in the third judicial district court in and for salt lake county, state of utah · 2020. 2. 1. ·...

Bruce R. Baird (0176)

Bruce R. Baird, P.C.

2150 S. 1300 E., 5th Floor

Salt Lake City, Utah 84106

Telephone:(801) 647-1400

[email protected]

Attorney for Plaintiffs

IN THE THIRD JUDICIAL DISTRICT COURT

IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

WDIS, LLC AS TRUSTEE OF THE MDMG

TRUST DATED APRIL 25, 2016, and

DREAMWORKS PROPERTY

MANAGEMENT INC. AS TRUSTEE OF

THE STEP MOUNTAIN ROAD LAND

TRUST DATED NOVEMBER 6, 2007,

Plaintiffs

v.

HI-COUNTRY ESTATES HOMEOWNERS

ASSOCIATION, A/K/A HI-COUNTRY

ESTATES HOMEOWNERS

ASSOCIATION PHASE 11 INC., A/K/A HI-

COUNTRY ESTATES HOMEOWNERS

ASSOCIATION PHASE 11, INC., A/K/A


ASSOCIATION PHASE I11 INC., A/K/A


ASSOCIATION PHASE II INC., A/K/A HI-

COUNTRY ESTATES HOMEOWNERS

ASSOCIATION, PHASE II, INC., A/K/A

HI-COUNTRY ESTATES PHASE II, A/K/A

HI-COUNTRY ESTATES PHASE II

HOMEOWNERS ASSOCIATION, A/K/A

HI-COUNTRY ESTATES, PHASE II,

A/K/A HI-COUNTRY HOMEOWNERS

ASSOCIATION, A/K/A HI-COUNTRY

PLAINTIFFS’ RULE 26 INITIAL

DISCLOSURES

Case No.: 160904994

Judge: Laura Scott

** Tier 2 Action**

2

ESTATES, A/K/A HI COUNTRY ESTATES

HOMEOWNERS ASSOCIATION, A/K/A

HI COUNTRY ESTATES II, A/K/A HI

COUNTRY ESTATES PHASE II, A/K/A HI

COUNTRY ESTATES PHASE II

HOMEOWNERS ASSOCIATION

Defendants.

Pursuant to Rule 26 of the Utah Rules of Civil Procedure, Plaintiffs WDIS, LLC as Trustee

of the MDMG Trust dated April 25, 2016, and Dreamworks Property Management Inc. as Trustee

of the Step Mountain Road Land Trust dated November 6, 2007 (collectively, “Plaintiffs”), submit

the following Initial Disclosures and reserve the right to supplement them pursuant to Rule 26(e):

Rule 26(a)(1)(A). The following individuals and entities have knowledge and information

concerning the dispute.

Rule 26 (a)(1)(A)(ii). The following list of witnesses are expected to be called at trial in

Plaintiffs’ case- in- chief:

1. Joseph Johnson, 4541 S. 700 E. Suite 200, SLC, UT 84107; 801-263-1040. The

HOA's CPA for several years, including 1995-1997, 2008-2012. Has knowledge of the HOA's

budgets, expenditures and financials. Has audited the HOA's financials many times. Has counted

HOA votes for elections and amendments for several years. Has knowledge of how the HOA has

counted and not counted votes of certain members. Has knowledge of the changes in vote counting

procedures through the years.

2. Mary J Pennington, 15081 S. Shaggy Mountain Rd, Herriman, UT 84096; 801-285-

4923. Currently lives within the HOA's purported boundaries. Is currently an HOA Director and

is the current HOA president. Has been on the HOA board since approximately 2011. Has

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extensive knowledge about the HOA, how it is governed, its documents, its history, its

enforcement, its actions towards HOA members, assessments, its water rights, its roads, its

governing document discrepancies, its amendments to governing documents, its elections, its legal

actions against owners, its collection practices, its meetings and vote counting practices. Has

extensive knowledge of the HOA's budgets, expenditures and financials. Currently oversees all

HOA assets and bank accounts and approves expenditures. Has information about other HOA

board members and their actions.

3. Agents or Principals of Advanced Community Services, LLC, PO Box 179, Lehi,

UT 84043; 801-641-1844. Is an HOA management company that currently manages the HOA

(since approximately July of 2014). Has extensive knowledge about the HOA, how it is governed,

its documents, its history, its enforcement, its actions towards HOA members, assessments, its

water rights, its roads, its governing document discrepancies, its amendments to governing

documents, its elections, its legal actions against owners, its collection practices, its meetings and

vote counting practices. Has extensive knowledge of the HOA's budgets, expenditures and

financials. Currently aids the HOA board in overseeing all HOA assets and bank accounts. Has

information about the HOA's board members and their actions.

4. Keith Emmer, 1619 W. Allegheny Dr., Taylorsville, UT 84123; telephone unkown.

Lived in the HOA's purported boundaries from approximately 1994-2014. Was an HOA Director

for the approximate years of 1994-2011. Was the HOA president for several of those years. Has

extensive knowledge about the HOA, how it was governed, its documents, its history, its



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extensive knowledge of the HOA's budgets, expenditures and financials. While a board member,

oversaw all HOA assets and bank accounts, approved expenditures and approved the sale of the

water rights to Herriman City. Has information about other HOA board members and their actions.

5. Thomas Williams, 14875 S. 7560 W., Herriman, UT 84096; 801-253-1024.

Currently lives within the HOA's purported boundaries. Was an HOA Director for the approximate

years of 2003-2015. Was in charge of the HOA's water system for many of those years. Has






oversaw all HOA assets and bank accounts and approved expenditures. Has extensive knowledge

of the sale of the water rights and approved the sale with Herriman City. Has information about

other HOA board members and their actions.

6. Jeffrey Campbell, 802 Murphy Creek Rd., Grants Pass, OR 97527; telephone

unkown. A resident in the HOA's purported boundaries for many years until his home burnt down

from a wildfire. Has knowledge of the HOA, the health and safety of the HOA and the HOA's

governance.

7. Kathy Engle, PO Box 2225, Arvada, CO 80001; telephone unknown. A vacant

land owner that has owned property in the HOA's purported boundaries's purported boundaries

since approximately the mid-1970's. Has knowledge of the HOA, how it has governed, its

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documents, its history, its enforcement, its actions towards HOA members, assessments, its water

rights, its roads, its elections, its legal actions against owners, its collection practices, its meetings

and vote counting. Has knowledge of the HOA's illegal and oppressive conduct.

8. Leilani Vaivaka, address unknown; telephone unkown. A vacant land owner in the

HOA's purported boundaries from approximately 2005-2011. Was an HOA Director for the

approximate years of 2010-2011. Has knowledge about the HOA Boards dealings, how it was

governed, its history, its enforcement, its actions towards HOA members, assessments, its water


and vote counting practices. Has knowledge of the HOA's budgets, expenditures and financials.

Has knowledge of the HOA boards dealings against vacant land owners and their dealings in

"closed" meetings. Has information about other HOA board members and their actions. Has

knowledge of the HOA's illegal and oppressive conduct.

9. Brian Shellabarger, 8107 W. Country View Lane, Herriman, UT 84096; 801-856-

3505. Currently lives within the HOA's purported boundaries. Is a current HOA Director and has

been on the HOA board since 2015. Has knowledge about the HOA, how it is governed, its


rights, its roads, its governing document discrepancies, its amendments to governing documents,

its elections, its legal actions against owners, its collection practices, its meetings and vote counting

practices. Has extensive knowledge of the HOA's budgets, expenditures and financials. Currently

oversees all HOA assets and bank accounts and approves expenditures. Has information about


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10. Rodney Dansie, address unknown; telephone unkown. Has lived near the HOA's

purported boundaries since at least 1970 (before the HOA was formed). Has knowledge and

information about the HOA, the history of the HOA, water systems and water rights of the HOA.

11. Arlene Johnson, P. O. Box 158, Riverton, UT 84065; 801-254-9721. Currently

lives within the HOA's purported boundaries. Was an HOA Director for the approximate years of

1991-1995, 2001-2015. Was the HOA president for the approximate years of 2011-2015. Has






oversaw all HOA assets and bank accounts, approved expenditures and approved the sale of the

water rights to Herriman City. Has information about other HOA board members and their actions.

12. Jerry Gilmore, 3798 E. Clubhouse Lane, Eagle Mountain, UT 84005; 801-789-

6870. A vacant land owner that has owned property in the HOA's purported boundaries since

approximately the mid-1990's. Has knowledge of the HOA, how it has governed, its documents,

its history, its enforcement, its actions towards HOA members, assessments, its water rights, its

roads, its elections, its legal actions against owners, its collection practices, its meetings and vote

counting. Has knowledge of the HOA's illegal and oppressive conduct.

13. Scott Royal, 6734 S 2680 E, Cottonwood Heights, UT 84121; 801-856-8856. A

vacant land owner that has owned property in the HOA's purported boundaries since 2006. Has

knowledge of the HOA, how it has governed, its documents, its history, its enforcement, its actions

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towards HOA members, assessments, its water rights, its roads, its elections, its legal actions

against owners, its collection practices, its meetings, its vote counting and its legal description

boundary discrepancies. Has knowledge of the HOA's illegal and oppressive conduct.

