Windsor v. Coach Houses at Leesburg Condominium Lawsuit – PROFESSIONAL NEGLIGENCE

COUNT EIGHT

PROFESSIONAL NEGLIGENCE

1. WINDSOR adopts and realleges Paragraphs 1 through 505 and statements of fact in Counts Two, Three, Five, and Nine.
2. CLAYTON AND MCCULLOH Defendants, the SENTRY MANAGEMENT DEFENDANTS, and the DBPR DEFENDANTS.

• The CLAYTON AND MCCULLOH Defendants, the SENTRY MANAGEMENT DEFENDANTS, and the DBPR DEFENDANTS have been negligent.  They have failed to use reasonable care.  Reasonable care is the care that a reasonably careful attorney, licensed association manager, or government official would use under like circumstances.
• Negligence is doing something that a reasonably careful attorney, licensed association manager, or government official would not do under like circumstances or failing to do something that a reasonably careful attorney, licensed association manager, or government official would do under like circumstances.
• The Statement of Facts and Counts One, Two, Three, Five, and Nine herein identify many facts that prove negligence, failure to use reasonable care, and professional wrongdoing.  The DBPR DEFENDANTS showed bad faith, malicious purpose, and wanton and willful conduct.  There has never been an appellate decision in Florida granting immunity to the DBPR or its employees.
• This professional negligence damaged WINDSOR.

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