ALJDEC decisions subject to certification as final

19F-H1918033-REL-RHG · Department of Real Estate - H/C · 2020-04-01

IN THE OFFICE OF ADMINISTRATIVE HEARINGS

Steven D. Stienstra

Petitioner,

v.

Cedar Ridge Homeowners Association,

Respondent.

No. 19F-H1918033-REL-RHG

ADMINISTRATIVE LAW JUDGE REHEARING DECISION

REHEARING: March 12, 2020

APPEARANCES: Attorneys Diana Elston and Keith D. Collett, of Jones, Skelton & Hochuli, PLC., represented Cedar Ridge Homeowners Association (HOA) as petitioner for the rehearing. Steven D. Stienstra (Petitioner) appeared on his own behalf as respondent for the rehearing.

ADMINISTRATIVE LAW JUDGE: Kay Abramsohn

_____________________________________________________________________

FINDINGS OF FACT

The Arizona Department of Real Estate (Department) has jurisdiction to receive petitions, hear disputes between a property owner and a homeowners association, and take other actions pursuant to Arizona Revised Statutes (A.R.S.), Title 33, Chapter 16.

Cedar Ridge Homeowners Association (HOA) is an association of home owners located in Sedona, Arizona. Respondent’s Board of Directors (Board) is a voluntary Board.

Steven D. Stienstra (Petitioner) purchased a residence in the HOA in August of 2017.

In November 2018, Petitioner filed a one-issue petition (Petition) with the Department alleging that HOA had violated the provisions of A.R.S. § 33-1806.01 and the HOA CC&Rs - Section 1.1 and Section 18. See Exhibit I.

On or about December 18, 2018, the HOA Secretary filed an answer to the petition denying all allegations.

At the initial hearing session on October 7, 2019, while the parties presented evidence and argument regarding the alleged violation, they both indicated that the “issue” in this matter was legal fees.

Based on his position that HOA did not properly undertake to, or perform and provide due process for, enforcement of the CC&Rs as to rental activity, Petitioner argued that he should be released from any liability for the asserted legal fees.

HOA argued that, based on “facts and knowledge within its possession” regarding the rental activity, it reasonably sought legal advice regarding enforcement of the CC&Rs and incurred legal fees that were now owed to HOA by Petitioner.

At the initial hearing, Petitioner presented twenty-five exhibits, designated as Exhibits 1 through 25. HOA presented thirteen exhibits, designated as Exhibits A through M.

The official record of the hearing is the audio record made at the time of the hearing.

Following the October 7, 2019 hearing, the Administrative Law Judge issued a Decision dated November 15, 2019 in which she concluded that Petitioner had established the alleged HOA violation and that his Petition should be granted with the HOA reimbursing Petitioner for the $500.00 filing fee.

On or about December 19, 2019, after the issuance of the Administrative Law Judge Decision, HOA filed a Homeowner’s Association (HOA) Dispute Rehearing Request citing as particular grounds for the request that the ALJ Decision was “arbitrary, capricious, and an abuse of discretion, and was not support by the evidence.”

Within the rehearing request, HOA alleged that the ALJ had not considered the HOA evidence regarding whether the HOA had reason to believe that there were continued violations of the CC&R’s short-term leasing prohibition. HOA further alleged that the ALJ had erred in an interpretation of the CC&Rs and had not considered evidence regarding the steps HOA took to ensure compliance and “proper” enforcement of its CC&Rs.

On January 22, 2020, the Commissioner of the Arizona Department of Real Estate issued an Order Granting Rehearing and Notice of Hearing (Order). In that Order, the Commissioner indicated “the Department hereby grants the [HOA]’s request for rehearing for the reasons outlined in the ... Rehearing Petition ...”

On March 12, 2020, the Tribunal conducted the requested rehearing. At the rehearing, the exhibits from the first hearing were considered admitted to the rehearing record; the number and letter designations have not changed. Additionally, during the rehearing, HOA relied on admitted Exhibits N, O, P, Q, and R.

The Findings of Fact in this Rehearing Decision are the result of evidence and arguments from the Initial Hearing and from the Rehearing. Overall, some but not all factual evidence from the Initial Hearing was repeated in the rehearing session, and new factual evidence and legal arguments were presented through the rehearing process.