14. Jose Galvan, 15441 S. Arnold Hollow Road, Herriman, UT 84096; 801-446-0696.

Currently lives within the HOA's purported boundaries. Is a current HOA Director and has been

on the HOA board since 2014. Has knowledge about the HOA, how it is governed, its documents,


roads, its governing document discrepancies, its amendments to governing documents, its

elections, its legal actions against owners, its collection practices, its meetings and vote counting




15. Kathy Fuller, 15467 S. Rose Canyon Rd., Herriman, UT 84096; telephone unkown.

Recently moved into the HOA's purported boundaries (approximately August of 2015). Is a

current HOA Director and was just elected to the board in June of 2016. May have knowledge

about the HOA, how it is governed, its documents, its history, its enforcement, its actions towards

HOA members, assessments, its water rights, its roads, its governing document discrepancies, its

amendments to governing documents, its elections, its legal actions against owners, its collection

practices, its meetings and vote counting practices. May have knowledge of the HOA's budgets,

expenditures and financials. Currently oversees all HOA assets and bank accounts and approves

expenditures. Has information about other HOA board members and their actions.

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16. Tom Souvall, 5659 Canal Street, Murray, UT 84123; 801-856-8618. A vacant land

owner that has owned property in the HOA's purported boundaries since approximately the mid-

1980's. Has knowledge of the HOA, how it has governed, its documents, its history, its


elections, its legal actions against owners, its collection practices, its meetings and vote counting.

Has knowledge of the HOA's illegal and oppressive conduct.

17. Lenell Chace, 8869 S. 3200 W., W. Jordan, UT 84088; 801-255-0716. A vacant

land owner that has owned property in the HOA's purported boundaries since approximately the

mid-1980's. Has knowledge of the HOA, how it has governed, its documents, its history, its




18. Celeste Niesen, 7575 S. 2700 W., West Jordan, UT 84084; 801-870-7295. Vacant

land owner in the HOA's purported boundaries. Lived in a camper on her property for many years

(approximately 2000-2005). Has knowledge of the HOA, how it has governed, its history, its

enforcement, its actions towards HOA members, assessments, its road conditions and maintenance

(while living there), its collection practices. Has knowledge of the HOA's illegal and oppressive

conduct.

19. Annette Emmer, 1619 W. Allegheny Dr., Taylorsville, UT 84123; telephone

unkown. Lived in the HOA's purported boundaries from approximately 1994-2014. Was an ACC

member for several years and aided in the creating of the ACC manual. Was in charge of the

HOA's newsletter, "The Canyon Breeze," for many years. Has extensive knowledge about the

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HOA, how it was governed, its documents, its history, its enforcement, its actions towards HOA

members, assessments, its water rights, its roads, its governing document discrepancies, its


practices, its meetings and vote counting practices. Has extensive knowledge of the HOA's

budgets, expenditures and financials. Has information about HOA board members and their

actions.

20. Michael Keene, 15081 S. Shaggy Mountain Rd, Herriman, UT 84096; 801-285-

4923. A resident living in the HOA's purported boundaries and has knowledge about the HOA,

how it is governed, its history, its actions towards HOA members and its meetings. Has

information about HOA board members and their actions.

21. Brandon Frank, PO Box 621, Draper, UT 84020; telephone unkown. A vacant land

owner that has owned property in the HOA's purported boundaries since approximately 2005. Has




actions against owners, its collection practices, its meetings, its vote counting practices, the initial

setup of the HOA and its legal description boundary discrepancies. Has knowledge of the HOA's

budgets, expenditures and financials. Has knowledge of the HOA's illegal and oppressive conduct.

22. Shirley Brown, 7539 W. 14900 S., Herriman, UT 84096; 801-446-9132. Currently

lives within the HOA's purported boundaries. Is currently the HOA's Treasurer (since

approximately 2014) and elected as the HOA Secretary in June of 2016. Has knowledge about the

HOA, how it is governed, its documents, its history, its enforcement, its actions towards HOA

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members, assessments, its water rights, its roads, its governing document discrepancies, its


practices, its meetings and vote counting practices. Has extensive knowledge of the HOA's

budgets, expenditures and financials. Currently oversees all HOA assets and bank accounts. Has

information about HOA board members and their actions.

23. Chris Earl, 7597 W. 14900 S., Herriman, UT 84096; 801-518-9481. A resident

living in the HOA's purported boundaries and has knowledge about the HOA, how it is governed,

its history, its enforcement, its actions towards HOA members, assessments, its legal actions

against owners. Has knowledge of the HOA's illegal and oppressive conduct.

24. Jack Darton, 14570 Shaggy Mountain Rd, Herriman, UT 84096; 801-571-4955.

Currently lives within the HOA's purported boundaries. Has been the HOA's secretary from

approximately 2002-2016. Has knowledge about the HOA, how it is governed, its documents, its

history, its enforcement, its actions towards HOA members, assessments, its water rights, its roads,

its governing document discrepancies, its amendments to governing documents, its elections, its

legal actions against owners, its collection practices, its meetings and vote counting practices. Has

extensive knowledge of the HOA's budgets, expenditures and financials. Aided in overseeing all

HOA assets and bank accounts. Has information about HOA board members and their actions.

25. Stefan Wolowina, 1085 Orion Rd #4, Helena, MT 59602; 406-431-3617. A vacant




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26. Terri Williams, 14875 S. 7560 W., Herriman, UT 84096; 801-253-1024. Currently

lives within the HOA's purported boundaries. Was an ACC member for several years and aided

in the creating of the ACC manual. Has knowledge about the HOA, how it was governed, its




practices. Has knowledge of the HOA's budgets, expenditures and financials.

27. Glenn Johns, 7897 W. Shaggy Mountain Rd., Herriman, UT 84096; 801-565-8474.

Currently lives within the HOA's purported boundaries. Was an HOA Director from

approximately 2009-June of 2016. Has knowledge about the HOA, how it is governed, its




practices. Has knowledge of the HOA's budgets, expenditures and financials. Currently oversees

all HOA assets and bank accounts and approves expenditures.

28. Ken Johnson, P. O. Box 158, Riverton, UT 84065; 801-254-9721. Currently lives

within the HOA's purported boundaries. Has knowledge about the HOA, how it is governed, its




12

practices. Has knowledge of the HOA's budgets, expenditures and financials. Has information

about other HOA board members and their actions.

29. Thomas Chace, 8869 S. 3200 W., W. Jordan, UT 84088; 801-255-0716. A vacant






30. Elizabeth Wilson, 15142 S. Rose Canyon Rd, Herriman, UT 84096; 801-254-1991.

Currently lives within the HOA's purported boundaries. Was the HOA's Treasurer from

approximately 2000-2014. Has knowledge about the HOA, how it is governed, its documents, its




extensive knowledge of the HOA's budgets, expenditures and financials. While she was the

treasurer, she oversaw all HOA assets and bank accounts.

31. Robert Augason, 8121 S Telford Way, Sandy, UT 84093; 801-942-5747. A vacant

land owner that has owned property in the HOA's purported boundaries for many years. Has



against owners, its collection practices, its meetings and vote counting. Has knowledge of the

HOA's illegal and oppressive conduct.

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32. Lindsey Atwood, 9486 S. Wasatch View Circle, South Jordan, UT 84095; 801-254-

7258. A vacant land owner that has owned property in the HOA's purported boundaries for many

years. Has knowledge of the HOA, how it has governed, its documents, its history, its




33. Anthony Sarra, 14220 S. Shaggy Mountain Road, Herriman, UT 84096; 801-446-

9921. Currently lives within the HOA's purported boundaries. Was an HOA Director for the

approximate years of 2002-2011. Was the HOA director over "Legal" for many of those years.

Has knowledge about the HOA, how it is governed, its documents, its history, its enforcement, its

actions towards HOA members, assessments, its water rights, its roads, its governing document

discrepancies, its amendments to governing documents, its elections, its legal actions against

owners, its collection practices, its meetings and vote counting practices. Has extensive

knowledge of the HOA's budgets, expenditures and financials. While a board member, oversaw

all HOA assets and bank accounts and approved expenditures. Has extensive knowledge of the

sale of the water rights and approved the sale to Herriman City. Has information about HOA board

members and their actions.

34. Ryan Bonham, PO Box 179, Lehi, UT 84043; 801-641-1844. Is the owner of

Advanced Community Services, LLC which is an HOA management company that currently

manages the HOA (since approximately July of 2014). Has extensive knowledge about the HOA,

how it is governed, its documents, its history, its enforcement, its actions towards HOA members,

assessments, its water rights, its roads, its governing document discrepancies, its amendments to

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governing documents, its elections, its legal actions against owners, its collection practices, its

meetings and vote counting practices. Has extensive knowledge of the HOA's budgets,

expenditures and financials. Currently aids the HOA board in overseeing all HOA assets and bank

accounts. Has information about the HOA board members and their actions.

35. Bill Souvall, 5659 Canal Street, Murray, UT 84123; 801-856-8618. A vacant land

owner that has owned property in the HOA's purported boundaries since approximately the mid-

1980's. Has knowledge of the HOA, how it has governed, its documents, its history, its




36. Fred Crooks, 2743 Milstead Way, Roseville, CA 95661; 916-765-5447. A vacant






37. Matthew Perry, 46 W. LaSalle Dr, Midvale, UT 84047; 801-913-8576. A vacant



towards HOA members, assessments, its roads, its road maintenance, its easements, its legal

actions against owners and its collection practices. Has knowledge of the HOA's illegal and

oppressive conduct.

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38. Sheila Adler, 14777 Shaggy Mountain Rd, Herriman, UT 84096; telephone

unkown. Currently lives within the HOA's purported boundaries. Is a current HOA Director and

has been on the HOA board since 2015. Has knowledge about the HOA, how it is governed, its







39. Bridgette Perry, 46 W. LaSalle Dr, Midvale, UT 84047; 801-913-8576. A vacant





oppressive conduct.

