- On December 1, 2019, WINDSOR sent an email to the ASSOCIATION, CLAYTON & MCCULLOH, and SENTRY asking to have someone at Friday’s Inspection of Records to show him where each record is located. [EXHIBIT 1488.] He also mailed a copy to BRIAN of CLAYTON & MCCULLOH.
- On December 6, 2019, WINDSOR conducted an Inspection of Records. Richard Ritterpusch of SENTRY met him at Sentry’s office and told me that no one would be available to answer any questions or direct him to any specific documents. He showed WINDSOR 15 Banker’s Boxes and four file folders. WINDSOR was also given the ability to download three file folders from a laptop. [EXHIBIT 1505. EXHIBIT 1506. EXHIBIT 1507.] WINDSOR immediately realized that very few of the records he had requested were being produced. EXHIBIT 1508 is a photo of the 15 Banker’s Boxes, file folders, and laptop with three file folders. EXHIBIT 1509 is a photo of the downloading from the laptop. EXHIBIT 1510 is the four file folders. Three of the paper file folders had been produced before. The fourth [EXHIBIT 1511 and EXHIBIT 1512] were the records from the purported November 14, 2019 meeting. EXHIBIT 1513, EXHIBIT 1514, EXHIBIT 1515, EXHIBIT 1516, EXHIBIT 1517, EXHIBIT 1518, EXHIBIT 1519, EXHIBIT 1520, EXHIBIT 1521, EXHIBIT 1522, EXHIBIT 1523, EXHIBIT 1524, EXHIBIT 1525, EXHIBIT 1526, EXHIBIT 1527, EXHIBIT 1528, EXHIBIT 1529, EXHIBIT 1530, and EXHIBIT 1531 are boxes that had been produced previously. WINDSOR went through each of the boxes, and EXHIBIT 1532 is the only folder WINDSOR had not previously photocopied.
On December 6, 2019, resignations in writing were not produced for OMAR Nuseibeh, VICKI Hedrick, Jason Chandler, Carol Still, or Donna Hey. Should the DBPR rule that they were lawfully elected, this could mean they are still Directors and have failed to attend any Board Meeting since March 22, 2019.
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