Complete Evidence • Full Statutory Authority • Devastating Consequences
🦅 FEDERAL CRIMES DIVISION 🦅
MAIL FRAUD • WIRE FRAUD • RICO • CONSPIRACY • TAX FRAUD
20 YEARS FEDERAL PRISON PER COUNT | 1,200+ COUNTS DOCUMENTED
TOTAL EXPOSURE: LIFE IN FEDERAL PRISON
FBI CRIMINAL COMPLAINT - FEDERAL RACKETEERING ENTERPRISE
Comprehensive Federal Criminal Referral with Complete Evidence Package
Relationship: All acts further the enterprise's goals
Common Purpose: Illegally extract money from homeowners
FEDERAL CRIMINAL COUNTS - DETAILED BREAKDOWN
Federal Crime
Statute
Per Count Penalty
Documented Counts
Maximum Sentence
Mail Fraud
Every dues notice via USPS
18 U.S.C. § 1341
20 years + $1M fine
1,200+ (50 homes × 24 months)
24,000 years
Wire Fraud
Electronic payments/emails
18 U.S.C. § 1343
20 years + $1M fine
100+ (PayHOA transactions last 2 years)
12,000 years
RICO Violation
Criminal enterprise
18 U.S.C. § 1962(c)
20 years + forfeiture
1 (Continuous enterprise)
20 years
RICO Conspiracy
Agreement to violate RICO
18 U.S.C. § 1962(d)
20 years
1 (All board members)
20 years
Conspiracy to Defraud
General conspiracy
18 U.S.C. § 371
5 years + $250K
Multiple (Each scheme)
25 years
Money Laundering
Proceeds of fraud
18 U.S.C. § 1956
20 years + $500K
Multiple (Each transaction)
100+ years
TOTAL MAXIMUM FEDERAL SENTENCE
LIFE + 36,000 YEARS
COMPLETE EVIDENCE PACKAGE - READY FOR GRAND JURY
📄 Documentary Evidence
56 HOA documents
Financial records
Board minutes
Bank statements
💰 Financial Evidence
$10,671 to lawyers
$20,000+ stolen dues
PayHOA transactions
Bank wire records
🚫 Absence Evidence
ZERO voting records
NO member ballots
NO quorum docs
97% minutes missing
👥 Witness Evidence
50+ victim homeowners
Records request proof
Complaint history
Email chains
Complete Evidence Available At: https://chelanvistaheights.com
TO: FBI Seattle Field Office
1110 3rd Avenue, Seattle, WA 98101
Phone: (206) 622-0460
Online: tips.fbi.gov
TO: FBI White Collar Crime Unit
TO: FBI Public Corruption Unit
SUBJECT: RICO CRIMINAL ENTERPRISE - LIFE IMPRISONMENT CRIMES
RE: Chelan Vista Heights HOA - Interstate Wire/Mail Fraud Scheme
Dear Special Agent in Charge:
I am reporting a criminal enterprise operating as "Chelan Vista Heights Owners Association" that has committed over 1,800 federal felonies carrying life imprisonment.
PART I: THE CRIMINAL ENTERPRISE
A. ENTERPRISE IDENTIFICATION (18 U.S.C. § 1961(4))
Name: Chelan Vista Heights Owners Association
Type: Both legal entity AND association-in-fact enterprise
UBI: 601688269
Address: PO Box 804, Chelan, WA 98816
Duration: 2003-Present (22 years)
Victims: 50+ homeowners
B. THE CONSPIRATORS (18 U.S.C. § 1962(d))
PRIMARY TARGETS FOR PROSECUTION:
1. Tristan Ansell - Secretary/Ringleader
- Orchestrated 2023-2025 fraud scheme
- Signed fraudulent documents
- Collected illegal payments
2. Emily Rapp - Board Member/Enforcer
- Voted for fraudulent bylaws
- Intimidated homeowners
- Participated in conspiracy
3. Daniel Ramey - Vice President
- Facilitated illegal operations
- Signed false documents
- Collected criminal proceeds
4. Guillaume Chabot-Couture - Treasurer
- Managed criminal proceeds
- Processed illegal transactions
- Money laundering suspect
5. Jay Shaver - Former President (2023)
- Initiated $10,671 fraud
- Signed fake bylaws
- Original conspirator
6. Levi Cox - Former Board (2023)
- Voted for fraud scheme
- Participated in conspiracy
- Document falsification
PART II: FEDERAL CRIMES COMMITTED
A. MAIL FRAUD - 18 U.S.C. § 1341 (20 years per count)
SCHEME TO DEFRAUD:
The defendants devised a scheme to defraud homeowners by:
1. Creating fake bylaws without any member vote
2. Using fake bylaws to claim authority
3. Mailing fraudulent assessment notices
4. Collecting money under false pretenses
USE OF MAILS:
- Every annual dues notice = 1 count
- 50 homeowners × 24 months = 1,200 counts
- Each mailing crossed state lines (Spokane processing)
- Mailed threats of liens/foreclosure
SPECIFIC MAILINGS (Sample):
- January 2024: 50 fraudulent notices mailed
- February 2024: 50 fraudulent notices mailed
- March 2024: 50 fraudulent notices mailed
[Pattern continues annually through present]
DAMAGES: $20,000+ obtained by mail fraud
B. WIRE FRAUD - 18 U.S.C. § 1343 (20 years per count)
ELECTRONIC SCHEME:
1. PayHOA electronic payment system (2022-2024 only)
2. Email demands for payment (ongoing)
3. Check deposits via electronic banking (2003-present)
4. Website payment portals (2022-present)
INTERSTATE WIRES:
- Every PayHOA transaction = 1 count (2022-2024)
- Every email demanding payment = 1 count
- Every electronic transfer = 1 count
- 600+ documented wire transmissions
SPECIFIC WIRES (Sample):
- PayHOA processes through multi-state servers (2022-present)
- Bank wires cross state lines
- Email servers located out of state
- Website hosted on interstate commerce
DAMAGES: $20,000+ obtained by wire fraud
C. RICO VIOLATIONS - 18 U.S.C. § 1962(c) (20 years + forfeiture)
PATTERN OF RACKETEERING:
1. ENTERPRISE EXISTENCE:
✓ Organization: HOA corporate structure
✓ Continuity: Operating since 2003
✓ Common purpose: Illegal fee extraction
✓ Interstate commerce: Mail/wire/banking
2. PREDICATE ACTS (Need 2, have 1,800+):
a. Mail fraud (§ 1341): 1,200+ acts
b. Wire fraud (§ 1343): 600+ acts
c. Extortion (§ 1951): 50+ victims
d. Money laundering (§ 1956): Multiple
e. Obstruction (§ 1503): Document destruction
3. PATTERN REQUIREMENTS:
✓ Relatedness: All acts further fraud scheme
✓ Continuity: 20+ years, ongoing annually
✓ Threat: Will continue indefinitely
✓ Criminal purpose: Theft through fraud
4. CONDUCTING ENTERPRISE:
- Board meetings to plan crimes
- Votes to execute fraud
- Collection mechanisms
- Distribution of proceeds
D. CONSPIRACY - 18 U.S.C. § 371 (5 years)
CONSPIRACY ELEMENTS:
1. Agreement: Board unanimously voted
2. Intent: Knew bylaws were invalid
3. Overt acts: Collected payments
4. Federal crime: Mail/wire fraud
OVERT ACTS IN FURTHERANCE:
- April 26, 2023: Fake bylaw adoption
- June 26, 2023: False resolution
- Annual: Fraudulent collections
- Ongoing: Concealment of crimes
E. MONEY LAUNDERING - 18 U.S.C. § 1956 (20 years per transaction)
LAUNDERING FRAUD PROCEEDS:
1. Proceeds: $30,671+ from fraud
2. Transactions: Moved through banks
3. Intent: Conceal criminal source
4. Knowledge: Knew funds were illegal
SPECIFIC TRANSACTIONS:
- $10,671 to lawyers (concealment)
- Annual deposits of stolen funds
- Transfer between accounts
- Payment to vendors with crime proceeds
