Witness Tampering is taking place in Coach Houses Litigation in Lake County Florida

Witness TamperingThere has been witness tampering in the Coach Houses litigation in Lake County, Florida.

William M. WindsorWilliam M. Windsor received an email (that was not intended for him) that revealed an attorney in the Coach Houses litigation was telling witnesses who had been subpoenaed to give depositions and produce documents NOT to show up.  This appears to be a federal crime of Witness Tampering.

See the evidence in the motion William M. Windsor filed in the case: witness tampering in the Coach Houses litigation.

Here’s the text of the Motion:

  1. On January 29, 2020, Windsor served Isabel Campbell with Notice of Deposition in this case. [EXHIBIT 2356.] The Deposition was scheduled for February 9, 2021.  The Notice was served by email to Isabel Campbell and to the Defendant’s Attorney, Christina Bredahl Gierke. [EXHIBIT 2370.]
  2. On February 1, 2020, Windsor served Isabel Campbell with the Subpoena Duces Tecum in this case. [EXHIBIT 2357.]  The Subpoena COMMANDED Isabel Campbell to appear on February 9, 2021.  The Subpoena was served by email to Isabel Campbell and to the Defendant’s Attorney, Christina Bredahl Gierke. [EXHIBIT 2371.]  The Subpoena was also served to Isabel Campbell by personal delivery by process server to her residence at 100 East Oak Terrace Drive, Unit F 2, Leesburg, Florida 34748. [EXHIBIT 2355.]
  3. On February 9, 2021, Isabel Campbell did not attend the Zoom Deposition.Isabel Campbell Windsor has a Zoom recording of her failure to appear at 9:00 a.m.  Isabel Campbell had already failed to respond or produce the records requested in the Subpoena Duces Tecum.
  4. On February 9, 2021, Windsor filed and served Motion for Civil Contempt and Enforcement in this case. It was served by email to Isabel Campbell and to the Defendant’s Attorney, Christina Bredahl Gierke. [EXHIBIT 2358.]
  5. On February 12, 2021, Windsor emailed Attorney Christina Bredahl Gierke. [EXHIBIT 2363.] Windsor informed her that he smelled something foul in Lake County courts, a smell that he had experienced 10 years ago in the extremely corrupt federal courts in Atlanta, Georgia.  He asked if anyone had bribed Judge Dan R. Mosley or Judge James R. Baxley.  Windsor asked how she could “continue to lie her posterior off about his Complaint in 1647 with this ridiculous claim of inspection of records?  That’s the kind of thing someone will say to a judge because they know the fix is in.”  She did not respond.
  6. On February 13, 2021, Windsor sent an email to owners of Coach Houses, attorneys, and employees of Sentry Management. Omar Nuseibeh and Attorney Christina Bredahl Gierke received it.  This informed all that Notices of Depositions were to follow in this case.  The email explained that attendance at the deposition will be by court order and failure to appear could result in a court order of contempt. [EXHIBIT 2364.]
  7. On February 13, 2021, Windsor filed and served Notice of Taking Oral DepositionChristina Bredahl Gierke of Omar Nuseibeh in Case No. 35-2019-CA-001528. [EXHIBIT 2362.] It was served on Omar Nuseibeh and Russell Klemm.  Attorney Christina Bredahl Gierke is not now and never has been an attorney in Case No. 35-2019-CA-001528.  Attorney Christina Bredahl Gierke was an attorney for Omar Nuseibeh in Case No. 35-2019-CA-001438, but that case was dismissed on February 10, 2021 following sham pleadings filed by Attorney Christina Bredahl Gierke.  That case is now on appeal and complaints against Judge Dan R. Mosley have been filed.  Windsor believes it is possible that Judge Dan R. Mosley was bribed to rule as he did.  Attorney Christina Bredahl Gierke and her 509-attorney law firm, Cole Scott & Kissane, have just emerged as the leading suspect in this potential crime.
  8. On February 15, 2021 at 9:47 a.m., Windsor received an email from OmarOmar Nuseibeh Nuseibeh. [EXHIBIT 2360.]
  9. Omar Nuseibeh obviously screwed up and didn’t intend to send this email to Windsor.  This email disclosed witness tampering by Attorney Christina Bredahl Gierke aka “Christie.”  Attorney Christina Bredahl Gierke does not represent Omar Nuseibeh in this case.  She has obviously committed witness tampering.
  10. On February 15, 2021 at 9:53 a.m., Windsor sent an email to Omar Nuseibeh so he would know Windsor received the email. Omar Nuseibeh is not the sharpest knife in the drawer. [EXHIBIT 2360.]
  11. On February 15, 2021 at 10:01 a.m., Windsor sent an email to Attorney Christina Bredahl Gierke and her associates and to the attorneys with Clayton & McCulloh. [EXHIBIT 2366.]
  12. On February 15, 2021 at 11:27 a.m., Windsor sent a “Meet and Confer” email to Attorney Christina Bredahl Gierke. [EXHIBIT 2367.] He advised her he would be filing an EMERGENCY MOTION to have her disqualified in the case.  Windsor suggested that she withdraw, but she did not respond.

