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

  1. 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.
  2. 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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Windsor v. Coach Houses at Leesburg Condominium Lawsuit – FACTS – NOVEMBER 2019

  1. On November 14, 2019, a purported Board Meeting of Coach Houses at Leesburg Condominium Association, Inc. was held, and a purported Special Members Meeting was held.  WINDSOR attended by telephone.  There is supposed to be an audio recording, but WINDSOR’s requests have been ignored.  EXHIBIT 1484 is the agenda.  EXHIBIT 1485 is the package mailed to owners.  EXHIBIT 1486 is the agenda posted on bulletin boards.
  2. On November 14, 2019, WINDSOR served a Notice of Intent to file Petition for Arbitration regarding a purported Board Meeting and a purported Members’ Meeting of Coach Houses at Leesburg Condominium Association, Inc. on November 14, 2019 that were not properly conducted. [EXHIBIT 1491.]
  3. On November 27, 2019, Russell Klemm of CLAYTON & MCCULLOH filed RESPONDENT’S MOTION TO DISMISS FOR FAILURE TO STATE A CAUSE OF ACTION AND TO COMPLY WITH ARBITRATION FINAL ORDER OF DISMISSAL in DBPR Case No. 2019-04-7339. [EXHIBIT 1475.]

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

  1. On October 8, 2019, WINDSOR sent BRIAN of CLAYTON & MCCULLOH notice of a Fair Credit Collection Act dispute. [EXHIBIT 1459.]  EXHIBIT 1457 is the Certified Mail Receipt.  EXHIBIT 1458 is the signed Certified Mail Receipt.
  2. On October 8, 2019, WINDSOR sent an email to CLAYTON & MCCULLOH, SENTRY, and the purported Board of the ASSOCIATION with notice of a Fair Credit Collection Act dispute. [EXHIBIT 1456.]
  3. On September 6, 2020, WINDSOR emailed all of the owners of the ASSOCIATION; BRAD, Debra Zimmerman, Katie Ciccotelli, CHARLIE ANN, and ART with SENTRY; NEAL, RUSSELL, and BRIAN with CLAYTON & MCCULLOH; and DBPR. [EXHIBIT 1798.]  WINDSOR enclosed a copy of his letter to the Secretary of State.  He wrote: “I demand that Russell Klemm cease pretending to represent the ASSOCIATION in legal matters in Lake County or with the DBPR.  He has no authority, and he just lies all the time.”  WINDSOR enclosed his letter seeking to have the corporate charter revoked.  He also said: “Please do not pay any money to Sentry or CLAYTON & MCCULLOH until this is resolved.  I will consider so to be a breach of fiduciary duty.”
  4. On October 16, 2019, WINDSOR finalized his Petition for Arbitration regarding many issues, signed, and had it notarized.  [EXHIBIT 1453.]  This was sent by certified mail to the DBPR.  EXHIBIT 1460 is the Cashier’s Check for the filing fee.  EXHIBIT 1472 is the cover letter.  It also asks why there has been no response to his September 9, 2019 filing.
  5. On October 16, 2019, WINDSOR finalized his SIXTH VERIFIED AFFIDAVIT, signed, and had it notarized.  [EXHIBIT 1455.]  This was sent by certified mail to the DBPR.  EXHIBIT 1483 is the signed certified mail receipt.  EXHIBIT 1487 is the cover letter.

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

  1. On September 3, 2019, Ray Treadwell, General Counsel of the DBPR, emailed me to say he would not speak with me about incompetence and/or corruption on his staff. [EXHIBIT 1293.]
  2. On September 3, 2019, WINDSOR emailed Ray Treadwell, General Counsel of the DBPR emailed, to say he lied to him in his email. [EXHIBIT 1294.]
  3. On September 4, 2019, MAHLON issued an ORDER DENYING MOTION FOR REHEARING, MOTION FOR RECUSAL AND REQUEST FOR DISCOVERY in DBPR Case No. 2019-04-0349. [EXHIBIT 1329.]
  4. On September 4, 2019, MAHLON issued an ORDER DENYING MOTION FOR REHEARING, MOTION FOR RECUSAL AND REQUEST FOR DISCOVERY in DBPR Case No. 2019-03-8814. [EXHIBIT 1329.]
  5. On September 6, 2019, WINDSOR served MAHLON and RUSSELL E. KLEMM of CLAYTON & MCCULLOH with his Notice of Order in DBPR Case No. 2019-02-1020, 2019-02-6834, 2019-03-8814, and 2019-04-0349. [EXHIBIT 1327.]
  6. On September 6, 2019, WINDSOR mailed his Notice of Order to the DBPR and Russell of CLAYTON & MCCULLOH in DBPR Case No. 2019-02-6834. [EXHIBIT 1324.]
  7. On September 6, 2019, WINDSOR mailed his Notice of Order to the DBPR and Russell of CLAYTON & MCCULLOH in DBPR Case No. 2019-03-8814. [EXHIBIT 1325.]
  8. On September 6, 2019, WINDSOR mailed his Notice of Order to the DBPR and Russell of CLAYTON & MCCULLOH in DBPR Case No. 2019-04-0349. [EXHIBIT 1323.]
  9. On September 6, 2019, WINDSOR mailed his Notice of Order to the DBPR and Russell of CLAYTON & MCCULLOH in DBPR Case No. 2019-02-1020. [EXHIBIT 1326.]
  10. On September 8, 2019, WINDSOR sent an email to the members of the ASSOCIATION. [EXHIBIT 1434.]
  11. On September 9, 2019, WINDSOR filed a SECOND AMENDED REQUEST FOR TRIAL DE NOVO in Case No. 2019-CA-001528 in Lake County Court. [EXHIBIT 1333.]
  12. On September 9, 2019, WINDSOR filed a SECOND MOTION FOR CONFERENCE in Case No. 2019-CA-001528 in Lake County Court. [EXHIBIT 1334.]
  13. On September 9, 2019, WINDSOR sent a PETITION FOR ARBITRATION REGARDING FAILURE TO ALLOW INSPECTION OF BOOKS AND RECORDS to the DBPR for filing. [EXHIBIT 1332.]  EXHIBIT I thereto is the FIFTH VERIFIED AFFIDAVIT OF WILLIAM M. WINDSOR IN SUPPORT OF MANDATORY NON-BINDING PETITION FOR ARBITRATION.
  14. On September 9, 2019, WINDSOR sent a REQUEST FOR DISCOVERY [EXHIBIT 1335] for filing with the PETITION FOR ARBITRATION REGARDING FAILURE TO ALLOW INSPECTION OF BOOKS AND RECORDS. [EXHIBIT 1332.]
  15. On September 13, 2019, WINDSOR emailed a letter demanding an Inspection of Records that were not provided. [EXHIBIT 1352.]
  16. On September 15, 2019, WINDSOR emailed the ASSOCIATION his Notice of Intent to file a Petition for Arbitration regarding Inadequate Notice of Meetings. [EXHIBIT 1362.]
  17. On September 16, 2019, WINDSOR mailed the ASSOCIATION by certified mail his Notice of Intent to file a Petition for Arbitration regarding Inadequate Notice of Meetings. [EXHIBIT 1363.]  EXHIBIT 1369 is the certified mail receipt.  EXHIBIT 1441 is the signed certified mail receipt.
  18. On September 17, 2019, WINDSOR emailed notice to the ASSOCIATION, Sentry, and CLAYTON & MCCULLOH that he was still working on his massive legal action against Coach Houses. [EXHIBIT 1439.]
  19. On September 21, 2019, WINDSOR received a Notice of Intent to File Lien.  It showed WINDSOR to owe $678.68, and they charged WINDSOR $107.20 for Intent to File Lien Notice.  It was dated September 13, 2019 but was not received until eight days later.
  20. On September 23, 2019, WINDSOR sent an email to the members of the ASSOCIATION, SENTRY, and CLAYTON & MCCULLOH. [EXHIBIT 1435.]  This was about SENTRY charging fees for filing Notice of a Lien when not permitted in the corporate documents.
  21. On September 23, 2019, WINDSOR sent a certified letter to BRIAN of CLAYTON & MCCULLOH. [EXHIBIT 1436.]  This was about SENTRY charging fees for filing Notice of a Lien when not permitted in the corporate documents.
  22. On September 21, 2019, WINDSOR sent an email regarding the Notice of Intent to File Lien.  WINDSOR asked to be shown where in the corporate documents a $107.20 fee was specified. [EXHIBIT 1395.]  There was no response.
  23. On September 21, 2019, WINDSOR emailed a Notice of Intent to File a Petition for Arbitration by certified mail to the ASSOCIATION. [EXHIBIT 1393.]  EXHIBIT 1442 is the signed certified mail receipt.
  24. On September 23, 2019, WINDSOR mailed a Notice of Intent to File a Petition for Arbitration by certified mail to the ASSOCIATION. [EXHIBIT 1393.]  This regards all of the disputes WINDSOR has documented.  EXHIBIT 1443 is the signed certified mail receipt.
  25. On September 23, 2019, WINDSOR emailed a Notice of Intent to File a Petition for Arbitration regarding fraud with the December 12, 2018 meetings to the ASSOCIATION, SENTRY, and C&M. [EXHIBIT 1437.]
  26. On September 23, 2019, WINDSOR sent an email to the members of the ASSOCIATION, SENTRY, and CLAYTON & MCCULLOH. [EXHIBIT 1435.]  This was about SENTRY charging fees for filing Notice of a Lien when not permitted in the corporate documents.
  27. On September 29, 2019, WINDSOR emailed a message to the ASSOCIATION, SENTRY, and CLAYTON & MCCULLOH. [EXHIBIT 1424.]