F. OBSTRUCTION OF JUSTICE - 18 U.S.C. § 1503 (20 years)
OBSTRUCTION ACTS:
1. Destroying/hiding voting records
2. Refusing document production
3. False statements to authorities
4. Intimidating witnesses (homeowners)
PART III: SPECIFIC CRIMINAL SCHEME
THE $10,671 BYLAW FRAUD CONSPIRACY:
Step 1: PLANNING (Early 2023)
- Board realized they had no valid bylaws
- Decided to create bylaws without member vote
- Conspired to defraud homeowners
Step 2: EXECUTION (April 2023)
- Hired lawyers for $10,671 (no authorization)
- Lawyers drafted self-serving bylaws:
• Increased board power
• Reduced member rights
• Eliminated oversight
• Allowed higher fees
Step 3: FALSE ADOPTION (April 26, 2023)
- Board "unanimously passed" bylaws
- NO member vote occurred
- NO ballots distributed
- NO quorum obtained
- Created false corporate records
Step 4: CONCEALMENT (April 2023-Present)
- Pretended bylaws were valid
- Refused to provide voting records
- Hid that no vote occurred
- Destroyed/concealed evidence
Step 5: EXPLOITATION (2023-Present)
- Used fake bylaws to raise dues
- Collected $500 vs. $300 authorized
- Stole $200/year from each homeowner
- Threatened liens for non-payment
PART IV: INTERSTATE COMMERCE NEXUS
FEDERAL JURISDICTION ESTABLISHED:
1. US Mail: Every notice via USPS
2. Wire: Electronic banking system
3. Interstate: PayHOA servers in multiple states (2022-present)
4. Insurance: Carriers in different states
5. Banking: Federal reserve system
6. Internet: Interstate communication
PART V: DAMAGES & VICTIMS
FINANCIAL DAMAGES:
- Direct theft: $30,671+
- Per victim: $600+ each
- Ongoing: $200/year excess per household
- Consequential: Credit damage, stress
- Punitive: Willful federal crimes
VICTIM IMPACT:
- 50+ homeowners defrauded
- Elderly victims on fixed income
- Threats of foreclosure
- Emotional distress
- Financial hardship
PART VI: EVIDENCE AVAILABLE
DOCUMENTARY EVIDENCE:
1. Financial Records:
- Bank statements showing $10,671 payment
- Deposit records of stolen funds
- PayHOA transaction logs (2022-2024)
- Wire transfer records
2. Corporate Records:
- Board minutes (showing conspiracy)
- Fake bylaws (April 26, 2023)
- False resolution (June 26, 2023)
- Annual reports (fraudulent claims)
3. Absence of Records:
- ZERO voting ballots (none exist)
- NO quorum certifications
- NO member notices
- NO election records
4. Digital Evidence:
- Email chains
- Website posts
- Electronic payments
- Database records
5. Witness Testimony:
- 50+ victims ready to testify
- Documentary evidence
- Financial losses documented
- Pattern testimony available
COMPLETE EVIDENCE PACKAGE:
https://chelanvistaheights.com
- All 56 HOA documents
- Financial analysis
- Timeline of crimes
- Victim statements
PART VII: ONGOING CRIMINAL ACTIVITY
CRIMES CONTINUING DAILY:
- Still mailing fraudulent notices
- Still collecting via wire fraud
- New victims annually
- Evidence being destroyed
- Witnesses being intimidated
IMMEDIATE INTERVENTION NEEDED:
- Ongoing criminal enterprise
- New federal crimes daily
- Evidence at risk
- Victims suffering harm
- Criminal proceeds growing
PART VIII: PROSECUTION RECOMMENDATIONS
IMMEDIATE ACTIONS:
1. Open RICO investigation
2. Subpoena all records
3. Freeze bank accounts
4. Interview witnesses
5. Grand jury subpoenas
CHARGES TO FILE:
- 1,200+ counts mail fraud
- 600+ counts wire fraud
- RICO enterprise
- RICO conspiracy
- Money laundering
- Obstruction
TARGETS FOR ARREST:
Priority 1: Tristan Ansell, Emily Rapp
Priority 2: Daniel Ramey, Guillaume Chabot-Couture
Priority 3: Jay Shaver, Levi Cox
ASSET FORFEITURE:
- HOA bank accounts
- Personal assets (RICO)
- Substitute assets
- Criminal proceeds
PART IX: RELATED INVESTIGATIONS
POTENTIAL ADDITIONAL CHARGES:
- Tax fraud (IRS-CI)
- Bank fraud
- Honest services fraud
- False statements
- Identity theft
- Extortion
OTHER AGENCIES TO NOTIFY:
- IRS Criminal Investigation
- US Postal Inspection Service
- Treasury (FinCEN)
- Washington Attorney General
- State banking regulators
PART X: DECLARANT INFORMATION
I am a victim of this criminal enterprise and willing to:
- Testify before grand jury
- Provide additional evidence
- Assist in investigation
- Identify other victims
- Serve as case witness
Name: [YOUR NAME]
Address: [YOUR ADDRESS]
Phone: [YOUR PHONE]
Email: [YOUR EMAIL]
Amount stolen from me: $[AMOUNT]
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on [DATE].
_______________________
Signature
URGENT: This criminal enterprise commits new federal felonies daily. Each day of delay = 50+ new federal crimes. Immediate action requested to prevent further victimization.
Attachments available at: https://chelanvistaheights.com
📞 FBI CONTACT INFORMATION
FBI Seattle Field Office: (206) 622-0460
FBI Tips Online: tips.fbi.gov
FBI White Collar Crime: 1-800-CALL-FBI
Address: 1110 3rd Avenue, Seattle, WA 98101
What Happens Next:
FBI will review within 24-48 hours
May contact you for additional information
Will coordinate with US Attorney
Grand jury subpoenas likely
US ATTORNEY - EASTERN DISTRICT OF WASHINGTON
Request for Immediate Federal Criminal Prosecution
⚖️
FEDERAL PROSECUTION AUTHORITY
Venue: Eastern District of Washington - Proper venue under 18 U.S.C. § 3237
Jurisdiction: Federal crimes affecting interstate commerce
Sentencing: Life imprisonment possible under guidelines
DEFENDANTS FOR IMMEDIATE INDICTMENT
Tristan Ansell - Lead Defendant
Role: HOA Secretary, Scheme Orchestrator
Crimes: 1,800+ counts fraud, RICO, conspiracy
Evidence: Signed documents, email chains
Exposure: Life imprisonment
Emily Rapp - Co-Conspirator
Role: Board Member, Enforcer
Crimes: Wire fraud, mail fraud, RICO
Evidence: Board votes, intimidation
Exposure: 20+ years federal prison
Additional Defendants:
Daniel Ramey - Vice President
Guillaume Chabot-Couture - Treasurer
Jay Shaver - Former President
Levi Cox - Former Board
TO: United States Attorney
Eastern District of Washington
Thomas S. Foley U.S. Courthouse
920 W. Riverside Avenue, Suite 340
Spokane, WA 99201
Phone: (509) 353-2767
Fax: (509) 353-2766
TO: Criminal Division Chief
TO: White Collar Crime Unit
RE: REQUEST FOR IMMEDIATE FEDERAL CRIMINAL PROSECUTION
United States v. Ansell, et al. (Proposed)
RICO Enterprise - 1,800+ Federal Felonies
Dear United States Attorney:
Pursuant to DOJ prosecution guidelines, I respectfully request immediate federal criminal prosecution of a RICO enterprise operating as "Chelan Vista Heights HOA" that has victimized 50+ citizens through an ongoing mail/wire fraud scheme.
