Saturday, February 28, 2015

THIS JUST IN: POR BOARD NOT REQUIRED TO FOLLOW OWN RULES


(It will help you understand this posting if you have read the “recap” post immediately preceding this one. )
After thinking through our various strategies to protest the unlawful and unjust fine assessment made against us by the Board in its January 16th letter to us we decided to take the step of filing formal complaints against each member of the Board who were in office when the letter was issued. We filed our three complaints on February 16th (and amended them on the 17th, although the correspondent writing to us below failed to take note of the amendments to our complaint). 

The complaints against Directors Popp, Tarrence, and Rasmussen were all the same.  We complained that, when they issued the fine assessment to us on January 16th they broke the Rule (VI. C. (5)) that required them to have received a written complaint before considering any penalty and that required them to fully, fairly, and objectively investigate that written complaint before taking any action.  As discussed in the recap post, they absolutely had no complaint (but lied and said they did) and they did not do a full, fair, and objective investigation because they never spoke to me about what happened and I was one of three persons present.  We don’t believe they ever spoke to the third person present, either, and she was the one who was hurt in the dog altercation that occurred.
What would you do if you were the only three directors of a nonstock Wisconsin corporation; you are mandated by State law to strictly comply with the corporation’s rules; and you are all very solidly and credibly accused of intentionally violating those rules for the express purpose of harassing one of your corporation’s members?
In those shoes, I would hire a competent lawyer to help protect my backside, wouldn’t you?  Your Board of Directors has not done that, to my knowledge.  As a lawyer, I can tell you quite frankly that your Board gives every indication that it is not receiving competent legal advice in the matter of our protest.
If I didn’t hire a lawyer but had nothing to hide, I would appoint a blue ribbon panel of the best qualified neutral Residents to review our actions.  We k have members in our Association who are illustrious lawyers, educators, business executives and so on, who know how to read Bylaws and Rules and who would not be afraid of speaking truth to power.  Why not call on them?  The Board could have selected such a panel of Association members, given them carte blanche to investigate fully, fairly, and objectively, and let the facts win out in the end.  That would have looked pretty good to the rest of us, right?  Would I have received the email included above?
So, what did the Board do?  Its entire response to our three complaints is set out below verbatim:
____________________________________Start
Mr. Kurtz:
Below is the response to your "General Complaint", issued from the http://www.thepointontheriver.org/ web site to all POR board members as of that date.
Although you sent three identical complaints, one to each Board member, this single response will serve as the response to all of them.  Furthermore, Lynn Tarrence is no longer a member of the RC nor BOD, and Robert Popp is not a member of the RC, rendering any response from him moot as the violation was issued from the RC.
1.            Under Bylaw Section 2.2.2.1(h) the Board has the authority levy fines against Unit Owners for Rule violations.
2.            Under Bylaw Section 2.2.2.2(i) the RC has the authority to levy fines against Residential Unit Owners for Rule violations.
3.            Under Bylaw Section 2.2.1 the actions of the RC are subject to review and authorization by the Board.
4.            Rule VI.A.2. Permits the Board or the RC to initiate an enforcement action without a complaint being made by an Owner.
5.            The violation letter issued on 1-16-15 re. Violation of Rules IV.B.5, IV.B.7 and IV.B.8. (the dog bite incident on 1-9-15) is within the scope of authority granted to the Board and the RC. 
6.            The 1-16-15 violation letter is hereby deemed to have been issued by the RC and is hereby approved by the Board.
7.            The members of the Board and the RC were acting within the scope of their authority under the Rules and Bylaw Sections 2.2.2.1. (h) and 2.2.2.2(i) when the 1-16-15 letter was issued.
8.            The approval of the actions by the RC by the Board is within the scope of the authority granted to the Board under Bylaw Section 2.2.1.
9.            Consequently, there has been no violation of Rule VI. by Dave, Bob or Lynn.
10.          Furthermore, the Board’s proper enforcement of the Rules cannot, by definition, be a “Nuisance” under sec. IV(R)(1), and because your  alleged “violation” turns on whether the Board followed the Association Rules when issuing the fine, there are no facts the Board needs to investigate with respect to your complaint.
Thank you for using the POR's On-line Complaint system,
/s/ Poul David Rasmussen
------------------------------
Dave Rasmussen 
414-520-8505
@worstHOApresidentever
_______________________________________END 

Let’s parse this response out with some care: 

1.        Who is it from?  Dave Rasmussen, Board President. This is to point out that the memo is status quo. Dave speaks for both the Board and the Residential Committee and imputes actions to each whether or not they have actually taken such action at a duly called meeting, whenever he feels it necessary to do so. 

2.       What does the second full paragraph say?  

“Furthermore, Lynn Tarrence is no longer a member of the RC nor BOD, and Robert Popp is not a member of the RC, rendering any response from him moot as the violation was issued from the RC.” 

This second sentence seems to say that our complaint against Lynn Tarrence is [not clear what—not a good complaint?] because she is no longer a member of the Board or the Residential Committee.  That sure isn’t a correct statement of the law.   

This sentence also seems to say that Mr. Popp, the third Director from the Commercial Section, is not a member of the Residential Committee so anything he says about this matter is moot.  The sentence does not make any sense but is also not relevant.  Director Popp is fully accountable for the issuance of the bogus fine assessment letter and has to date never suggested that is not.  

Here is how the January 16, 2015, letter to us begins:  “On behalf of the Board of Directors of First Place Condominium Association….”  That seems pretty clear to us.  What do you say? 

