Elms Mummy Pucr-r, PC.

Attorneys at Law
9515 E. 59'h Street, Suite 3
Indianapolis, IN 46216
Telephone: (317) 536-2565
Fax: (317) 536--2568

lndianaHOAan.com

September 4, 201 8

James and Vicki New

Re: Twin Creeks Homeowners Association. Inc.

Dear James and Vicki New:

This firm represents Twin Creeks Homeowners Association, Inc ("Association"). As
you may recall. I previously sent you a letter advising of several concerns about Vicki's
behavior, including repeated harassment of residents. members of the Association's Board of
Directors. Association-hired contractors and the community's managerr All such antics were to
cease at that time. Unfortunately. the situation has escalated. In fact, as I understand, incidents
of harassment have grown signficantly in frequency and intensity. to a point where residents are
fearful of leaving their own homes.

Over the past two months, the Association's Board and community manager have been
speaking with Twin Creeks residents regarding these issues. They have been gathering
documentation of Vicki's behavior, including personal accounts, videotapes and photographs.
To date. more than twenty residents have come forth with reports of harassment, which does not
even include the myriad of other occmions on which Vicki has verbally accosted the
Association's Board members, contractors and property managers. Most disconcerting is that
many of Vicki's recent actions were motivated by racial animus and specifically targeted African
American and Hispanic residents. Thus, Vicki has not only singehandedly created an
unwelcoml'ng living environment, but has also caused minority residents to be demeaned and

discriminated against based upon race. Calling this unacceptable is a grass understatement,

The below list is just a smattering of the incidents which have been reported to the
Association:

- Numerous accounts of trespassing onto private property.
- Repeatedly confronting residents in an unwelcome, vociferous, abrasive and
intimidating manner.
a Engaging in various forms of discriminatory intimidation 0f Mk" Wilda",
including repeated use of the Word," telling Hispanic residents to "go beck to
Mexico." and uttering other Similar racial epithets.