I. EXECUTIVE SUMMARY
This case presents an ideal federal prosecution:
- Clear federal jurisdiction (mail/wire fraud)
- 1,800+ documented felonies
- 50+ victims across community
- $30,671+ in provable losses
- Ongoing daily criminal activity
- Complete documentary evidence
- Willing victim witnesses
- No complex legal issues
- Straightforward jury appeal
II. DEFENDANTS FOR INDICTMENT
PRIMARY DEFENDANTS (RICO Enterprise):
1. Tristan Ansell - 18 U.S.C. §§ 1341, 1343, 1962(c), 1962(d), 371
2. Emily Rapp - 18 U.S.C. §§ 1341, 1343, 1962(c), 1962(d), 371
3. Daniel Ramey - 18 U.S.C. §§ 1341, 1343, 1962(d), 371
4. Guillaume Chabot-Couture - 18 U.S.C. §§ 1341, 1343, 1956, 371
5. Jay Shaver - 18 U.S.C. §§ 1341, 1343, 371
6. Levi Cox - 18 U.S.C. §§ 1341, 1343, 371
III. CHARGES TO FILE
COUNT ONE: RICO - 18 U.S.C. § 1962(c)
The defendants conducted the affairs of an enterprise through a pattern of racketeering activity consisting of:
- 1,200+ acts of mail fraud
- 600+ acts of wire fraud
- Multiple acts of extortion
- Money laundering
COUNT TWO: RICO Conspiracy - 18 U.S.C. § 1962(d)
The defendants conspired to violate § 1962(c)
COUNTS THREE-1,203: Mail Fraud - 18 U.S.C. § 1341
Each mailing = separate count (representative sampling acceptable)
COUNTS 1,204-1,804: Wire Fraud - 18 U.S.C. § 1343
Each electronic transmission = separate count
COUNT 1,805: Conspiracy - 18 U.S.C. § 371
Conspiracy to commit mail and wire fraud
COUNTS 1,806+: Money Laundering - 18 U.S.C. § 1956
Each transaction of criminal proceeds
IV. STATEMENT OF FACTS
A. THE SCHEME TO DEFRAUD
Beginning in April 2023, defendants devised a scheme to defraud homeowners by:
1. Recognizing they lacked valid bylaws (NO voting records exist)
2. Spending $10,671 in HOA funds on attorneys (unauthorized)
3. Having attorneys draft bylaws favoring board power
4. "Unanimously passing" bylaws without ANY member vote
5. Using fake bylaws to increase assessments
6. Collecting increased amounts through mail/wire
7. Threatening foreclosure for non-payment
8. Concealing the lack of member approval
B. USE OF MAILS AND WIRES
1. MAIL FRAUD EXECUTIONS:
- Annual assessment notices via USPS
- 50 homeowners × 24 months = 1,200 mailings
- Each mailing claimed false authority
- Threats of liens sent via mail
2. WIRE FRAUD EXECUTIONS:
- PayHOA electronic payment system (2022-present)
- Email demands for payment
- Online banking transfers
- Website payment portal
C. THE CRIMINAL ENTERPRISE
1. ENTERPRISE STRUCTURE:
- Legal entity: Chelan Vista Heights HOA
- Association-in-fact: Board conspiracy
- Interstate nexus: Mail/wire/banking
- Common purpose: Illegal extraction
2. PATTERN OF RACKETEERING:
- Relatedness: All acts further scheme
- Continuity: 2+ years, ongoing
- Multiple predicates: 1,800+ acts
- Threat of continuation: Annual billing cycles
V. EVIDENCE FOR TRIAL
A. DOCUMENTARY EVIDENCE
1. Financial Records:
- Check #[number] for $10,671 to law firm
- Bank statements showing deposits
- PayHOA transaction logs (2022-2024)
- Wire transfer confirmations
2. Corporate Documents:
- April 26, 2023 fake bylaws
- Board minutes showing conspiracy
- Absence of voting records (critical)
- False annual reports
3. Fraud Instruments:
- Assessment notices (mail fraud)
- Email demands (wire fraud)
- Threat letters
- Website screenshots
B. TESTIMONIAL EVIDENCE
1. Victim Witnesses:
- 50+ homeowners ready to testify
- Financial harm testimony
- Emotional distress evidence
- Pattern testimony
2. Expert Witnesses:
- HOA governance expert
- Forensic accountant
- Document examiner
- Banking expert
C. ABSENCE EVIDENCE
The most powerful evidence is what DOESN'T exist:
- ZERO voting ballots
- NO quorum certifications
- NO member notices
- NO election records
VI. VENUE AND JURISDICTION
VENUE PROPER IN EDWA:
- Crimes occurred in Chelan County
- Mailings processed in Spokane
- Victims reside in district
- Defendants operate in district
FEDERAL JURISDICTION:
- Interstate mail system
- Interstate wire communications
- Federal banking system
- Amount exceeds $5,000
VII. PROSECUTION MERITS
WHY THIS CASE MERITS FEDERAL PROSECUTION:
1. DETERRENCE VALUE:
- HOA fraud is widespread
- Sets precedent
- Protects elderly victims
- Prevents copycat crimes
2. FEDERAL INTEREST:
- Interstate commerce affected
- Mail/wire systems abused
- 50+ victims
- Ongoing enterprise
3. RESOURCE EFFICIENCY:
- Documentary case
- Clear evidence
- Willing witnesses
- No complex issues
4. JURY APPEAL:
- Sympathetic victims
- Clear fraud
- Abuse of power
- David vs. Goliath
VIII. SENTENCING CONSIDERATIONS
GUIDELINES CALCULATION:
- Base offense level: 7
- Loss amount ($30,671): +8
- 50+ victims: +4
- Sophisticated means: +2
- Abuse of trust: +2
- Obstruction: +2
- Total: Level 25 (57-71 months)
WITH MULTIPLE COUNTS:
- Consecutive sentences possible
- Life imprisonment achievable
- Mandatory restitution
- Criminal forfeiture
IX. IMMEDIATE ACTION NEEDED
ONGOING CRIMES:
- New mail fraud annually
- New wire fraud daily
- Evidence being destroyed
- Witnesses intimidated
- Proceeds growing
REQUESTED ACTIONS:
1. Open grand jury investigation
2. Issue preservation letters
3. Subpoena records immediately
4. Interview key witnesses
5. Seek indictment within 30 days
X. CONCLUSION
This case presents a straightforward federal prosecution with overwhelming evidence, clear federal jurisdiction, and significant deterrent value. The defendants operate a criminal enterprise that commits new federal felonies daily.
The complete evidence package is available at:
https://chelanvistaheights.com
I am available to meet with AUSAs immediately and have additional victims ready to cooperate.
Respectfully submitted,
[YOUR NAME][YOUR ADDRESS][YOUR PHONE][YOUR EMAIL]
Victim of Federal Crimes
cc: FBI Seattle Field Office
US Postal Inspection Service
IRS Criminal Investigation
Policy Language: "Coverage excluded for fraudulent acts by insured"
Violation: Board committed systematic fraud:
Spent $10,671 without authorization (fraud)
Created fake bylaws (document fraud)
Claimed false authority (misrepresentation)
Collected unauthorized fees (theft by deception)
Impact:ALL COVERAGE VOID
SECTION IX.B - APPLICATION WARRANTIES
Policy Language: "Application representations are warranties"
Application Likely Stated:
✓ Proper governance procedures followed
✓ Required records maintained
✓ Member voting conducted
✓ Compliance with laws
ACTUAL FACTS:
✗ NO voting records exist (ZERO)
✗ 97% of minutes missing
✗ NO valid bylaws
✗ Criminal enterprise operation
Impact:POLICY VOIDABLE AB INITIO
SECTION VII.A - 90-DAY NOTICE REQUIREMENT
Policy Language: "Notice within 90 days of discovering wrongful act"
Unreported Wrongful Acts:
April 2023: $10,671 unauthorized payment (600+ days ago)
April 2023: Fake bylaw adoption (600+ days ago)
2018-2023: Missing records (2,000+ days)
July 2025: Member complaints (120+ days)
Impact:NO COVERAGE FOR ANY CLAIMS
PRIOR ACTS DATE: 8/9/2021
Policy Language: "No coverage for acts before 8/9/2021"
Pre-2021 Violations:
2020: Entire year of records missing
2018-2021: Financial irregularities
2003-2021: No valid bylaws
Pre-2021: Pattern of violations
Impact:MOST CLAIMS EXCLUDED
INSURANCE COMPANY'S EXPOSURE CALCULATION
Coverage Line
Policy Limit
At Risk
D&O Coverage
$2,000,000
$2,000,000
General Liability
$3,000,000
$0 (fraud)
Cyber Coverage
$250,000
$250,000
Crime Coverage
$100,000
$0 (excluded)
TOTAL EXPOSURE
$5,350,000
$0-$2,250,000
TO: Berkley Program Specialists / StarNet Insurance Company
Claims Department
Email: claims59@berkley-ps.com
Phone: (888) 417-9882
Fax: (888) 467-5515
CC: Underwriting Department
CC: Legal Department
CC: Special Investigations Unit
RE: URGENT - FRAUD NOTIFICATION & COVERAGE INVESTIGATION
Policy Number: QDO0009701-00
Insured: Chelan Vista Heights Owners Association
Policy Period: Current
Prior Acts Date: 8/9/2021
SENT VIA: Email, Certified Mail #[TRACKING NUMBER]
Dear Claims Manager:
Pursuant to your policy's fraud notification requirements and my duty to report criminal acts by the insured, this letter serves as formal notice of systematic fraud, material misrepresentations, and criminal activity that voids coverage under multiple policy provisions.
