Tag: Tia King

Windsor v. Coach Houses at Leesburg Condominium Lawsuit – FACTS – AUGUST 2019

  1. On August 1, 2019, WINDSOR served his Request for Findings of Fact and Conclusions of Law in DBPR Case No. 2019-02-6834 on Mahlon C. Rhaney, Jr. and the ASSOCIATION. [EXHIBIT 1188.]
  2. On August 1, 2019, WINDSOR sent by email a Request for Findings of Fact and Conclusions of Law in DBPR Case No. 2019-02-6834 to the DBPR and the ASSOCIATION. [EXHIBIT 1187.]
  3. On August 2, 2019, the Arbitrator issued another FINAL ORDER OF DISMISSAL in DBPR Case No. 2019-02-6834. [EXHIBIT 1185.]  It appears to be identical to the July 31, 2019 “FINAL ORDER OF DISMISSAL,” and no explanation was provided as to why there are two final orders of dismissal.
  4. On August 2, 2019 at 8:37 p.m., WINDSOR sent an email to the owners of the ASSOCIATION complaining about false advertising by OMAR and Dorothy Liebl. [EXHIBIT 1273.]  There was no response.
  5. On August 3, 2019 at 6:32 p.m., WINDSOR sent an email to the owners of the ASSOCIATION, SENTRY, and CLAYTON & MCCULLOH complaining about cleaning of the common area carpets. [EXHIBIT 1279.]
  6. On August 5, 2019, the Arbitrator issued an ORDER DENYING MOTION FOR REHEARING in DBPR Case No. 2019-02-6834 regarding the March 22, 2019 election. [EXHIBIT 1211.]  WINDSOR did not file a motion for rehearing.  MAHLON claimed a request for findings of fact and conclusions of law was a motion for rehearing.  WINDSOR received a copy of the ORDER by email from Tia King of DBPR. [EXHIBIT 1271.]
  7. On August 6, 2019, the Arbitrator issued a FINAL ORDER OF DISMISSAL in DBPR Case No. 2019-03-8814 regarding inspection of books and records. [EXHIBIT 1192.]
  8. On August 9, 2019, MAHLON of the DBPR issued a FINAL ORDER OF DISMISSAL in Case No. 2019-04-0349, the petition regarding Building B at Coach Houses. [EXHIBIT 1196.]
  9. On August 9, 2019 at 1:32 p.m., WINDSOR received an email from Tia King at the DBPR with a FINAL ORDER OF DISMISSAL in Case No. 2019-04-0349, the petition regarding Building B at Coach Houses. [EXHIBIT 1197.]
  10. On August 9, 2019 at 5:15 p.m., WINDSOR sent an email to Ms. Tia King at DBPR regarding ex parte communication by MAHLON. [EXHIBIT 1195.]
  11. On August 14, 2019, WINDSOR mailed for filing a Notice of Order, Motion for Recusal, Affidavit, and Certificate of Counsel in in DBPR Case No. 2019-03-8814, 2019-02-1020, 2019-02-6834, and 2019-04-0349. [EXHIBIT 1236.]  He also emailed it to the DBPR and Russell Klemm. [EXHIBIT 1237.]  The Affidavit in Support of Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-02-1020 is EXHIBIT 1246.  The Affidavit in Support of Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-02-6834 is EXHIBIT 1247.  The Affidavit in Support of Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-03-8814 is EXHIBIT 1248.  The Affidavit in Support of Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-04-3349 is EXHIBIT 1249.  The Certificate of Counsel of Record in DBPR Case No, 2019-02-1020 is EXHIBIT 1250.  The Certificate of Counsel of Record in DBPR Case No, 2019-02-6834 is EXHIBIT 1251.  The Certificate of Counsel of Record in DBPR Case No, 2019-03-8814 is EXHIBIT 1252.  The Certificate of Counsel of Record in DBPR Case No, 2019-04-3349 is EXHIBIT 1253.  The Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-02-1020 is EXHIBIT 1254.  The Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-02-6834 is EXHIBIT 1255.  The Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-03-8814 is EXHIBIT 1256.  The Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-04-3349 is EXHIBIT 1257.
