A. Lawful Acquisition of Evidence as Managing Agent

In February 2025, the Sierra del Sol (SDS) HOA Board of Directors determined that the long-term management company, DANA Properties, had no valid contract to provide services or lease to occupy the community clubhouse. To address this governance failure, the Board appointed me as the new Managing Agent for the Association, pursuant to their authority under the SDS Bylaws.

On the morning of February 15, 2025, I acted on this appointment to reclaim the Association's property. To ensure a lawful and transparent process, I requested a civil standby from the El Paso Police Department. With officers present, I lawfully entered the SDS Clubhouse to secure the property and records on behalf of the Association. This action was explicitly authorized by the Bylaws, which grant the Managing Agent the right to enter the property to remedy a breach and state the agent "shall not be deemed guilty in any manner of trespass."

Upon entry, I took possession of numerous business records. All documents and evidence submitted with this complaint were lawfully obtained during the execution of my official duties as Managing Agent.

B. The Catalyst: Animus Directed at Ron Perkins

The conflict began on January 28, 2023, when I publicly questioned the El Mirador HOA's treasurer about 16 years of unpaid dues (Exhibit A). The board's response was not to address the issue, but to hire Mr. Skipworth on February 3, 2023, for the express purpose of pursuing me. His first invoice immediately references "defamation" and a "Letter to laswuit [sic] participants," showing that his engagement was retaliatory from its inception (Exhibit H).

C. Complicity in Unlawful Acts in New Mexico

Mr. Skipworth then provided legal cover for the board's improper actions within New Mexico. He consulted on the secret filing of a 16-year-old, invalid bylaw amendment in Doña Ana County to retroactively excuse the treasurer's debt (Exhibit B, Exhibit J). He also blessed the hiring of DANA Properties at a special meeting that violated New Mexico's statutory notice requirements, admitting the purpose was to "shield the board from obnoxious members" like me (Exhibit C). When I formally notified him of these violations of New Mexico law, he confessed he had "not researched the accuracy" of my claims, demonstrating a clear lack of competence regarding the statutes governing his actions in this state (Exhibit E).

D. The Unauthorized Lawsuit: Animus Transferred to Leticia Trevino

The EMHOA board, his client, established a clear policy on July 15, 2024: no foreclosure lawsuits for balances under $7,500 (Exhibit U). Mr. Skipworth was repeatedly made aware of this policy. However, his animus toward me persisted, as shown in emails where he asked, "When can I sue this guy?" (Exhibit AC). Unable to sue me, he targeted my wife. After his own office confirmed in writing on November 19, 2024, that the case against Leticia Trevino "was not filed" due to the policy (Exhibit AF), Mr. Skipworth personally filed the lawsuit just two days later for an amount far below the board's threshold (Exhibit AG). This was done without the knowledge of his client's designated representative, who testified she believed the matter had been "dropped" (Exhibit AK, p. 152-153). This action was not a legitimate attempt to collect a debt, but a retaliatory act against me, executed by improperly targeting my wife in a New Mexico court.