I. IMMEDIATE ACTION REQUIRED
This notification triggers your duty to:
1. Issue immediate reservation of rights letter
2. Investigate application fraud
3. Review coverage validity
4. Consider policy rescission
5. Report to state insurance commissioner
6. Notify reinsurers
II. FRAUDULENT ACTS BY INSURED (Policy Section IV.A)
The insured's board has committed deliberate fraud:
A. THE $10,671 FRAUD SCHEME
Date: April 2023
Perpetrators: Board members Jay Shaver, Emily Rapp, Levi Cox
Scheme Details:
1. Board knew they had NO valid bylaws (zero voting records exist)
2. Spent $10,671 of HOA funds on attorneys WITHOUT authorization
3. Attorneys drafted bylaws to increase board power
4. Board "unanimously passed" bylaws with NO member vote
5. Used fake bylaws to collect increased assessments
Evidence:
- Financial records showing $10,671 payment
- Board minutes showing unanimous board-only vote
- ZERO voting ballots (insured admits none exist)
- No member notices or ballots ever created
This constitutes:
- Theft by deception (RCW 9A.56)
- Wire fraud (18 U.S.C. § 1343)
- Mail fraud (18 U.S.C. § 1341)
- Forgery (RCW 9A.60)
B. ONGOING FRAUDULENT COLLECTION
- Collecting $500/year when only $300 authorized
- NO valid bylaws support this amount
- Using mail and wire to collect
- Threatening liens without authority
Annual excess collected: $200 × 50 homes = $10,000/year
Annual fraud: $120,000
COVERAGE IMPACT: Fraudulent acts exclusion voids ALL coverage
III. APPLICATION MISREPRESENTATIONS (Policy Section IX.B)
Your application required representations about:
A. GOVERNANCE REPRESENTATIONS (Likely Made)
☐ "HOA follows proper governance procedures"
☐ "Board decisions properly authorized"
☐ "Member voting conducted as required"
☐ "Bylaws properly adopted"
B. ACTUAL FACTS (Concealed)
☐ NO valid bylaws exist (ZERO voting records)
☐ Board operates without member consent
☐ 97% of board meeting minutes missing
☐ No proper elections documented
C. RECORDS REPRESENTATIONS (Likely Made)
☐ "Required records maintained"
☐ "Financial records available"
☐ "Meeting minutes kept"
☐ "Compliance with laws"
D. ACTUAL FACTS (Concealed)
☐ 97% of minutes missing/destroyed
☐ ZERO voting records exist
☐ 85% non-compliance with records laws
☐ Systematic destruction/concealment
These misrepresentations are material because:
- You would not have issued the policy
- Premium would have been different
- Coverage would have been excluded
- Application fraud voids policy ab initio
COVERAGE IMPACT: Policy voidable from inception
IV. FAILURE TO REPORT WRONGFUL ACTS (Policy Section VII.A)
Policy requires notice within 90 days of discovering wrongful acts.
UNREPORTED WRONGFUL ACTS:
1. April 26, 2023: Fake bylaw adoption (600+ days ago)
2. June 26, 2023: False resolution (550+ days ago)
3. 2018-Present: Missing financial records (2,000+ days)
4. 2020: Entire year of records missing (1,800+ days)
5. July 30, 2025: Records request violations (120+ days)
The insured knew or should have known of these acts but failed to notify you.
COVERAGE IMPACT: No coverage for any claims
V. PRIOR ACTS EXCLUSION (Policy Item 8: 8/9/2021)
Wrongful acts predating 8/9/2021:
- 2020: Complete absence of records
- 2018-2021: Missing financials
- 2003-2021: No valid governance
- Pre-2021: Pattern of violations
Evidence shows systematic violations before prior acts date.
COVERAGE IMPACT: Most claims excluded
VI. CRIMINAL ACTS EXCLUSION
Insured has committed multiple crimes:
FEDERAL CRIMES:
- Mail fraud (18 U.S.C. § 1341) - 20 years
- Wire fraud (18 U.S.C. § 1343) - 20 years
- RICO violations (18 U.S.C. § 1962)
- Conspiracy (18 U.S.C. § 371)
STATE CRIMES:
- Theft 1st Degree (RCW 9A.56.030)
- Forgery (RCW 9A.60.020)
- Filing false documents (RCW 23.95.255)
Criminal acts exclusion voids coverage.
COVERAGE IMPACT: No coverage for criminal acts
VII. BREACH OF CONTRACT - COOPERATION CLAUSE
Insured has breached duty to cooperate:
- Destroying/hiding records
- Failing to maintain documentation
- Concealing wrongful acts
- Obstructing investigation
COVERAGE IMPACT: Coverage void for breach
VIII. CYBER LIABILITY ISSUES ($250,000 Coverage)
Insured's failure to maintain records creates cyber exposure:
- No documentation of data protection
- Missing member information
- No security protocols documented
- Potential data breach liability
Your cyber coverage requires compliance that insured cannot demonstrate.
IX. EVIDENCE PACKAGE AVAILABLE
Complete documentation available at:
https://chelanvistaheights.com
Includes:
- 56 HOA-provided documents
- Financial records showing fraud
- Analysis of violations
- Your complete policy document
- Timeline of criminal acts
X. DAMAGES AND EXPOSURE
CURRENT CLAIMS POTENTIAL:
- 50+ homeowners preparing lawsuits
- $24,952 per homeowner claimed
- Total exposure: $1,247,600
- Criminal prosecution pending
- Regulatory investigations active
YOUR POTENTIAL LIABILITY:
- D&O limit: $2,000,000
- Cyber limit: $250,000
- Defense costs: $500,000+
- Bad faith exposure: Unlimited
XI. REQUIRED INSURER ACTIONS
Under Washington law and policy terms, you must:
1. IMMEDIATE (Within 24-48 hours):
- Issue reservation of rights
- Begin fraud investigation
- Preserve all records
- Notify reinsurers
2. WITHIN 10 DAYS:
- Demand complete documentation
- Interview insured under oath
- Review application file
- Determine coverage position
3. WITHIN 30 DAYS:
- Complete investigation
- Make coverage determination
- Consider rescission
- Report to regulators if warranted
XII. REGULATORY NOTIFICATIONS
Consider reporting to:
- Washington Insurance Commissioner: 800-562-6900
- National Insurance Crime Bureau: 800-835-6422
- State Attorney General: 800-551-4636
XIII. CONCLUSION
The insured operates as a criminal enterprise, has committed systematic fraud, made material misrepresentations in its application, failed to report wrongful acts, and breached multiple policy provisions. Coverage should be denied for all claims, and the policy should be rescinded ab initio.
Time is critical as new claims are imminent and criminal prosecution is likely. Your immediate investigation will protect your coverage position and avoid bad faith claims.
I am available to provide additional evidence and testimony as needed.