  12. On August 15, 2019 at 12:19 a.m., WINDSOR sent an email to the DBPR and Russell Klemm with copies of the Motion for Rehearing in DBPR Case No. 2019-02-6834 that was mailed on August 14, 2019. [EXHIBIT 1235.]
  13. On August 15, 2019 at 9:49 a.m., WINDSOR received five emails from Tia King of DBPR saying electronic filings are not acceptable. [EXHIBIT 1218.]
  14. On August 15, 2019 at 1:43 p.m., Tia King of DBPR provided WINDSOR with the contact information for Alison Parker, the DBPR Deputy General Counsel who would be handling his complaint against MAHLON. [EXHIBIT 1234.]
  15. On August 15, 2019 at 1:54 p.m., WINDSOR sent an email to Alison Parker of DBPR.  It was a formal complaint against MAHLON. [EXHIBIT 1224.]  WINDSOR sent a copy to Russell E. Klemm of CLAYTON &  MCCULLOH. [EXHIBIT 1233.]
  16. On August 17, 2019, WINDSOR sent by certified mail his August 16, 2019 letter identifying the Records that were not produced at the Inspection of Records on August 16, 2019. [EXHIBIT 1228.]
  17. On August 17, 2019, WINDSOR sent by certified mail his Sixth Notice of Intent to File Petition for Arbitration and/or Lawsuit due to Failure to Produce Records for Inspection. [EXHIBIT 1230.]
  18. On August 17, 2019, WINDSOR sent by email his Sixth Notice of Intent to File Petition for Arbitration and/or Lawsuit due to Failure to Produce Records for Inspection and the letters that he mailed by certified mail that day. [EXHIBIT 1227.]
  19. On August 19, 2019, WINDSOR received an email from Alison Parker of DBPR saying she would look into the complaint against MAHLON. [EXHIBIT 1225.]
  20. On August 19, 2019, WINDSOR sent an email to Alison Parker of DBPR saying he would provide the requested information promptly. [EXHIBIT 1226.]
  21. On August 20, 2019, WINDSOR sent BRIAN of CLAYTON &  MCCULLOH by certified mail a Notice of Intent to File a Petition for Arbitration regarding the August 2017 meetings. [EXHIBIT 1239.]  EXHIBIT 1278 is the signed receipt.  WINDSOR emailed it to the ASSOCIATION, SENTRY, and the attorneys at C&M. [EXHIBIT 1240.]  [EXHIBIT 1263 is the signed certified mail receipt.]
  22. On August 21, 2019, WINDSOR sent an email to Alison Parker of DBPR saying he would be sending a flash drive. [EXHIBIT 1270.]
  23. On August 22, 2019, MAHLON filed a Notice After Order Denying Petitioner’s Motion for Rehearing and Petitioner filing for Trial De Novo. [EXHIBIT 1261.]
  24. On August 22, 2019, WINDSOR sent an email to Alison Parker of DBPR.  He told her that MAHLON C. Rhaney, Jr. had refused to recuse himself and did not address the facts.  WINDSOR told her that he would have to sue MAHLON and the DBPR. [EXHIBIT 1277.]
  25. On August 23, 2019, Mahlon C. Rhaney, Jr. filed an ORDER DENYING MOTION FOR REHEARING in DBPR Case No. 2019-02-6384. [EXHIBIT 1276.]  He did not address two other motions, but he included them in his order.
  26. On August 26, 2019, WINDSOR emailed Alison Parker of DBPR to say that Mahlon had refused to recuse himself and that he was convinced he is corrupt. [EXHIBIT 1299.]
  27. On August 27, 2019, WINDSOR emailed Alison Parker of DBPR to cite Article 1, Section 21 of the Florida Constitution as a fundamental law that Mahlon had violated. [EXHIBIT 1319.]
  28. On August 27, 2019, Alison Parker of DBPR emailed WINDSOR to say she would have a response to him shortly. [EXHIBIT 1319.]