Petitioner purchased the home, intending to use the home as a vacation get-away not only for the immediate family but also for friends. Petitioner’s son began living in the home and managing the schedule for family and friends vacationing in the area and staying at the home. In order to track multiple friends and family staying at the home at various times, Petitioner’s son (Son) set up an account with VRBO, an Expedia Group website containing listings for property rentals around the world. While not intended to be a revenue source, the rentals began to expand to persons other than family members and did produce some revenue between approximately December 2017 or January 2018 and April 2018.

On April 3, 2018, HOA Board Secretary, Vic Burolla penned a memo indicating that he had called Petitioner about a motor home with Canadian plates parked in Petitioner’s driveway in violation of a CC&R prohibiting the parking of motor homes anywhere in the development. See Exhibit H. Other than telling Petitioner to move the motor home “out of” the development, Mr. Burolla had no suggestions for Petitioner.

At some point, in April 2018, HOA Board President, Bill Ferguson, called Petitioner about rental activity at the property. The participants have widely variant recollections of exactly what was said and in what tone. However, based on the testimony regarding that call, it appears that the phone call was intended to bring to Petitioner’s attention that the CC&Rs prohibited short-term rentals of less than 30 consecutive days. Absent a recording of such call, no particular findings can be made regarding specific CC&R information shared during that phone call.

While Mr. Ferguson indicated that he could not recall the exact wording, he testified at the initial hearing that the conversation was “not going in a positive direction” and that it was his impression that Petitioner was not going to stop the short-term rentals. Mr. Ferguson recalled he kept repeating to Petitioner “shut it down.”

The hearing record does not support that a phone call is, in any manner, an enforcement mechanism of alleged violations of CC&RS; therefore, it simply is a courtesy or informational call.

At the initial hearing, Petitioner testified that he had acknowledged to Mr. Ferguson during the phone call that there had been short-term rentals and that he had stated to Mr. Ferguson they would stop the short-term rentals, i.e., would comply with the CC&Rs from then on.

At the initial hearing, Son indicated that Petitioner had called him after the Ferguson call and that he then shut down short-term rentals. Son testified that he took down two of the three VRBO listings and left one up, setting that listing up to not take any bookings for less than 30 days.

Mr. Ferguson indicated at the hearings that, after the phone call, he called a Board meeting and the Board then decided to contact an attorney and send a letter to Petitioner about compliance with the CC&Rs. Mr. Burolla echoed that action when he indicated, at initial hearing, that the Board had relied on the advice of its attorney in sending the May 11, 2018 Cease & Desist Letter.

At rehearing, Mr. Burolla indicated that, in April 2018 and May 2018, they had discussed the reasons for, and benefits of, proceeding under either Section 1.1 or Section 18. However, at initial hearing, Mr. Burolla had stated that he was “not aware of any specific instructions in the CC&Rs” about notifying a homeowner about a violation, and that there was no description therein about how to notify a homeowner.

At rehearing, Mr. Burolla noted that, while the Board had believed that it had the choice to enforce the CC&Rs under either section, it had seemed more expeditious, to be able to collect, to go with Section 1.1 because Section 1.1 dealt with legal fees (Board expenses) and not with a [future] lien (in Section 18).

The May 11, 2018 Cease & Desist Letter states as follows, in pertinent part:

Since February of 1996, the CC&Rs have required under Section 1.1 that “all leasing or rental of a lot” must be in writing and shall not be for “transient or hotel purposes, which shall be defines as rental [of] any period of less than thirty (30) consecutive days.” Section 1.1 goes on to require that a lease must be for no less than the “owner’s entire lot.” You are in repeat violation of this Section of the CC&Rs as your son openly lists your Property as multiple units on www.vrbo.com as a vacation rental by the night (see enclosed VRBO print out from May 9, 2018).

...

You have already been verbally warned that your actions are in violation of the CC&Rs.

...

Your failure to comply with the clear terms of the CC&Rs has caused the Board to hire our office to send this demand letter.

If you do not cease and desist from all rentals of your Property for a period less than thirty days, or renting less than all of your Property in one lease, within ten (10) days of your receipt of this written demand, the Board has directed our office to file suit as authorized in Section 1.1 of the CC&Rs. Based upon your violations of the CC&Rs as a breach of contract, CRHOA will also seek to recover its attorney’s fees and costs from you in addition to having an injunction put in place prohibiting your short term rentals.

