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Showing posts from 2025

Cost of Lawsuit Against Philpott

How much is the HOA's lawsuit against Gus Philpott costing? Disregarding for the moment the cost for the August 2024 legal work to send Gus a Cease and Desist Letter, the ball really got rolling in December, when Danny Trapp turned the lawyers loose to file a Summons and Complaint and a Motion for a Temporary Restraining Order or Preliminary Injunction in Richland County Court of Common Pleas. Those were filed on December 28, 2024, along with an Affidavit sworn to by Danny Trapp.  The bills for that legal work should have shown up in January for payment in January or February. In January the HOA paid $530 in Line 6500 (Legal/Professional). In February the HOA paid $305 in Line 6500. Why is the HOA slow-pay on the legal fees, which could reasonably expected to be over $6,000? Invoices forr legal fees might be payable upon receipt or Net 10. Very likely, no longer than Net 30. Is the Board shocked by the legal bills? Wait until they see the bill for the February 11, 2025 Hearing on t...

Line 2330 - February 2025. What is it?

Line 2330 in the monthly financial reports is "SCS Administrative Costs". SCS is one of the CAMS entities. This expense shows up on the Balance Sheet, not on the Income/Expense Report. When I attended the December 2023 Finance Committee meeting, no one knew what costs were included in the monthly amount, which changes every month. As of February 28, 2025 that number surged  to $33,742.38. This Line Item is in the Liabilities Section of the Balance Sheet. However, it doesn't seem to show up as a Paid Expense in the Income/Expense Report. Compare the February 28th amount to prior months. $33,742.38 February 2025 $29,292.38 January 2025 $27,722.38 December 2024 $27,312.38 November 2024 $27,752.38 October 2024 $23,247.38 September 2024 Why did it increase $10,495 (45%) from September to February? One of the problems is that the HOA's "numbers" are never compared with previous months. So nobody notices that the February SCS Administrative Costs are 45% higher tha...

How Could Reserves Increase in Mid-2024?

The following question arises after examination of the February 2025 Financial Overview Report, Page 2. See the graph at the top of that page. Notice that Reserve Accounts totaled approximately $765,000 in February and March, 2024. Two months later, Reserves totaled over $1,000,000. However, the amount budgeted for Reserves in 2024 was Zero. See Line 8000 in the 2024 Budget. Where did that $200,000-plus increase in Reserves come from?

Does Anyone Understand Finance?

Just got my first look at the February 2025 Financial Overview Report. Let's start with Page 1.  Look at the Reconciled Operating Cash (Balance Sheet) graph. It looks like an EKG for a heart patient in th ICU. Why in the world would Operating Cash dip to $100,000 in May 2024? Didn't anyone get nervous last May? Does anyone on the Board, on the Finance Committee, or in the office (or at CAMS HQ management) understand that graph? Why isn't it ever explained at a Board Meeting? Because no one ever asked any questions! Next, look at Operating Expenses (Significant Variances). This is for the first two months of 2025 GL-5010. There is a note that "I have requested to move this invoice to GL-3810 reserves." First, who is the anonymous "I"?. General repairs don't get paid out of Reserves. Replacement might be paid out of Reserves, but not repairs. And why are electricity and Lighting Repair in the same category? GL-5011 Are the "2 lights [ sic ] poles...

New Management Company on the Way?

I wasn't at the April 1st board meeting, but word has reached me that the Board voted to give the management company contract for 2026 to a different company. CAMS will likely continue as the management company until December 31. There should have been thorough discussion at the board meeting, disclosure of the bid amounts, and why the bid winner was selected. Was there? When the Minutes of the board meeting are published later this month, there should be enough disclosure for Members to understand how the bid process worked. What did the RFP look like? How many bids were there? Who was on the committee that reviewed the bids? Were they kept sealed until being opened? Did the Contracts Committee review the bids and make a recommendation? Did the Board accept that recommendation? The Members of the Contracts Committee are Brenda Bryant (Director), Carmen Claud, Jeff Lummel, and Vicki McCarthy. Several years ago I suggested that the HOA establish email addresses for the office, ...

Broadcast the HOA Meetings? Zoom?