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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 – JULY 2019

  1. On July 2, 2019, an Order Denying Petitioner’s Motion for Rehearing (“ORDER DENYING MOTION FOR REHEARING”) was filed in DBPR Case No. 2019-02-1020. [EXHIBIT 1071.]
  2. On July 8, 2019, WINDSOR sent an email to inform the ASSOCIATION, Sentry, and C&M that someone had stolen his Notices of Intent to Apply for Receivership at Coach Houses at Leesburg. [EXHIBIT 1086.]  ED Broom, Jr. responded that he removed one of the three notices as someone wrote “FUC* YOU” on it.  EXHIBIT 1087 is the Notice that was defaced and removed by ED.
  3. On July 8, 2019, WINDSOR posted new Notices of Intent to Apply for Receivership at Coach Houses at Leesburg. [EXHIBIT 1070.]
  4. On July 8, 2019, WINDSOR sent an email to the DBPR Ombudsman asking who to contact about a complaint against DBPR Arbitrator Mahlon C. Rhaney. [EXHIBIT 1199.]
  5. On July 8, 2019, WINDSOR sent a MOTION FOR AMENDMENT TO ORDER REQUIRING RESPONSE in DBPR Case No. 2019-02-6834. [EXHIBIT 1331.]
  6. On July 13, 2019, WINDSOR wrote a Letter to Ronell James of the DBPR regarding Inspection of Records Requests. [EXHIBIT 1141.]  EXHIBIT 1067 is the certified mail receipt.  EXHIBIT 1268 is the signed certified mail receipt.  WINDSOR advised Ronell James that there is no issue before a federal court.  WINDSOR advised him that he suspected fraud and perhaps forgery.
  7. On July 13, 2019, WINDSOR wrote a Letter to Paula Bouie of the DBPR regarding Inspection of Records Requests. [EXHIBIT 1142.]  EXHIBIT 1068 is the certified mail receipt.  EXHIBIT 1269 is the signed certified mail receipt.  WINDSOR advised her that there is no proceeding before a court.  He suggested that there is fraud and perhaps forgery by the ASSOCIATION or its purported attorney.  There has been no response.
  8. On July 16, 2019, WINDSOR filed a Request for Trial De Novo with the County Court in Lake County, Florida. [EXHIBIT 1073.]  WINDSOR served it by certified mail on the DBPR and the attorney for the ASSOCIATION, the Defendants.  EXHIBIT 1074 is the Certified Mail Receipt to Mahlon C. Rhaney of the DBPR.  EXHIBIT 1075 is the Certified Mail Receipt to the attorney for the ASSOCIATION.  EXHIBIT 1076 is the postal receipt. EXHIBIT 1149 is the proof of delivery to Mahlon C. Rhaney of the DBPR.  EXHIBIT 1150 is the proof of delivery to the attorney for the ASSOCIATION.  It was assigned Case No, 35-2019-CA-001528. [EXHIBIT 1854 is the full file on this case.]
  9. On July 16, 2019, WINDSOR sent an email with notice regarding intent to file a legal action for racketeering activity. [EXHIBIT 1077.]
  10. On July 16, 2019, WINDSOR sent an email to inform members of the ASSOCIATION that he filed Case No. 2019-CA-001528 in County Court of Lake County, Florida. [EXHIBIT 1078.]
  11. On July 19, 2019, an Inspection of Records was held at SENTRY.  WINDSOR ‘s request was dated June 26, 2019. [EXHIBIT 1038.]  Virtually none of the requested records were produced.  EXHIBIT 1146 contains all of the pdf files produced on a laptop.  EXHIBIT 1147-1 to EXHIBIT 1147-41 contains photos that WINDSOR took of the records produced.  Almost all of these were produced previously and were not responsive to previous requests.  EXHIBIT 1109-1 to EXHIBIT 1109-29 are all the photocopies WINDSOR made during the July 19, 2019 Inspection of Records.
  12. On July 19, 2019, WINDSOR sent a letter to the ASSOCIATION and BRIAN of CLAYTON & MCCULLOH about the failure to produce the requested records in response to Inspection of Records Requests. [EXHIBIT 1092.]  Virtually none of the requested records were produced.
  13. On July 19, 2019, WINDSOR sent a Fifth Notice of Intent to File Petition for Arbitration and/or Lawsuit due to Failure to Produce Records for Inspection to the ASSOCIATION and BRIAN of CLAYTON & MCCULLOH. [EXHIBIT 1093.]
  14. On July 19, 2019, WINDSOR sent an email to owners of the ASSOCIATION, purported Directors of the ASSOCIATION, ISABEL, ED, SERGIO; BRIAN, NEAL, and RUSSELL of CLAYTON & MCCULLOH; BRAD, ART, and CHARLIE ANN of SENTRY.  This was regarding fraud charges against Coach Houses, purported Directors, SENTRY, and C&M. [EXHIBIT 1095.]  The email detailed dozens of requests for any minutes of the purported August 2017 meeting where some claim the BYLAWS were amended.  The Minutes do not indicate that the BYLAWS were amended.  THERE ARE NO MINUTES OF ANY MEETING OF COACH HOUSES TO AMEND THE BYLAWS TO CHANGE THE DATE OF THE ANNUAL MEETING AND ELECTION.  The March 22, 2019 meetings and election were a fraud, and we have no lawfully-elected directors or officers.  August 1, 2017 violations were detailed.[See SOF 331.]
  15. On July 19, 2019, WINDSOR sent an email to the ASSOCIATION, SENTRY, and CLAYTON & MCCULLOH regarding the July 19, 2019 Inspection of Records. [EXHIBIT 1296.]
  16. On July 19, 2019, WINDSOR sent an email with copies of all July 19, 2019 letters to the ASSOCIATION, SENTRY, and CLAYTON & MCCULLOH. [EXHIBIT 1096.]
  17. On July 22, 2019, a purported Board Meeting was held. [EXHIBIT 1280.]  No minutes were published for the purported meeting.  Video of the meeting is EXHIBIT 1135-1, EXHIBIT 1135-2, EXHIBIT 1135-3, EXHIBIT 1135-4, EXHIBIT 1135-5, EXHIBIT 1135-6, EXHIBIT 1135-7.  There was no quorum, and CHARLIE ANN refused to justify how the meeting could be held.  WINDSOR proposed to end all legal action against the ASSOCIATION if they would admit and correct all the wrongdoing.  There was no response.  Charlie Ann blurted out that there is a Board Portal on the Sentry website for the ASSOCIATION.  These documents have never been produced to WINDSOR in Inspection of Records.  This provides absolute proof of violations of the Florida Statutes and BYLAWS regarding Inspection of Records.
  18. On July 22, 2019, WINDSOR sent an email to owners about the purported Board Meeting of July 22, 2019. [EXHIBIT 1281.]  WINDSOR demanded that the purported Board act to put an end to the fraud on the non-existent amendment to the bylaws to change the annual election date.
  19. On July 25, 2019, WINDSOR sent an email to the ASSOCIATION informing all that he is seeking $12,000 pursuant to Florida statutes for failure to produce records for inspection. [EXHIBIT 1274.]
  20. On July 27, 2019, WINDSOR’s Petition for Mandatory Non-Binding Arbitration for Failure to Produce Records for Inspection was sent to the DBPR for filing.  It was assigned DBPR Case No. 2019-03-8814. [EXHIBIT 1190.]
  21. On July 27, 2019, WINDSOR sent an email to the ASSOCIATION about the owners who are being allowed to illegally rent their condos. [EXHIBIT 1283.]
  22. On July 28, 2019, WINDSOR sent an email to the ASSOCIATION about the failure to remove the “enhancement” outside Unit B2. [EXHIBIT 1282.]
  23. On July 29, 2019, WINDSOR’s Petition for Mandatory Non-Binding Arbitration for Failure to Produce Records for Inspection was filed by the DBPR.  It was assigned DBPR Case No. 2019-03-8814. [EXHIBIT 1190.]
  24. On July 30, 2019, WINDSOR sent his Mandatory Non-Binding Petition Form Regarding Failure to Require Udo and Dorothy Liebl to Remove Unauthorized Appurtenances and Clean Carpets. [EXHIBIT 1191.]  This was assigned Case No. 2019-04-0349.
  25. On July 31, 2019, the Arbitrator issued a FINAL ORDER OF DISMISSAL in DBPR Case No. 2019-02-6834. [EXHIBIT 1184.]  WINDSOR was served a copy by email on August 1, 2019. [EXHIBIT 1243.]