See Exhibit 5.

There is no method set forth in the May 11, 2018 letter for Petitioner to demonstrate compliance with the demand letter to the Board.

Rather than accept Petitioner’s May 11, 2018 email explanation and information provided in response, and consider the matter resolved, HOA sent another Cease & Desist letter, dated June 1, 2018, to Petitioner. See Exhibit 7. The letter states, in pertinent part:

Mr. Ferguson provided you a courtesy call as a verbal warning of the violations being caused by your VRBO rentals of multiple units within the Property. You say that you ceased rentals, but acknowledge that the listing stayed up on the VRBO website. ... You claim the listing would not have allowed a booking, but there was no statement in the listing saying the unit was not open for booking. CRHOA has no duty to try to pay for a rental to “see if it would go through”.

It is important to note in your [April] call with Mr. Ferguson that you indicated that did not believe that your rentals could be restricted. You did not say that you would be ceasing such operations.

...

You have [now] indicated in writing that you will not again rent the Property for less than the required minimum term, that does not alter your months of prior violations. While the CRHOA will therefore no longer consider filing suit to enjoin you from VRBO rentals, based upon your violations of the CC&Rs as a breach of contract, CRHOA hereby demands payment from you on or before July 2, 2018 in the amount of $1,500.00 to recover attorney’s fees and costs for bringing you into compliance. Please note that this is a number authorized by the Board as a flat amount to resolve the matter; however, if a suit or collection process is necessary to collect such amount, CRHOA reserves the right to pursue collection of all its fees and costs in excess of that number.

HOA’s position was that the remaining listing, as could be seen on VRBO, “remained active” and the fact that the “presence of vehicles outside the home changed on a regular basis” demonstrated to the Board that the [short-term] leasing was still going on.

On June 17, 2018, HOA sent another Cease & Desist letter to Petitioner. See Exhibit 9. The letter states, in pertinent part:

In our May demand to cease and desist, we noted that short term rentals of the property were prohibited. We also explicitly stated that Section 1.1 of the CC&Rs also requires that a lease must be for no less than the “owner’s entire lot.” After you and your son were told to cease renting the Property out through [VRBO], you and your son apparently decided to continue violating the CC&Rs by trying to rent the Property in three separate units through Facebook Marketplace ...

What is particularly egregious about this ongoing intentional pattern of activity to violate the CC&Rs is that your son ... actually acknowledges in the Facebook post that very intent. He clearly indicates that he is renting a two bedroom, one bath “basement unit” while noting that “there are two other month-to-month renters in separate parts of this home. He still calls himself a “property manager” that “lives on location.” He even states that this was a “short-term vacation rental” that is “now transitioning to monthly rentals.” Your son’s statements are further supported by the neighborhood observation of multiple cars parked there daily. You are responsible for your son’s actions in the Property and your son is not able to rent the Property piecemeal any more than you are.

...

If you do not cease and desist from all rentals of your Property for a period of less than thirty days as well as renting less that all of you Property in one lease, on or before August 17, 2018, the Board has directed our office to file suit as authorized in Section 1.1 of the CC&Rs. ... You are now required to also pay $2,600.00 in attorney’s fees for the repeated necessity of our firm’s involvement to bring you into compliance.

The matter was not resolved informally after the filing of the Petition.

Initially, Petitioner had believed that the law permitted “vacation” rentals. Son indicated there were three VRBO listings (apparently to demonstrate the various sleeping accommodations). Petitioner called Son after Petitioner received the phone call from Bill Ferguson regarding the CC&R, and Son subsequently discontinued all active bookings, taking down two of the listings but kept one listing posted. The hearing and rehearing evidence provides several explanations for that remaining post: to “show” the accommodation; to be able to contact persons who had booked for less than 30 days in order to cancel that booking; and, to have a calendar reference for already blocked-out dates (that were planned for the family’s own use). Son indicated that, although the listing was still posted, it was not possible to “book” the rental because it was not an active listing. In his explanation in response to the June 1, 2018 letter, Petitioner noted that a person only had to click on any date and a message on the listing would have popped up indicating that there was a minimum 30-day booking. See Exhibit 8.

