The Lawsuit & Exhibits
These are the source documents. Each entry states what the document is, where it came from, and how you can verify it independently. Click any title to open the full PDF.
Sourcing policy. Every document here falls into one of four categories:
(1) documents I authored or received directly; (2) filings in the public court file;
(3) public records from government agencies (Secretary of State, Department of Real Estate, the court);
or (4) documents the Association itself mailed to owners or posted publicly. Nothing here comes
from any confidential, sealed, or non-public source.
Exhibit 1 — The Complaint They Filed
Their words, their law firm, court-stamped November 3, 2025.
“Flores is sued herein both in her individual capacity and as a representative of any members who may share her position regarding the applicability of the Davis-Stirling Common Interest Development Act to R-Wild Horse Ranch.” — Complaint, ¶2
Complaint for Declaratory Relief — Case No. 25CI-000260 (filed Nov. 3, 2025) (PDF, 6.4 MB)
What it is: The lawsuit filed by the Association’s outside law firm (Neumiller & Beardslee) asking the court to declare that the Davis-Stirling Act does not apply to R-Wild Horse Ranch. Names Denise Flores (Breese) and “DOES 1 through 50.”
Source: Public court file, Tehama County Superior Court; electronically-filed stamped copy.
How to verify: Request the case file for No. 25CI-000260 (consolidated with No. 24CI-000010) from the Tehama County Superior Court clerk.
Exhibit 2 — The Decision Behind It
The Board’s own approved minutes announcing the change — never put to a membership vote.
“...the association will no longer operate under Davis-Stirling law and will instead follow its CC&Rs and California Corporate Code sections 7110-8910.” — Minutes, item 16.2
Open Board Meeting Minutes — February 22, 2025 (approved 3/22/25, signed by the Secretary) (PDF, 0.4 MB)
What it is: The Association’s own approved minutes of the February 22, 2025 open meeting — the first meeting with Brian Keating as President (item 3) — announcing at item 16.2 that the Ranch “will no longer operate under Davis-Stirling law.”
Source: Association records distributed to owners.
How to verify: Request the February 2025 open-meeting minutes from the Association office; compare word for word.
Exhibit 3 — The Announcement To Owners
The President’s email, the day after the meeting.
“The Board feels strongly that this clarification will relieve us from some of the burdens the state puts on CID’s and homeowner’s associations.” — Message from the Board President, Feb. 23, 2025
“Message from the Board President” — Association email to owners, February 23, 2025 (PDF, 0.2 MB)
What it is: The Constant Contact email the Association sent to owners announcing it is “not a Common Interest Development (CID) covered by the Davis and Sterling Act,” signed “Brian Keating, President.”
Source: Received directly by the publisher as an owner on the Association’s mailing list; reproduced as received.
How to verify: Any owner on the mailing list received the same message on February 23, 2025; compare against your copy.
Exhibit 4 — What The State’s Records Say
Four decades of government records on what this Association is.
1985 Final Subdivision Public Report (Department of Real Estate) (PDF, 1.3 MB)
What it is: The state-issued public report under which R-Wild Horse Ranch interests were sold, from the year the operative Declaration and Bylaws were adopted. This copy carries the publisher’s reference notations.
Source: California Department of Real Estate public report file No. 010274SA.
How to verify: Request the public report history for file No. 010274SA from the California DRE.
2015 Public Report — 010274SA-A12 (Department of Real Estate) (PDF, 0.4 MB)
What it is: The most recent amended public report in the same DRE file, three decades later — same project, same state oversight.
Source: California Department of Real Estate public report file No. 010274SA.
How to verify: Request the report from the California DRE by file number.
Secretary of State — Common Interest Development record CD-368490 (2021) (PDF, 0.1 MB)
What it is: The Association’s Common Interest Development filing on record with the California Secretary of State.
Source: California Secretary of State public filings.
How to verify: Search the entity at bizfileonline.sos.ca.gov; filings are publicly downloadable.
Secretary of State — Common Interest Development filing (2023) (PDF, 0.1 MB)
What it is: The Association’s 2023 CID filing with the Secretary of State — filed by the Association itself, identifying the Ranch as a common interest development.
Source: California Secretary of State public filings.
How to verify: Search the entity at bizfileonline.sos.ca.gov.
Secretary of State — “data entry error” correspondence (PDF, 0.1 MB)
What it is: Correspondence concerning the alteration of the Association’s classification in state records — and the Secretary of State’s response.
Source: Publisher’s correspondence with the California Secretary of State; public-record subject matter.
How to verify: Contact the Secretary of State regarding entity classification history for the Association.
Exhibit 5 — The Response On File
What one owner filed back — both court-stamped.
Answer to the Complaint — Case No. 25CI-000260 (filed April 8, 2026) (PDF, 1.2 MB)
What it is: The Answer filed in response to the Association’s complaint, including affirmative defenses of estoppel, waiver, unclean hands, and retaliation.
Source: Public court file, Tehama County Superior Court; e-filed stamped copy.
How to verify: Request the file for consolidated case No. 24CI-000010 from the court clerk.
Second Amended Cross-Complaint (filed August 13, 2026) (PDF, 2.7 MB)
What it is: The cross-complaint on file with the court, formally alleging — among other causes — breach of fiduciary duty, wrongful candidate disqualification, open-meeting violations, and unlawful unilateral abandonment of Davis-Stirling status.
Source: Public court file, Tehama County Superior Court; e-filed stamped copy.
How to verify: Request the file for consolidated case No. 24CI-000010 from the court clerk.
2026 Election Materials (as mailed)
Included in the election mailing; reproduced here for reference.
Rebuttal to Candidate Statement of Brian Keating (submitted June 26, 2026)
What it is: The factual rebuttal included in the 2026 election mailing under the Election Guidelines, presented as submitted.
Candidate Statement — Denise Flores (Breese), Owner #2357
What it is: The candidate statement for the 2026 election of directors, presented as submitted.
More documents are being added as they are prepared. To request a copy of anything referenced on this site, use the contact form.