ARGUMENT

CHRISTINA BREDAHL GIERKE HAS COMMITTED WITNESS TAMPERING

  1. Windsor’s requests for production are proper under Florida Rules of Civil Procedure.
  2. Florida Statute 914.22 [EXHIBIT 2368]:

Tampering with or harassing a witness, victim, or informant; penalties.

(1) A person who knowingly uses intimidation or physical force, or threatens another person, or attempts to do so, or engages in misleading conduct toward another person, or offers pecuniary benefit or gain to another person, with intent to cause or induce any person to:

(a)Withhold testimony, or withhold a record, document, or other object, from an official investigation or official proceeding;

(b)Alter, destroy, mutilate, or conceal an object with intent to impair the integrity or availability of the object for use in an official investigation or official proceeding;

(c)Evade legal process summoning that person to appear as a witness, or to produce a record, document, or other object, in an official investigation or an official proceeding;

(d)Be absent from an official proceeding to which such person has been summoned by legal process;

(e) Hinder, delay, or prevent the communication to a law enforcement officer or judge of information relating to the commission or possible commission of an offense or a violation of a condition of probation, parole, or release pending a judicial proceeding; or

(f) Testify untruthfully in an official investigation or an official proceeding,

commits the crime of tampering with a witness, victim, or informant. [emphasis added.]

  1. This applies to Criminal Proceedings. There does not appear to be s civil statute regarding witness tampering, so this can be used as a guide for the Court to consider the serious nature of what Christina Bredahl Gierke (and possibly co-conspirators) have done.
  2. Christina Bredahl Gierke has violated a host of the Rules in the Florida Rules of Professional Conduct.
    1. RULE 4-1.2 (d) Criminal or Fraudulent Conduct. A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows or reasonably should know is criminal or fraudulent. However, a lawyer may discuss the legal consequences of any proposed course of conduct with a client and may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning, or application of the law.
    2. RULE 4-3.4 FAIRNESS TO OPPOSING PARTY AND COUNSEL A lawyer must not: (a) unlawfully obstruct another party’s access to evidence or otherwise unlawfully alter, destroy, or conceal a document or other material that the lawyer knows or reasonably should know is relevant to a pending or a reasonably foreseeable proceeding; nor counsel or assist another person to do any such act; (b) fabricate evidence, counsel or assist a witness to testify falsely, or offer an inducement to a witness, except a lawyer may pay a witness reasonable expenses incurred by the witness in attending or testifying at proceedings; a reasonable, noncontingent fee for professional services of an expert witness; and reasonable compensation to a witness for the time spent preparing for, attending, or testifying at proceedings; (c) knowingly disobey an obligation under the rules of a tribunal except for an open refusal based on an assertion that no valid obligation exists;
    3. RULE 4-4. TRANSACTIONS WITH PERSONS OTHER THAN CLIENTS RULE 4-4.1 TRUTHFULNESS IN STATEMENTS TO OTHERS In the course of representing a client a lawyer shall not knowingly: (a) make a false statement of material fact or law to a third person; or (b) fail to disclose a material fact to a third person when disclosure is necessary to avoid assisting a criminal or fraudulent act by a client, unless disclosure is prohibited by rule 4-1.6.
  3. There are undoubtedly others that address lying, witness tampering, and conspiracy.
  4. Courts may not allow attorneys for the only Defendant in a case to contact people subpoenaed as witnesses in the case and tell them not to show up.