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

  1. On June 5, 2019, the ASSOCIATION filed Respondent’s Motion to Dismiss for Failure to State a Cause of Action (DBPR Case No. 2019-02-1020). [EXHIBIT 796.]
  2. On June 5, 2019, investigator Ron James from the DBPR called to discuss WINDSOR’s second Complaint regarding failure to produce documents (DBPR Complaint No. 2019028466).  He sent WINDSOR a letter dated June 5, 2019. [EXHIBIT 994.]
  3. On June 5, 2019, WINDSOR entered into a contract to sell his Coach Houses Unit B3 for $80,000. [EXHIBIT 1015.]
  4. On June 6, 2019, a purported Board Meeting was held. [EXHIBIT 973.] [EXHIBIT 1367 is the Minutes.]  ISABEL CAMPBELL, SERGIO NAUMOFF, and ED BROOM were present.  Purported Officer and Board Member ISABEL CAMPBELL told the attendees that the Board was very confident that the ASSOCIATION would prevail in WINDSOR’s First Petition for Arbitration.  She gave no explanation.  She discussed her review of the finances of the ASSOCIATION and presented a Proposed Adjusted Budget for 2019. [EXHIBIT 974.]  The Proposed Adjusted Budget showed a reduction in Building Maintenance by $26,729.27 and no change in Grounds Maintenance, Utilities, or Budgeted Transfer to Reserves.  It showed an increase of approximately $50,000 in Income and Administrative & Management Expense.  Those costs showed a $75,000 increase in legal fees.  Those are all costs related to the ASSOCIATION’S defense of all the violations WINDSOR had identified.  The video of the June 6, 2019 meeting is EXHIBIT 995-1, EXHIBIT 995-2, EXHIBIT 995-3, EXHIBIT 995-4, EXHIBIT 995-5, EXHIBIT 995-6, and EXHIBIT 995-7.
  5. On June 6, 2019, WINDSOR sent an email to the purported Board, CLAYTON & MCCULLOH, and SENTRY MANAGEMENT regarding the Board Meeting. [EXHIBIT 822.]  He said:

I hereby request to be named a Board Member.  If we have openings, you are required by statute to notify the owners, and you didn’t.  You want an odd number, though that is not in our Bylaws or the Florida statutes.  But, now I’m Board Member #5.  37 years of Minutes show this is what is done when there are openings pre-Omar.

For the record, today’s meeting was invalid.  The March election was invalid.  I didn’t raise a Point of Order as owners don’t have such a right at a Board Meeting. 

A very intelligent request was made today by an owner to have special expenses treated through Special Assessments.  CHARLIE ANN ALDRIDGE told all at the meeting that the attorneys said our BYLAWS prohibit this.  There is NOTHING in our BYLAWS that prohibits special assessments.  I asked for the Bylaw to be identified, and CHARLIE ANN ALDRIDGE told me to hire an attorney.   I came home and read the BYLAWS for about the hundredth time.  I am preparing to file another Petition that will list this as another violation.  Florida law specifically permits Special Assessments (Section 718.112(2)(c)1, Florida Statutes): http://www.condo-owner.com/article/special-assessments-do-it-right-or-pay-the-price/

By the way, Florida Statutes take precedence over bylaws.

I have an eyewitness to the Libel dog soiling the carpets in Building B.  Ask Jason and Karen Chandler.  Mrs. DOROTHY LIEBL (Libel) claimed her dog never did any such thing.  WRONG!

Unfortunately, your new Board has chosen to fight me legally.  At today’s meeting, I offered to withdraw my actions against the Association.  I am willing to do this if CLAYTON & MCCULLOH and SENTRY MANAGEMENT refund to the Association all money paid by the Association to them from 2016 to 2019.

The people responsible for our outrageous legal fees are OMAR NUSEIBEH, VICKI HEDRICK, KAREN BOLLINGER, CHARLIE ANN ALDRIDGE, SENTRY MANAGEMENT, BRIAN HESS, NEAL MCCULLOH.”

  • On June 7, 2019, WINDSOR sent a certified letter to attorney BRIAN HESS of CLAYTON AND MCCULLOH for the ASSOCIATION. WINDSOR enclosed a Letter from Karen Chandler about B3 Carpet; Email from him about Breach of Fiduciary Duty, Liebls, and Lawyers; Letter from him agreeing to be a Director; Email from WINDSOR about Board Meeting; Email from WINDSOR about Vandalism in Building B; Email from WINDSOR with Notice of Intent to file Third Petition for Arbitration; Notice of Intent for his Third Petition, pre-arbitration letter and Exhibits AA, BB, CC, DD, EE, and FF; Email from WINDSOR with Notice of Intent to file Third Petition Part 1 of 3; Email from WINDSOR with Notice of Intent to file Third Petition Part 2 of 3; Email from WINDSOR with Notice of Intent to file Third Petition Part 3 of 3. [EXHIBIT 991.]  The certified mail receipt is EXHIBIT 992.  WINDSOR also hand-delivered a copy to SENTRY; Richard accepted the envelope.
  • On June 7, 2019, Karen Chandler from Unit B4 wrote a letter with evidence that the Liebl’s dog in B2 was responsible for staining the carpets in Building B. [EXHIBIT 821.]  She gave the letter to WINDSOR, and he emailed it to the purported Board, SENTRY MANAGEMENT, and CLAYTON AND MCCULLOH.
  • On June 7, 2019, WINDSOR sent an email to the purported Board, SENTRY MANAGEMENT, and CLAYTON & MCCULLOH charging Breach of Fiduciary Duty. [EXHIBIT 823.]  The email says:

“Karen Chandler in Unit B4 will speak to the Board and sign an affidavit stating that the Libels dog caused the carpet mess in Building B.  She has seen the dog do it.  She has seen Dorothy Libel with the dog when the dog did it.  Dorothy Libel has told Karen and Jason that the dog has “bladder issues.”

