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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