Violation of 18 U.S. Code § 1512

  1. 18 U.S. Code § 1512 – Tampering with a witness, victim, or an informant:

(b)Whoever knowingly uses intimidation, threatens, or corruptly persuades another person, or attempts to do so, or engages in misleading conduct toward another person, with intent to

(1) influence, delay, or prevent the testimony of any person in an official proceeding;

(2) cause or induce any person to

(A) withhold testimony, or withhold a record, document, or other object, from an official proceeding;

(B) alter, destroy, mutilate, or conceal an object with intent to impair the object’s integrity or availability for use in an official proceeding;

(C) evade legal process summoning that person to appear as a witness, or to produce a record, document, or other object, in an official proceeding; or

(D) be absent from an official proceeding to which such person has been summoned by legal process; [EXHIBIT 2369.]

  1. Christina Bredahl Gierke has violated 18 U.S. Code § 1512 with Omar Nuseibeh.
  2. Christina Bredahl Gierke has likely also violated 18 U.S. Code § 1512 with Isabel Campbell.
  3. 18 U.S. Code § 1512 indicates the punishment is a fine or imprisonment for not more than 20 years, or both.

BRIBERY

  1. Attorneys may not bribe judges.
  2. This is something the State Attorney should investigate.

PRAYER FOR RELIEF

  1. Wherefore, Windsor moves the Court for an order scheduling an EMERGENCY HEARING to consider this motion prior to any further consideration of the DEFENDANT’S Motion to Dismiss; ordering that if Judge Baxley is not available for an immediate hearing, this matter will be referred to another judge who can hear it; issuing an Order to Show Cause to Christina Bredahl Gierke to respond to charges she has committed witness tampering; issuing sanctions pursuant to Court’s inherent powers; ordering Christina Bredahl Gierke to appear for a deposition with Windsor and produce all communication with anyone except the DEFENDANT without objections; ordering Christina Bredahl Gierke to produce all communication with the DEFENDANT with a Privilege Log to indicate what she claims is attorney-client privileged; ordering Christina Bredahl Gierke to have no further contact with any current or former owner of Coach Houses at Leesburg or anyone involved as a party or as an attorney in Case No. 2020-CA-1438; lifting the discovery stay ordered sua sponte on February 12, 2021; asking the State Attorney to investigate; and granting such other and further relief as is deemed just and proper.

This 15th day of February, 2021.

______________________________

William M. Windsor

Judge Dan R Mosley accused of Corruption in Coach Houses at Leesburg Scandal

Judge Dan R. MosleyJudge Dan R Mosley (aka Danny Ray) has been accused of corruption in the Coach Houses at Leesburg Condominium Scandal as has the law firm of Clayton & McCulloh.

In May 2019, Governor Ron DeSantis appointed Judge Dan R. Mosley.  It took Judge Dan just a year to start inflicting his bias and prejudice.  He established early on that he is a heartless judge who would probably pull someone out of the hospital with COVID-19 because he wanted them to appear in a Zoom Hearing.

William M. Windsor asks anyone who has been abused by corrupt Judge Dan R. Mosley to contact him.  William M. Windsor is filing an Open Records request as he seeks to determine if Judge Dan has ever ruled in favor of a pro se party and whether his rulings show bias for big law firms with lots of money.

In a recent court hearing, Judge Dan R Mosley indicated he had not even read the Complaint in Case No. 2020-CA-001438 in Lake County Circuit Court before he ruled against the pro se Plaintiff and in favor of attorneys with huge law firms.

Complaints against Judge Danny Ray Mosley have been filed with the Fifth District Court of Appeals and will be filed with the State Attorney, the U.S. Department of Justice, the Chief Judge of the Lake County Circuit Court,  the Judicial Disqualification Board, the Florida State Bar Association, the Lake County Sheriff’s Department, and Governor Ron DeSantis.

En Banc Complaint

Complaint for Writ of Prohibition

The entire story will be told RIGHT HERE.

 

Reasons to Avoid Buying a Condo

Do not buy a condo

There are many reasons to avoid buying a condo.  As a condo owner for three years after owning homes for 35 years, I advise you to stay as far away from condo ownership as possible.

There are a number of articles online about the Pros and Cons of Condo Ownership, but they seem to be written by real estate people who want to promote the sales of condos.

Money Crashers has a good article titled Pros & Cons of Buying a Condo – Is It Worth It?

Realtor.com has Should I Buy a Condo? The Pros and Cons.  Guess what they think!  LOL.

