[WSBARP] Homeowner non-compliant with minimal CCRS - need complaint for injunctive relief for cleanup and access

[Rob Rowley]

I need a template/draft complaint for injunctive relief by a homeowners
association against one of its homeowners.  Older CC&Rs are not that
helpful.  Homeowner has a history of allowing large amounts of trash,
garbage and numerous vehicles to be located on the outside of his house
which is in a very expensive waterfront neighborhood.



CCR&s allow for filing of a lien for monetary defaults.  Owner is not in
default of money obligations.



Need something that allows for injunctive relief which would allow the
homeowners association to physically enter the property to clean it up and
either have a judgment or a lien.  Kind of like what happens with city code
enforcement with a recalcitrant homeowner with lots of trash.



I represent numerous homeowners associations and typically advise to file
the lien and wait till the homeowner eventually either sells or refinances
to get paid. Never injunctive relief with poor CCRs.



Thoughts?



*Robert R. Rowley* | Attorney at Law

7 S. Howard St, Suite 218

Spokane, WA  99201

Telephone: (509) 252-5074

Mobile: (509) 994-1143

Facsimile: (509) 928-3084

Email: rob at rowleylegal.com

Web Site: www.rowleylegal.com



Practice concentrated on business, real estate and general legal matters in
Washington and Idaho.



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