40. Charles Lewton, PO Box 1901 (Or PO Box 726), Jackson, WY 83001; telephone

unkown. Has knowledge about the formation of the HOA. Has knowledge about the original

Covenants, Certificate of Incorporation and the Bylaws. Has knowledge of the HOA and the

history of the HOA and the area. Has knowledge of the formation of the original governing

documents and early amendments to those documents. Has knowledge of the development

companies that tried to develop the HOA area and their transactions. Has knowledge of the plat

maps of the HOA area. Has knowledge of the legal descriptions of the HOA and the discrepancies.

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41. Jimmy Perry, 46 W. LaSalle Dr, Midvale, UT 84047; 801-913-8576. A vacant land

owner that has owned property in the HOA's purported boundaries for many years. Has knowledge

of the HOA, how it has governed, its documents, its history, its enforcement, its actions towards

HOA members, assessments, its roads, its road maintenance, its easements, its legal actions against

owners and its collection practices. Has knowledge of the HOA's illegal and oppressive conduct.

42. Bridgette Taylor, 46 W. LaSalle Dr, Midvale, UT 84047; 801-913-8576. A vacant





oppressive conduct.

43. Agents or Principals of Step Mountain LLC, 5659 Canal Street, Murray, UT

84123; 801-856-8618. A vacant land owner that has owned property in the HOA's purported

boundaries since approximately the mid-1980's. Has knowledge of the HOA, how it has governed,


water rights, its roads, its elections, its legal actions against owners, its collection practices, its

meetings and vote counting. Has knowledge of the HOA's illegal and oppressive conduct.

44. Agents or Principals of the Trust of Homer Engle, PO Box 2225, Arvada, CO

80001; telephone unkown. A vacant land owner that has owned property in the HOA's purported



17



45. Jolynn Darton, 14570 Shaggy Mountain Rd, Herriman, UT 84096; 801-571-4955.

A resident living in the HOA's purported boundaries and has knowledge about the HOA, how it is

governed, its history, its actions towards HOA members and its meetings. Has information about

HOA board members and their actions.

46. Kerry Knighton, PO Box 1333, Riverton, UT 84065; telephone unkown. A vacant


knowledge of the HOA, how it has governed, its history, its enforcement, assessments, its legal

actions against owners. Has knowledge about how the HOA enforces covenants and unauthorized

rules against owners, while allowing many other owners free of harassment. Has knowledge of

the HOA's illegal and oppressive conduct.

47. Agents or Principals of Mountain Top Properties LLC, PO Box 2225, Arvada, CO

80001; 406-431-3617. A vacant land owner that has owned property in the HOA's purported





48. Gregory Brown, P. O. Box 1350, West Jordan, UT 84084; 801-446-1707. A vacant

land owner. Served on the HOA board for 2009-2010. Has knowledge of the HOA, how it has

governed, its documents, its history, its enforcement, its actions towards HOA members,

assessments, its water rights, its roads, its elections, its legal actions against owners, its collection

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practices, its meetings and vote counting. Has information about other HOA board members and

their actions. Has knowledge of the HOA's illegal and oppressive conduct.

49. Richard Casper, 912 E. Chandler Dr, Salt Lake City, UT 84103; 801-359-4797. A

vacant land owner that has owned property in the HOA's purported boundaries since approximately

the mid-1970's. Has knowledge of the HOA, how it has governed, its documents, its history, its




50. Cathi Hughes, address unknown; 801-631-7653. A resident that has lived in the

HOA's purported boundaries since 2014. Has knowledge of the HOA, how it has governed, its

actions towards HOA members and its meetings. Has information about mailers sent to HOA

members.

51. Justun Edwards, 13011 S. Pioneer Street, Herriman, UT 84096; telephone unkown.

Director of Municipal Water at Herriman City. Has knowledge of the HOA's water system,

management of the water system and the HOA's water system financials. Has knowledge of the

sale of the HOA's water rights to Herriman City.

52. Rex Facer, 4091 W 12600 S, Riverton, UT 84096; telephone unkown. Has

information about the HOA's roads, road maintenance, snow removal etc. Has knowledge of the

HOA, how it has governed, its documents, its history, its enforcement, its actions towards HOA

members, assessments, its elections, its legal actions against owners, its collection practices, its

meetings and vote counting. Has information about the HOA's bids for work. Has information

about the roads the HOA pays to maintain.

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53. Larry Fuller, address unknown; telephone unkown. Lived in the HOA's purported

boundaries for many years. Was on the HOA board from approximately 1983-1994. Was the

HOA president for many of those years. Has extensive knowledge about the HOA, how it was




meetings and vote counting practices. Has knowledge of the HOA's budgets, expenditures and

financials. Has information about other HOA board members and their actions.

54. Greg Schmidt, 3464 S. Cleveland Circle, Salt Lake City, UT 84109; 801-463-3094.

A vacant land owner that has owned property in the HOA's purported boundaries for many years.

Has knowledge of the HOA, how it has governed, its documents, its history, its enforcement, its

actions towards HOA members, assessments, its water rights, its roads, its elections, its legal

actions against owners, its collection practices, its meetings and vote counting. Has knowledge of


55. Robert Stromberg, PO Box 352, Torrey, UT 84775; 435-491-1018. A vacant land

owner that has owned property in the HOA's purported boundaries for many years. Has knowledge


HOA members, assessments, its water rights, its roads, its elections, its legal actions against

owners, its collection practices, its meetings and vote counting. Has knowledge of the HOA's

illegal and oppressive conduct.

56. Kim Wilson, 1447 E. Edgecliff Dr., Sandy, UT 84092; 801-571-5490. Owns

property in the HOA's purported boundaries. Was an HOA Director for the approximate years of

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1994-1999. Has knowledge about the HOA, how it is governed, its documents, its history, its




knowledge of the HOA's budgets, expenditures and financials. Has knowledge of the HOA's

roads, bids for roads and road construction.

57. Agents or Principals of Mascaro Family Partnership, 4091 W 12600 S, Riverton,

UT 84096; telephone unkown. Owns property inside the HOA's purported boundaries. Has

knowledge about the formation of the HOA. Has knowledge about the HOA, how it is governed,


water rights, its roads, its amendments to governing documents, its elections, its legal actions

against owners, its collection practices, its meetings and vote counting practices. Has extensive

knowledge of the HOA's road construction, road maintenance and snow removal. Has knowledge

of the land and the area before the HOA was formed.

58. Don Andreason, 14740 Rose Canyon Rd, Herriman, UT 84096; 801-254-7975. A

resident that has lived in the HOA's purported boundaries for many years. Has knowledge of the

HOA, how it has governed, its documents, its history, its enforcement, its actions towards HOA

members, assessments, its water rights, its roads, its elections, its legal actions against owners, its

collection practices, its meetings and vote counting.

59. Elizabeth Andreason, 14740 Rose Canyon Rd, Herriman, UT 84096; 801-254-

3749. A resident that has lived in the HOA's purported boundaries for many years. Has knowledge


21


owners, its collection practices, its meetings and vote counting.

60. John Andreason, 14780 S. Rose Canyon Rd., Herriman, UT 84096; 801-254-6099.

A resident that has lived in the HOA's purported boundaries for many years. Has knowledge of

the HOA, how it has governed, its documents, its history, its enforcement, its actions towards HOA

members, assessments, its water rights, its roads, its elections, its legal actions against owners, its

collection practices, its meetings and vote counting.

61. Robbie Frank, PO Box 621, Draper, UT 84020; telephone unkown. A vacant land

owner in the HOA's purported boundaries. Has knowledge of the HOA, how it has governed, its




62. Mickey Brown, 7575 S. 2700 W., West Jordan, UT 84084; 801-870-7295. Vacant

land owner in the HOA's purported boundaries. Lived in a camper on the property for many years

(approximately 2000-2005). Has knowledge of the HOA, how it has governed, its history, its

enforcement, its actions towards HOA members, assessments, its road conditions and maintenance

(while living there), its collection practices. Has knowledge of the HOA's illegal and oppressive

conduct.

63. Tony Mascaro, 4091 W 12600 S, Riverton, UT 84096; telephone unkown. Owns

property inside the HOA's purported boundaries. Has knowledge about the formation of the HOA.

Has knowledge about the HOA, how it is governed, its documents, its history, its enforcement, its

actions towards HOA members, assessments, its water rights, its roads, its amendments to

22


meetings and vote counting practices. Has extensive knowledge of the HOA's road construction,

road maintenance and snow removal. Has knowledge of the land and the area before the HOA

was formed. Has knowledge of the development companies that tried to develop the HOA area.

64. Robert Chew, 6935 Columbia Dr, West Jordan, UT 84084; 801-897-0503. Has

knowledge of the HOA, how it has governed, its history, its enforcement, its actions towards HOA

members and its roads. Has knowledge about greenbelt. Has knowledge of harassment of HOA

directors towards members. Has knowledge of the HOA's illegal and oppressive conduct.

65. Rob Dean, address unknown; telephone unkown. Lived in the HOA's purported

boundaries for several years. Was an ACC member for several years and aided in the creating of

the ACC manual. Has knowledge about the HOA, how it was governed, its documents, its history,

its enforcement, its actions towards HOA members, assessments, its water rights, its roads, its


actions against owners, its collection practices, its meetings and vote counting practices.