PocketSense has Reasons Not to Buy a Condo.  There is some good information in this article, but I believe all of these articles sugarcoat it and don’t seem to have true knowledge of condo ownership.

Reasons to Avoid Buying a Condo — Just DON’T

Don't buy a condo

If you can afford to buy a home, buy a home.  And buy one that doesn’t have a homeowner’s association.  If you can’t afford to buy a home, I recommend that you rent a home, condo, or apartment.  (Condos are usually nicer than apartments.)  As a renter, your landlord has all of the problems discussed below…NOT YOU!

It’s Amateur Hour

Don't buy a condo

Your neighbors run the condo.  Do you really want a widowed senior citizen from Pasadena who was always a stay-at-home-mom deciding how you must spend your money?

Your condo association will be “managed” by people elected by you and your fellow owners.

From my experience, these people don’t know what they are doing and/or they have ulterior motives.  As Board members, these folks are all-powerful.  They have control of all the money and how anything and everything is done.

You Don’t Really Own Anything with a Condo – Reasons to Avoid Buying a Condo

Inside the walls of a condoCondo unit owners do not hold the title to the land on which the structure sits, so you only own what’s inside the walls, which is air.

With a house, you own the land and the building.

Please understand: You don’t own squat with a condo.  I own 1,600-square-feet of air.

At Coach Houses at Leesburg, the owners are not allowed to rent their units, so no AirBnB income potential.  That’s a bad deal.

You have No Control  Over What it Will Cost YOU to Live in YOUR Condo in the Future

You have no control over the costs in a condoWhen I bought my condo, the monthly assessment (dues) was $300 per month.  Thirteen months later, the three-member Board of Directors voted to increase my monthly assessment to $980 per month.  SERIOUSLY!

I’m 72-years-old, disabled, divorced, live alone, and my sole source of income is social security retirement.  $980 per month is half of my monthly social security payment.  I was at break-even at $300 per month, but I am now having to use very limited savings to live in the condo that I allegedly own.

My Condo Association forecloses on people who are just a month or two late.  If they foreclose on you, they own your condo, and you are homeless.  I can’t risk that.  I pray I can find someone who thinks they want to live in a condo to buy mine so I can move as far away from here as possible before I lose my condo.

Your State Agency that “Manages” the Condominium Businesses is Probably Incompetent and Possibly Corrupt

Florida Department of Business and Professional RegulationIn Florida, the Department of Business and Professional Regulation is responsible for the condominium business.  I thought I would be saved by the government of the State of Florida.  You are led to believe that these paid government employees are there to help condo owners.  Nope.  I believe the DBPR is totally corrupt.  They are buddies with the condo association attorneys and condo association management companies who are your enemies as a lowly condo owner.

If your Board violates every rule in the book and you complain to the agency and they screw you, you could lose tens of thousands of dollars in legal fees.  The only way to be protected is to NOT buy a condo.

Click on the Tag for “Department of Business and Professional Regulation” below, and it will link you to every page in my story that discusses DBPR.

Reasons to Avoid Buying a Condo – You are Legally Screwed in a Condo

You are legally screwed in a condoAny time any of us have to go to a courthouse, we are screwed.  Justice in America is rare for folks who aren’t rich or connected.  If you have to hire a lawyer, you have to pay to be screwed.

If you get into litigation with the condo association, they get to use your money to pay their lawyers to screw you.  In my case, the never-lawfully-elected Board has spent over $130,000 fighting me as I simply try to get them to operate legally.  Why in God’s name would these people spend that kind of money?  They must be hiding some bad stuff.  Our condos are only valued at about $60,000.  And by the way, guess who gets to pay part of that $130,000?  You guessed it: ME.  Screwed again.

There is no way to win legally because the corrupt deck is stacked against you.  I’m doing it because I hate, loathe, and despise liars.

You can Lose Your Condo Home if the Condo Association seeks to Screwzee Vouzee Youzee.

You can be screwed by your condo associationAs I said before, you have no control, and your condo association can pretty much do whatever they want to you.

If the condo association raises your dues to an amount that you can’t afford, they can foreclose and take your condo, and you get nothing.

If your condo association does a special assessment for $250,000 to fix faulty foundations, and you are one of 32 owners, you owe $7,812.50.  If you can’t pay it, they can foreclose and take your condo.