About two years ago a long-time homeowner and active committee member suggested to a previous board of directors that monthly, in-person, board meetings should be streamed. This would greatly increase the number of homeowners who could view the monthly meetings. The idea never got any consideration. What if the April 1st meeting had been streamed? How many "WTH?" emails would have flooded the office on Wednesday morning? One person with a good video-camera and proper microphone could record the meeting and simultaneously stream it on Zoom or Facebook Live. It could be recorded and archived for viewing at a later date, in the event a homeowner had a time conflict with a school or work event or even dinner-hour. One downfall is that the organization of the meeting would have to tighten up, so that only one person spoke at a time. No side-conversations among board members. No side-conversations in the audience. Use of the microphone/sound system that all could hear everything. N...

How Can Minority on the Board Be Heard?

Some wise person once said, "If you don't know your rights, you don't have any." How does this apply to The Summit's HOA? The HOA's seven-member board of directors seems to be divided into two factions; Danny Trapp and three others (now being referred to as "Team Danny" by some) are the majority; the other three directors are the minority. The minority is not to be considered out-of-sight and out-of-mind. They are important. At the April 1st meeting one director (in the minority group) made a Motion. A second director (also in the minority group) seconded it. It was reported to me that Danny Trapp, President of the Board, stated that no vote was going to be taken and he stated to table the Motion.  If that happened, Trapp exceeded his authority as President and fellow board member. But none of the board members knew the rules, as stated in Robert's Rules of Order . The HOA has never had a Parliamentarian. Does anyone on the board even have a copy...

Importance of Voting Members (legit.)

Because homeowners do not elect directors of the HOA, it is all the more important that Voting Members be properly elected in compliance with the By-Laws. As a homeowner, you do not have a direct say in who becomes a member of the Board of Directors. It is your neighborhood's Voting Member who votes for directors. Almost all neighborhoods in The Summit do not have duly-elected Voting Members! This means you are not legally represented. For years the boards of directors have allowed homeowners to be recognized as "Voting Members", even though they were not elected by their neighbors. This is a serious problem. Because I have spoken about it and written about it for five years, the HOA is suing me. They don't want money; they just want to shut me up. This year (2025) there may be an attempt to amend the By-Laws and the CC&Rs. It should not happen, because there is nowhere close to the number of Voting Members who can approve it. This will not keep the current Board...

Did You Attend the 4/1/25 BOD Meeting?

If you attended the April 1st Board of Directors meeting, you got a good dose of the HOA's "leadership". How did you like it? Now is the time for you to join forces. Get in touch with all the people who were there. Exchange names and contact information. Stay in touch. Gather together. Learn more about your HOA. Look at the list of "Voting Members" in The Summit Scoop. Those are the homeowners responsible for the people who were sitting at the front of the room, the directors. Those "Voting Members" are supposed to represent you, the homeowners. Did they, when they elected directors in November 2024 and November 2023. A few of the "Voting Members" are new. Only one of the Voting Members is legitimate; that is, duly-elected. Get busy and elect a Voting Member from your neighborhood who will actually represent you. The Voting Members must do more than just show up once a year and vote. They should be paying attention! When they see someone on ...

Summit HOA Facebook Group?

This afternoon Summit HOA Secretary Ciara Bates (2024-2026) posted this message on NextDoor: Hey neighbors! 👋🏼 I hope you’re all doing well. As a resident of Hunter’s Pond in the Summit and a member of The Summit HOA Board, I’m passionate about strengthening our community ties. As part of my initiative, I thought it would be helpful to start a private Summit community Facebook group where we can share updates, events, and helpful info—a virtual neighborhood hub. It would be a friendly space for collaboration, not for complaints. However, I’ve encountered some resistance from the board president regarding this idea. If you’re interested in supporting this initiative, even unofficially, please email me at However, I’ve encountered some resistance from the board president regarding this idea. If you’re interested in supporting this initiative, even unofficially, please email me at bates.cf@gmail.com . You can also share your thoughts with the front office. 🗓️ Your voice matters! I p...

"Meeting Adjourned!" Seriously?

What is the proper way to adjourn a board meeting? When the business of a meeting is finished, the president should call for a motion to adjourn. Another board member will second the motion. Usually, there is no discussion, but there could be. Then the board votes. Usually, everybody is tired, and they vote to adjourn. The wrong way to adjourn a meeting is for the president to announce, "Meeting adjourned!" and walk out. What happened last Tuesday night? It was a contentious meeting. A lot of people were irritated at how the meeting was conducted. Many were at their first board meeting. Will they ever come back? When Danny abruptly declares that the meeting is adjourned and walks out, the rest of the board should stay seated. After he leaves the room, the Vice-President should say, "The board has not adjourned, because the board did not vote." And then she should ask, "Is there a motion to adjourn?" Probably somebody on Team Danny would make the motion, an...