66. Gordon Haight, 13011 S. Pioneer Street, Herriman, UT 84096; telephone unkown.

Assistant City Manager for Herriman City. Has knowledge about the HOA, how it is governed,

its history and its roads. Has knowledge about the sale of the water rights to Herriman City and

the management of the HOA's water system. Has knowledge of the sewer grant funds available

to the HOA in 2010.

67. Keith Hill, 15046 S. Rose Canyon Rd, Herriman, UT 84096; 801-254-0113. Lives

within the HOA's purported boundaries. Was an HOA Director for the approximate years of 1988-

1993. Was the HOA president for some of those years. Has knowledge about the HOA, how it is

23




meetings and vote counting practices. Has knowledge of the HOA's budgets, expenditures and

financials. Has knowledge about the amendment to the Covenants in 1990.

68. Dave Holtby, 4020 S. 700 E. #2, Murray, UT 84107; telephone unkown. Has

knowledge of the HOA and the property values in the area.

69. Craig White, 1253 West Jordan Basin Lane, Bluffdale, UT 84065; telephone

unkown. Has knowledge about the sewer studies that have been done in the area of the HOA. Has

knowledge of the sewer grant funds that were available in 2010.

70. Debra Sarra, 14220 S. Shaggy Mountain Road, Herriman, UT 84096; 801-446-

9921. Lives within the HOA's purported boundaries. Has knowledge about the HOA, how it was




meetings and vote counting practices.

71. Laurie Roberts, 3464 S. Cleveland Circle, Salt Lake City, UT 84109; 801-463-

3094. A vacant land owner that has owned property in the HOA's purported boundaries for a long

time. Has knowledge of the HOA, how it has governed, its documents, its history, its enforcement,

its actions towards HOA members, assessments, its water rights, its roads, its elections, its legal

actions against owners, its collection practices, its meetings and vote counting. Has knowledge of


24

72. Sam Granato, 1423 Brookshire Drive, Salt Lake City, UT 84106; 801-649-3850.

A vacant land owner in the HOA's purported boundaries. Has knowledge of the HOA, how it has



practices, its meetings and vote counting. Has knowledge of the HOA's illegal and oppressive

conduct.

73. Karen Westerlin, 14646 S Juniper View Dr, Herriman, UT 84096; 801-440-6719.





conduct.

74. Steve Hunsaker, 14879 S. Rose Canyon Rd., Herriman, UT 84096; telephone

unkown. Lives within the HOA's purported boundaries. Is currently on the HOA's ACC. Has

knowledge of the HOA, how it is governed, its enforcement against owners, its roads, its elections

and its meetings.

75. David Moore, 15637 S Thunder Gulch Dr, Bluffdale, UT 84065; 801-718-0791. A






25

76. Anthony Clayton Leavitt, 1575 W 4470 S, Taylorsville, UT 84123; 403-360-2903.

Owned property in the HOA's purported boundaries for many years. Has knowledge of the HOA,

how it has governed, its documents, its history, its enforcement, its actions towards HOA members,


practices, its meetings and vote counting. Has knowledge of the HOA's dealings with selling real

property. Has knowledge of the HOA's illegal and oppressive conduct.

77. David Smugala, 16184 S. Arnold Hollow Road, Herriman, UT 84096; 801-302-

9252. A resident that lives within the HOA's purported boundaries. Has knowledge of the HOA,

how it has governed, its actions towards HOA members and its meetings. Has information about

mailers sent to HOA members.

78. Mark Fruin, 1912 E Yalecrest Ave, SLC, UT 84108; 801-891-2901. A vacant land





79. Shawn Goodwin, PO Box 621, Draper, UT 84020; telephone unkown. A vacant

land owner in the HOA's purported boundaries. Has knowledge of the HOA, how it has governed,




80. Gerald Bagley, 2242 Melodie-Ann Way, Salt Lake City, UT 84117; telephone


26


history of the HOA.

81. Maeona Kramer, PO Box 32, Driggs, ID 83422; telephone unkown. Owned

property in the HOA's purported boundaries for many years. Has knowledge of the HOA, how it

has governed, its documents, its history, its enforcement, its actions towards HOA members,



conduct.

82. W. Gardner Schmutz, 2246 S. 250 E., Bountiful, UT 84010; telephone unkown.

Has knowledge about the formation of the HOA. Has knowledge about the original Covenants,

Certificate of Incorporation and the Bylaws. Has knowledge of the HOA and the history of the

HOA.

83. Harold D. Glazier, 2259 Melodie-Ann Way, Salt Lake City, UT 84117; telephone



history of the HOA.

84. WDIS, LLC, 3187 N. 980 W., Lehi, UT 84043; telephone unkown. A vacant land





27

85. Hollie Orton, 3464 S. Cleveland Circle, Salt Lake City, UT 84109; 801-463-3094.

A vacant land owner that has owned property in the HOA's purported boundaries since

approximately the mid-1980's. Has knowledge of the HOA, how it has governed, its documents,


roads, its elections, its legal actions against owners, its collection practices, its meetings and vote

counting. Has knowledge of the HOA's illegal and oppressive conduct.

86. Glenda Fredrickson, 3800 S. Montecito St, Salt Lake City, UT 84106; 801-424-

2175. A vacant land owner in the HOA's purported boundaries. Has knowledge of the HOA, how

it has governed, its documents, its history, its enforcement, its actions towards HOA members,



conduct.

87. Robin Smugala, 16184 S. Arnold Hollow Road, Herriman, UT 84096; 801-302-

9252. A resident that lives within the HOA's purported boundaries. Has knowledge of the HOA,

how it has governed, its actions towards HOA members and its meetings. Has information about

mailers sent to HOA members.

88. Nancy Manning, 4071 N. Imperial Way, Provo, UT 84604; 801-434-7282. A






28

89. Dennette Mascaro-Facer, 4091 W 12600 S, Riverton, UT 84096; telephone

unkown. Owns property inside the HOA's purported boundaries. Has knowledge about the HOA,

how it is governed, its documents, its history, its enforcement, its actions towards HOA members,

assessments, its water rights, its amendments to governing documents, its elections, its legal


extensive knowledge of the HOA's roads, road maintenance and snow removal. Has knowledge

of the land and the area before the HOA was formed.

90. D. Keith Spencer, 430 Parkview Drive, Casper, WY 82601; telephone unkown.

Has knowledge about the formation of the HOA. Has knowledge about the original Covenants,


HOA.

91. Dale Jones, 51 N. East Ridge Drive, St. George, UT 84790; 435-632-5130. A


the late-1970's. Was an HOA board member from 1986-1988. Has knowledge of the HOA, how

it has governed, its documents, its history, its enforcement, its actions towards HOA members,


practices, its meetings and vote counting. Has information about other HOA board members and


92. Nate Reeve, 5160 S. 1500 W., Riverdale, UT 84405; telephone unkown. Has

knowledge of the legal description discrepancies in the governing documents. Has knowledge of

the HOA, the HOA roads, the HOA's water system, fire hazards in the area, health and safety

hazards in the HOA.

29

93. Agents or Principals of Schmidt Family Holding LC, 3464 S. Cleveland Circle,

Salt Lake City, UT 84109; 801-463-3094. A vacant land owner that has owned property in the

HOA's purported boundaries for many years. Has knowledge of the HOA, how it has governed,




94. Agents or Principals of J&S Property Ventures LLC, 6734 S 2680 E, Cottonwood

Heights, UT 84121; 801-856-8856. A vacant land owner in the HOA's purported boundaries. Has





95. William Bryan, 7445 E. Eagle Crest Dr. #1004, Mesa, AZ 85207; 480-699-3379.





conduct.

96. Larry Beagley, 7538 W. 14000 S., Herriman, UT 84096; 801-254-3153. A vacant

land owner that has owned property in the HOA's purported boundaries for a long time. Has



30



97. Walt Hoffman, 7626 W. Mountain Top Rd, Herriman, UT 84096; 801-915-0033.

Lives within the HOA's purported boundaries. Is a realtor and has sold many properties inside the

HOA. Has knowledge about the HOA, how it is governed, its history, its enforcement, its actions

towards HOA members, assessments, its roads and its meetings. Has knowledge of properties and

values in the area.

98. Jeremy Honeycutt, 7741 Country View Ln, Herriman, UT 84096; 801-502-9444.

Lives within the HOA's purported boundaries. Was an HOA Director for the approximate years

of 2011-2014. Has knowledge about the HOA, how it is governed, its documents, its history, its




knowledge of the HOA's budgets, expenditures and financials.

99. Ingrid Rauter, 7831 W. Country View Lane, Herriman, UT 84096; telephone

unkown. A resident that lives within the HOA's purported boundaries. Has knowledge of the

HOA, how it has governed, its actions towards HOA members and its meetings. Has information

about mailers sent to HOA members.

100. Stanley Manning, 4071 N. Imperial Way, Provo, UT 84604; 801-434-7282. A




31



101. Mike Bruun, P. O. Box 572, San Juan Bautista, CA 95045; 831-245-9687. A vacant

land owner in the HOA's purported boundaries. Has knowledge of the HOA, how it has governed,




102. Agents or Principals of Mascaro Family Limited Partnership, 4091 W 12600 S,

Riverton, UT 84096; telephone unkown. Owns property inside the HOA's purported boundaries.

Has knowledge about the formation of the HOA. Has knowledge about the HOA, how it is


assessments, its water rights, its roads, its amendments to governing documents, its elections, its


extensive knowledge of the HOA's road construction, road maintenance and snow removal. Has

knowledge of the land and the area before the HOA was formed.