3.       What do items 1 – 5 mean or say? 

a.       Nothing of significance and they are reasonably accurate for as far as they go-which is not far enough. The Board and the Residential Committee are charged with maintaining order in the building, where 147 different households reside, mostly peacefully.  No one is questioning the authority of the Board to act within the Rules.  Our challenge is that in this case the Board has gone far outside the Rules (ultra vires acts) and has done so intentionally to harass us cause us discomfort and insecurity about our ability to continue to live here, safely and comfortably. 

4.       What do items 1 – 5 fail to mention? 

a.       Rule VI. B. is not mentioned.  A written report of a Rule violation is required to be reported to the Board or the applicable Committee before the Board or applicable Committee may initiate an enforcement action based on a complaint.  

b.      VI. C. is not mentioned.  This is the Rule about the process the Board must go through before issuing an enforcement action (full, fair, and objective investigation etc.) 

5.       What does the Board say in item 6? 

“The 1-16-15 violation letter is hereby deemed to have been issued by the RC and is hereby approved by the Board.” 

This sentence goes to the toxicity of Mr. Rasmussen’s Board and Residential Committee leadership.  Whatever he says goes.  It doesn’t matter that there are no properly called meetings; no records of who attended; no votes recorded. He is completely free to say:  “The Board has done this, and the Residential Committee has done that, because I say so.”  No questions may be asked and no explanations or evidence of good practice will be provided.  

6.      What does the Board say in item 7? 

It is very hard to make sense of the statement in item 7.  First of all, let’s get serious about the involvement of the Residential Committee with issuance of the fine assessment in the January 16th letter.  It was Nil.  Nada. Nothing.  The references to the Residential Committee in this sentence are smoke and mirrors to keep us from seeing what is really going on.   

This sentence, once pruned, appears to say that the Board was acting within the scope of its powers in issuing the January 16th letter.  That is hardly an accurate statement. 

a.       Section 2.2.2.1(h) of the Bylaws says that the Board has the power to levy fines against Unit Owners, the Commercial Committee or the Residential Committee for violations of the Rules and Regulations.  That is a true statement for as far as it goes.

b.      Section 2.2.2.2.(i) says that the Residential Committee has the power to levy fines against Residential Unit Owners for violations of the Rules (subject to the approval of the Board).  This is irrelevant smoke and mirrors but harmless because it is correct. 

It looks like all we have here is that the Board may levy fines for violations of the Rules.  But I don’t think it is reasonable to conclude that the Board may levy fines in violation of the Rules.  That would be an incredibly wrong approach to condo governance—to say that the Rules do not apply to the Board.  (But isn’t that what the author is actually saying in item 7?) 

7.      Item 8 is also meaningless. So what if the Board approved the fake action of the Residential Committee that never actually happened. As I have observed over the last three years, our Board does this all the time.  

8.      Item 9 says this:  “Consequently, there has been no Violation of Rule VI. By Dave, Bob, or Lynn.”  

I guess this is the nonsense we get when our Board investigates its own alleged wrongdoing.   

9.  Item 10 is the Grand Finale. It states: 

“Furthermore, the Board’s proper enforcement of the Rules cannot, by definition, be a “Nuisance” under sec. IV(R)(1), and because your  alleged “violation” turns on whether the Board followed the Association Rules when issuing the fine, there are no facts the Board needs to investigate with respect to your complaint.” 

a.       In this incredibly obtuse statement our violation now appears in quotation which suggests that it was never taken seriously.  Why does the Board not have to take our allegation of very serious wrongdoing by the Board seriously?  Apparently because the Board followed Association Rules when it issued the fine.  That is so incredibly wrong that it is almost impossible to believe we have Board members who will write this kind of bologna.  I agree that the Board may not have violated the parts of the Rules cited by the author of this sentence.  But who says the Board only has to follow the Rules it agrees with? I understand that may be Dave Rasmussen’s view of how things work but it isn’t mine and it isn’t the view of any court of law in this country, I know that.   

b.      Let’s read the sentence above from my point of view, i.e., that we have credibly alleged improper actions by the Board and that we presume that the Board is required to follow all the Rules.  Here is what I come up with: 

“The Board’s alleged improper enforcement of the Rules cannot be an actual violation of the Rules because the Board was acting in compliance with those sections of the Rules the Board has determined really apply to the Board; as a result, since there has been no violation of the Rules (that we feel apply to us) there are no facts the Board needs to investigate with respect to your complaint.”  

c.       If you don’t agree with my translation get out your copy of the Rules and Bylaws and come up with a better reading.  My bottom line is that David Rasmussen does not feel that his actions must conform to our rules and his colleagues on the Board and on the Residential Committee agree wholeheartedly with that position. 


To address the easy dismissal of our complaint that the Board’s actions violated the nuisance rule, please read on.  According to the Rules, a “nuisance” is a thing, act, or condition or use of property which continues for such length of time as to: (i) substantially injure or endanger the comfort, health, repose, or safety of the Condominium or Owners or Residents; or (ii) in any way renders Owners and Residents insecure in the use and enjoyment of property; or (iii) any other act or omission which would otherwise be recognized as constituting a public nuisance pursuant to the statutory or common law of the City of Milwaukee or State of Wisconsin. 

a.       If, as we have alleged, the POR Board failed to follow the Rules when it wrongfully assessed a monetary fine against us, because it lied in doing so and failed to satisfy all of the requirements of the Rules, it seems to me, we believe that is, indeed, a nuisance under the Rule cited above.  Here is why:

The unjust and illegal fine assessment is an act that has substantially injured or endangered our comfort, health, repose, and feeling of safety in our condominium home at the POR; it has rendered us insecure in the use and enjoyment of our home. --H. A. Kurtz 

All you need to know is this:  If David Rasmussen can do this once, he can do it twice; if he can do it to us, he can do it to you.

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