April 4 - STILL No Feb. Financial Reports

Homeowners, why haven't the February 2025 Financial Operating Results been posted on the HOA's website? The monthly financial operating results are often posted before the monthly board meetings. A few printed copies of the monthly financial results are available at monthly board meetings. Were they available last Tuesday night? Were there  enough for the 100 or so homeowners who showed up, many of whom could not find seats in the board meeting room? They should have been posted online on April 1st. Or on April 2nd. Or on April 3rd. As of 11:53AM on Friday, April 4th, they still haven't been posted. Why not? Will they be posted before the office closes for the week-end? Call the office and ask that they be posted. Call 803.865.0609 If you don't know where to find them online, ask the office. Or post your question in the Comment box below.

April Summer Scoop - Trampolines

You can now read The Summit Scoop, April 2025 edition, online. Read it on the HOA's website at https://summithomeowners.com   Scroll down on the homepage and click on the button for Recent News. (I have recommending changing the name of that button to "Summit Scoop".) On Page 1 is the President's Report. Read it carefully, and keep last Tuesday's board meeting in mind. That's the one where you didn't get answers about trampolines. "Later" never came. Danny Trapp wrote, in part,  "There will also be enforcements [ sic ] of the display [ sic ] of trampolines after hours [ sic ]. Some have been leaving them up constantly and allowing them to come into disrepair by [ sic ] creating an eyesore for their neighbors and the community. I am in support of these efforts. If any of this applies to you, please make the necessary corrections  before receiving notification from the association." What are "enforcements"? What does "disp...

Do You Have a Legitimate Voting Member?

Does your neighborhood have a legitimate Voting Member? Look at the Voting Member listing in The Summit Scoop and on the HOA's website. First of all, if you live in Autumn Glen, Indigo Springs, Pine Clave, and Waverly Place, you don't even have a Voting Member - at all. That's 487 homes with no representation whatsoever. That's 19.6% of the homes in the HOA. And you haven't had a Voting Member for a long time. Many other neighborhoods have homeowners who are "recognized" by the Board as "Voting Members", because they "got signatures" on a form from the office. But they were not duly-elected, in compliance with the By-Laws. Shall I name them? Still other neighborhoods have "Voting Members", even though they haven't had Neighborhood Meetings for years*. Shall I name them ? What is a legitimate Voting Member?  He or she is one who was elected by your neighborhood's (local) three-member Neighborhood Committee. Your Neighbo...

Easy Way to Find Past Articles

Looking for an easy way to find past articles on this blog? Just click on "Archive" in the left side-bar. It will open an index to past articles by title.

Whom Does the HOA Attorney Represent?

Last May 7, 2024 the HOA's Board of Directors, upon motion by Linda Potter and second by Dennis Rybicki, voted unanimously to "hire" (retain) the law firm of Turner Padget. At the time the board really didn't seem to know how much the legal fees were going to be for important categories of legal services; ex., collection services, general legal advice, amendment of CC&Rs and By-Laws, etc. The Board had apparently not received an Engagement Letter, and subsequently the Board never authorized Danny Trapp to sign any Engagement Letter, which spells out services and fees. The Board never discussed in public how it would disengage itself from the law firm of McCabe, Trotter & Beverly, P.C., which had handled legal business for the HOA for years. That separation has never been discussed at a monthly board meeting. Was it ever completed? At what cost to the Association? The Question is, whom does Turner Padget represent? Since it was the Board that retained Turner Pa...

What Qualities Should Board Members Have?

What are the qualities you should expect from your Board of Directors? When the Nominating Committee examines the applications of candidates for the Board before elections are held each November, this is what they are supposed to look for. According to Art. II, §B, ¶2 (Page 8) of the Procedures Reference Manual,  The Nominating Committee "Provides quality candidates to hold office on the Board. Candidates will be of the highest caliber, selected for interpersonal skills, dedication to the betterment of the Association and community, and free of any personal agenda." How did the Nominating Committee do before the election in November 7, 2023, when Danny Trapp and Linda Potter were elected and Brenda Bryant and Greg Thomas were re-elected? (Greg Thomas resigned shortly after being elected.) How did the Nominating Committee do before the election in November 12, 2024, when LaToya Adams and Ciara Bates were elected and Tanisha Holmes was re-elected? All the directors are elected ...