The provision of copies of leases to the Board was another matter of contention between the parties. It is not clear whether and when any or all of the redacted leases were provided to the Board. In regard to a copy of a lease being demonstrative of activity of leasing, the hearing record does not evidence any copies of short-term leases prior to the April 2018 phone call to Petitioner from Mr. Burolla. However, Petitioner does not dispute the fact that there were short-term leases prior to April 2018; Petitioner disputes that there were any short-term leases after April 2018. Further, the hearing record does not evidence any copies of short-term leases executed after the April 2018 phone call by Petitioner or Son with any tenant.

Based on an explanation provided by Petitioner following the June 17, 2018 letter, Petitioner had not been aware of Son’s Facebook posting offering to lease bedrooms separately. See Exhibit 11. Once Petitioner was so informed, he told Son to take the posting down; Petitioner’s explanation further indicates that there were no leases from the Facebook posting.

Upon request of Petitioner, and despite the Board maintaining that he was not entitled to a meeting (because the Board had proceeded under Section 1.1, which did not provide for such), three members of the Board met with Petitioner on September 4, 2018. This was a meeting agreed to with specific conditions; the meeting was not arranged as an official or a special Board meeting. See Exhibits 12 and 14. However, an audio recording was made as well as a subsequent transcript. See Exhibit A.

The unofficial meeting transcript reflects the tense relationship between the parties. For example, at one point, after Petitioner and Son again indicated that the short-term leases had stopped, that the listings were taken down, that leases had been provided, and that there was “nobody under lease,” Ms. Tucker asked “[w]ho’s there then?” to which Petitioner replied “[i]t’s not anybody’s business who’s in our house, really.” See Exhibit A at 23:19 to 23:24. Another example is a discussion about the number of cars, where Mr. Burolla stated that the Board was not complaining about the cars and Son noted the Cease and Desist Letter had stated “multiple cars parked there daily” to which Mr. Burolla replied “[t]hat is evidence of something else that’s going on, that might be a violation.”

Section 1.1 of the CC&Rs provides as follows:

Any agreement for the leasing or rental of a lot (hereinafter in this Section referred to as “lease”) shall provide that the terms of such lease shall be subject in all respects to the provisions of this Declaration and the By-laws of the Association. Said lease will be restricted to a single family and shall further provide that any failure by the occupant thereunder to comply with the terms of the foregoing documents shall be a default under the lease. All leases shall be in writing. No owner shall be permitted to lease his property for transient or hotel purposes, which shall be defined as rental [of] any period of less than thirty (30) consecutive days. No owner may lease less than such owner’s entire lot. Any owner who shall lease the owner’s lot shall be responsible for assuring compliance by the occupant with the Declaration and the By-laws of the Association. Failure by an owner to take legal action, including the institution of a forcible entry and detainer procedure against an occupant who is in violation of this Declaration and By-laws within ten (10) days after receipt of written demand to do so from the Board of Directors, shall entitle the Association, through the Board, to take any and all such action as attorney in fact for owner including the institution of proceedings in forcible entry and detainer on behalf of such owner against owner’s occupant. Any expenses incurred by the Association, including attorney’s fees and costs of suit, shall be repaid to it by such owner as a special assessment levied against such owner and the owner’s lot. In the event of a failure of the lot owner to pay such special assessment within thirty (30) days of its due date, for which the owner shall also be personally liable, the amount of the unpaid assessment shall constitute a lien upon the lot owned by the owner. The lien may be enforced in equity as the case of a real estate mortgage judicial like foreclosure in accordance with Arizona law and such policies as the Board of Directors may from time to time adopt. The foreclosure judgment may award to the Association reasonable attorney fees and taxable court costs incurred in connection with the foreclosure, such fees and costs to be fixed by the court without a jury.

Section 18 of the CC&Rs is entitled “Enforcement of Covenants.” Section 18 requires that, when the Board believes there has been a breach or a threatened breach of the covenants, the Board’s required enforcement action is to “notify the [owner] in writing of the breach.” See Exhibit 2. Section 18 also requires that the owners are to be given 30 days thereafter to appear before the Board and respond. Section 18 further requires that the owner is to be given a time period, as reasonably determined by the Board not to exceed 60 days to remedy the breach. Finally, if the breach is not remedied, the Board is authorized to levy a fine, which would be a special assessment and result in a lien on the owner’s Property.