103. Sue Huether, PO Box 32, Driggs, ID 83422; telephone unkown. Owned property

in the HOA's purported boundaries for many years. Has knowledge of the HOA, how it has




conduct.

32

104. Agents or Principals of Jordan Acres, PO Box 352, Torrey, UT 84775; 435-491-

1018. A vacant land owner that has owned property in the HOA's purported boundaries for many

years. Has knowledge of the HOA, how it has governed, its documents, its history, its




105. Lawrence Webber, PO Box 40, Overton, NV 89040; 702-968-6541. A vacant land

owner that has owned property in the HOA's purported boundaries for a long time. Has knowledge



owners, its collection practices, its meetings and vote counting. Has knowledge of the HOA's

illegal and oppressive conduct.

106. Agents or Principals of SMR LLC, PO Box 621, Draper, UT 84020; telephone

unkown. A vacant land owner in the HOA's purported boundaries. Has knowledge of the HOA,

how it has governed, its documents, its history, its enforcement, its actions towards HOA members,



conduct.

107. Shane Hughes, address unknown; 801-631-7653. A resident that has lived in the

HOA's purported boundaries since 2014. Has knowledge of the HOA, how it has governed, its

actions towards HOA members and its meetings. Has information about mailers sent to HOA

members.

33

108. Richard Hunt, address unknown, Jackson, WY 83001; telephone unkown. Has

knowledge about the formation of the HOA. Has knowledge about the original Covenants,


HOA.

109. Rick Andrus, address unknown; telephone unkown. HOA past board member from

1995-2001, 2004-2007. Has knowledge about the HOA, how it is governed, its documents, its




knowledge of the HOA's budgets, expenditures and financials. While a board member, oversaw

all HOA assets and bank accounts and approved expenditures. Has knowledge of the sale of the

water rights. Has information about other HOA board members and their actions.

110. Agents or Principals of the State of Utah, Division of Corporations and Commercial

Code; 160 E. 300 S. 2nd Floor, Salt Lake City, UT 84111; 801-530-4849. Has information about

the HOA’s entity filings, including the HOA’s purported Articles and subsequent amendments.

Has information about all entity filings and entity names in the State of Utah. Has information

about the legal requirements for entities in the State of Utah.

111. Agents or Principals of Salt Lake County, 2001 South State Street, Salt Lake City,

UT 84114; 385-468-8145. Has information about the actions of the HOA Board in the Hi-Country

Estates Phase II area. Has information about illegal recordings (Covenants and Bylaws) on

properties in and around the purported HOA boundaries. Has information about ownership of

properties and documents recorded against such properties. Has information about tax values of

34

properties inside and outside of HOA boundaries. Has information about FCOZ and the HOA

Boards involvement with that ordinance. Has information about greenbelt of properties inside the

purported HOA boundaries and the HOA Boards actions with the greenbelt status of these

properties. Has information about the illegal subdivision of Hi-Country Estates Phase II. Has

information about any meetings between the HOA Board (and Arlene Johnson) and employees of

Salt Lake County regarding the area of Hi-Country Estates, Phase II. Has information about the

zoning, the HOA Boards involvement with the zoning of the area and land use of the area of Hi-

Country Estates, Phase II. Has information about plat maps of the area of Hi-County Estates,

Phase II.

112. Agents or Principals of the Unified Police Greater Salt Lake, 3365 South 900 West,

Salt Lake City, UT 84119; 385-468-9901. Has information about police reports in the HOA area

including information about trespassing, HOA meetings, crimes and claims made against HOA

members and HOA Board members.

113. Agents or Principals of the Unified Fire Authority, 3380 S. 900 W., Salt Lake City,

UT 84119; 801-743-7200. Has information about the fire hazards of the area commonly known

as Hi-Country Estates, Phase II, HOA. Has information about the exits and egress from the HOA

if there were a major fire or emergency. Has information about how the HOA has dealt with past

wildfires in the area. Has information about the HOA board and their past safety plans in the

HOA.

Rule 26 (a)(1)(A)(i). The following list of individuals have discoverable information and

may be called to testified at trial.

35

1. Agents or Principals of Herriman City, 13011 S. Pioneer Street, Herriman, UT

84096; telephone unknown. Has information about the HOA and issues in this action. Has

information about the sale of the water rights to Herriman City.

2. Agents or Principals of Eide Bailly, 6695 S. 1300 E., SLC, UT 84121; telephone

unknown. Hired by the HOA to do an annual audit in 2013. Has knowledge of the HOA's budgets,

expenditures and financials.

3. Agents or Principals of FJ & Associates, PLLC, 1284 W. Flint Meadow Dr. Ste

D, Kaysville, UT 84037; telephone unknown. Hired by the HOA to do an annual audit in 2014.

Has knowledge of the HOA's budgets, expenditures and financials.

4. Agents or Principals of Lake, Hill & Myers, 6695 S. 1300 E., SLC, UT 84121;

telephone unknown. Hired by the HOA to do an annual audit in 2011 & 2012. Has knowledge of

the HOA's budgets, expenditures and financials.

5. Agents or Principals of Child, Sullivan & Company, 1284 W. Flint Meadow Dr.

Suite D, Kaysville, UT 84037; telephone unknown. Hired by the HOA to do an annual audit in

2001-2005. Has knowledge of the HOA's budgets, expenditures and financials.

6. Agents or Principals of Child, Van Wagoner & Bradshaw, PLLC, 1284 W. Flint

Meadow Dr. Suite D, Kaysville, UT 84037; telephone unknown. Hired by the HOA to do an

annual audit in 2006. Has knowledge of the HOA's budgets, expenditures and financials.

7. Agents or Principals of Armstrong & Company, 4541 S. 700 E. Suite 200, SLC,

UT 84107; telephone unknown. Hired by the HOA to do an annual audit in 1997-2000 & 2007.

Has knowledge of the HOA's budgets, expenditures and financials.

36

8. Agents or Principals of Johnson & Semken, CPAs, PC, 4885 S 900 E, Suite 203,

Murray, UT 84117; telephone unknown. The HOA's CPA for at least one year. Has knowledge

of the HOA's budgets, expenditures and financials. Has audited the HOA's financials in 2013.

May have counted HOA votes for elections and amendments for several years. May have

knowledge of how the HOA has counted and not counted votes of certain members. May have

knowledge of the changes in vote counting procedures through the years.

9. Agents or Principals of Armstrong, Johnson & Semken, LLC, 4541 S. 700 E. Suite

200, SLC, UT 84107; 801-263-1040. The HOA's CPA for several years. Has knowledge of the

HOA's budgets, expenditures and financials. Has audited the HOA's financials many times. Has

counted HOA votes for elections and amendments for several years. Has knowledge of how the

HOA has counted and not counted votes of certain members. Has knowledge of the changes in

vote counting procedures through the years.

10. Wendy Crowther, 201 S. Main Street, Suite 1800, SLC, UT 84111; telephone

unknown. Has information regarding the negotiation and sale of the HOA's water rights to

Herriman City.

11. Agents or Principals of Ducks Property Management, 11576 S. State #1002,

Draper, UT 84020; 801-243-9572. Vacant land owner in the HOA's purported boundaries. Has

information about the HOA, financials, voting, HOA actions against owners, assessments,

collections, meetings & road maintenance. Has knowledge of the HOA's illegal and oppressive

conduct.

12. Agents or Principals of Royal Canyon LC, 11576 S. State St. #204, Draper, UT

84020; 801-243-9514. Vacant land owner in the HOA's purported boundaries. Has information

37

about the HOA, financials, voting, HOA actions against owners, assessments, collections,

meetings & road maintenance. Has knowledge of the HOA's illegal and oppressive conduct.

13. Agents or Principals of the South Valley Sewer District, 1253 West Jordan Basin

Lane, Bluffdale, UT 84065; telephone unknown. Has knowledge about the sewer studies that have

been done in the area of the HOA. Has knowledge of the sewer grant funds that were available in

2010.

14. Agents or Principals of Bureau of Land Management, Utah State Office, 440 W.

200 S., Suite 500, SLC, UT 84101; 801-539-4001. Has information about the HOA, the BLM

lands next to the HOA and any trespassing infringements. Also has information about any leases

and/or easements on BLM land. May have knowledge of the HOA's illegal and oppressive

conduct.

15. Linda Stringer, 10182 S Chattel Circle, South Jordan, UT 84095; 801-618-6259.

Vacant land owner in the HOA's purported boundaries. Has information about the HOA,

financials, voting, HOA actions against owners, assessments, collections, meetings & road

maintenance. May have knowledge of the HOA's illegal and oppressive conduct.

16. Alan Nielson, 11522 E Madero Ave, Mesa, AZ 85209; 480-659-1780. Vacant land

owner in the HOA's purported boundaries. Has information about the HOA, financials, voting,

HOA actions against owners, assessments, collections, meetings & road maintenance. May have


17. Tarlton Blair, 1154 W 560 N, Orem, UT 84057; telephone unknown. Vacant land


38



18. Jared Bramwell, 11576 S. State #1002, Draper, UT 84020; 801-243-9572. Vacant

land owner in the HOA's purported boundaries. Has information about the HOA, financials,

voting, HOA actions against owners, assessments, collections, meetings & road maintenance. May

have knowledge of the HOA's illegal and oppressive conduct.

19. Ryan Kelly, 11576 S. State #1002, Draper, UT 84020; 801-243-9572. Vacant land




20. Mike Huber, 11576 S. State St. #204, Draper, UT 84020; 801-243-9514. Vacant


voting, treatment from the HOA, assessments, collections, meetings & road maintenance. Has

information about septic and sewer systems in the area. Has knowledge of the HOA's illegal and

oppressive conduct.