Rate Your BOD: 4/1/25 Meeting

Did you attend the April 1st Board of Directors meeting? It was Standing Room Only (SRO); right? First time ever? Or, at least, in a very long time. How did the Board do? Did you feel that the Board listened to you? Did the Board respect you? Was the Board organized? Was the meeting run in accordance with generally-accepted meeting protocol or Robert's Rules of Order?  Could everyone hear? Were the microphone and the sound system used? Did the President control the meeting and call the room to order when multiple people spoke out at once? Is there anything you'd like the Board to know? Or that you'd like to say? You may know that I am under Court Order not to communicate with any of the seven directors, including the President, about affairs of the Association. I can, however, publish any comments or opinions that I receive from you. Enter your comments below. On a scale of 1-10, where one is Terrible and 10 is Great, how did they do? If you prefer to remain anonymous, emai...

Public Comment - Trampolines

Did the issue of trampolines ever make it to the floor of last night's Board meeting (4/1/2025)? I heard that somebody said it would be discussed "later", but later never came. How is Danny Trapp doing as President of the HOA? The Board can't remove him from the Board, but they can definitely elect someone else to be President. Should they do that? Is Danny's "leadership style" helping or harming the HOA? The Voting Members have the authority to remove a Director, so they could remove Danny. If they convened in a Special Meeting and discussed doing that, would I suddenly be Danny's BFF? Would Danny say, "You guys (except for Barony Place) aren't legitimate. You weren't duly-elected by your neighborhoods. You can't remove me!"

Can President Order a Motion Tabled?

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Did this really happen last night? One board member made a motion, and a second board member seconded it. Did Danny Trapp really declare that there wasn't going to be any vote and say the motion was tabled? Has Danny ever heard of Robert's Rules of Order (RONR)? Does he own a copy of it? Has he ever seen a copy? Has he ever held a copy of it? Has he ever tried to read any of RONR? When a Motion has been made and seconded, another board member (President or not) cannot just declare that there isn't going to be a vote! After the second, it is time for discussion. After discussion, there is a vote. The Board (not the President) determines whether the Motion passes or fails. Section 17 in RONR covers this. If Danny wanted to stop action on the Motion made and seconded, he should have made a secondary motion to table the primary motion. Then his secondary motion should have been discussed and voted on.  If Danny's secondary motion passed, then the primary motion is tabled. ...

Can the HOA Amend the CC&Rs? By-Laws?

The mechanism is in place, so that the HOA could amend its CC&Rs and the By-Laws. What is that mechanism? In the CC&Rs, read Art. XIII, Section 2 Amendment, ¶2  (Page 25). It reads, in part, "...  this Declaration may be amended only by the affirmative vote or written consent, or any combination thereof of Voting Members representing seventy-five (75%) percent of the total Class “A” votes in the Association, including seventy-five (75%) percent of the... Members ..." There are 2,480 Members. 75% is 1,860. How many Voting Members are needed to hit that 1,860 mark? This is why it is critical to know how many homes there are in each Neighborhood. As of June 2024 the office did not know the correct number. The office gave me a list of Neighborhoods, and the number of homes totaled 2,595, which is 115 more homes than are assessed! How many Voting Members are there? One (1). Barony Place has the only legitimate Voting Member in the entire HOA. By "legitimate", I ...

Vandalism - Indigo Springs

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Why would someone vandalize this sign at the entrance to Indigo Springs? The wire frame was bent, and the sign was partially pulled off the frame. A concerned citizen straightened the frame and slid the sign back onto it. Will lndigo Springs hold a Neighborhood Meeting, with a quorum of its property owners present, and elect a (local) Neighborhood Committee that will elect a legitimate Voting Member? Is that what the office tells callers is required? Or does the office tell callers to "get signatures" on a form, in order to be recognized as a "Voting Member"?

Feb. Financials still not posted

As of 2:00PM today the February 2025 Financial Report still has not been posted.  Presumably, it was available at last night's BOD meeting and was on the back table.  Is there a reasonable explanation for the failure to post it on The Summit's HOA website? Are there numbers in it that the Board would rather not have the general Membership know about? What could those be? Maybe the cost of filing the lawsuit in December against Gus Philpott (me)? I mean the lawsuit that the CC&Rs prohibit without approval of the Voting Members. The lawsuit that the Board never voted on or approved. The lawsuit that the Board never authorized Danny Trapp to initiate. That lawsuit!

ad hoc Committee?

