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 The information contained in this e-mail and in any attached document(s) is CONFIDENTIAL and may be protected by attorney-client privilege and/or the work-product doctrine. The e-mail (and attached document(s)) is intended for use by the person(s) to whom this e-mail is addressed. If you are not the intended recipient, you are hereby notified that any dissemination, distribution, copying, or other use of such e-mail and/or document(s) is strictly prohibited. If you have received this e-mail and/or any attached document(s) in error, please immediately notify us by telephone at (206) 441- 5739.