21. David Yates, 1213 W. Jordan River Drive, South Jordan, UT 84095; 801-558-2805.



maintenance. Has knowledge of the HOA's illegal and oppressive conduct.

22. Tim Yates, 1213 W. Jordan River Drive, South Jordan, UT 84095; 801-558-2805.


39



23. Neil Yates, 1213 W. Jordan River Drive, South Jordan, UT 84095; 801-558-2805.




24. Agents or Principals of Equity Property Management, 1218 E. 7800 S. #150,

Sandy, UT 84094; telephone unknown. Manages a house in the HOA's purported boundaries. Has



conduct.

25. Ann Mathis, 1218 E. 7800 S. #150, Sandy, UT 84094; telephone unknown. Owns

a house in the HOA's purported boundaries. Has information about the HOA, financials, voting,



26. Max Wheelright, 1218 E. 7800 S. #150, Sandy, UT 84094; telephone unknown.

Owns a house in the HOA's purported boundaries. Has information about the HOA, financials,



27. Agents or Principals of 15273 Rose Canyon LLC, 1250 E. 3900 S. #310, Salt Lake

City, UT 0; 801-263-2020. Vacant land owner in the HOA's purported boundaries. Has


40

collections, meetings & road maintenance. May have knowledge of the HOA's illegal and

oppressive conduct.

28. Francis Wapner, 1250 E. 3900 S. #310, Salt Lake City, UT 0; 801-263-2020.




29. Mike Foerester, 1253 West Jordan Basin Lane, Bluffdale, UT 84065; telephone

unknown. Has knowledge about the sewer studies that have been done in the area of the HOA.

Has knowledge of the sewer grant funds that were available in 2010.

30. Verne Stein, 1270 E Vintage Lane, SLC, UT 84124; 801-486-1437. Vacant land


HOA actions against owners, assessments, collections, meetings & road maintenance. Has


31. Bryn McCarty, 13011 S. Pioneer Street, Herriman, UT 84096; telephone unknown.

Has information about the HOA, its dealings with its members, its dealings with Herriman City

and the sale of the water rights to Herriman City.

32. Blake Thomas, 13011 S. Pioneer Street, Herriman, UT 84096; telephone unknown.

May have information about the HOA, its dealings with its members, its dealings with Herriman

City and the sale of the water rights to Herriman City.

33. Brett Wood, 13011 S. Pioneer Street, Herriman, UT 84096; telephone unknown.

Has information about the HOA, its dealings with its members, its dealings with Herriman City

and the sale of the water rights to Herriman City.

41

34. Carmen Freeman, 13011 S. Pioneer Street, Herriman, UT 84096; telephone

unknown. Has information about the HOA, its dealings with its members, its dealings with

Herriman City and the sale of the water rights to Herriman City.

35. Agents or Principals of Granda Real Estate LLC, 1348 W. 4800 S., Taylorsville,

UT 84123; 801-792-3119. Vacant land owner in the HOA's purported boundaries. Has


collections, meetings & road maintenance. May have knowledge of the HOA's illegal and

oppressive conduct.

36. Grant Mackay, 1348 W. 4800 S., Taylorsville, UT 84123; 801-792-3119. Vacant




37. Victor Chavez, 13602 S. Blayde Dr, Herriman, UT 84096; 801-680-2225. Vacant




38. Gary Mickelsen, 13955 S. Maple Hollow Cir, Draper, UT 84020; 801-641-7508.


financials, voting, treatment from the HOA, assessments, collections, meetings & road

maintenance. Has information about some of the installation of roads and/or water system in the

HOA. Has knowledge of the HOA's illegal and oppressive conduct.

42

39. Kim Mickelsen, 13955 S. Maple Hollow Cir, Draper, UT 84020; 801-641-7508.



maintenance. Has information about some of the installation of roads and/or water system in the

HOA. Has knowledge of the HOA's illegal and oppressive conduct.

40. Joshua Hansen, 14121 S Murdoch Peak Dr, Riverton, UT 84096; 801-652-3573.




41. Brooklyn Hansen, 14121 S Murdoch Peak Dr, Riverton, UT 84096; 801-652-3573.




42. Joel Eberhard, 14277 S. Shaggy Mt. Road, Herriman, UT 0; 801-253-3363. Lives

within the HOA's purported boundaries. Has information about the HOA, financials, voting, HOA

actions against owners, assessments, collections, meetings & road maintenance. May have


43. Kevin Capito, 14314 S. Shaggy Mt. Rd., Herriman, UT 0; telephone unknown.

Lives within the HOA's purported boundaries. Has served on the ACC in the past. Has


collections, meetings & road maintenance.

43

44. Jeanmarie Sears, 14352 S. Shaggy Mountain Road, Herriman, UT 0; 801-759-

0237. Lives within the HOA's purported boundaries. Has information about the HOA, financials,



45. Jamie Hayward, 14359 S. Muirwood Circle, Herriman, UT 84096; 801-253-3461.




46. Tyler Martin, 14391 S. Fox Creek Drive, Herriman, UT 84096; 801-870-8686.




47. Charles Moon, 14480 S. Rose Canyon Road, Herriman, UT 0; 801-254-3401.

Lives within the HOA's purported boundaries. Has information about the HOA, financials, voting,

HOA actions against owners, assessments, collections, meetings & road maintenance.

48. Roger Rostrom, 14502 S. Rose Canyon Road, Herriman, UT 0; 801-254-3804.




49. Sheryl Rostrom, 14502 S. Rose Canyon Road, Herriman, UT 0; 801-254-3804.


44



50. Adam Myers, 3274 Star Fire Rd, South Jordan, UT 84095; 801-302-0636. Vacant


voting, HOA actions against owners, assessments, collections, meetings & road maintenance. Has


51. Arthur Kriss, 2398 W. 1050 N., Hurricane, UT 84737; telephone unknown. Owned

land in the HOA's purported boundaries. Has information about the HOA, financials, voting, HOA

actions against owners, assessments, collections, meetings & road maintenance. Has knowledge

of the HOA's illegal and oppressive conduct.

52. Catherine Gilmore, 3798 E. Clubhouse Lane, Eagle Mountain, UT 84005; 801-789-

6870. Vacant land owner in the HOA's purported boundaries. Has information about the HOA,



53. Clare & Ila Bishop, address unknown; telephone unknown. Owned land in the

HOA. Has information about the HOA, financials, voting, HOA actions against owners,

assessments, collections, meetings & road maintenance. Has knowledge of the HOA's illegal and

oppressive conduct.

54. Cordell Peters, address unknown; telephone unknown. HOA past board member

from 2000-2001. Has information about the HOA and the HOA's financials. Has information


45

55. Dan Gorney, address unknown; telephone unknown. HOA past board member



56. Dan McCampbell, 8061 W. Country View Lane, Herriman, UT 0; 510-388-0885.



57. Daphne Whitworth (Draper), 2805 W. 8870 S., West Jordan, UT 84088; 801-569-




58. Donald Paullet, 3392 E. Mile High Dr., Salt Lake City, UT 84124; 801-466-3282.




59. Donna Soto, 3392 E. Mile High Dr., Salt Lake City, UT 84124; 801-466-3282.




60. Ed MacCauley, address unknown; telephone unknown. Has knowledge about the

sewer studies that have been done in the area of the HOA. Has knowledge of the sewer grant funds

that were available in 2010.

46

61. Ed Huish, address unknown; telephone unknown. HOA past board member from

1986-1994. Has information about the HOA and the HOA's financials. Has information about


62. Ed Heintz, address unknown; telephone unknown. HOA past board member from



63. Edgar Ferrera-Grand, 24405 Mockingbird Place, Lake Forest, CA 92630; 949-951-




64. Gary Evans, address unknown; telephone unknown. HOA past board member from



65. George Holling, address unknown; telephone unknown. HOA past board member



66. Gus Colovos, 8727 Oakcrest Place N.W., Albuquerque, NM 87114; 505-897-2309.

Vacant land owner in the HOA's purported boundaries. Was an HOA Board member from 1983-

1984. Has information about the HOA, financials, voting, HOA actions against owners,

assessments, collections, meetings & road maintenance. Has information about other HOA board

members and their actions. May have knowledge of the HOA's illegal and oppressive conduct.

47

67. Guy Dake, 4415 S 1600 W, Hurricane, UT 84737; 435-669-8820. Vacant land




68. Harvey Heed, address unknown; telephone unknown. HOA past board member



69. J. Lynne Crane, address unknown; telephone unknown. Past Herriman City Mayor.

Has information about the HOA, the sale of the water rights to Herriman City and the sewer grant

funds.

70. James Garland, 3255 E. Seven Springs Dr, Sandy, UT 0; 801-661-4824. Owns a

house in the HOA's purported boundaries. Has information about the HOA, financials, voting,



71. James Wade, 51 N. East Ridge Drive, St. George, UT 84790; 435-632-5130.

Vacant land owner in the HOA's purported boundaries. Was on the HOA board from 1986-1988.

Has information about the HOA, financials, voting, treatment from the HOA, assessments,

collections, meetings & road maintenance. Has information about other HOA board members and


72. Jared Laudie, 5336 W Rolling Brook Dr, Herriman, UT 84096; 801-598-1523.


48



73. Jay Ehlers, 4052 E Mirror Lake Hwy, Kamas, UT 84036; 702-565-3074. Vacant




74. Jesse Peacock, address unknown; telephone unknown. HOA past board member


about other HOA board members and their actions. May have knowledge of the HOA's illegal and

oppressive conduct.

