Minutes Document Board Authorization

No minutes of any Board meeting document a Board action authorizing the sale. The Board voted in closed meetings to impose sanctions without notice or hearing — a direct violation of NRS 116.31085.

Key Document:CAM Lori Martin's June 1, 2016 email refusing a minutes request: “Those minutes are Executive Session minutes and not privy to anyone except the Board.”

Due Process Violation

NRS 116.31031 requires 30-day written notice and a hearing opportunity before any sanction can be imposed on a homeowner. No such notice or hearing was provided before the sale of 2763 White Sage Drive.

Adam Clarkson's Own Admission

In his own May 12, 2017 opinion, Adam Clarkson admitted that the SCA Board did not comply with NRS 116 meeting laws regarding the foreclosure process. The HOA's own attorney confirmed the Board acted outside the law.

Falsified Evidence: R-05-120513

Falsified evidence was used to trick the court into believing that R-05-120513was the Board's approval of the sale at the December 5, 2013 Board session. This document was fabricated.

The Red Rock Foreclosure File (RRFS 001-425) was released by SCA as if they were SCA's official records in SCA176-643. These discovery documents have been preserved permanently.

View Discovery Documents (PDF, 16.4 MB)

Permanently hosted on scastrong.com — no Google Drive dependency.

NRS Citations

NRS 116.3102(m)

Board fiduciary duty to homeowners

NRS 116.31031

Due process — 30-day notice and hearing before sanctions

NRS 116.31083

Meeting agenda requirements

NRS 116.31085

Meeting minutes requirements

NRS 116.3108(4)

Foreclosure sale compliance

Video Evidence

$1M Gift — Evidence Walkthrough

2020 Sworn Declaration (10:51)

Complaint to NV Commission on Judicial Discipline (7:38)

Fraud on the Court Has NO Statute of Limitations

When falsified documents are used to deceive a court, the resulting judgment can be challenged at any time. The evidence shows R-05-120513 was fabricated. This fight is not over.