  29. On August 27, 2019, WINDSOR filed a FIRST AMENDED REQUEST FOR TRIAL DE NOVO in Case No. 2019-CA-001528 in County Court of Lake County, Florida.  Mahlon and Russell Klemm were served with copies. [EXHIBIT 1473.]
  30. On August 27, 2019, WINDSOR emailed Alison Parker of DBPR to say he had two more petitions to file, and he expressed that he did not want Mahlon to be the arbitrator. [EXHIBIT 1320.]
  31. On August 28, 2019, Alison Parker, Deputy General Counsel of DBPR, sent WINDSOR a letter ignoring the issues in his complaint against Mahlon. [EXHIBIT 1288.]
  32. On August 28, 2019, WINDSOR emailed Ray Treadwell, General Counsel of DBPR, to say “I need to speak with you about incompetence and/or corruption on your staff.” [EXHIBIT 1298.].
  33. On August 29, 2019, WINDSOR filed a First Amended Request for Trial De Novo in Case No, 35-2019-CA-001528. [EXHIBIT 1854.]
  34. On August 29, 2019, WINDSOR filed a Request for Trial De Novo in Lake County Court. [EXHIBIT 1289.]  It was assigned Case No. 2019-CA-1871.  On August 29, 2019, I served Mahlon and Russell E. Klemm of CLAYTON &  MCCULLOH by email. [EXHIBIT 1292.]  WINDSOR served Mahlon and Russell E. Klemm of CLAYTON &  MCCULLOH by certified mail.  EXHIBIT 1290 is the certified mail receipt for MAHLON, and EXHIBIT 1291 is the certified mail receipt for Russell E. Klemm of CLAYTON &  MCCULLOH.  EXHIBIT 1351 is the signed certified mail receipt for Russell of CLAYTON & MCCULLOH.  EXHIBIT 1336 is a signed certified mail receipt for MAHLON.  [EXHIBIT 1855 is the full file on Case No. 2019-CA-001871.]

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Windsor v. Coach Houses at Leesburg Condominium Lawsuit – FACTS – MAY 2019

  1. An Order Vacating Dismissal and Requiring Amended Petition was filed in DBPR Case No. 2019-02-1020 on May 1, 2019. [EXHIBIT 1003.]  WINDSOR was instructed to use a form that would base his first petition for arbitration on Chapter 61-B-50, Florida Administrative Code (specifically Rule 61-B-50.105(2).  [EXHIBIT 1008.]  WINDSOR’s review of that form indicated it was designed for an association board’s filing, so WINDSOR questioned this in the amended petition and incorporated additional information.  MAHLON was setting WINDSOR up for a dismissal.
  2. On May 5, 2019, WINDSOR mailed a Second Notice of Intent to file a Petition for Arbitration regarding the March 22, 2019 meeting.  He sent it to CLAYTON & MCCULLOH giving them until May 13, 2019 before he filed. [EXHIBIT 322.]
  3. On May 5, 2019, WINDSOR emailed a Second Notice of Intent to file a Petition for Arbitration regarding the March 22, 2019 meeting.  WINDSOR sent it to CLAYTON & MCCULLOH, SENTRY, and the ASSOCIATION giving them until May 13, 2019 before he filed. [EXHIBIT 323.]
  4. On May 5, 2019, WINDSOR emailed an addition to his Second Notice of Intent to file a Petition for Arbitration regarding the March 22, 2019 meeting.  WINDSOR sent it to CLAYTON & MCCULLOH, SENTRY, and the ASSOCIATION.  He informed them of two violations of the DECLARATION. [EXHIBIT 324.]
  5. On May 6, 2019, WINDSOR sent an email to DBPR with a link to the form he found on the DBPR website asking if it was to be used for the Petition in Case No. 2019-02-1020. [EXHIBIT 1259.]