Karen cared for the dog when the Liebels were out of town, and the dog peed on the carpet at the top of the stairs.  Karen obviously observed this.

Just like the Old Board, the New Board is not requiring Dorothy Libel to clean the carpets, and this is imposing an expense on the owners that is wrongful.  23 spots have been documented with photos.

Have Libels pay, or I will sue.  Consider this Notice of Intent to file a Petition and sue.

ALSO, the Minutes of the ASSOCIATION establish that carpets have been replaced at various times.  Building B is the newest.  There is no reason to not stagger this work over the years.  It should be a budgeted Reserves item.  Building B simply needs the 23 spots of pee and poo cleaned.  Doing all buildings at one time hurts all owners.

Your approval of payments to CLAYTON AND MCCULLOH constitutes breach of fiduciary duty, in my opinion.

Your approval of fighting my first Petition also constitutes breach of fiduciary duty, in my opinion.  And if a letter from Monalene Werner magically appears after months of requests, I believe this constitutes fraud.  You better believe I will pursue that in court.

Thank you for establishing a rule yesterday that limits owners to three minutes per agenda item.  This helps enforce the fact that my rights and the rights of others were violated prior to this alleged Board enactment when CHARLIE ANN ALDRIDGE and OMAR NUSEIBEH claimed there was such a rule.  No such rule in the Rules or Minutes over the last 37 years.

  • On June 9, 2019, WINDSOR emailed attorney RUSSELL KLEMM (“RUSSELL”) of CLAYTON AND MCCULLOH, attorney BRIAN HESS, attorney NEAL MCCULLOH of CLAYTON AND MCCULLOH, and the ASSOCIATION asking them to withdraw the sham Motion to Dismiss for Failure to State a Cause of Action. [EXHIBIT 818.]
  • On June 9, 2019 at 9:54 a.m., WINDSOR emailed ISABEL CAMPBELL, SERGIO NAUMOFF, and ED BROOM advising them of his intent to sue them for breach of fiduciary duty. [EXHIBIT 819.]  The email said:

I intend to sue ISABEL CAMPBELL, SERGIO NAUMOFF, and ED BROOM for breach of fiduciary duty and other causes of action.  Please notify your insurance carrier, and ask the insurance folks to call me.

I will allege that you folks have failed to take the necessary actions to operate legally; you have spent money improperly; you are using dishonest attorneys and a dishonest management company and have been provided with massive proof.  You have presented false information to the owners about BYLAWS and special assessments.  You have concealed wrongdoing with Reserve funds.  You have failed to get the fraudulent BYLAW filing removed from Lake County Records.  You have told owners that all work must be done at the same time so some owners don’t feel slighted.  That’s a load of you-know-what.  You have not enforced the letter sent several years ago to the Libels.  You have evidence that the Libels are guilty, but you want all owners to pay to clean it up.  You have not had the Libels “installation” removed, though they were ordered to do so years ago.  And more…

It took you 76 days to hold a meeting in which ISABEL CAMPBELL essentially recited information that I had prepared back in February.

Should a letter from Monalene Werner magically appear next week, I will also charge you with fraud.  If allowed by Florida law or federal law, I will charge you with criminal racketeering (RICO).

Please keep all emails and other communications safe as they will be evidence in the case.  Please do not delete anything.  I will seek a forensic audit of your electronic devices, if necessary.

The D&O Insurance carrier was not notified.  This email was also sent to BRAD POMP, ART SWANTON, and CHARLIE ANN ALDRIDGE with SENTRY MANAGEMENT and BRIAN HESS and NEAL MCCULLOH with CLAYTON AND MCCULLOH.

  1. On June 10, 2019, WINDSOR emailed the ASSOCIATION, ISABEL, SERGIO, and ED, SENTRY, and CLAYTON AND MCCULLOH advising them of his intent to petition for arbitration regarding failure to enforce the Rules. [EXHIBIT 875.]
  2. On June 11, 2019, WINDSOR sent an email to the owners, purported Board, SENTRY, and CLAYTON AND MCCULLOH.  WINDSOR said payables must be frozen so C&M will not be paid $80,000 in legal fees. [EXHIBIT 988.]
  3. On June 11, 2019, WINDSOR sent a Notice of Intent to File Petition for Arbitration regarding Violations of Corporate Documents, Rules, and Florida Statutes, purported Board, SENTRY, and CLAYTON AND MCCULLOH.  WINDSOR also mailed a copy to attorney BRIAN. [EXHIBIT 989.]
  4. On June 11, 2019, DBPR investigator Paula Bouie sent WINDSOR a letter about the Complaint he filed over failure to produce records for January 9, 2019, February 5, 2019, February 22, 2019, and February 27, 2019 in response to Inspection of Records Requests. [EXHIBIT 1014.]
  5. On June 13, 2019, a second Final Order of Dismissal (“SECOND FINAL ORDER OF DISMISSAL”) was filed in DBPR Case No. 2019-02-1020. [EXHIBIT 1008.]
  6. On June 14, 2019, SUE Yokley purchased Unit C3 from Medea Minnich.  She paid $48,000. [EXHIBIT 1426.]
  7. On June 17, 2019, the buyers of his Unit B3 condo canceled the purchase agreement.  They canceled because of the excessive monthly “dues” and the lack of amenities at Coach Houses. [EXHIBIT 1016.]  On June 17, 2019, WINDSOR sent an email to the owners advising them that his sale fell through. [EXHIBIT 1040.]
  8. On June 17, 2019, WINDSOR sent an email to the ASSOCIATION demanding that the Building B carpets be cleaned. [EXHIBIT 1041.]
  9. On June 18, 2019, WINDSOR sent the ASSOCIATION an email stating that the potential buyers for his condo were repulsed by the carpets and the failure to have the Liebls clean the carpets undoubtedly contributed to the loss of a sale. [EXHIBIT 1156.]
  10. On June 18, 2019, the MOTION FOR REHEARING in DBPR Case No. 2019-02-1020 was executed, served, and sent to DBPR for filing. [EXHIBIT 1018.] 
  11. On June 18, 2019, the FOURTH AFFIDAVIT in DBPR Case No. 2019-02-1020 was executed, served, and sent to DBPR for filing. [EXHIBIT H.] 
  12. On June 18, 2019, the THIRD AFFIDAVIT in DBPR Case No. 2019-02-1020 was executed, served, and sent to DBPR by email. [EXHIBIT G.] 
  13. On June 18, 2019, PETITIONER’S RESPONSE TO RESPONDENT’S MOTION TO DISMISS AND MOTION TO STRIKE RESPONDENT’S MOTION TO DISMISS in DBPR Case No. 2019-02-1020 was executed, served, and sent to DBPR for filing. [EXHIBIT 1022.]

 

  1. On June 20, 2019, a purported Board Meeting was held. [EXHIBIT 1059.] [EXHIBIT 1368 is the Minutes.]  Barbara and Larry Lunsford attended the meeting as did SERGIO NAUMOFF and CHARLIE ANN ALDRIDGE OF SENTRY MANAGEMENT (shown above).  There was no discussion of quorum (0:00 to 0:42 in the video.)  CHARLIE ANN ALDRIDGE denied WINDSOR’s right to speak on the subject of “reorganization of the Board.” [EXHIBIT 1059 from 1:04 to 1:30.]  At 2:50, WINDSOR asked “what about the eight open spots on the Board?”  CHARLIE ANN ALDRIDGE said the meeting was adjourned.  She then ordered WINDSOR to leave the building.  The remainder of the video is CHARLIE ANN ALDRIDGE escorting WINDSOR out of the building.  Later that day, owner Larry Lunsford informed WINDSOR that two Tavares Police Officers arrived after he left.  As the video shows, there was absolutely no basis for reporting WINDSOR to the police.
  2. On June 21, 2019, WINDSOR sent a Notice of Intent to File Petition for Arbitration and/or a Lawsuit Regarding Violations of Corporate Documents, Rules, and Florida Statutes to BRIAN HESS of CLAYTON AND MCCULLOH. [EXHIBIT 1080.]  EXHIBIT 542 is the certified mail receipt.
  3. On June 21, 2019, the MOTION FOR REHEARING in Case No. 2019-02-1020 was executed, served, and sent to DBPR by mail. [EXHIBIT 1018.]  The Microsoft Word version of this filing is EXHIBIT 1019.  EXHIBIT 476 is the Certified Mail Receipt.
  4. On June 21, 2019, the FOURTH AFFIDAVIT in Case No. 2019-02-1020 was executed, served, and sent to DBPR by mail. [EXHIBIT H.]  The Microsoft Word version of this filing is EXHIBIT 1024.
  5. On June 21, 2019, the THIRD AFFIDAVIT in Case No. 2019-02-1020 was executed, served, and sent to DBPR by mail. [EXHIBIT G.]
  6. On June 21, 2019, PETITIONER’S RESPONSE TO RESPONDENT’S MOTION TO DISMISS AND MOTION TO STRIKE RESPONDENT’S MOTION TO DISMISS in Case No. 2019-02-1020 was executed, served, and sent to DBPR by mail. [EXHIBIT 1022.]  EXHIBIT 1037 is the certified mail receipt for the THIRD AFFIDAVIT, FOURTH AFFIDAVIT, PETITIONER’S RESPONSE TO RESPONDENT’S MOTION TO DISMISS AND MOTION TO STRIKE RESPONDENT’S MOTION TO DISMISS, and MOTION FOR REHEARING in DBPR Case No. 2019-02-1020 that was served on KLEMM.  [EXHIBIT 522 is the certified mail receipt.]
  7. On June 23, 2019, WINDSOR sent a Notice of Intent to Apply for Receivership to the ASSOCIATION. [EXHIBIT 569.]
  8. On June 23, 2019, WINDSOR emailed the ASSOCIATION with a request to be able to post the Notice of Intent to Apply for Receivership where conspicuous notices are posted. [EXHIBIT 1039.]  There was no response.
  9. On June 25, 2019, Ronell James of DBPR sent WINDSOR a letter saying the ASSOCIATION provided documentation to show his issue in Case No. 2019028466 was before federal court in Atlanta, Georgia. [EXHIBIT 1139.]  This is absolutely false, and WINDSOR suspects forgery.
  10. On June 25, 2019, WINDSOR served his Motion for Default and Motion for Fees and Costs in DBPR Case No. 2019-02-6384. [EXHIBIT 1186.]
  11. On June 27, 2019, WINDSOR received RESPONDENT’S MOTION TO DISMISS FOR FAILURE TO STATE A CAUSE OF ACTION in DBPR Case No. 2019-02-6834. [EXHIBIT 1042.]
  12. On June 28, 2019, WINDSOR sent a Motion for Leave to file Condominium Arbitration Complaints to the U.S. District Court for the Northern District of Georgia – Case No. 1-11-CV-01923-TWT. [EXHIBIT 1202.]
  13. On June 29, 2019, WINDSOR paid Stanley Steemer $83.75 to clean the carpets in Building B. [EXHIBIT 1062.]
  14. On June 29, 2019, WINDSOR sent an email to inform owners that he had been reported to the police by the ASSOCIATION or SENTRY MANAGEMENT on June 20, 2019. [EXHIBIT 1088.]  [EXHIBIT 1059 at 2:50, I asked “what about the eight open spots on the Board?”  CHARLIE ANN ALDRIDGE said the meeting was adjourned.  She then ordered WINDSOR to leave the building.  The remainder of the video is CHARLIE ANN ALDRIDGE escorting WINDSOR out of the building.  Later that day, owner Larry Lunsford informed WINDSOR that two Tavares Police Officers arrived after he left.  As the video shows, there was absolutely no basis for reporting WINDSOR to the police.
  15. On June 29, 2019, WINDSOR sent for filing his Response to Respondent’s Motion to Dismiss and Motion to Strike Respondent’s Motion to Dismiss in DBPR Case No. 2019-02-6834. [EXHIBIT 1089.]
  16. On June 29, 2019, WINDSOR sent the DBPR and RUSSELL KLEMM of CLAYTON and MCCULLOH an email with his Motion to Strike the Motion to Dismiss in DBPR Case No. 2019-02-6834. [EXHIBIT 1090.]