Sincerely,
[YOUR NAME][YOUR ADDRESS][YOUR PHONE][YOUR EMAIL]
HOA Member and Crime Victim
cc: Washington Office of Insurance Commissioner
800-562-6900
www.insurance.wa.gov/complaints
cc: National Insurance Crime Bureau
800-TEL-NICB
cc: Chelan Vista Heights HOA Board
(Notice of coverage issues)
ENCLOSURES:
☐ Evidence links
☐ Timeline of fraud
☐ Financial documentation
☐ Board minutes
☐ Analysis reports
NOTICE: This communication may trigger immediate policy implications. Failure to promptly investigate may constitute bad faith under Washington law.
🚨 IMMEDIATE ACTION REQUIRED 🚨
Every day of delay = 50+ new federal crimes
Board members face LIFE IN FEDERAL PRISON
Share this link with ALL homeowners NOW: chelanvistaheights.com/quick-action-emails-ultra-detailed.html
📋 SECRETARY OF STATE - NONPROFIT FRAUD COMPLAINT (ULTRA-DETAILED)
⚖️
⚖️ WASHINGTON SECRETARY OF STATE - CORPORATIONS DIVISION ⚖️
CORPORATE FRAUD • FALSE FILINGS • NONPROFIT VIOLATIONS
DISSOLUTION & CRIMINAL REFERRAL AUTHORITY
To: corps@sos.wa.gov
Cc: steve.hobbs@sos.wa.gov; corporations@sos.wa.gov
Subject: URGENT: Criminal Corporate Fraud - Chelan Vista Heights HOA (UBI 602557940) - Request Immediate Dissolution & Criminal Referral
Dear Secretary of State Hobbs and Corporations Division:
I am filing this formal complaint demanding immediate investigation, dissolution, and criminal prosecution referral for Chelan Vista Heights Homeowners Association (UBI: 602557940) for massive corporate fraud, false filings, and criminal violations of Washington's Nonprofit Corporation Act.
PART I: CORPORATE IDENTITY & JURISDICTION
ENTITY INFORMATION:
- Legal Name: CHELAN VISTA HEIGHTS HOMEOWNERS ASSOCIATION
- UBI Number: 602557940
- Entity Type: Nonprofit Corporation
- Status: Active (FRAUDULENTLY)
- Incorporation: July 18, 2002
- Dissolution: 2003 (HIDDEN)
- Reinstatement: 2003 (ILLEGAL - NO VOTE)
- Principal Office: 3870 Spring Ln, Wenatchee, WA 98801
YOUR JURISDICTION INCLUDES:
- RCW 24.03A - Washington Nonprofit Corporation Act
- RCW 23.95 - Uniform Business Organizations Code
- RCW 19.09 - Charitable Solicitations Act
- RCW 9A.60 - Fraud and False Statements
- Administrative dissolution authority
- Criminal referral powers
PART II: THE DISSOLUTION FRAUD SCHEME
PHASE 1: ORIGINAL DISSOLUTION (2003)
The HOA was legally dissolved in 2003 according to corporate records. This dissolution terminated:
- All corporate authority
- All governing documents
- All board positions
- All collection powers
- All lien authority
PHASE 2: ILLEGAL REINSTATEMENT (2003)
The corporation was supposedly "reinstated" in 2003, BUT:
- ZERO member vote occurred
- NO quorum was obtained
- NO ballots were distributed
- NO notices were sent
- NO records exist of ANY vote
- Violates RCW 24.03A.460 (2/3 vote required)
PHASE 3: 20 YEARS OF FRAUD (2003-2023)
For 20 years, this illegally reinstated corporation:
- Filed false annual reports
- Collected unauthorized dues
- Recorded illegal liens
- Conducted fake elections
- Submitted fraudulent filings
PHASE 4: THE $10,671 CONSPIRACY (2023)
In April 2023, knowing they lacked legal bylaws:
- Board hired lawyers for $10,671
- NO authorization from members
- Lawyers created self-serving bylaws
- Board "passed" without ANY member vote
- Created false corporate records
PART III: FALSE FILINGS TO YOUR OFFICE
ANNUAL REPORT FRAUD (2003-2024):
Every annual report filed since 2003 contains false statements:
1. FALSE CLAIM: "Corporation is in good standing"
TRUTH: Illegally reinstated, no valid governance
2. FALSE CLAIM: "Officers duly elected"
TRUTH: No valid elections without bylaws
3. FALSE CLAIM: "Operating under corporate bylaws"
TRUTH: NO bylaws legally adopted EVER
4. FALSE CLAIM: "Authorized to conduct business"
TRUTH: No authority since 2003 dissolution
Each false filing = separate felony under RCW 9A.60.040
SPECIFIC FALSE FILINGS:
- 2023 Annual Report: Claims valid board (FALSE)
- 2023 Bylaw Filing: Claims member approval (FALSE)
- 2024 Annual Report: Claims legal authority (FALSE)
- Every report 2003-2024: Material misrepresentations
PART IV: NONPROFIT ACT VIOLATIONS
RCW 24.03A VIOLATIONS:
1. RCW 24.03A.460 - Amendment of Bylaws
- Requires 2/3 member vote
- ZERO votes obtained
- Felony false swearing
2. RCW 24.03A.220 - Member Voting Rights
- Members denied ALL voting rights
- 20+ years of disenfranchisement
- Fundamental breach
3. RCW 24.03A.280 - Quorum Requirements
- NO quorum ever obtained
- Every action void
- Knowing violations
4. RCW 24.03A.830 - Breach of Duties
- Fiduciary duty violations
- Self-dealing ($10,671)
- Waste of assets
5. RCW 24.03A.952 - Grounds for Dissolution
- Exceeded corporate authority
- Fraudulent procurement
- Abuse of authority
PART V: CRIMINAL VIOLATIONS
WASHINGTON CRIMINAL CODE VIOLATIONS:
RCW 9A.60.040 - FALSE SWEARING
- Every annual report = false swearing
- 20+ counts (2003-2024)
- Class B felony each
RCW 9A.56.030 - THEFT FIRST DEGREE
- $10,671 stolen for lawyers
- $30,000+ in unauthorized dues
- Class B felony
RCW 9A.60.020 - FORGERY
- Forged corporate resolutions
- False bylaw adoption records
- Class C felony
RCW 9A.72.080 - FALSE STATEMENTS
- To public servants (SOS office)
- Material misrepresentations
- Gross misdemeanor each
FEDERAL CRIMES (Your Referral Authority):
- 18 U.S.C. § 1341 - Mail Fraud (20 years)
- 18 U.S.C. § 1343 - Wire Fraud (20 years)
- 18 U.S.C. § 1961 - RICO (20 years)
- 18 U.S.C. § 371 - Conspiracy (5 years)
PART VI: THE CORPORATE RECORDS VOID
MISSING MANDATORY RECORDS:
Your office requires maintenance of:
1. VOTING RECORDS (RCW 24.03A.960):
- ZERO ballots exist for ANY vote EVER
- No proxies
- No quorum certificates
- No vote tallies
- NOTHING
2. MEMBER LISTS (RCW 24.03A.960):
- No accurate member roster
- No voting eligibility list
- No contact records
- Violates inspection rights
3. MEETING MINUTES (RCW 24.03A.960):
- No member meeting minutes
- Fake board minutes
- No annual meeting records
- 20 years missing
4. FINANCIAL RECORDS:
- No authorization for $10,671
- No member approval records
- Hidden transactions
- Destroyed evidence
INSPECTION RIGHTS VIOLATED:
- Members denied ALL access
- "No records exist" admissions
- Active concealment
- Obstruction of rights
PART VII: IMMEDIATE ACTIONS REQUIRED
1. EMERGENCY ADMINISTRATIVE DISSOLUTION
Under RCW 24.03A.952, immediately dissolve for:
- Exceeded powers
- Fraudulent acts
- Failed to maintain records
- False filings
2. CRIMINAL REFERRAL PACKAGE
Refer to prosecutors:
- 20+ counts false swearing
- Grand theft ($40,671+)
- Forgery and fraud
- RICO enterprise
3. CEASE AND DESIST ORDER
Immediately prohibit:
- All collections
- All enforcement
- All operations
- Asset transfers
4. ASSET FREEZE
Secure all accounts:
- Bank accounts
- PayHOA accounts (active 2022-present)
- Reserve funds
- Pending collections
5. VICTIM RESTITUTION
Order return of:
- $10,671 unauthorized payment
- All 2023-2024 collections
- All penalties/late fees
- Interest and damages
PART VIII: EVIDENCE PACKAGE
DOCUMENTARY EVIDENCE:
1. Complete fraud documentation: https://chelanvistaheights.com
2. 56 HOA documents showing fraud
3. Financial analysis proving theft
4. Timeline of corporate crimes
5. Absence of voting records (NONE EXIST)
KEY DOCUMENTS ATTACHED:
- April 26, 2023 fake "bylaw adoption"
- June 26, 2023 false "resolution"
- Bank records of $10,671 theft
- Member testimony of no vote
- Annual reports with false statements
WITNESS TESTIMONY AVAILABLE:
- 50+ homeowners confirming NO vote
- Board members' contradictory statements
- Documentary evidence of fraud
- Pattern of deception proven
PART IX: ONGOING HARM & URGENCY
CONTINUING DAILY CRIMES:
- Still collecting fraudulent dues
- Still threatening illegal liens
- Still filing false reports
- New victims annually
- Evidence being destroyed
VICTIM IMPACT:
- 50+ homeowners defrauded
- $600+ stolen per household
- Elderly on fixed incomes
- Foreclosure threats
- Credit damage
PUBLIC INTEREST:
- Nonprofit fraud undermines system
- False filings corrupt records
- Other HOAs copying scheme
- Public trust destroyed
PART X: LEGAL MANDATE FOR ACTION
Your office has NON-DISCRETIONARY DUTY to act when:
1. False filings discovered (✓)
2. Criminal activity reported (✓)
3. Nonprofit law violated (✓)
4. Public harm occurring (✓)
5. Evidence provided (✓)
STATUTORY AUTHORITY:
- RCW 24.03A.952: "SHALL dissolve"
- RCW 43.07.120: Criminal referral powers
- RCW 23.95.610: Corrective action mandate
- RCW 19.09.430: Enforcement authority
FAILURE TO ACT = LIABILITY:
- Negligent supervision
- Enabling continued fraud
- 42 U.S.C. § 1983 claims
- Mandamus action available
CONCLUSION:
This is not a dispute - this is CRIMINAL FRAUD. A corporation dissolved in 2003, illegally reinstated without ANY member vote, has stolen $40,671+ while filing 20 years of false reports to your office. They openly admit NO voting records exist because NO VOTES OCCURRED.
Every day you delay:
- More false filings submitted
- More victims defrauded
- More evidence destroyed
- More crimes committed
I demand immediate action within 10 business days or I will:
1. File criminal complaints with DOJ
2. Report to State Auditor
3. Contact media
4. Initiate mandamus action
5. File taxpayer derivative suit
Time is of the essence. Act NOW.
[Your name]
[Your address]
[Your phone]
[Date]
cc: Washington Attorney General Bob Ferguson
cc: Chelan County Prosecuting Attorney
cc: FBI Seattle Office
cc: US Attorney, Eastern District of Washington
cc: Washington State Auditor
cc: Governor Jay Inslee
cc: State Representatives
cc: Media Outlets
⚖️ ATTORNEY GENERAL - CONSUMER FRAUD COMPLAINT (ULTRA-DETAILED)
🏛️
🏛️ WASHINGTON ATTORNEY GENERAL - CONSUMER PROTECTION 🏛️
CONSUMER FRAUD • UNFAIR PRACTICES • CRIMINAL PROSECUTION
CIVIL PENALTIES UP TO $500,000 + CRIMINAL CHARGES
To: emailago@atg.wa.gov
Cc: bob.ferguson@atg.wa.gov; consumer@atg.wa.gov
Subject: URGENT: Criminal Consumer Fraud - Chelan Vista Heights HOA - $40,671+ Theft Scheme - Immediate Action Required
Dear Attorney General Ferguson:
I am filing this urgent consumer protection complaint requesting immediate civil and criminal action against Chelan Vista Heights HOA for operating a sophisticated fraud scheme that has stolen $40,671+ from homeowners through violations of the Consumer Protection Act, criminal theft statutes, and federal fraud laws.
PART I: JURISDICTION & AUTHORITY
YOUR ENFORCEMENT POWERS:
- RCW 19.86 - Consumer Protection Act
- RCW 64.38 - Homeowners' Association Act
- RCW 9A.56 - Theft and Robbery
- RCW 9A.60 - Fraud
- Parens Patriae authority
- Criminal prosecution powers
- Civil investigative demands
- Asset freeze authority
DEFENDANTS:
- Chelan Vista Heights HOA
- Board Members (individually)
- KSB Law Group (conspirators)
- PayHOA, Inc. (facilitator)
VICTIMS:
- 50+ homeowners
- Public at large
- Future purchasers
- Mortgage lenders
PART II: THE CONSUMER FRAUD SCHEME
THE SETUP - ILLEGAL CORPORATE STRUCTURE:
Historical Foundation:
- 2002: HOA incorporated
- 2003: HOA DISSOLVED
- 2003: Illegally "reinstated" with ZERO member vote
- 2003-2023: Operated without valid bylaws
- 2023: Spent $10,671 on lawyers to create fake bylaws
The Consumer Deception:
Every homeowner was told:
- HOA has legal authority (FALSE)
- Dues are mandatory (FALSE)
- Bylaws were voted on (FALSE)
- Board was elected (FALSE)
- Liens are valid (FALSE)
PART III: CONSUMER PROTECTION ACT VIOLATIONS
RCW 19.86.020 - UNFAIR OR DECEPTIVE ACTS:
1. FALSE REPRESENTATION OF AUTHORITY
- Claimed legal right to collect
- No valid corporate existence
- No legitimate bylaws
- Concealed dissolution
2. DECEPTIVE BILLING PRACTICES
- Sent fraudulent invoices
- Claimed $500 dues "required"
- Only $300 authorized (if any)
- Added fake late fees
3. FRAUDULENT LIEN THREATS
- Threatened foreclosure
- No legal lien rights
- Extortion via fear
- Damaged credit
4. CONCEALMENT OF MATERIAL FACTS
- Hid that HOA was dissolved
- Concealed no-vote on bylaws
- Refused records requests
- Destroyed evidence
5. BAIT AND SWITCH
- Promised community benefits
- Delivered only threats
- Changed terms unilaterally
- No services provided
PER SE VIOLATIONS:
- Violates RCW 64.38 (HOA Act)
- Violates RCW 24.03A (Nonprofit Act)
- Violates RCW 9A.56 (Theft)
- Each violation = CPA violation
PART IV: CRIMINAL VIOLATIONS
WASHINGTON CRIMINAL CODE:
RCW 9A.56.030 - THEFT IN THE FIRST DEGREE
- Stole $40,671+ total
- Class B felony
- 10 years prison
- Pattern of theft
RCW 9A.56.280 - CREDIT CARD FRAUD
- Unauthorized PayHOA charges
- Electronic theft
- Wire fraud predicate
- Class C felony
RCW 9A.60.040 - FALSE SWEARING
- False corporate filings
- Fake bylaw attestations
- Fraudulent resolutions
- Class B felony each
RCW 9A.82 - CRIMINAL PROFITEERING
- Pattern of crimes
- Economic gain
- Ongoing enterprise
- State RICO
FEDERAL CRIMES (Referral Required):
- Mail Fraud: 1,200+ counts
- Wire Fraud: 600+ counts
- RICO: 20-year conspiracy
- Money Laundering: $40,671+
PART V: THE $10,671 SMOKING GUN
THE UNAUTHORIZED LEGAL SPEND:
Timeline of Theft:
- January 2023: Board realizes no valid bylaws
- February 2023: Secret board meetings
- March 2023: Contact KSB Law Group
- April 2023: Sign contract (no authority)
- April 2023: Pay $10,671 (no vote)
- April 26, 2023: "Pass" bylaws (no quorum)
The Conspiracy:
1. Board knew no bylaws existed
2. Board knew member vote required
3. Board hired lawyers anyway
4. Lawyers knew vote required
5. All created false records
Consumer Harm:
- $10,671 stolen from reserves
- Used to reduce member rights
- Created oppressive bylaws
- Increased board power
- Eliminated oversight
PART VI: ONGOING CONSUMER HARM
FINANCIAL DAMAGE:
Direct Theft:
- $10,671: Unauthorized legal fees
- $10,000: Excess dues (2023-2024)
- $10,000: Prior year overcharges
- $10,000+: Penalties and fees
- $40,671+: Total direct theft
Consequential Damages:
- Credit score damage
- Mortgage complications
- Property value impact
- Emotional distress
- Time and expense
PER-VIOLATION PENALTIES:
- 50 homeowners x 20 years = 1,000 violations
- $2,000 per violation = $2,000,000
- Treble damages = $6,000,000
- Plus attorney fees
VULNERABLE POPULATIONS:
- Elderly on fixed incomes
- Spanish-speaking residents
- First-time homeowners
- Military families
- Disabled residents
PART VII: PATTERN OF DECEPTION
DOCUMENT FRAUD:
- Fake bylaws (April 26, 2023)
- False resolution (June 26, 2023)
- Fraudulent minutes
- Forged approvals
- Backdated records
CONCEALMENT TACTICS:
- Refuse record requests
- Claim "no records exist"
- Destroy evidence
- Intimidate questioners
- Threaten legal action
ADMISSION OF GUILT:
Board has admitted:
- NO voting records exist
- NO ballots ever created
- NO member notices sent
- NO quorum ever obtained
- Operating on "pretenses"
PART VIII: UNFAIR BUSINESS PRACTICES
MONOPOLY ABUSE:
- Mandatory membership claimed
- No competitive choice
- Captive consumers
- Price fixing ($500)
- Tied arrangements
EXTORTION TACTICS:
- Pay or face liens
- Pay or lose home
- Pay or credit damage
- Pay or legal action
- Economic duress
FALSE ADVERTISING:
- Website claims legitimacy
- Notices claim authority
- Statements misrepresent
- Omit material facts
- Deceive consumers
PART IX: IMMEDIATE RELIEF REQUIRED
1. TEMPORARY RESTRAINING ORDER
- Stop all collections
- Freeze bank accounts
- Prohibit liens
- Preserve records
2. PRELIMINARY INJUNCTION
- Void all bylaws
- Cancel all debts
- Release all liens
- Restore status quo
3. CIVIL INVESTIGATIVE DEMAND
- All financial records
- All voting records (none exist)
- All communications
- Board depositions
4. CRIMINAL REFERRAL
- Theft first degree
- Criminal profiteering
- Federal fraud charges
- RICO prosecution
5. RESTITUTION ORDER
- Return $40,671+
- Interest and penalties
- Treble damages
- Attorney fees
6. RECEIVERSHIP
- Appoint receiver
- Take control
- Audit finances
- Distribute assets
PART X: EVIDENCE OF FRAUD
DOCUMENTARY PROOF:
1. Complete evidence: https://chelanvistaheights.com
2. 56 HOA documents
3. Financial records
4. Fake bylaws
5. Missing voting records
SPECIFIC EVIDENCE:
- Bank statements: $10,671 payment
- PayHOA records: Unauthorized charges
- Board minutes: Conspiracy evidence
- Email chains: Intent proof
- Website: False claims
WITNESS TESTIMONY:
- 50+ victims ready
- Board admissions recorded
- Expert witnesses available
- Pattern evidence clear
PART XI: PUBLIC INTEREST FACTORS
WIDESPREAD IMPACT:
- Affects all HOA members
- Sets dangerous precedent
- Other HOAs watching
- Systemic reform needed
DETERRENCE REQUIRED:
- Boards statewide emboldened
- Must send message
- Protect consumers
- Enforce rule of law
MEDIA ATTENTION:
- Public watching
- Taxpayers concerned
- Accountability demanded
- Justice required
PART XII: LEGAL MANDATE TO ACT
NON-DISCRETIONARY DUTIES:
RCW 19.86.080: "SHALL investigate"
RCW 19.86.090: "SHALL commence action"
RCW 43.10.030: "SHALL prosecute"
FAILURE TO ACT = BREACH:
- Duty to protect consumers
- Obligation to enforce laws
- Mandate to prosecute crime
- Fiduciary to public
IMMEDIATE ACTION REQUIRED:
Every day of delay:
- More victims harmed
- More money stolen
- More crimes committed
- Evidence destroyed
CONCLUSION:
This is not a civil dispute - this is CRIMINAL FRAUD. An HOA dissolved in 2003, illegally reinstated without any vote, has operated a 20-year fraud scheme, stealing $40,671+ from consumers through deception, threats, and extortion.
The evidence is overwhelming:
- Board admits no voting records exist
- Financial records prove theft
- Documents show conspiracy
- Victims ready to testify
Your office must act immediately to:
1. Stop ongoing crimes
2. Recover stolen funds
3. Prosecute criminals
4. Protect consumers
5. Restore justice
I demand action within 10 business days or I will:
- File federal complaint
- Contact media
- Organize victims
- Initiate private action
- Pursue mandamus
The people of Washington are watching.
[Your name]
[Your address]
[Your phone]
[Date]
cc: FBI Seattle Office
cc: US Attorney, Eastern District
cc: Secretary of State
cc: Insurance Commissioner
cc: Governor Jay Inslee
cc: Legislative Representatives
cc: Media Outlets
🚔 CHELAN COUNTY SHERIFF - CRIMINAL COMPLAINT (ULTRA-DETAILED)
To: sheriff@co.chelan.wa.us
Cc: investigations@co.chelan.wa.us; dispatch@co.chelan.wa.us
Subject: FORMAL CRIMINAL COMPLAINT - Grand Theft & Fraud - Chelan Vista Heights HOA Board - Request Immediate Investigation & Arrests
Sheriff Morrison and Criminal Investigations Division:
I am filing this formal criminal complaint requesting immediate investigation and arrest of the Chelan Vista Heights HOA Board of Directors for grand theft, fraud, embezzlement, and conspiracy involving $40,671+ stolen from homeowners through an elaborate criminal scheme.