  6. On May 7, 2019, WINDSOR sent an email to CLAYTON & MCCULLOH, SENTRY, and the ASSOCIATION advising them that he would be amending his Petition for Arbitration regarding the Election / Recall. [EXHIBIT 407.]  WINDSOR asked them to advise him if they will agree that the Recall / Election passed.  There was no response.
  7. On May 7, 2019, Tia King of DBPR responded regarding WINDSOR’s Petition in Case No. 2019-02-1020 and told him to use the form he emailed on May 6, 2019. [EXHIBIT 1259.]  The form is EXHIBIT 1258.
  8. From April 26, 2019 to May 7, 2019, WINDSOR communicated with Alicia Lawrence and Tia King of DBPR regarding DBPR Case No. 2019-02-1020. [EXHIBIT 1259.]
  9. On May 9, 2019, Tia King of DBPR emailed to admit to WINDSOR that Mahlon C. Rhaney, Jr. made a mistake in the order in DBPR Case No., 2019-02-1020 First Amended Mandatory Non-Binding Petition Form (“AMENDED PETITION”) was not due until Monday, May 13, 2019. [EXHIBIT 1297.]
  10. The First Amended Mandatory Non-Binding Petition Form (“AMENDED PETITION”) was executed on May 9, 2019 and sent to the DBPR for filing in DBPR Case No. 2019-02-1020 with the Second Verified Affidavit of William M. Windsor in Support of Mandatory Non-Binding Petition for Arbitration (“SECOND AFFIDAVIT”) as EXHIBIT F thereto. [EXHIBIT 1009.] [EXHIBIT 1010.]  The exhibits referenced therein match the exhibit numbers on the flash drive.
  11. On May 13, 2019, WINDSOR sent the ASSOCIATION a Notice of Intent to Challenge Violations in Building B regarding the patio “enhancement” and the dog urine. [EXHIBIT 1153.]
  12. On May 13, 2019, WINDSOR emailed the ASSOCIATION, Sentry, and CLAYTON & MCCULLOH a Notice of Intent to Challenge Violations in Building B. [EXHIBIT 1154.]
  13. On May 15, 2019, WINDSOR emailed the ASSOCIATION, Sentry, and CLAYTON & MCCULLOH and stated that the Liebls should have been required to clean up violations years ago. [EXHIBIT 1155.]
  14. On May 15, 2019, WINDSOR filed a Petition for Arbitration regarding the March 22, 2019 meeting and election of the ASSOCIATION.  It was assigned DBPR Case No. 2019-02-6384. [EXHIBIT 1011.] [EXHIBIT 1012.]  The exhibits referenced therein match the exhibit numbers on the flash drive. [EXHIBIT 1851 is the complete file.]
  15. On May 15, 2019, WINDSOR sent a copy of his Petition for Arbitration regarding the March 22, 2019 Election to CLAYTON & MCCULLOH and SENTRY. [EXHIBIT 813.]  He also served notice of intent to file a third petition for arbitration regarding additional issues.
  16. On May 23, 2019, WINDSOR served the ASSOCIATION with Notice of Intent to file a Petition for Arbitration regarding failure to produce records in response to Inspection of Records Requests. [EXHIBIT 811.]
  17. On May 28, 2019, Paula Bouie of DBPR sent WINDSOR a letter regarding his first Complaint for Failure to Produce Records in response to Inspection of Records Requests (DBPR Complaint No. 2019019600). [EXHIBIT 602.]  The investigator claimed WINDSOR never responded, but that is incorrect.  WINDSOR has come to realize that everyone with DBPR is corrupt.
  18. On May 30, 2019, an ORDER REQUIRING ANSWER was served on the ASSOCIATION on WINDSOR’s Petition for Arbitration regarding the March 22, 2019 meeting and election of the ASSOCIATION — Case No. 2019-02-6384. [EXHIBIT 584.]
  19. On May 31, 2019, the DBPR sent WINDSOR a letter regarding his second Complaint for Failure to Produce Records in response to Inspection of Records Requests (DBPR Complaint No. 2019-02-8466). [EXHIBIT 798.]

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