25F-H800-REL_Salcedo_JudicialReview_SupplementalPacket_7.17.25.pdf

25F-H008-REL · Department of Real Estate - H/C · 2025-07-16

Page 1 of 3 – Supplemental Procedural Note

SUPPLEMENTAL PROCEDURAL NOTE Regarding Motion for Judicial Review

Matter No.: 25F-H800-REL Office of Administrative Hearings

Filed: July 17, 2025 Petitioner: Robert M. Salcedo For: Honorable Judge Adam Stone

Petitioner respectfully submits this Supplemental Procedural Note to preserve filing chronology and address a procedural contradiction in Respondents’ July 16, 2025 submission.

Approximately thirty minutes prior to Petitioner’s filing of the Motion for Judicial Review of Document Obstruction, Respondents’ counsel, Attorney Adrianne Speas, submitted a response indicating that internal board records—specifically regarding island maintenance and liability— were presumed not to exist. However, counsel simultaneously conceded that a comprehensive review of responsive materials, including emails, had not yet occurred.

This admission directly contradicts the July 10, 2025 certification of full compliance previously submitted by Respondents. Petitioner asserts that this reversal strengthens the legal grounds for judicial review and underscores the necessity of Petitioner’s Motion.

Counsel’s reliance on speculative phrasing—such as “do not believe records exist”—without having conducted a review is not accepted as credible. Petitioner respectfully contends that such language reflects procedural evasion rather than verified compliance, and therefore warrants judicial scrutiny.

Petitioner respectfully requests that this Supplemental Procedural Note be docketed alongside the July 17 Motion for Judicial Review to maintain procedural accuracy and reinforce the evidentiary record.

Respectfully submitted, Robert M. Salcedo – Petitioner Page 2 of 3 – Cover Letter

Date: July 17, 2025 To: Honorable Judge Adam Stone Office of Administrative Hearings

Re: Matter No. 25F-H800-REL Subject: Submission of Exhibit A – Support for Supplemental Procedural Note

Petitioner respectfully submits Exhibit A, titled Emergency CRC Executive Board Agenda – July 11, 2025, in support of the Supplemental Procedural Note filed July 17, 2025.

The document reflects a closed executive board session held on July 11, 2025—just one day after Respondents certified full compliance with subpoenaed records on July 10, 2025. The meeting includes legal discussion under board quorum, suggesting that governance activity continued beyond the certification date and the possible existence of undisclosed responsive documents. The meeting was held via Zoom and was closed to all parties except board members and management. This supports the grounds for judicial review by demonstrating contradiction and procedural evasion.

Petitioner respectfully requests that Exhibit A be docketed alongside the Judicial Review Motion filed on July 17, 2025, and reviewed as part of the evidentiary record.

Thank you for your attention to this supplemental filing.

Respectfully submitted, Robert M. Salcedo – Petitioner Bullhead City, Arizona Filed: July 17, 2025 3 of 3 – Exhibit A

EXHIBIT A – Emergency CRC Executive Board Agenda Date of Meeting: July 11, 2025 Document Reference: Emergency CRC Executive Board Agenda 7-11-25.pdf Submitted in Support of Petitioner’s Motion for Judicial Review Matter No.: 25F-H800-REL

COLORADO RIVER CONDOMINIUMS ASSOCISTION, INC

BOARD OF DIRECTORS MEETING EMERGENCY EXECUTIVE AGENDA CLOSED MEETING FOR BOARD MEMBERS ONLY July 11, 2025 @ 3:30pm 2755 Silver Creek Rd., Suite 203, Bullhead City, AZ 86442 This agenda is subject to be changed prior to the meeting open This meeting will be held by Zoom Only

EXECUTIVE SESSION Per A.R.S. Section 33-1804 A 1-5 the Board of Directors will enter Executive Session

I. CALL TO ORDER

II. ESTABLISHED QUORUM - a. Board Members: Ed Wamil, David Baker, Mary Russo, Craig Kurth b. Management: Michelle Vandenberg- Community Manager

III. EMERGENCY BOARD ISSUES - a. Legal Review: Discussion/Action:

IV. ADJOURN EXECUTIVE SESSION: