Windsor v. Coach Houses at Leesburg Condominium Lawsuit – FACTS – MARCH 2020

  1. On March 9, 2020, RUSSELL Klemm filed a Motion to Dismiss in Case No. 35-2019-CA-001871. [EXHIBIT 1778.]
  2. On March 9, 2020, RUSSELL Klemm filed a Motion to Dismiss in Case No. 35-2019-CA-001528. [EXHIBIT 1854.]
  3. On March 10, 2020, an Order setting a Case Management Conference was issued in Case No. 35-2019-CA-001528. [EXHIBIT 1854.]
  4. On March 13, 2020, WINDSOR filed an Application for Default Judgment in Case No. 35-2019-CA-001528. [EXHIBIT 1672.]
  5. On March 13, 2020, WINDSOR filed a Request to File Evidence on Flash Drive in Case No. 35-2019-CA-001528. [EXHIBIT 1677.]
  6. On March 13, 2020, WINDSOR filed a Response to Motion to Dismiss in Case No. 35-2019-CA-001528. [EXHIBIT 1730.]
  7. On March 17, 2020, RUSSELL Klemm filed a Motion to Strike and Motion for More Definitive Statement for the ASSOCIATION in Case No. 35-2019-CA-001528. [EXHIBIT 1724.] [EXHIBIT 1725.]
  8. On March 24, 2020, WINDSOR filed a Response to Motion to Dismiss in Case No. 35-2019-CA-001528. [EXHIBIT 1709.]

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Windsor v. Coach Houses at Leesburg Condominium Lawsuit – FACTS – FEBRUARY 2020

  1. On February 3, 2020, a NOTICE OF HEARING ON CASE MANAGEMENT was filed in DBPR Case No. 2019-04-7339 and DBPR Case No. 2019-05-3927.  The Hearing was set for February 18, 2020. [EXHIBIT 1544.] [EXHIBIT 1852 is the full file on Case No. 2019-04-7339.]
  2. On February 5, 2020, Russell Klemm filed DEFENDANT’S LIMITED APPEARANCE AND REQUEST FOR JUDICIAL NOTICE” in Case No. 2019-CA-001871-AXXX-XX in the County Court of the Fifth Judicial District in Lake County, Florida. [EXHIBIT 1547.]
  3. On February 10, 2020, Judge James R. Baxley conducted a Case Management Conference in Case No. 2019-CA-001871-AXXX-XX in the County Court of the Fifth Judicial District in Lake County, Florida.  Russell Klemm attended in person, and WINDSOR attended by CourtCall telephone.  Klemm told Judge Baxley that he had not received service in the case.  This was a lie.  This is detailed and documented in EXHIBIT 1550.  Russell told Judge Baxley that WINDSOR could not pursue the case as he had moved to Texas.  Russell said the President of the ASSOCIATION had informed him of this.  This was a lie.  Since September 2017, WINDSOR has owned Condo Unit B3 at Coach Houses at Leesburg in Leesburg, Florida.  Russell told Judge Baxley that WINDSOR could not pursue the case because of a federal court order in Georgia.  This is a lie, and Russell has been sent proof on many, many occasions.  Judge Baxley indicated that WINDSOR needed to spell out his complaint.  He set a subsequent Case Management Conference for March 9, 2020 at 3:45 pm.
  4. On February 11, 2020, WINDSOR prepared a PROOF OF SERVICE for filing in Case No. 2019-CA-001871-AXXX-XX in the County Court of the Fifth Judicial District in Lake County, Florida. [EXHIBIT 1550.]  This was prepared because Russell told Judge James R. Baxley that he had not been served.  As EXHIBIT 1550 shows, Russell was served by certified mail and email on August 29, 2019.  The email and the signed certified mail receipt were attached as proof.  WINDSOR planned to file and serve this on February 18, 2020.
  5. On February 18, 2020, WINDSOR prepared a FIRST AMENDED VERIFIED COMPLAINT ON REQUEST FOR TRIAL DE NOVO for filing in Case No. 2019-CA-001871-AXXX-XX in the County Court of the Fifth Judicial District in Lake County, Florida. [EXHIBIT 1551.]  An AFFIDAVIT was attached thereto as EXHIBIT K.
  6. On February 18, 2020, WINDSOR prepared a MOTION TO STRIKE JUDICIAL NOTICE for filing in Case No. 2019-CA-001871-AXXX-XX in the County Court of the Fifth Judicial District in Lake County, Florida. [EXHIBIT 1552.]
  7. On February 19, 2020, WINDSOR filed a First Amended Complaint on Request for Trial De Novo in Case No. 35-2019-CA-001528. [EXHIBIT 1674.]
  8. On February 20, 2020, the First Amended Complaint on Request for Trial De Novo in Case No. 35-2019-CA-001528 was served on the registered agent for the ASSOCIATION. [EXHIBIT 1854.]

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Windsor v. Coach Houses at Leesburg Condominium Lawsuit – FACTS – JANUARY 2020

  1. On January 15, 2020, an ORDER SETTING CAUSE FOR CASE MANAGEMENT CONFERENCE was filed in Case No. 2019-CA-001871-AXXX-XX in the County Court of the Fifth Judicial District in Lake County, Florida. [EXHIBIT 1545.]
  2. On January 31, 2020, Russell Klemm filed DEFENDANT’S LIMITED APPEARANCE AND DESIGNATION OF E-MAIL ADDRESSES PURSUANT TO FLA. R. JUD. ADMIN. 2.515 AND 2.516 in Case No. 2019-CA-001871-AXXX-XX in the County Court of the Fifth Judicial District in Lake County, Florida. [EXHIBIT 1546.]

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