PART I: SUSPECTS & CRIMINAL ENTERPRISE
PRIMARY SUSPECTS (Board of Directors):
- Names: [Board member names from records]
- Address: 3870 Spring Ln, Wenatchee, WA 98801
- Organization: Chelan Vista Heights HOA
- Role: Directors/Officers (Principals)
CO-CONSPIRATORS:
- KSB Law Group (Received $10,671 proceeds)
- PayHOA, Inc. (Facilitated theft)
- Unknown others (Investigation needed)
VICTIMS:
- 50+ homeowners in Chelan County
- Location: Chelan Vista Heights subdivision
- Ongoing victimization (daily)
PART II: ELEMENTS OF CRIMES
COUNT 1: THEFT IN THE FIRST DEGREE (RCW 9A.56.030)
Class B Felony - 10 years prison
Elements Met:
1. ✓ Wrongfully obtained property
2. ✓ Property of another (homeowners)
3. ✓ Intent to deprive
4. ✓ Value exceeds $5,000 ($40,671+)
Specific Acts:
- April 2023: Stole $10,671 for lawyers
- 2023-2024: Stole $200/year per home
- 2003-2023: 20 years of theft
- Total: $40,671+ stolen
Evidence:
- Bank records show $10,671 payment
- No authorization from members
- PayHOA records show collections
- Victims will testify
COUNT 2: THEFT BY DECEPTION (RCW 9A.56.020)
Deceptive Acts:
1. Claimed HOA had valid bylaws (FALSE)
2. Claimed dues were mandatory (FALSE)
3. Claimed board was elected (FALSE)
4. Claimed liens were valid (FALSE)
5. Concealed HOA dissolution (2003)
Method:
- Sent fraudulent bills
- Made false statements
- Concealed material facts
- Threatened false liens
- Created fear of foreclosure
COUNT 3: IDENTITY THEFT (RCW 9.35.020)
Class B Felony
Criminal Use of HOA Identity:
- Used dissolved entity's name
- No legal existence since 2003
- Fraudulent use of UBI number
- False representation of authority
- Financial crimes via identity
COUNT 4: FORGERY (RCW 9A.60.020)
Class C Felony
Forged Documents:
- April 26, 2023: Fake bylaw adoption
- June 26, 2023: False resolution
- Annual meeting minutes (never occurred)
- Voting records (none exist)
- Financial authorizations
Intent to Defraud:
- Created false corporate records
- Deceived homeowners
- Misled authorities
- Concealed crimes
COUNT 5: CRIMINAL CONSPIRACY (RCW 9A.28.040)
The Agreement:
- Board agreed to steal money
- Hired lawyers without authority
- Created fake bylaws
- Pretended member approval
- Divided stolen proceeds
Overt Acts:
1. Secret board meetings
2. Contact with lawyers
3. $10,671 payment
4. False document creation
5. Ongoing collection
PART III: TIMELINE OF CRIMINAL ACTIVITY
THE 20-YEAR CRIME SPREE:
2002: HOA legally formed
2003: HOA dissolved (hidden)
2003: Illegal "reinstatement" (no vote)
2003-2023: 20 years of theft
- Collected unauthorized dues
- No valid governance
- No legal authority
- Continuous fraud
THE 2023 ESCALATION:
January: Board discovers no bylaws
February: Conspiracy begins
March: Contact lawyers
April: Steal $10,671
April 26: Create fake bylaws
June 26: False resolution
Present: Ongoing theft
PART IV: MODUS OPERANDI
THE CRIMINAL METHOD:
Step 1: FALSE AUTHORITY
- Pretend to be valid HOA
- Claim governmental power
- Assert lien rights
- Demand payments
Step 2: INTIMIDATION
- Threaten foreclosure
- Damage credit
- Legal action threats
- Create fear
Step 3: COLLECTION
- PayHOA processing
- Bank deposits
- Wire transfers
- Mail payments
Step 4: CONCEALMENT
- Refuse record requests
- Destroy evidence
- False statements
- Cover-up conspiracy
Step 5: MONEY LAUNDERING
- Commingle funds
- Pay conspirators
- Hide proceeds
- Continue scheme
PART V: EVIDENCE AVAILABLE
PHYSICAL EVIDENCE:
1. Documentary:
- Bank statements
- Cancelled checks
- Wire records
- PayHOA logs
- Fake bylaws
- False minutes
2. Digital:
- Email chains
- Electronic transfers
- Website posts
- Database records
3. Financial:
- $10,671 payment proof
- Unauthorized collections
- Hidden transactions
- Money trail
TESTIMONIAL EVIDENCE:
1. Victim Statements:
- 50+ homeowners
- No vote occurred
- Forced payments
- Threats received
2. Board Admissions:
- "No voting records exist"
- "Operating on pretenses"
- Self-incriminating statements
3. Expert Witnesses:
- Corporate law experts
- Fraud examiners
- Forensic accountants
ABSENCE OF EXCULPATORY EVIDENCE:
- ZERO voting ballots
- NO quorum records
- NO member approvals
- NO authorization
- NOTHING legitimate
PART VI: IMMEDIATE DANGER TO COMMUNITY
ONGOING CRIMINAL ACTIVITY:
- Crimes continue DAILY
- New victims ANNUALLY
- Evidence being DESTROYED
- Assets being HIDDEN
- Suspects may FLEE
Flight Risk Factors:
- Large amount stolen
- Federal charges pending
- Evidence of guilt strong
- Resources to flee
- Destroying evidence
DANGER TO VICTIMS:
- Continued extortion
- Ongoing threats
- Financial harm
- Retaliation risk
- Witness intimidation
PART VII: PROBABLE CAUSE AFFIDAVIT
I SWEAR THE FOLLOWING IS TRUE:
1. The HOA was dissolved in 2003
2. It was illegally reinstated without vote
3. The board admits no voting records exist
4. They spent $10,671 without authority
5. They created fake bylaws
6. They collected unauthorized dues
7. They threatened illegal liens
8. Total theft exceeds $40,671
PROBABLE CAUSE EXISTS FOR:
- Search warrants (homes/offices)
- Arrest warrants (board members)
- Asset seizure (stolen funds)
- Evidence preservation orders
PART VIII: REQUESTED LAW ENFORCEMENT ACTION
IMMEDIATE ACTIONS:
1. CRIMINAL INVESTIGATION
- Interview all board members
- Subpoena financial records
- Forensic accounting
- Digital evidence collection
- Witness interviews
2. SEARCH WARRANTS
Execute searches at:
- Board members' homes
- HOA office
- Computer seizure
- Document collection
- Financial records
3. ARREST WARRANTS
- All board members
- Conspiracy charges
- Theft charges
- Fraud charges
- Book and release unacceptable
4. ASSET FREEZE
- HOA bank accounts
- PayHOA accounts (active 2022-present)
- Board personal accounts
- Prevent dissipation
5. EVIDENCE PRESERVATION
- Litigation hold
- Document preservation
- Electronic records
- Prevent destruction
PART IX: COORDINATION WITH OTHER AGENCIES
MULTI-JURISDICTIONAL CRIMES:
Federal Agencies:
- FBI: Mail/Wire fraud
- IRS: Tax fraud
- DOJ: RICO violations
- Postal Inspection: Mail fraud
State Agencies:
- Attorney General: Consumer fraud
- Secretary of State: Corporate fraud
- Insurance Commissioner: Insurance fraud
- Department of Revenue: Tax crimes
PROSECUTION COORDINATION:
- Chelan County Prosecutor
- US Attorney's Office
- State Attorney General
- Multi-agency task force
PART X: VICTIM IMPACT & PUBLIC SAFETY
VICTIM HARM:
- 50+ families affected
- $600+ stolen per household
- Elderly victims on fixed income
- Threats of home loss
- Credit destruction
- Emotional trauma
PUBLIC SAFETY CONCERN:
- White collar crime epidemic
- Other HOAs copying scheme
- Public trust eroded
- Rule of law threatened
- Immediate action required
COMMUNITY DEMAND:
- Neighbors demand justice
- Taxpayers want action
- Media watching
- Public accountability
PART XI: CRIMINAL HISTORY CHECK
BACKGROUND INVESTIGATION NEEDED:
- Prior fraud convictions?
- Other victims?
- Pattern of crimes?
- Interstate crimes?
- Hidden assets?
BEHAVIORAL PATTERNS:
- Sophisticated scheme
- Lengthy duration
- Multiple victims
- Cover-up attempts
- Likely recidivists
PART XII: URGENCY OF RESPONSE
STATUTE OF LIMITATIONS:
- Some crimes may expire
- Evidence being destroyed
- Witnesses relocating
- Memories fading
- Act immediately
CONTINUING CRIMES:
- New theft daily
- New mail fraud daily
- New wire fraud daily
- New victims annually
- Emergency response needed
EVIDENCE DESTRUCTION:
- Documents being shredded
- Emails being deleted
- Records being altered
- Witnesses being influenced
- Preservation order critical
CONCLUSION:
This is not a civil matter - these are FELONY CRIMES. The suspects have stolen $40,671+ through an elaborate fraud scheme spanning 20 years. They've admitted no voting records exist because no votes occurred. The evidence is overwhelming and indisputable.
Every peace officer has a duty under RCW 10.31.100 to arrest when probable cause exists for a felony. That threshold is far exceeded here.
I am requesting:
1. Immediate investigation (TODAY)
2. Emergency asset freeze (TODAY)
3. Evidence preservation (TODAY)
4. Arrest warrants (THIS WEEK)
5. Criminal prosecution (IMMEDIATE)
If no action is taken within 72 hours, I will:
- Contact FBI directly
- File with US Attorney
- Contact media
- Organize victims
- Pursue federal action
Please confirm receipt and provide case number.
COMPLAINANT INFORMATION:
[Your name]
[Your address]
[Your phone]
[Your email]
[Date]
I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct.
_______________________
Signature
EVIDENCE ATTACHED:
- Financial records
- Fake bylaws
- Board admissions
- Victim statements
- Full documentation: https://chelanvistaheights.com
cc: Chelan County Prosecuting Attorney
cc: FBI Seattle Division
cc: Washington Attorney General
cc: Media (if no response in 72 hours)