At rehearing, Petitioner argued that the HOA had not followed the enforcement steps set forth the Section 18 of the CC&Rs. Petitioner maintained that Son had stopped the rental activities once notified clearly of the prohibitions of, first, short-term leases and, then, the less-than-full-lot lease. Essentially, Petitioner argued that the HOA took unnecessary actions against them and he should not be held responsible for the asserted attorney’s fees.

At rehearing, for the first time, HOA cited the application of A.R.S. § 10-3830, arguing that HOA had discharged its enforcement duties in good faith relying on advice from its attorney and, thus, the ALJ had erred and the HOA should not have been held to have violated the CC&Rs. Additionally, HOA argued, at rehearing, that the Petitioner’s short-term leases had been a violation of the CC&Rs, and that even after being warned about rentals, the subsequent monthly rental of less than the full home was a continued violation of the CC&Rs by Petitioner and, thus, Petitioner had “unclean hands” and he was not able seek relief from the Department regarding the HOA actions.

CONCLUSIONS OF LAW

The Department has jurisdiction to receive petitions, hear disputes between a property owner and a homeowners association, and take other actions pursuant to Arizona Revised Statutes (A.R.S.), Title 33, Chapter 16.

In this proceeding, Petitioner bear the burden of proving by a preponderance of the evidence that HOA violated A.R.S. § 33-1806.01 and the Respondent’s own CC&Rs pursuant to Arizona Administrative Code (A.A.C.) R2-19-119.

A preponderance of the evidence is “[e]vidence which is of greater weight or more convincing than the evidence which is offered in opposition to it; that is, evidence which as a whole shows that the fact sought to be proved is more probable than not.” Black’s Law Dictionary 1182 (6th ed. 1990).

Petitioner alleged that HOA violated Section 1.1 and Section 18 of the CC&Rs and A.R.S. § 33-1806.01 in its enforcement actions against Petitioner.

A.R.S. § 33-1806.01(A) provides that a planned community property owner may use his or her property as a rental “unless prohibited in the declaration and shall use it in accordance with the declaration’s rental time period restrictions.”

Section 1.1 of the CC&Rs contains multiple provisions; these provisions are not connected to one single action or the activity of the same person.

Section 1.1 mandates that a lease agreement is subject to the CC&Rs. Leases must be in writing. Leases are restricted to a single family. Owners are not permitted to lease for transient or hotel purposes, defined as “rental [of] any period of less than thirty (30) consecutive days.” Finally, the owner may not lease less than the entire property. When an owner creates a lease agreement that violates these lease provision requirements, that circumstance would be a violation by the owner.

The hearing record demonstrated that Petitioner, or more specifically Son, was “managing” the property and as a part of that management, had been coordinating known persons (family and friends) to come and stay at the home. At some point, beginning in December of 2017 or January of 2018, Son also leased out portions of the home to unknown persons (i.e., tenants) for a consideration.

Section 1.1 of the CC&Rs mandates that “any failure by the occupant [under a lease agreement] to comply with the CC&Rs “shall be a default under the lease” and indicates that one proposed legal action regarding such failure, and resulting default, is institution of a forcible entry and detainer procedure against the occupant who is in violation. Thus, the Administrative Law Judge concludes that the written demand language is connected to requiring an owner to take legal action against a lessee who has failed to comply with the CC&Rs. The 10-day period is a time frame within which an owner is supposed to take legal action against the lessee. Actions that the Board may take after the 10-day period are on behalf of the owner against the lessee. Those were not the exact circumstances in this case.

Son was not an occupant under a lease.

Once the May 11, 2018 letter was sent to Petitioner, he had ten days to take legal action to be in compliance with Section 1.1, i.e., to have Son stop any and all leases for less than 30-days. The evidence of record demonstrates that Son had previously ceased all short-term rentals after the April 2018 phone call from Petitioner. Thus, while the May 11, 2018 letter can be determined to have been appropriately sent to Petitioner, the letter was of no effect, as that short-term leasing had ceased.

The hearing record further demonstrates that HOA simply did not believe Petitioner had stopped short-term rentals, or believed that rentals of some sort continued, based on the VRBO listing and the presence of cars. The hearing record does not demonstrate that miscommunication contributed to this HOA belief. Despite Petitioner indicating to HOA that the VRBO listing would not allow any potential renter to book the listing, HOA determined to continue enforcement action.