What is the ad hoc Committee of The Summit's HOA? If there really is such a committee, it should be known to ALL board members. The committee should have been established with the advice and consent of the Board, and the members and chair of the committee should be known to all. The Board should have voted to create it and to confirm the appointment of a chairman of it. Its establishment should be recorded in the Minutes of a BOD meeting, and it should be listed on the HOA's website and in The Summit Scoop. It's not a secret committee. There should be Minutes of its meetings, and the Minutes should be published and easily accessible. It should have a specific purpose, known to all, and it probably should have a pre-determined duration. The Minutes of the November 7, 2023 Board meeting include this statement: "The Ad Hoc Committee will hold an orientation of the board members on November 11th." That certainly was not a duty of the ad hoc Committee. Who authorize...

Any recording?

 Did anyone record last night's BOD meeting? When I drove by the church on the way to Publix about 7:30PM, the parking lot was full.  I'm already getting some "interesting" feedback about the meeting. I hope someone recorded it. Let me know. A while back, a long-time committee member recommended broadcasting the meetings on Zoom. The Board at that time put the kabosh on that idea. Should it come up again?

Summit HOA Meeting Tonight

Attend tonight's Board of Director's meeting. 6:30PM. Brookland Baptist Church Northeast.  Meetings are not broadcast on Zoom or recorded. You might want to record on your phone or a recorder. A hot topic tonight will be trampolines. If the President tries to eliminate public comment, ask if it is his decision or the Board's. Ask for a Board vote. Ask about financial solvency of the HOA, in view of no dues increase this year (Finance Committee recommended it) and only $3,000 going into Reserves in 2025 (compare with $163,965 budgeted in 2020 and $0.00 in 2024). Public comment at BOD meetings is essential to transparent operations.

Post Financial Reports Before BOD Meeting?

Should the HOA post monthly financial reports online before the Board of Directors meetings? Why should it do that? The reports are complicated. It's difficult for most Members to read and understand them. If Members had some time to examine them and compare them with previous months, Members could ask intelligent and appropriate questions at Board Meetings. Ex., Members could ask about the Variances. Why are Line Items over-budget? Members could ask for explanations of the two charts, which make no sense at all. The legend on the Reconciled Operating Cash Chart shows two lines: Operating Cash and Net Cash. Yet the chart contains only one line. If your EKG looked like that, your doctor would have you in the ICU. Members could (should!) ask why, on the Reserve Accounts Trends chart, there is a steady decline from May 2024 to January 2025. Recall that the contribution to Reserves in 2024 was ZERO (and it is only $3,000 for 2025). Members could ask why Accounts Receivable (Line 1200 f...

HOA Shouldn't Have Started Lawsuit

The Summit's HOA shouldn't have started a lawsuit against me, according to the CC&Rs. But it did so, anyway. The controlling section in the CC&Rs is in Article XIII, Section 13. It reads, in part, "Section 10. Litigation . No judicial or administrative proceeding shall be commenced or prosecuted by the Association unless approved by a vote of seventy-five (75%) percent of the Voting Members. In the case of such a vote, and notwithstanding anything contained in this Declaration or the Articles of Incorporation or By-Laws of the Association to the contrary, a Voting Member shall not vote in favor of bringing or prosecuting any such proceeding unless authorized to do so by a ‘vote of seventy-five (75%) percent of all Members of the Neighborhood represented by the Voting Member." Section 10 lists four exceptions. This case is not one of them. Upon information and belief, the Voting Members were  not asked for approval. Even if they had been, approval would not hav...

HOA's Legal Bills for Lawsuit Against Gus

The HOA's large legal bills for suing Gus Philpott (me) should begin showing up in the monthly financial statements. Turner Padget would have put in considerable time inn December to prepare the lawsuit, interview Danny Trapp and prepare the Affidavit that he signed on December 30, 2024, and file the lawsuit and paperwork for a TRO. January's Line 6500 (Legal/Professional) was only $530. Were legal bills for those fees paid in January? You certainly don't get all that legal work from a top-floor, deep-carpet law firm for $530. Were the bills delayed and not paid until February? On April 1st the monthly financial statements for February 2025 will be distributed at the 6:30PM Board meeting. You can view them online (soon). Go to the HOA's website. Hover over RESIDENTS. Click on DOCUMENTS. Click on Financial Operating Results. Click on February 2025. Scroll down past the Balance Sheet to the Income/Expense Report, and then scroll on down to Line 6500. Fasten your seatbelt....