75. Jim Ling, address unknown; telephone unknown. HOA past board member from


other HOA board members and their actions. May have knowledge of the HOA's illegal and

oppressive conduct.

76. Joe Schivala, address unknown; telephone unknown. HOA past board member



oppressive conduct.

77. John Scivally, address unknown; telephone unknown. HOA past board member



oppressive conduct.

49

78. John Soule, address unknown; telephone unknown. HOA past board member from



oppressive conduct.

79. Joshua E. Mills, address unknown; telephone unknown. Past Herriman City

Mayor. Has information about the HOA, the sale of the water rights to Herriman City and the

sewer grant funds.

80. Jules Soto, 3392 E. Mile High Dr., Salt Lake City, UT 84124; 801-466-3282.




81. Kim Buchholdt, address unknown; telephone unknown. Owned land in the HOA.

Has information about the HOA, financials, voting, HOA actions against owners, assessments,


conduct.

82. Kirk Jensen, 2818 W. Whitehall Dr., WVC, UT 84119; 801-968-3827. Vacant land




83. Kurt Haeker, 3315 38th Street West, Billings, MT 59102; 406-425-2521. Vacant


50



84. Larry Green, address unknown; telephone unknown. HOA past board member



oppressive conduct.

85. Layne Johnson, address unknown; telephone unknown. HOA past board member



oppressive conduct.

86. Lee McKinzey, address unknown; telephone unknown. HOA past board member



oppressive conduct.

87. Lloyd McMahan, address unknown; telephone unknown. Vacant land owner in the

HOA's purported boundaries. Has information about the HOA, financials, voting, HOA actions

against owners, assessments, collections, meetings & road maintenance. Has knowledge of the


88. Marty Griffis, 2296 W. Saddleback View Cir, Bluffdale, UT 84065; 801-254-1279.




51

89. Marty Philips, address unknown; telephone unknown. HOA past board member



oppressive conduct.

90. Maw-Shyong Gene Jenn, 3759 E. Catamount Ridge Way, Sandy, UT 84092; 801-

944-3941. Vacant land owner in the HOA's purported boundaries. Has information about the

HOA, financials, voting, HOA actions against owners, assessments, collections, meetings & road


91. Molly Dumas, 300 E Kimballs Ln, Draper, UT 84020; 801-984-7659. Vacant land




92. Nancy Bill, 5085 67th St., San Diego, CA 92115; 801-446-1798. Owns a house in

the HOA's purported boundaries. Has information about the HOA, financials, voting, HOA actions

against owners, assessments, collections, meetings & road maintenance.

93. Paul Jacobik, 5702 Karalynn Ct., Herriman, UT 84096; 801-302-8597. Vacant land

owner in the HOA's purported boundaries. Was on the ACC for a few years. Has information

about the HOA, financials, voting, treatment from the HOA, assessments, collections, meetings &

road maintenance. Has knowledge of the HOA's illegal and oppressive conduct.

94. Rafael Aguilar, 8145 Dartmoor Ave, Las Vegas, NV 89129; 702-655-2450. Vacant


52



95. Rhea Black, 417 Harding Ave, Livermore, CA 94550; 925-447-8338. Vacant land




96. Richard Anderson, address unknown; telephone unknown. HOA past board

member from 1994-1997, 2000-2001. Has information about the HOA and the HOA's financials.

Has information about other HOA board members and their actions. May have knowledge of the


97. Rick Stubbs, 5425 E Mornings Star Rd, Cave Creek, AZ 85331; 801-446-5652.




98. Ron Graham, address unknown; telephone unknown. HOA past board member



oppressive conduct.

99. Shane Housekeeper, address unknown; telephone unknown. HOA past board

member from 2000-2002. Has information about the HOA and the HOA's financials. Has

information about other HOA board members and their actions. May have knowledge of the


53

100. Sheldon Peipenburg, address unknown; telephone unknown. HOA past board

member from 1993-1994. Has information about the HOA and the HOA's financials. Has

information about other HOA board members and their actions. May have knowledge of the


101. Sid Furr, address unknown; telephone unknown. HOA past board member from



oppressive conduct.

102. Svetlana Kopytkovskiy, address unknown; telephone unknown. Has knowledge

about the sewer studies that have been done in the area of the HOA. Has knowledge of the sewer

grant funds that were available in 2010.

103. Terry Shobe, address unknown; telephone unknown. HOA past board member



oppressive conduct.

104. Todd Borthick, address unknown; telephone unknown. HOA past board member



oppressive conduct.

105. Todd Beckstrand, 7803 164th St. East, Payallup, WA 98375; 253-604-4412.


54



106. Tom Atkins, address unknown; telephone unknown. HOA past board member



oppressive conduct.

107. Valgene Black, 417 Harding Ave, Livermore, CA 94550; 925-447-8338. Vacant




108. Van Brimhall, address unknown; telephone unknown. HOA past board member


about other HOA board members and their actions. Has information about other HOA board

members and their actions. May have knowledge of the HOA's illegal and oppressive conduct.

109. Wendy Paullet, 3392 E. Mile High Dr., Salt Lake City, UT 84124; 801-466-3282.




110. Agents or Principals of Skaggs Catholic Center LLC, 300 E Kimballs Ln, Draper,

UT 84020; 801-984-7659. Vacant land owner in the HOA's purported boundaries. Has


55


conduct.

111. Agents or Principals of Carefree Homes Inc, 3260 S. Redwood Rd., West Valley

City, UT 84119; 801-604-2661. Vacant land owner in the HOA's purported boundaries. Has



conduct.

112. Agents or Principals of Quality for Animallife Inc, 6037 S Highland Dr #2,

Holladay, UT 84121; telephone unknown. Owns property in the HOA's purported boundaries.

Has information about the HOA, financials, voting, HOA actions against owners, assessments,


113. Agents or Principals of Salt Lake County Real Estate Department # S3200, PO

Box 144575, Salt Lake City, UT 84114; telephone unknown. Has information about the HOA,

assessments and collection practices.

114. Travis Peterson, 8145 Dartmoor Ave, Las Vegas, NV 89129; 702-655-2450.




115. Attila Varszegi, 14508 S. Shaggy Mountain Rd., Herriman, UT 0; 801-446-5512.



56

116. Melinda Varszegi, 14508 S. Shaggy Mountain Rd., Herriman, UT 0; 801-446-5512.



117. David Rostrom, 14520 S. Rose Canyon Rd, Herriman, UT 0; 801-254-5326. Lives


actions against owners, assessments, collections, meetings & road maintenance. May have


118. Kayleen Rostrom, 14520 S. Rose Canyon Rd, Herriman, UT 0; 801-254-5326.




119. David Rostrom, 14546 S. Rose Canyon Road, Herriman, UT 0; 801-254-5917.




120. Stephen Howe, 14594 S. Rose Canyon Road, Herriman, UT 0; 801-254-4221.




121. Susan Sterner-Howe, 14594 S. Rose Canyon Road, Herriman, UT 0; 801-254-


voting, HOA actions against owners, assessments, collections, meetings & road maintenance.

57

122. Douglas Crane, 14643 Rose Creek Lane, Herriman, UT 84096; 801-446-0573.




123. David Joseph, 14643 S Juniper View Dr, Herriman, UT 84096; 801-414-3060.




124. Jim Gust, 14666 S Desert Sage Dr, Herriman, UT 84096; 801-381-0274. Vacant




125. Richard Mittelstaedt, 14675 S. Rose Canyon Rd, Herriman, UT 0; 801-253-0645.



126. Sydney Morganson, 14700 S. Rose Creek Lane, Herriman, UT 0; 801-254-1262.

Lives within the HOA's purported boundaries. Was on the HOA board from 1990-1994. Has



their actions. May have knowledge of the HOA's illegal and oppressive conduct.

58

127. Dennis Moore, 14715 S. Rose Canyon Rd, Herriman, UT 0; 801-253-4691. Lives


actions against owners, assessments, collections, meetings & road maintenance.

128. Dale Kenison, 14768 S. Rose Creek Lane, Herriman, UT 0; 801-253-6549. Lives



129. Carolee Kenison, 14768 S. Rose Creek Lane, Herriman, UT 0; 801-253-6549.



130. Michael Adler, 14777 Shaggy Mountain Rd, Herriman, UT 0; telephone unknown.




131. David Murphy, 14829 Rose Canyon Rd, Herriman, UT 84096; telephone unknown.



132. Doug Winlow, 14876 S. 7460 W., Herriman, UT 84096; 801-557-7828. Lives



133. Raymond Coleman, 14950 Rose Creek Lane, Herriman, UT 0; 801-446-1474.



59

134. Agents or Principals of Heaton Property Investments, 15 W South Temple St.

#1700, Salt Lake City, UT 84101; 801-524-1000. Vacant land owner in the HOA's purported

boundaries. Has information about the HOA, financials, voting, HOA actions against owners,

assessments, collections, meetings & road maintenance. May have knowledge of the HOA's illegal

and oppressive conduct.

135. Jon Heaton, 15 W South Temple St. #1700, Salt Lake City, UT 84101; 801-524-




136. Maureen Gaspari, 15028 S. Rose Creek Lane, Herriman, UT 0; telephone unknown.



137. Fred Johnston, 15053 S. Shaggy Mountain Road, Herriman, UT 0; 801-253-9846.

Lives within the HOA's purported boundaries. Has served on the ACC in the past. Has



138. Patrick Beckstead, 15067 S. Rose Creek Lane, Herriman, UT 0; 801-808-4239.



139. Michael Morgan, 15090 S. Rose Canyon Rd, Herriman, UT 0; 801-446-8010.



60

140. Jeffrey Ohlson, 15095 S. Rose View Lane, Herriman, UT 0; 801-253-0922. Lives

within the HOA's purported boundaries. Has served on the ACC in the past. Has information


meetings & road maintenance.