However, the hearing record also further demonstrates that, through Son’s confusion about “vacation” rentals and/or the specifics of Section 1.1, Son continued to manage the property and sought monthly rentals while he continued to reside, off and on, at the home. Admittedly, this was a violation of Section 1.1. When Petitioner was made aware of such activity, he again mandated Son to desist, and Son gave notice to the “monthly” couple that was at the home that their lease would be over.

Based on the foregoing, the Administrative Law Judge concludes that HOA proceeded, based on advice of an attorney, with its May 11, 2018 Cease and Desist Letter regarding the short-term lease violations attributed to the owner, Petitioner. However, such conclusion does not end the matter, it simply denotes that the HOA sought legal advice regarding their options and then acted upon the legal advice, proceeding to further retain the attorney to write the letter. The HOA incurred expenses in the form of legal fees.

Section 1.1 provides that if the owner does not take legal action against the occupant within ten days, that the HOA may “take and all such action on behalf of the owner against the occupant. Emphasis added here. Here, the hearing record demonstrates that Petitioner took action to stop the leasing. Therefore, no “legal action” was required by HOA against the occupant and, in this case, no such legal action was taken by HOA against Son; therefore, there were no expenses incurred pursuant to the parameters of Section 1.1 by the HOA on behalf of the owner against the occupant to be repaid to the HOA. The remaining letters to Petitioner were not within the parameters required when utilizing Section 1.1 as enforcement action. Accordingly, the Administrative Law Judge concludes that the remaining letters sent by HOA were not within the purview of Section 1.1 or Section 18 of the CC&Rs.

Even if the June 1, 2018 letter were to be considered a second enforcement action under Section 1.1 against Petitioner, it failed to give Petitioner the requisite ten days to take “legal action.”

The June 1, 2018 letter indicated that, because Petitioner had violated the CC&Rs as a “breach of contract,” the HOA was demanding a “payment” in the amount of $1,500.00 “to recover attorney’s fees and costs for bringing you into compliance.” However, that letter then specified that the stated amount of $1,500.00 was “authorized by the Board as a flat amount to resolve the matter.” In no instance, would an amount of “attorney’s fees and costs” be determined by anything other than the actual fees and costs. Therefore, the stated amount could only be looked at as either a settlement offer or as some sort of fine, which is not authorized under Section 1.1 but only under Section 18. In any event, the Administrative Law Judge concludes that the asserted legal fees are not assigned to Petitioner.

Finally, whether the Board determined to follow the advice of an attorney or not, it is implausible that the Board’s Secretary was “unaware” of any specific instructions in the CC&Rs as to how to proceed with a CC&R violation enforcement action. At rehearing, Mr. Burolla had explained that they/he had discussed the options of proceeding either under Section 1.1 or under Section 18 with the attorney. Section 18 of the CC&Rs clearly states that, when the Board believes there is “a breach or threatened breach” a written notice is to be given to the owner along with allowing a 30-day time frame within which the owner may appear before “the Board of Directors.” A verbal warning, in this case the call from Mr. Ferguson, while appropriate in the nature of education and in the spirit of garnering compliance with the CC&Rs, is not an “enforcement” action under the CC&Rs and does not comply with the Board’s responsibilities of enforcement as set forth in either Section 1.1 or Section 18 of the CC&Rs.

REHEARING ORDER

IT IS ORDERED that the Petitioner is the prevailing party and HOA be required to reimburse Petitioner the $500.00 filing fee.

NOTICE

This administrative law judge order, having been issued as a result of a rehearing, is binding on the parties. A.R.S. § 32-2199.02(B). A party wishing to appeal this order must seek judicial review as prescribed by A.R.S. § 41-1092.08(H) and title 12, chapter 7, article 6. Any such appeal must be filed with the superior court within thirty-five days from the date when a copy of this order was served upon the parties. A.R.S. § 12-904(A).

Done this day, April 1, 2020.

/s/ Kay A. Abramsohn

Administrative Law Judge

Transmitted electronically to:

Judy Lowe, Commissioner

Arizona Department of Real Estate

Transmitted through U.S. Mail to:

Steven D. Stienstra

9923 E Jensen St.

Mesa, AZ 85207

Diana J. Elston,

Keith D. Collett

JONES, SKELTON & HOCHULI, P.L.C.

40 North Central Avenue, Suite 2700

Phoenix, Arizona 85004