ICYMI - First 50 Fence Posts

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  In case you are wondering what is going on at Birch Park, the first 50 fence posts were "planted" more than a month ago along Rolling Knoll Drive. This is part of a plan to keep a few cars from parking on the grass between the curb and the sidewalk. A chain will be strung between the fence posts. Perhaps that has even been already done. Rolling Knoll Drive is a public roadway, owned by and maintained by Richland County. There are no posted No Parking signs. It is not illegal to park on Rolling Knoll Drive, unless such parking blocks the street. Will cars still park along the curb? I think you can count on it. It will not be unlawful for them to do so. If vehicles block the roadway, call the S.C. Highway Patrol or RCSD. Will all the posts be stained, so that they match? Will there be increased lawncare costs? A riding mower will no lower be able to zip along between the curb and the sidewalk, and extended time will be needed to edge carefully around each post. How many more ...

More from Danny Trapp's Affidavit

Danny Trapp's   Affidavit   for the TRO, which was sought by the HOA in its court case against Gus Philpott (me), contains more accusations about which you might want to know. In a previous article I commented on Items 7, 8, and 9 in the Affidavit. Item 10 in the Affidavit reads, "In my time as President, Mr. Philpott has been at every Association meeting and routinely behaved in a disruptive manner." Danny was elected to the Board on November 7, 2023. The election of officers should have been held that night but wasn't. Instead of holding the Organizational Meeting and the election of officers in compliance with the By-Laws (as the first board meeting following the Annual Meeting of Voting Members), the board met in a special-called, closed, private, secret board meeting, believed to have been held on Saturday, November 11, 2023.  The Minutes of the November 7, 2023 board meeting indicate that an  ad hoc Committee was going to hold an "orientation of board memb...

Latest Crime Report

Want to view the latest Crime Report for The Summit from the Richland County Sheriff's Department? Go to the HOA's website . On the homepage, scroll down to and click on Public Service Announcements. Click on the link for Crime Report. Oh, wait. The "most recent" Crime Report is for March-May 2022 ! Not only that, five of the nine pages are missing. Notice the gaps in dates from one page to the next. Notice that the first page is "Page 2 of 9"; the last is "Page 8 of 9". In 2022 I noticed immediately that the Report of four pages was too short for a three-month period. I informed the office and suggested that they obtain and publish the full report. I never learned whether RCSD had sent all nine pages to the HOA. What good is a Crime Report when you can't tell where the crimes occurred? The addresses are redacted. The Treasurer at the time claimed that addresses are PII (Personally Identifiable Information); they aren't. If they were, RCSD ...

Dissecting Danny's Affidavit

If you read through Danny Trapp's Affidavit for the TRO that was sought by the HOA in its court case against Gus Philpott (me), it didn't take you long to get to Item 7 "Upon information and belief, Mr. Philpott is not a property owner" and Item 8 "Despite this, he routinely appears at Association meetings." As everyone knows, I have never (not even once) claimed to be a property owner. Why not? Because I am not a property owner.  I am a resident. I have been a resident* since January 2018. The office issued my ID card on 05-14-18. Look again at Item 8, "Despite this, he routinely appears at Association meetings." What is "Despite this,..." supposed to mean? In the March 2025 Summit Scoop, on Page 2, it reads, "Board meetings are open to all Summit Residents." In 2018, that sentence in the Scoop read, "Board meetings are open to ALL Summit residents." In September 2016, when Danny was on the Board of Directors the fir...

Danny Trapp's Affidavit in Court Case Against Gus

As part of the HOA's lawsuit against Gus Philpott (me), the HOA's President, Danny Trapp, gave a sworn Affidavit to the HOA's lawyer on December 30, 2024.  His Affidavit is a public document, on file with the Richland County Court of Common Pleas for the Fifth Judicial District.  Danny's Affidavit is reproduced here. Formatting changed when it was opened in Google Docs, so that it could be copied and pasted here. No alterations have been made. Nothing has been added or deleted. Page 3, the signature page, is not included. I shall elaborate on certain accusations in a separate article on this blog. STATE OF SOUTH CAROLINA  COUNTY OF RICHLAND  IN THE COURT OF COMMON PLEAS FOR THE FIFTH JUDICIAL CIRCUIT  C / A No : 2024 - CP - 40-07524  Summit Community Association , Inc. ,  )  Plaintiff ,  )  V.  )  AFFIDAVIT OF DANNY TRAPP  )  Gus Philpott ,  Defendant .  ELECTRONICALLY FILED - 2024 Dec 30 4:56 PM - RICHLAND ...