BREACH OF CONTRACT
- WINDSOR adopts and realleges Paragraphs 1 through 505.
- WINDSOR asserts this claim against the ASSOCIATION.
- DECLARATION, ARTICLES OF INCORPORATION, BYLAWS, RULES, and FLORIDA STATUTES is breach of contract and breach of governing documents. [EXHIBITS A, B, D, and E.]
- The ASSOCIATION has been operating unlawfully. Many violations have been repeated again and again. The Statement of Facts is filled with evidence.
- Dues and assessments have been levied against WINDSOR and other Owners without legal authority. WINDSOR, one of the 32 owners, believes he is owed at least $15,000 due to excessive charges.
- The ASSOCIATION, COACH HOUSES MEMBER DEFENDANTS, CLAYTON & MCCULLOH DEFENDANTS, and SENTRY DEFENDANTS are responsible for the breaches.
The ASSOCIATION’s corporate charter should be revoked due to failure of the ASSOCIATION to comply with the DECLARATION, ARTICLES OF INCORPORATION, BYLAWS, RULES, and FLORIDA STATUTES.
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IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL DISTRICT
IN AND FOR LAKE COUNTY, FLORIDA
William M. Windsor,
Case No. 35-2020-CA-001438
Coach Houses at Leesburg Condominium Association, Inc., Omar Nuseibeh, Vicki Hedrick, Karen Bollinger, Shehneela Arshi, Isabel Campbell, Sergio Naumoff, Ed Broom, Jr., Marta Carbajo, Sue Yokley, Wendy Krauss, Howard Solow, Sentry Management, Inc., Charlie Ann Aldridge, Art Swanton, Brad Pomp, Clayton & McCulloh, P.A., Brian Hess, Neal McCulloh, Russell Klemm, Florida Department of Business and Professional Regulation, Mahlon C. Rhaney, Leah Simms, and Does 1-20,
SECOND AMENDED COMPLAINT
PLAINTIFF hereby files this Second Amended Complaint (“SECOND AMENDED COMPLAINT”) and shows the Court the following:
PLEASE BE ADVISED: Everything you are about to read regarding the BIG LAWSUIT is the actual lawsuit Complaint. It was sworn under penalty of perjury before a notary to be true and correct based upon William M. Windsor’s knowledge. It is on file in Lake County Circuit Court for anyone to read.
Jurisdiction and Venue
Statement of Facts:
Facts — 2018
Facts — January 2019
Facts — February 2019
Facts — March 2019
Facts — April 2019
Facts — May 2019
Facts — June 2019
Facts — July 2019
Facts — August 2019
Facts — September 2019
Facts — October 2019
Facts — November 2019
Facts — December 2019
Facts — January 2020
Facts — February 2020
Facts — March 2020
Facts — May 2020
Facts — June 2020
Facts — July 2020
Facts — August 2020
Facts — September 2020
Facts — October 2020
CAUSES OF ACTION
COUNT ONE — BREACH OF FIDUCIARY DUTY
COUNT TWO — FRAUD
COUNT THREE — DERIVATIVE ACTION FOR LEGAL MALPRACTICE
COUNT FOUR — BREACH OF CONTRACT
COUNT FIVE — DERIVATIVE ACTION FOR MALPRACTICE AND BREACH OF CONTRACT
COUNT SIX — BREACH OF CONTRACT – FAILURE TO KEEP COMMON AREAS CLEAN
COUNT SEVEN — CONSPIRACY
COUNT EIGHT — PROFESSIONAL NEGLIGENCE
COUNT NINE — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
Prayer for Relief