From:	Michael Brandt [mbrandt@brandtlawgroup.com]
Sent:	Tuesday, April 12, 2011 11:42 AM
To:	William L. Cameron
Cc:	Roger Close; Molly Mueller
Subject:	Close v. Admiral's Cove

Bill:

The following is Roger Close’s counter-offer to the Association’s previous settlement offer:

Roger Close offers to settle the Close v. Admiral’s Cove litigation by either of the following 
alternatives:

(1)      Roger Close and the Association will simply dismiss the litigation with prejudice for the 
payment of 50% ($21,000) of the attorneys’ fees he has incurred in pursuing this matter; or 

(2)      a.  The Board will acknowledge and notify property owners in writing that the 1985 Beach 
Club Bylaws are the current bylaws in effect; and if and when they may be amended, they will 
be amended with the proper procedures, quorum, and vote;
      b.  The Board will acknowledge that the Court had yet to rule regarding whether the 
Association is currently a homeowners association governed by RCW 64.38, and that in order to 
become a homeowners’ association pursuant to RCW 64.38, a 100% affirmative vote of all the 
property owners in the community will be required;
      c.  The Association will record a document indicating that membership in the Beach Club, 
with its attendant assessments are a required part of purchasing a home in the Admiral's Cove 
community; 
              d.  The Association will reimburse Roger Close one-third ($14,000) of his attorneys' fees 
and costs incurred in pursuing this action;
e.  Roger Close and the Association will dismiss the Close v. Admiral's Cove litigation 
with prejudice.

If the Association is unwilling to settle on the basis of either of these alternatives, we will move 
forward with depositions and set the matter for a trial.  Please let me have a response from the 
Association by Friday, April 15th.

Michael D. Brandt
BRANDT LAW GROUP
1200 - 5th Avenue, Suite 1650
Seattle, Washington 98101
206.441.5739
206.654.0011 (fax)
www.brandtlawgroup.com
mbrandt@brandtlawgroup.com
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