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

  1. On April 2, 2019, WINDSOR went to the Lake County Courthouse for the hearing on a Petition for Injunction against Stalking filed by Dorothy Liebl in Unit B2. [EXHIBIT 416.]  She didn’t show up, and the case was dismissed.  WINDSOR was planning to have her commit count after count of perjury, so he was somewhat disappointed to lose his day in court.
  2. On April 4 and 6, 2019, five of the purported newly-elected Directors requested a Special Meeting of the Directors. [EXHIBIT 1400.]
  3. The Special Member Meeting that CLAYTON & MCCULLOH said would be held on April 4, 2019 was never noticed or held. [EXHIBIT 56 is WINDSOR’s Notice of Intent to file an Arbitration Petition regarding this.] 
  4. A purported Special Board Meeting was then scheduled for April 11, 2019. [EXHIBIT 968.]  Shehneela Arshi acknowledged receipt of the letters requesting the special meeting and scheduled the meeting for April 11, 2019. [EXHIBIT 1401.]  The Notice was posted on the bulletin boards in the buildings of Coach Houses at Leesburg. [EXHIBIT 968.]  Shehneela claimed that one of the letter writers, Donna Hey, lost her seat on the Board because she was past due. [EXHIBIT 1401.]  WINDSOR had provided evidence to show this was false and that the lien and foreclosure filed against Donna Hey was improper.  WINDSOR asked Shehneela for proof, and she failed to provide any. [EXHIBIT 1402.]
  5. On April 8, 2019 and April 9, 2019, WINDSOR advised the ASSOCIATION by email and mail that he would file his Petition for Arbitration regarding the Recall / Election by April 29, 2019 if his requests were not met. [EXHIBIT 321.] [EXHIBIT 353.]  The ASSOCIATION did not respond.
  6. On April 9, 2019, WINDSOR sent a Notice of Intent to Challenge the March 22, 2019 election to the ASSOCIATION, SHEHNEELA, ISABEL, Sergio, and the Election Monitor. [EXHIBIT 444.]
  7. On April 10, 2019, Notice of a Board Meeting for April 11, 2019 was posted on the bulletin boards at Coach Houses of Leesburg. [EXHIBIT 1399.]  The Notice of the Board Meeting was on the Building B bulletin board when WINDSOR walked in at approximately 4:45 pm on April 10, 2019. [EXHIBIT 968.]
  8. On April 10, 2019, WINDSOR sent an email to the owners (including SHEHNEELA, SERGIO, AND ISABEL) saying that if the April 11, 2019 meeting was not held, he would file all of his complaints against the Association, Sentry, and C&M. [EXHIBIT 990.] [EXHIBIT 1403.]
  9. emailed WINDSOR at 5:08 pm to say that Donna Hey and Carol Still were delinquent and cannot serve.  This is absolutely false. [EXHIBIT 1404.]  The Condominium Act, Section 718.112(2)(n), states that a director or officer who is more than 90 days delinquent in the payment of any monetary obligation due to the association shall be deemed to have abandoned the office, creating a vacancy in the office to be filled according to law.  There is no evidence of this for either Donna Hey or Carol, Still.
  10. Shehneela also claimed Larry Lunsford and Johnny Lynn withdrew their requests for the meeting because WINDSOR had harassed them into sending the letters. [EXHIBIT 1405.]  WINDSOR never did any such thing.  Larry Lunsford has confirmed in writing that WINDSOR never bullied him. [EXHIBIT 1406.]  Johnny Lynn responded in the same manner. [EXHIBIT 1407.]
  11. There is no Bylaw, state law, or Rule that provides that letters can be withdrawn.  WINDSOR requested legal authority for this and proof of the withdrawals, and Shehneela ignored him.
  12. At 6:25 pm on April 10, 2019, the Notice of a BOARD Meeting for April 11, 2019 was posted on the bulletin boards at Coach Houses of Leesburg with the word CANCELED written across it. [EXHIBIT 283.]
  13. Purported President Shehneela sent WINDSOR a cease and desist email saying he was never to contact her again. [EXHIBIT 1408.]
  14. On April 10, 2019, WINDSOR sent a Notice of Intent to Challenge the April 4, 2019 meeting to the ASSOCIATION. [EXHIBIT 437.]
  15. On April 10, 2019, WINDSOR emailed a Notice of Intent to Challenge the April 11, 2019 meeting to the ASSOCIATION, ED, ISABEL, SERGIO, other owners; BRIAN and NEAL of C&M; ART and CHARLIE ANN of SENTRY. [EXHIBIT 445.]
  16. On April 10, 2019, WINDSOR emailed a Notice of Intent to Challenge the February 19, 2019 Recall / Election to the ASSOCIATION. [EXHIBIT 446.]
  17. On April 10, 2019 at 7:29 pm, WINDSOR emailed a Condominium Complaint to the ASSOCIATION, BRIAN and NEAL of CLAYTON & MCCULLOH; ART and CHARLIE ANN of SENTRY. [EXHIBIT ­­­­­1541.]
  18. On April 10, 2019 at 7:29 pm, WINDSOR mailed a Condominium Complaint to the DBPR. [EXHIBIT ­­­­­1542.]
  19. On April 10, 2019 at 8:09 pm, WINDSOR emailed a Condominium Complaint to the ASSOCIATION, BRIAN and NEAL of CLAYTON & MCCULLOH; ART and CHARLIE ANN of SENTRY. [EXHIBIT ­­­­­1539.]
  20. On April 10, 2019 at 8:09 pm, WINDSOR mailed a Condominium Complaint to the DBPR. [EXHIBIT ­­­­­1540.]
  21. The April 11, 2019 meeting was not held.  EXHIBIT 57 is WINDSOR’s Notice of Intent to file an Arbitration Petition regarding this.
  22. On April 11, 2019, WINDSOR mailed a Condominium Complaint to the DBPR. [EXHIBIT ­­­­­1543.]
  23. On April 12, 2019, WINDSOR sent an email and letter to BRIAN and NEAL of CLAYTON & MCCULLOH and BRAD, ART, and CHARLIE ANN of SENTRY documenting that BRIAN was violating the ASSOCIATION’s Rules regarding Inspection of Records.  WINDSOR demanded production of ALL documents previously requested on April 23, 2019.  The documents were not produced. [EXHIBIT 278.]  (EXHIBIT 606 is the Certified Mail Receipt.)
  24. On April 14, 2019, WINDSOR mailed a Notice of Intent to Challenge the December 12, 2018 meetings to the ASSOCIATION. [EXHIBIT 439.]  He also sent the Notice of Intent to Challenge the December 12, 2018 meetings by email to the ASSOCIATION, C&M, and SENTRY. [EXHIBIT 440.]
  25. On April 17, 2019, WINDSOR sent an email to C&M, SENTRY, and the ASSOCIATION advising that his Petition for Arbitration on the Recall / Election had to be filed on April 19, 2019.  WINDSOR asked them to advise if they had decided to grant his requests. [EXHIBIT 351.]
  26. On April 18, 2019, WINDSOR executed a Mandatory Non-Binding Petition Form naming the ASSOCIATION as Respondent.  This “ORIGINAL PETITION” was regarding the events that led to and immediately after a purported meeting and election on February 19, 2019.  It was received by the DBPR on April 19, 2019. [EXHIBIT 1001.]
  27. On April 23, 2019, WINDSOR sent an email to CLAYTON & MCCULLOH, SENTRY, and the ASSOCIATION advising that he would be filing a Petition for Arbitration for failure to allow Inspection of Records. [EXHIBIT 300.]  WINDSOR requested a copy of the alleged Request for Inspection dated March 22.  Nothing was ever produced to show that WINDSOR made such a request.
  28. On April 23, 2019, WINDSOR conducted an Inspection of Records at SENTRY.  It was scheduled by CLAYTON & MCCULLOH claiming it was for his March 22, 2019 Request.  WINDSOR never made a March 22, 2019 Request for Inspection.  WINDSOR asked for proof that he requested such an Inspection, and his emails were ignored. [EXHIBIT 67.]  [EXHIBIT 1220.]  There was no one from the ASSOCIATION or SENTRY available during the Inspection of Records.
  29. Three file folders and four pdf files were produced on April 23, 2019. [EXHIBIT 61.]  EXHIBIT 61 – D and E show the total production on April 23, 2019; the laptop contained four pdf files.  EXHIBIT 61 — F, G, and H show the records produced regarding the August 1, 2017 “meeting.”  EXHIBIT 61 — I, J, and K show the records produced regarding the December 12, 2018 “meeting.”  EXHIBIT 61 – L, M, and N show the records produced regarding the March 22, 2019 “meeting.”  WINDSOR had previously copied the documents for December 12, 2018 and March 22, 2019, so he simply copied what he identified as new documents.  The third file folder (EXHIBIT 61 – F, G, and H) was the file for the August 1, 2017 meeting that WINDSOR had requested many times in January, February, and March.  WINDSOR believes CLAYTON & MCCULLOH may have pretended WINDSOR made a Request for Inspection to sneak in these documents after he filed his first Petition for Arbitration regarding the Recall / Election.  WINDSOR copied the entire folder.  EXHIBIT 330 contains the four pdf files produced on the laptop.
  30. On April 23, 2019, WINDSOR sent an email to CLAYTON & MCCULLOH, SENTRY, the ASSOCIATION, and owners advising of the proof that he obtained that day proving the BYLAWS were not legally amended. [EXHIBIT 355.]  The email served a notice of intent to file a petition for arbitration regarding the purported BYLAW amendment.  WINDSOR demanded action.  There was no response.
  31. WINDSOR has found the attorneys with CLAYTON & MCCULLOH and CHARLIE ANN with SENTRY to be dishonest.  He suspects that some of the documents that have been provided in response to Inspection of Records Requests have been altered.  EXHIBIT 366 is a Limited Proxy produced on April 23, 2019 that shows it was invalid on December 13, 2017.  “Needs to be corrected” is written in CHARLIE ANN’s handwriting.  The Received Stamp reads Dec 18 2017, so this appears to have been changed after the December 13, 2017 meeting and vote.  WINDSOR believes this is falsification of ASSOCIATION records, which may be a criminal offense.
  32. On April 25, 2019, WINDSOR sent two emails to BRIAN and NEAL of CLAYTON & MCCULLOH; BRAD, ART, and CHARLIE ANN of SENTRY; the ASSOCIATION; ISABEL, OMAR, KAREN, and VICKI; and some owners advising them of his intent to file a petition for arbitration or lawsuit regarding bylaw fraud. [EXHIBIT 400.]
  33. On April 26, 2019, WINDSOR sent an email to BRIAN and NEAL of C&M; BRAD, ART, and CHARLIE ANN with SENTRY; purported Board members; ISABEL, ED, SERGIO, the ASSOCIATION, and owners advising them of his intent to file a lawsuit and seek a Receiver. [EXHIBIT 399.]
  34. On April 26, 2019, a Final Order of Dismissal (“FIRST FINAL ORDER”) was issued in DBPR Case No. 2019-02-1020 due to alleged confusion over receipt of the original petition for arbitration that WINDSOR filed. [EXHIBIT 1002.]  The FIRST FINAL ORDER was sent by email. [EXHIBIT 1259.]  WINDSOR quickly learned that the DBPR is corrupt.
  35. On April 26, 2019, WINDSOR sent a Petition for Rehearing for filing regarding the FIRST FINAL ORDER issued in DBPR Case No. 2019-02-1020. [EXHIBIT 1200.]
  36. On April 29, 2019, WINDSOR received a certified letter from BRIAN of CLAYTON & MCCULLOH. [EXHIBIT 315.]  He said WINDSOR’s April 24, 2019 Request for Inspection of Records would be provided on September 13, 2019.  This is a violation of Florida statutes and the ASSOCIATION’S rules.
  37. On April 30, 2019, WINDSOR sent an email to CLAYTON & MCCULLOH, SENTRY, and the ASSOCIATION reminding them that he would be filing a Petition for Arbitration regarding the March 22, 2019 meeting. [EXHIBIT 312.]  WINDSOR asked them to contact him right away.  There was no response.
  38. On April 30, 2019, WINDSOR exchanged emails with Alicia Lawrence of DBPR regarding his Petition in Case No. 2019-02-1020.  WINDSOR needed to identify the form that Mahlon C. Rhaney, Jr. (“MAHLON”) was requiring him to use. [EXHIBIT 1259.]  WINDSOR later realized that this was corruption by MAHLON.

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

  1. On March 1, 2019, WINDSOR sent an email to OMAR, VICKI, and KAREN, the attorneys with CLAYTON & MCCULLOH, and CHARLIE ANN, BRAD and ART at SENTRY. [EXHIBIT 238.]   WINDSOR advised them that the ASSOCIATION was not operating legally because of the name.  Paragraph 1 of the DECLARATION says “The name by which this condominium is to be identified is COACH HOUSES AT LEESBURG.”  This violates Florida statute 718.104 (4) (b) requires that “the name by which the condominium property is to be identified, which shall include the word ‘condominium’ or be followed by the words ‘a condominium.’”  WINDSOR also noted that the ASSOCIATION only has 16 voting members according to the DECLARATION 13.3.  WINDSOR again demanded that OMAR, VICKI, and KAREN cease pretending to be the officers and directors.  There was no response.
  2. On March 1, 2019, ART of SENTRY, emailed in response to WINDSOR’s email to say the issues would be reviewed by the association’s attorney. [EXHIBIT 239.]  There was no response from the ASSOCIATION or the CLAYTON & MCCULLOH DEFENDANTS.
  3. On March 2, 2019, WINDSOR sent an email to OMAR, VICKI, and KAREN; BRIAN with CLAYTON & MCCULLOH; and BRAD, ART, and CHARLIE ANN at SENTRY. [EXHIBIT 252.]   WINDSOR expressed that he did not consider the announced March 22, 2019 meeting to be a valid meeting of the ASSOCIATION.
  4. On March 5, 2019, a so-called “Town Hall Meeting” was held. [EXHIBIT 281.]  WINDSOR considered it to be an effort by CLAYTON & MCCULLOH to dissuade owners from voting to replace OMAR, VICKI, and KAREN. [EXHIBIT 282-1, EXHIBIT 282-2, EXHIBIT 282-3, EXHIBIT 282-4, EXHIBIT 282-5, EXHIBIT 282-6, EXHIBIT 282-7 is video from the meeting.]  No minutes were published for the purported meeting. 
  5. On March 5, 2019, NEAL McCulloh of CLAYTON & MCCULLOH distributed a letter to the owners of the ASSOCIATION. [EXHIBIT 267.]  In the second paragraph on page 1, NEAL claims the actions taken on December 12, 2018 were at his firm’s direction.  I believe this is proof of malpractice.  In the first full paragraph on page 2, NEAL claims the directors were properly elected because “only three (3) people timely and properly submitted an intent to be a candidate for the current term.”  This is false.  This has been documented above.  In the first full paragraph on page 2, NEAL falsely claims individuals were recommending self-management and elimination of professional services.  I believe this is false and malicious.  In that paragraph, NEAL also claims so many of the legal challenges (by me) are “completely wrong, in error, and in derogation of the Florida Statutes and/or the Association’s Governing Documents.”  This is false and malicious.
  6. After the meeting ended, WINDSOR spoke with NEAL and suggested a meeting to discuss and attempt to resolve the issues.  WINDSOR expressed that this would be far less expensive to the owners.  NEAL refused.  He told WINDSOR to handle it through legal filings.
  7. On March 5, 2019, Dorothy Liebl of B2 told people in attendance that WINDSOR had harassed her.  [EXHIBIT 282-1, EXHIBIT 282-2, EXHIBIT 282-3, EXHIBIT 282-4, EXHIBIT 282-5, EXHIBIT 282-6, EXHIBIT 282-7, EXHIBIT 282-8, EXHIBIT 282-9.]  This was slander.
  8. Unknown to WINDSOR until several weeks later when he called the police to see if anything had been filed against him, WINDSOR learned that on March 14, 2019. Dorothy Liebl in Unit B2 tried to get the police to arrest him for the crimes of harassment and threats. [EXHIBIT 417.]  This was an absolute outrage.  This is a false police report that is a violation of Florida law.  Dorothy Liebl is a major supporter of OMAR, VICKI, and KAREN.  The police never contacted WINDSOR.
  9. On March 14, 2019, WINDSOR emailed OMAR, VICKI, and KAREN, CHARLIE ANN and ART of SENTRY, and BRIAN of CLAYTON & MCCULLOH saying they had failed to respond to him on the ability of Donna Dailey and Donna *** to vote.  WINDSOR asked them to confirm how much Donna Hey allegedly owed as he would pay it so she could vote. [EXHIBIT 292.]  They never responded to this Request for Inspection of Records.  WINDSOR had offered to loan the money to Donna ***.  She was scared that she would lose her home in foreclosure and become homeless.
  10. On March 15, 2019, the ASSOCIATION sent a Notice of Intent to Foreclose to Donna ***, Unit H2. [EXHIBIT 426.]  The Notice appears to have added approximately $1,700 in legal fees.  Donna *** has provided records to me to show that she was not past due.  This foreclosure notice was sent a week before the purported election of March 22, 2019 at which Donna *** was a candidate seeking to replace OMAR, VICKI, and KAREN.  PLEASE NOTE the letter that starts EXHIBIT 426 was not mailed, but it accurately summarizes the financial situation.
  11. On March 15, 2019, Nancy Camp of Unit C2 sent a letter to SENTRY enclosing a Quit Claim deed and an Affidavit of Trust.  She wrote: “I feel I was bullied by the board into transferring the subject property out of my parents trust into our individual interest.” [EXHIBIT 425.]
  12. On March 20, 2019, WINDSOR sent an email to OMAR, VICKI, and KAREN; CHARLIE AND, ART, and BRAD of SENTRY; and BRIAN of CLAYTON & MCCULLOH objecting to the apparent plan to appoint a chairman of the purported March 22, 2019 members’ meeting rather than elect the chairman. [EXHIBIT 257.]  WINDSOR’s email was ignored.
  13. On March 20, 2019, a Lake County Sheriff’s Deputy appeared at WINDSOR’s door and served him with an Order setting a hearing on a Petition for Injunction against Stalking that was sworn to by Dorothy Liebl in Unit B2. [EXHIBIT 416.]  This was an absolute outrage.  Her sworn affidavit is filled with perjury.  WINDSOR never stalked her, harassed her, threatened her, or did anything to her.  For much of the next 13 days, WINDSOR prepared for the April 2, 2019 trial.
  14. On March 21, 2019, WINDSOR sent a letter to OMAR, VICKI, KAREN, CHARLIE ANN of SENTRY, and BRIAN of CLAYTON & MCCULLOH objecting to the apparent plan to appoint a chairman of the purported March 22, 2019 members’ meeting rather than elect the chairman. [EXHIBIT 258.]  His letter was ignored.
  15. A purported March 22, 2019 meeting was purported to include the annual election for the ASSOCIATION, but that date is based on fraud by claiming an amendment changed the date in August 2017.
  16. On March 22, 2019, purported meetings and a purported election were held.  EXHIBIT 311 is video from the meetings (EXHIBIT 311-1, EXHIBIT 311-2, EXHIBIT 311-3, EXHIBIT 311-4, EXHIBIT 311-5, and EXHIBIT 311-6).  No minutes were published for the purported meeting.
  17. There were 30 Outer Envelopes and 13 were invalid.  The Outer Envelopes are supposed to show the name of the Owners on the first line and be signed by the valid Designated Voter.  13 had problems with one or both of these requirements.