141. Edward Taylor, 15101 S. Step Mountain Rd, Herriman, UT 0; 801-302-5655. Lives



142. Steven Riggs, 15103 S. Step Mountain Road, Herriman, UT 0; 801-253-3011.



143. Nancy McGahey, 15140 S. Shaggy Mountain Road, Herriman, UT 0; 801-254-



144. Russell Vance, 15152 S. Rose Canyon Rd, Herriman, UT 0; telephone unknown.



145. Jeffrey Dumas, 1517 W 12950 S, Riverton, UT 84065; 801-699-5943. Owns a lot

in the HOA's purported boundaries (house previously burned down from a wildfire). Has


collections, meetings & road maintenance. Has information about fire hazards and safety hazards

in the HOA. May have knowledge of the HOA's illegal and oppressive conduct.

61

146. Elon Mangelson, 15170 S. Rose Canyon Rd, Herriman, UT 84096; 801-254-4852.



147. Georgia Strickling, 15448 S. Arnold Hollow Road, Herriman, UT 0; 801-253-1523.



148. Thais Ruiz, 15560 S. Rose Canyon Rd., Herriman, UT 84096; telephone unknown.



149. John Shields, 15605 S. Rose Canyon Road, Herriman, UT 0; 801-254-6326. Lives



150. Joseph Snyder, 15621 S. Rose Canyon Road, Herriman, UT 0; telephone unknown.



151. James Fike, 15628 S. Rose Canyon Road, Herriman, UT 0; 801-254-2580. Lives



152. Laverl Roberts, 15649 S. Rose Canyon Road, Herriman, UT 0; 801-253-9734.



62

153. Lyle Hansen, 15959 S. Step View Lane, Herriman, UT 0; 801-446-6846. Lives

within the HOA's purported boundaries. Was an HOA board member from 1999-2000. Has



their actions.

154. Steven Shields, 16043 S. Step View Lane, Herriman, UT 84096; 801-446-6736.



155. Scott Weber, 1605 W. 12100 S., Riverton, UT 84065; 801-254-6474. Vacant land




156. Joseph Diaz, 16082 S. Arnold Hollow Road, Herriman, UT 84096; 801-280-8616.



157. Jeremy Franc, 16142 S. Arnold Hollow Road, Herriman, UT 0; 801-856-0775.



158. Jeremy Martinez, 16168 S. Step View Ln, Herriman, UT 0; 801-446-2784. Lives



63

159. Kimberly Martinez, 16168 S. Step View Ln, Herriman, UT 0; 801-446-2784. Lives



160. Per-ole Danfors, 1853 N. 110 E., Lehi, UT 84043; 801-598-0513. Vacant land




161. Cassie Danfors, 1853 N. 110 E., Lehi, UT 84043; 801-598-0513. Vacant land




162. Brent Smith, 1897 W. 13035 S., Riverton, UT 84065; 801-254-2461. Vacant land




163. Thale Ostler, 2146 E. Lambourne Ave, Salt Lake City, UT 84109; 801-484-5793.




164. Roger Roylance, 216 E. Coatsville Ave, SLC, UT 84115; 801-509-0917. Vacant


64



165. Thad Torres, 216 E. Coatsville Ave, SLC, UT 84115; 801-509-0917. Vacant land




166. Kim Een, 217 S. Torrey Pines Dr, Las Vegas, NV 89107; 702-877-2134. Owned

vacant land in the HOA's purported boundaries for many years. Has information about the HOA,



167. Rhonda Larsen, PO Box 40, Overton, NV 89040; 702-968-6541. Vacant land




168. Rosemary Meyers, 7240 W. Cole Creek Ct, Herriman, UT 0; 801-254-2749. Lives



169. Timothy Beagley, 7521 W 14000 S, Herriman, UT 84096; 801-254-3153. Vacant




65

170. Melissa Beagley, 7521 W 14000 S, Herriman, UT 84096; 801-254-3153. Vacant




171. Heber Beagley, 7521 W 14000 S, Herriman, UT 84096; 801-254-3153. Vacant




172. Bret Timmins, 7489 W. 14900 S., Herriman, UT 0; 801-254-6623. Lives within



173. Marcia Wendorf, 7489 W. 14900 S., Herriman, UT 0; 801-254-6623. Lives within



174. Agents or Principals of Sterling Trust Company, PO Box 1285, Bountiful, UT

84011; 801-295-8568. Vacant land owner in the HOA's purported boundaries. Has information


meetings & road maintenance. Has knowledge of the HOA's illegal and oppressive conduct.

175. Gregory Diven, PO Box 1285, Bountiful, UT 84011; 801-295-8568. Vacant land




66

176. Kimberlie Smith, 7246 W. Juniper Tree Cove, Herriman, UT 0; 801-302-7235.



177. James Anderson, 7879 W. Shaggy Mountain Road, Herriman, UT 0; 801-302-



178. Jerald Jolley, 7775 W. Mountain Top Road, Herriman, UT 0; 801-440-8069. Lives



179. Sheila Hardwick, 6168 W. 13900 S., Herriman, UT 84096; 801-446-0341. Vacant




180. Eric Balazs, 7588 W. Rodeo Creek Ct., Herriman, UT 0; 801-446-4432. Lives



181. Thomas Giallorenzi, 7 S Dawn Hill, Sandy, UT 0; 801-446-7305. Owns a house

in the HOA's purported boundaries. Has information about the HOA, financials, voting, HOA


182. Alma Biesinger, 7871 W. Shaggy Mountain Road, Herriman, UT 0; 801-446-7978.



67

183. Richard Brown, 7539 W. 14900 S., Herriman, UT 0; 801-446-9132. Lives within



184. Wyatt Thurman, 7247 W. Juniper Tree Cove, Herriman, UT 0; 801-446-9529.



185. Haruo Miyagi, 702 Hobble Creek Canyon, Springville, UT 84663; 801-491-4299.




186. Bob Pruitt, PO Box 683789, Park City, UT 84068; 801-518-9009. Vacant land



187. Ron Case, 9288 S Jana Lee Dr., West Jordan, UT 84088; 801-573-7663. Vacant




188. Bruce Cockrell, 916 E. Cherry Wood Cir, Draper, UT 84020; 801-576-0740.



maintenance.

68

189. Douglas McKinley, PO Box 457, Mesquite, NV 89024; 801-792-2904. Vacant



190. Jerry Dearinger, 7853 W. Shaggy Mountain Rd, Herriman, UT 84096; 801-796-

1777. Owns a home in the HOA's purported boundaries. Has information about the HOA,


maintenance.

191. Vickie Zelch, P. O. Box 877, Riverton, UT 84065; 801-808-3757. Vacant land




192. Melanie Shellabarger, 8107 W. Country View Lane, Herriman, UT 84096; 801-

856-3505. Lives within the HOA's purported boundaries. Has information about the HOA,


maintenance.

193. Deborah Chindlund, PO Box 1699, Arizona City, AZ 85123; 801-859-9177.



maintenance.

194. Agents or Principals of AE Owners, LLC, 7 Paradise Valley Court, Henderson,

NV 89052; telephone unknown. Owned vacant land in the HOA's purported boundaries for many

years. Has information about the HOA, financials, voting, HOA actions against owners,

69

assessments, collections, meetings & road maintenance. Has knowledge of the HOA's illegal and

oppressive conduct.

195. Michael Nicolosi, 8564 S Cork Oak Dr, West Jordan, UT 84081; telephone

unknown. Recently built a home in the HOA's purported boundaries. Has information about the

HOA, financials, voting, treatment from the HOA, assessments, collections, meetings & road

maintenance. Has information about building in the HOA.

196. Christian Larsen, PO Box 621, Draper, UT 84020; telephone unknown. Vacant




197. Hyrum Weight, PO Box 621, Draper, UT 84020; telephone unknown. Vacant land




198. Beth Macodee, PO BOX 651232, SLC, UT 84165; telephone unknown. Vacant




Rule 26(a)(1)(B)

Plaintiffs produce documents in their possession which they may rely upon in their case-

in-chief herewith, identified as PLTF 000001 - PLTF 012326. These documents are being mailed

on a flash drive. Plaintiffs reserve the right to supplement this production.

70

Rule 26(a)(1)(C)

Plaintiffs are not seeking damages in this action.

Rule 26(a)(1)(D)

Not applicable.

Rule 26(a)(1)(E)

Copies of documents referenced in the Complaint are included in the documents being

produced.

DATED this 29th day of August, 2016.

BRUCE R. BAIRD

/s/ Bruce R. Baird

Bruce R. Baird Attorney for Plaintiffs

71

CERTIFICATE OF SERVICE

I hereby certify that I served the foregoing PLAINTIFFS’ RULE 26 INITIAL DISCLOSURES by

email on August 29, 2016 and mailed the flash drive of documents to:

Jeffrey L. Silvestrini, Esq.

COHNE KINGHORN

111 East Broadway, 11th Floor

Salt Lake City, UT 84111

[email protected]

/s/ Bruce R. Baird

mailto:[email protected]

in the third judicial district court in and for salt lake county, state of utah · 2020. 2. 1. ·...

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