“Write the letter,” Leonard said.
Vera sent the demand letter May 5. It went to Sylvia Trent and to Frank Citro, the HOA’s retained counsel.
Vera’s demand ran nine pages and included twelve exhibits. Section 3 was quoted in full, and the board’s prior-approval theory was dismantled with cold legal precision.
Sylvia received the letter May 8 and called Frank Citro before she finished reading it.
Frank had practiced general law in the county for eighteen years. After reading Vera’s demand, Frank examined every alternative defense: scope, contractor selection, cost-reasonableness. None improved the HOA’s position.
He called Sylvia on May 12:
“I’ve looked at scope, contractor selection, and cost reasonableness. None of them gives us a viable defense. The prior approval argument is the HOA’s strongest position, and it is weak.”
“What do you recommend?” Sylvia asked.
“Pay the invoice. Twenty-four thousand seven hundred fifty dollars resolves the matter before June 6 and avoids whatever Leonard means by exercising his property rights over the road crossing.”
Sylvia reminded him the board had already voted to refuse payment.
“The board can vote again,” Frank said.
She called another board meeting for May 16. The same five board members attended, with Dale Morrow present and Frank participating by phone.
Phil Caruso spoke first: “I said this in April. The prior-approval requirement isn’t in the agreement. We should have paid then.”
Frank on speakerphone told the board directly:
“The maintenance agreement’s text does not support the prior-approval argument. Vera Okafor’s analysis is accurate on the contract language.”
Board member Carol Finch asked what would happen if they did not pay. Frank warned that the road crossed Leonard's parcel for 340 feet and the agreement had no access-easement clause.
Carol asked: “He can actually lock us out?”
“It is not a simple legal question,” Frank replied, “but it is not simple in our favor.”
Sylvia refused to retreat: “The board voted in April on a principle. Repairs require board approval, and we cannot abandon that principle because an attorney wrote a demand letter.”
“The principle isn’t in the agreement,” Dale said.
The board voted again, refusing payment four to one, with Phil dissenting a second time.
Frank spoke before the meeting ended: “I want the minutes to reflect that I recommended paying the invoice and the board voted against my recommendation.”
“So noted,” Sylvia said.
The days passed. Leonard used those three weeks to prepare. He bought a fourteen-foot commercial steel gate with a heavy drop bar and padlock hasp. He set two gate posts in concrete three feet inside his western property line and let them cure.
June 5 passed with no payment.
On June 6 at 6:00 a.m., Leonard hung the gate, locked it with a heavy commercial padlock, and mounted two aluminum signs:
*Private Property. Coss Parcel. Road Closed. Contact Leonard Coss.*