  18. There were 13 Designated Voter Certificates produced, and 6 were invalid.  The Designated Voter Certificate for Meade/Chandler was not produced, but it was delivered to SENTRY before the meeting began on March 22, 2019. [EXHIBIT 158.]  It is valid.
  19. There were 19 Proxy forms presented, and 4 were invalid.
  20. There were 24 Limited Proxy forms presented, and 5 were invalid.
  21. With exclusion of any of the votes that WINDSOR says are invalid, Denise King and WINDSOR would have been elected.
  22. At the March 22, 2019 meetings, BRIAN of CLAYTON & MCCULLOH refused to allow WINDSOR to see the Designated Voter Certificates, and the Election Monitor told him that those were not in his possession and were not part of his duties.  WINDSOR told them both that he had evidence that several of the voters did not have valid Designated Voter Certificates.  WINDSOR was told he would have to appeal.  WINDSOR had the evidence with him that A4 and B2 did not qualify.  He also had evidence with him that B1 and F3 likely didn’t qualify and evidence that E3 and G4 might fail to qualify.
  23. On March 22, 2019, Joseph L. Lunsford submitted a request to inspect all of the voting documents from March 22, 2019.  WINDSOR went with him on April 8, 2019, and they copied every document. [EXHIBIT 159.]
  24. OMAR, VICKI, and KAREN hired an armed policeman, Officer Pincus, to attend the March 22, 2019 meetings, and they paid BRIAN of CLAYTON & MCCULLOH, $1,100 to be there.  WINDSOR believes the police have been hired for show to support the defamatory claims that he threatened to kill purported Board members.  They know there is absolutely no truth to this, so there is no other logical explanation for such bizarre behavior.  At 12:20 into EXHIBIT 142-C, OMAR said the police were there because of threats to the Board.
  25. Jason Chandler and WINDSOR videoed most of the March 22, 2019 meetings until his battery died. [EXHIBIT 142-A, EXHIBIT 142-B, EXHIBIT 142-C, EXHIBIT 142-D, EXHIBIT 142-E, EXHIBIT 142-F.]
  26. CLAYTON & MCCULLOH, SENTRY, and those purporting to be the Board violated the BYLAWS by allowing Omar Nuseibeh to appoint himself to be the chairman of the meetings.  BYLAW 2.9 b. provides that the chairman is to be elected by a vote.  The Notice of the Meeting posted on the Bulletin Boards at Coach Houses said there would be an election. [EXHIBIT 241.]  Then the Notice was changed to delete the word “Election” and change it to “Appointment.” [EXHIBIT 242.]  WINDSOR raised the issue at 4:40 into EXHIBIT 142-A, and he was told the purported Board had decided who would be chairman.  WINDSOR believes this was done to block his access to the Designated Voter Certificates.
  27. OMAR spoke negatively about WINDSOR much of the time on March 22, 2019, and he got into arguments with several others seeking to have him removed from the Board.
  28. OMAR, VICKI, and KAREN did not have legal authority to schedule or conduct the meetings.
  29. CHARLIE ANN claimed all ASSOCIATION documents had been produced.  She said there was nothing else to produce, but that proved to be absolutely false on June 23, 2019 when some August 1, 2017 records were produced.  There is still a great deal that has not been produced.  She said the August 2017 Baywood Condominiums minutes that were produced was an error. [EXHIBIT 142-D @ 2:00 into the video.]  She never corrected this “error.”
  30. The purported March 22, 2019 election was invalid as it was not held on the first Tuesday in August.  It was called by people with no legal authority.  Only three members had complied with BYLAW 2.1.  BYLAW 2.9 b was violated.  Fraudulent information was provided to the Election Monitor.
  31. On March 25, 2019, WINDSOR sent a letter to SHEHNEELA of the ASSOCIATION requesting an Inspection of Records that had never been produced. [EXHIBIT 243.]
  32. On March 25, 2019, WINDSOR sent an email and evidence to the purported New Board (including COACH HOUSE MEMBER DEFENDANTS SHEHNEELA, ISABEL, SERGIO) identifying wrongdoing on March 22, 2019. [EXHIBIT 352.]  There was no response.
  33. On March 26, 2019, WINDSOR received an email from SHEHNEELA, the purported New Board President, claiming that SENTRY had ALL of the ASSOCIATION’s records. [EXHIBIT 301.]
  34. On March 26, 2019 at 11:59 am, the ASSOCIATION manager, CHARLIE ANN, stated that all of the records of the ASSOCIATION were being produced for WINDSOR at an Inspection of Records on March 27, 2019.  CHARLIE ANN also claimed WINDSOR had been provided every document within the possession of SENTRY on multiple occasions.  In a separate email at 8:39 am, she stated that Sentry had all of the ASSOCIATION’S documents.  She lied.  WINDSOR was never provided all the documents, and they most definitely were not provided on March 27, 20-19. [EXHIBIT 49.]  CHARLIE ANN knew she was continuing to conceal these records from WINDSOR.
  35. On March 26, 2019, WINDSOR sent an email to the purported New Board (SHEHNEELA, ISABEL, SERGIO), CHARLIE ANN of SENTRY, and BRIAN of C&M in response to an email from the purported New Board President, Shehneela Arshi, confirming that all of the ASSOCIATION’S documents were in the possession of SENTRY. [EXHIBIT 296.]  This was very important because it meant that key documents did not exist – no letter from Monalene Werner and no documentation that OMAR, VICKI, and KAREN were ever lawfully elected.  WINDSOR also sent an Inspection of Records Request for emails. [EXHIBIT 298.]
  36. On March 27, 2019, WINDSOR inspected records at SENTRY for eight hours. [EXHIBIT 326 – 1 to 17 are photos of the Inspection.]  EXHIBIT 326-4 shows the August 2017 minutes of Baywood Condominiums that were produced as the August 2017 minutes for the ASSOCIATION.  EXHIBIT 329 contains the files produced for Inspection on the laptop.  [EXHIBIT 1220.]
  37. WINDSOR has been ignored on many requests for inspection of records.  WINDSOR filed two Complaints with the Division of Condominiums. [EXHIBIT 54.] [EXHIBIT 55.]  WINDSOR finally filed a Petition for Arbitration over all Inspection of Records issues. [EXHIBIT 1190.]
  38. On March 28, 2019, WINDSOR sent an email to ART and CHARLIE ANN of SENTRY, BRIAN of C&M, and SHEHNEELA complaining of malpractice over the failure to schedule and conduct an April 4, 2019 meeting. [EXHIBIT 368.]  They did nothing.
  39. On March 28, 2019, WINDSOR sent two emails to the purported New Board (including SHEHNEELA, ISABEL, ED, SERGIO, OMAR) and BRIAN of CLAYTON & MCCULLOH objecting to the fraud in the purported March 22, 2019 election.  WINDSOR gave notice that he would file a petition if not resolved.  He provided some proof of the fraud. [EXHIBIT 255.]
  40. On March 28, 2019, WINDSOR sent a letter to the purported New Board (including SHEHNEELA, ISABEL, ED, SERGIO, OMAR), ART and CHARLIE ANN of SENTRY, and BRIAN of CLAYTON & MCCULLOH objecting to the failure to hold the April 4, 2019 meeting. [EXHIBIT 256.]
  41. On March 29, 2019, WINDSOR emailed the purported New President, SHEHNEELA, with issues about the fraudulent March 22, 2019 meetings. [EXHIBIT 398.]

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