8/20/25 My Litigation Hold Notice & Document Preservation Request email with the attached PDF Notice.
8/20/25
Attached is my LITIGATION HOLD NOTICE & DOCUMENT PRESERVATION REQUEST
Please acknowledge receipt of this email.
Thank you,
Christine Baker
2025-8-20 Litigation Hold and Preservation Request to MCA
Because many residents cannot view pdf files, here is the Litigation Hold Notice with slightly different formatting, replaced underline with bold formatting:
August 20, 2025
Christine Baker
PO Box 858
Meadview, AZ 86444
christine@trado.info
Parcel #: 336-07-044VIA EMAIL ONLY
Meadview Civic Association Board of Governors:
Donald Swartz
Larry Reilley
NorretaCaldwell
Sharon Baur
Ron Balsamo
William ZajcRE: Litigation Hold and Preservation Notice
Dear Board Members:I recently discovered at the Meadview Civic Association (“MCA”) website the AMENDMENT AND RESTATEMENT OF DECLARATION OF COVENANTS, CONDITIONS AND RESTRICTIONS FOR KEYSTONE UNIT 13-29-17 [Unit 7].
I concluded that this Amendment was improperly recorded on 5/1/1989 and it is therefore invalid.
When I purchased my home in 2006, the MCA failed to provide these 1989 Amended CC&Rs and I received only the 1970 Declaration of CC&Rs. This document was not recorded and appears to have been created by the MCA. It is therefore also invalid.
Please IMMEDIATELY advise if any of my published information and my conclusions regarding the validity of the CC&Rs are incorrect:
https://highdesertdirt.com/mca/docs/my-home-in-unit-7-is-not-subject-to-the-ccrs/
Since 2012 the MCA abused, slandered and defamed me because I exposed its illegal activities and I was seeking MCA documents and information I was legally entitled to.
With hindsight, it is rather obvious that the MCA has been operating in secrecy like Skull & Bones and violated numerous laws to keep members from discovering that the MCA was enforcing invalid CC&Rs and collecting membership fees from properties never subject to MCA membership. A board member advised that legal documents had been destroyed.
I will be describing and documenting the many abusive and reprehensible and illegal MCA actions against me at my MCA Knowledgebase in preparation for litigation:
https://highdesertdirt.com/mca/docs/
Since 2012 the MCA’s communications with me were mostly limited to legal threats.
I am urging you to cooperate as I will be seeking compensatory and punitive damages.
I have not received a response from the MCA to my 2/10/25 email regarding the employment of Thom O’Keeffee:
https://highdesertdirt.com/mca/docs/2025-2-10-email-to-the-mca-re-thom-okeeffes-it-work/
Please at least acknowledge receipt of this email.
I cannot force you to answer until litigation commenced, but legal fees will be much lower if you cooperate now.
Additionally, as you know, it is of course important that you advise of any incorrect information or conclusions because I publish my research on social media and at my websites.
How many thousands of dollars did the MCA waste on attorney Basinger after I exposed the MCA illegal $25/month late fees in 2013?
The MCA could have acknowledged its noncompliance instead of arguing that it was exempt from Arizona state law and wasting the members’ dues on legal fees.
As I compile the exhibits for the litigation at my MCA Knowledgebase I will be seeking your comments and feedback and you might want to designate a person to handle these communications.
I am looking forward to establishing the facts prior to filing the lawsuit.
LITIGATION HOLD NOTICE & DOCUMENT PRESERVATION REQUEST
In accordance with Arizona law as set forth in detail below, you must preserve all documents related to your operations, including any and all communications between you and your agents since the MCA was established.
You must give this litigation hold letter to all of your board members, agents, contractors, volunteers, or anyone else who is designated, retained, employed, or otherwise utilized by you and all those persons are likewise subject to this litigation hold letter.
In general, litigants have a duty to preserve documents and evidence that they know, or reasonably should know “‘is relevant in the action, is reasonably calculated to lead to the discovery of admissible evidence, is reasonably likely to be requested during discovery and/or is the subject of a pending discovery request.’” Souza v. Fred Carries Contracts, Inc., 191 Ariz. 247, 250 (Ct. App. 1997) (citing Turner v. Hudson Transit Lines, Inc., 142 F.R.D. 68, 72 (S.D.N.Y.1991)). Please preserve and ensure that you preserve all such documents and evidence in their possession, custody and/or control. This includes, but is not limited to the following:
1. All documents and evidence, whether paper or electronic, including but not limited to written records, photographs, video, audio, recordings, spreadsheets, calendars, contact lists and/or contact files, logs, data files, dictations, databases, images, texts, timelines, archive files, browsing histories and tangible evidence.
2. All communications and correspondence, whether paper or electronic, including but not limited to written correspondence, voice mails, e-mails, calendar invites, text messages, instant messages, third-party messaging systems/applications messages and data, chats/chat strings, video files, audio files, and social media posts and messages, whether designated as public or private. This includes but is not limited to any communications and/or correspondence on third party messaging systems/applications such as WhatsApp, SnapChat, Telegram, and Signal.
3. All Social Media information, including but not limited to account information, posts, communications, photographs, images, videos, audio, invites, likes, tweets, comments and messages. Social Media includes, but is not limited to, Facebook, X (Twitter), Instagram, TikTok, Reddit, Tumblr, SnapChat, Meetup, Parler, MeWe, Gab, and/or LinkedIn.
The above list is not exhaustive and is not intended to act as a substitute for your and your agents’ careful review of all documents, files, evidence, and Devices to identify and preserve those documents and evidence.
Please keep in mind that the term “documents” is interpreted broadly to include paper, electronic, audio and video recordings, computer-based records (i.e., databases), e- records/digital records, and any other recorded forms of information that may be related to your and your agents’ actions related to MCA operation. It is imperative that any documents that relate to the above allegations be (1) identified, (2) separated from other files, and (3) preserved and protected from destruction or alteration. All documents that may relate to the allegations should be maintained and preserved regardless of their date. This may include documents that were created prior to the alleged events in question, as well as after. All documents that are preserved must be maintained in their original state, without destruction or alteration, until I notified you in writing that any dispute arising from the allegations has been fully resolved. This includes maintaining in its original form all metadata.
A failure to preserve these materials could prove detrimental to the legal interests of the MCA. The case law in Arizona and the Ninth Circuit empower the trial courts to impose significant sanctions against parties who fail to preserve evidence. The body of case law includes the imposition of potentially significant sanctions for the willful destruction of evidence as well as non-willful and non-bad faith failure to preserve evidence. See, e.g., Souza, 191 Ariz. 247; Unigard Security Insur. Co. v. Lake Engineering & Manuf. Corp., 982 F.2d 363 (9th Cir. 1992).
Please take steps immediately to preserve any and all documents and evidence that may be related to the creation of the MCA, adoption of Lots, the CC&Rs, board and member meetings, billing and general operations, complaints and enforcement, all committees including the election committee and the architectural committee, member complaints and disputes and legal actions.
If you should have any questions or need further information, please do not hesitate to contact me.
Please acknowledge receipt of this Notice by email to christine@trado.info.
Sincerely,
Christine Baker
