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.
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.