If the next year, they say $500,000 is needed to repair plumbing, electrical, roofs, or whatever, you owe $15,625.  If you can’t pay it, they can foreclose and take your condo, and your “investment” in your home is gone.

How do you like the idea of being homeless?  That is one of the risks you take if you buy a condo.

After what I have experienced, I don’t believe anyone in their right mind should buy a condo (except mine, of course, because I need to get the Hell out of Dodge aka Leesburg Florida).

Your Neighbors may be Dumber than The Little Old Lady from Pasadena – Reasons to Avoid Buying a Condo

Do not buy a condoAt Coach Houses at Leesburg Condominium in Leesburg, Florida, I have been amazed by how dumb many of the owners are.  I don’t mean to be rude, I’m just telling it like it is.  Dumb people are easily manipulated by those in power (the Board).

These folks do not seem to have any understanding of laws or legal documents, and they can’t afford attorneys.  Most just want to live in peace and hope they can ignore what’s going on around them.

The Condominium Management Company may be Less than Competent at Best and Corrupt at Worst

Sentry Management Sentry Management was the condo association management company for Coach Houses at Leesburg Condominium Association.

Sentry Management is a horrible company, in my experienced opinion.  You don’t want anything to do with them.  Consider the laws and condo governing documents that SENTRY MANAGEMENT violated at Coach Houses at Leesburg.

A management company is supposed to know the law to ensure the amateur Board members don’t screw up.  In my case, SENTRY MANAGEMENT violated the laws and rules again and again and again.  From my evaluation, the only reason for them to act as they did was to try to cover up for their malpractice.

You Could Go to Jail

Tavares Florida Police issue an All Points Bulletin for a Condo OwnerBelieve it or not, Sentry Management and Clayton and McCulloh tried to have me arrested for attempting to speak at a condo meeting.

The Tavares Police Department actually issued an All Points Bulletin for me.

I attended a meeting held at the offices of Sentry Management.  About half of the owners of Coach Houses at Leesburg Condominium Association were there.  I tried to speak.  Association members are allowed by Florida law to speak on as many of the Agenda items as they choose.  Charlie Ann Aldridge refused to allow me to speak.  She ordered me to leave.  I immediately gathered my stuff and got up to leave to have her escort me out, and she summoned the Tavares Police Department.  I later learned all of this had been set up in advance with the Tavares Police Department by Neal McCulloh of Clayton & McCulloh, the Association’s law firm.  I kid you not.

The Condo Association’s Attorneys may be Incompetent at Best and Corrupt at Worst

Clayton and McCulloh law firmClayton and McCulloh of Maitland, Florida is the law firm for Coach Houses at Leesburg Condominium Association, Inc.

I have sued CLAYTON & MCCULLOH for malpractice.  Read the linked portion of my lawsuit about the wrongdoing and malpractice of Clayton and McCulloh.  If you decide to retain them after reading this, I believe you will undoubtedly make an outstandingly incompetent Board member or a potentially-screwed condo owner.

Clayton and McCulloh malpracticeI believe CLAYTON AND MCCULLOH has committed the largest case of legal malpractice in history, at least with condominiums.  I believe Clayton and McCulloh’s attorneys are either absolutely incompetent or corrupt or both.  I believe both.

Click on the Tag for “Clayton and McCulloh” below, and it will link you to every page in my story that discusses CLAYTON AND MCCULLOH.

You should also read my article about all the malpractice committed by Clayton and McCulloh.

Here is a pdf file of my BIG lawsuit regarding Coach Houses at Leesburg.

I’m Going to Begin Helping Other Condo Owners with Problems

William M. WindsorI’m William M. Windsor.  I’m not an attorney… just smarter than most attorneys.  I know a lot about condo laws and related problems in Florida.  If you need help, email me at billwindsor1@outlook.com, or call 352-577-9988 and leave a message for a return call.

So, I’m becoming a Florida Condominium Consultant.

As I’m not an attorney, I don’t have to charge hundreds of dollars an hour.  $25 bucks an hour.  I can at least tell you how badly I feel you are screwed.  I can definitely give you a game plan for fighting the wrongdoing.  You should get $25 worth of “pleasure” out of speaking to a fellow screwee.

I didn’t write this article to start a new business, but when I got to the bottom of the page, I realize I have a valuable service to provide.

Copyright William M. Windsor, 2021