Category Archives: Uncategorized

My Lawyers Respond to the HOA’s Motion to Dismiss

Posted on May 24, 2013 by Raquel Baranow

PDF My lawyers have asked for suggestions for witness list, I have questions about the following: I thought our HOA dues covered lawsuits and that the HOA had their own lawyer on retainer, so why is Russo’s law-firm representing the … Continue reading →

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Russo & the HOA Respond by not Saying Much

Posted on May 4, 2013 by Raquel Baranow

They must think Judge Cornelio (the comments on article support the Judge) is a good-old-boy and he will dismiss my case. PDF PDF So Russo’s law firm represents the HOA? Two lawyers from his law-firm (none of them on the HOA Boards) respond. … Continue reading →

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Sycamore Vista Annual HOA Meeting 25 April 2013

Posted on April 26, 2013 by Raquel Baranow

Beginning of meeting was about impending water shortage, which can be solved by assessing each lot a portion of the $1.3-million to improve the well. ($3-million total, our share, 35% is $1.3-M) Other communities must also chip-in to get more … Continue reading →

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Prior majority lot owners’ plans failed, leading to more than $32-million debt

Posted on April 8, 2013 by Raquel Baranow

From the Sparlin Complaint, page 28-29: i. Figueroa’s representation in October 2003 that Western Recovery Services (WRS) could get by with $6 million in capital depended on two key assumptions: first, that it would focus “exclusively” on a project in … Continue reading →

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2013 Annual HOA Meeting Announcement & HOA Budgets for 2012

Posted on April 7, 2013 by Raquel Baranow

Received 2012 annual budgets for Units 5, 7, 9 & 10S — all I received for Unit 8 was a postcard announcing a quarterly meeting on 9 April 2013 at 6pm in the Corona de Tucson Fire Department. This will be my … Continue reading →

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The Pima Pineapple Problem at Sycamore Vista

Posted on April 5, 2013 by Raquel Baranow

Before the development (dump, blade & scrape) got underway, the US Department of the Interior did a 15-page study of the cacti. Here’s a link to the 15 December 2004 report. Many cacti, including Ocotillo, were moved to the 5-acre … Continue reading →

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My Answer Counterclaim and 3rd Party Complaint

Posted on April 4, 2013 by Raquel Baranow

Answer Counterclaim and 3rd Party Complaint PDF Exhibit A: Second amended Declaration of Covenants, Conditions and Restrictions for New Tucson Unit 5, Lots 1 – 191, both inclusive, Being a Subdivision Recorded at Book 17 Page 51 of the Maps and … Continue reading →

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Cheifetz (my lawyer) vs Maltz

Posted on March 28, 2013 by Raquel Baranow

My lawyer(s) sent two hard-hitting letters to Steve Russo’s lawyer, Gerald Maltz, an old, well-connected lawyer here in Tucson, his AZ Bar Association number is very low, he was admitted to the bar in 1977.  One of the other lawyers in the … Continue reading →

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2nd Amended Complaint and My Narrative of the Case

Posted on March 17, 2013 by Raquel Baranow

In this update, I wrote a narrative for our Answer to the 2nd Amended Complaint. Ms Baranow bought her first lots in the New Tucson / Sycamore Vista subdivision sight-unseen on April 9, 1997. She was surprised that there were … Continue reading →

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Thanks to all who called

Posted on February 14, 2013 by Raquel Baranow

Thanks to everyone who called me on the phone after receiving my post card, this hasn’t been easy for me. At the last HOA meeting Mr Russo told us they were going to develop the SW corner of Unit 5. … Continue reading →

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