Category: Lawsuits

COUNT ONE

BREACH OF FIDUCIARY DUTY

1. COACH HOUSES MEMBER DEFENDANTS and the ASSOCIATION.
2. have a fiduciary duty to WINDSOR and Owners, and they breached that duty repeatedly.
3. have purported to be officers and/or directors of the ASSOCIATION.
4. OMAR, VICKI, KAREN, MARTA, and SHEHNEELA had a fiduciary duty to WINDSOR and Owners of condos at Coach Houses of Leesburg.
5. ISABEL, SERGIO, ED, WENDY, HOWIE, and SUE have a fiduciary duty to WINDSOR and Owners of condos at Coach Houses at Leesburg.
6. COACH HOUSES MEMBER DEFENDANTS have acted in an unauthorized manner.
7. COACH HOUSES MEMBER DEFENDANTS have failed to manage the association’s affairs prudently and reasonably.  They have acted with conscious disregard for the best interests of the ASSOCIATION and its owners.  They have failed to show the care that an ordinary prudent person in a like position would reasonably believe appropriate under similar circumstances.
8. The COACH HOUSES MEMBER DEFENDANTS have not acted in a reasonable manner pretending to be officers or directors; in spending over $130,000 on legal fees to defend violations of the law; in committing fraud claiming a bylaw was amended; in rejecting lower bidders for condominium foundation repair work; filing criminal charges against WINDSOR; reporting WINDSOR to the police; telling ASSOCIATION owners that WINDSOR had threatened to kill Board members; in committing hundreds of violations of Florida statutes and the corporate governing documents; in doing nothing about the violations after they were notified repeatedly; and much more.
9. WINDSOR has suffered damages as an individual.
10. Dues and assessments have been levied against WINDSOR and other Owners without legal authority
11. By refusing to respond to WINDSOR and correct violations, the acts of the COACH HOUSES MEMBER DEFENDANTS and the ASSOCIATION were in bad faith. [See SOF 181, and others].
12. The COACH HOUSES MEMBER DEFENDANTS and the ASSOCIATION breached fiduciary duty by allowing the corporation to operate with a name that violates Florida statute 718.104 (4) (b).  Case law indicates the State can declare the ASSOCIATION is illegal. [See SOF 181.]  WINDSOR and the owners could lose their homes because they own nothing if the ASSOCIATION doesn’t own the buildings valued at $5 million.
13. It is possible that some of the COACH HOUSES MEMBER Defendants have received unjust enrichment.  C&M and SENTRY clearly have.  There has been self-dealing.  WINDSOR will seek discovery.
14. The COACH HOUSES MEMBER Defendants were provided with specific evidence to show that none of them were lawfully elected as Directors or Officers.  Not only have they ignored the evidence, they have all participated in a conspiracy to claim the BYLAWS were amended, when the evidence produced by the ASSOCIATION proves the claim of a BYLAW amendment was a fraud.
15. The COACH HOUSES MEMBER Defendants ignored notices they received of violations and wrongdoing and demands to rectify. [See SOF 42, 122, 123, 125, 126, 226, 181, 227, 229, 235, 237, 238, 240, 242, 245, 246, 248, 251, 253, 254, 258, 261, 262, 263, 265, 266, 270, 271, 272, 274, 275, 283, 284, 285, 287, 288, 289, 290, 291, 295, 296, 297, 303, 308, 309, 315, 319, 320, 325, 327, 329, 330, 331, 334, 346, 358-360, 363, 371, 376, 386, 391, 392, 394, 396-406, 410, 461, 486, 489, 491, 492, 498, and others.]
16. As the COACH HOUSES MEMBER Defendants were not lawfully elected as Directors or Officers, WINDSOR has named the ASSOCIATION in this Cause of Action.  The ASSOCIATION would not normally have a fiduciary duty to an owner/member, but in this case, the ASSOCIATION caused the breaches of fiduciary duty, and WINDSOR should not be denied this cause of action if the Court says it doesn’t apply to the COACH HOUSES MEMBER Defendants.
17. The COACH HOUSES MEMBER Defendants have been informed for years that C&M and SENTRY were committing significant malpractice.  The facts, laws, and violations of the corporate documents have been fully documented.  The COACH HOUSES MEMBER Defendants purported to be Directors, so they knew they had a fiduciary duty to inform themselves “of all material information reasonably available” prior to making a business decision. (Smith v. Van Gorkom, 488 A.2d 858, 872 (Del. 1985).)  Failing to do so and ignoring the evidence denies any right to claim protection of the business judgment rule. 
18. There is no evidence that the ASSOCIATION or COACH HOUSES MEMBER Defendants obtained legal advice from any advisors other than C&M, the ASSOCIATION’s lawyers, or SENTRY, the condominium association management firm.  C&M and SENTRY have been accused of malpractice for two years, so entrusting any investigation to them is negligence and just plain stupid.  C&M and SENTRY could not independently evaluate the corporation’s interests, because their interests were at odds.  Using these advisors that have represented them in proceedings related to the very subject matter that the law firm is now asked to neutrally investigate is gross negligence and is incompatible with a purported board’s fiduciary duty to inform itself “of all material information reasonably available” prior to making a business decision. Smith v. Van Gorkom, 488 A.2d 858, 872 (Del. 1985).
19. This shows a lack of good faith in the conduct of the corporation’s internal affairs.
20. OMAR, VICKI, and KAREN spent approximately $27,000 with American Geo Technical and Gartner Group when one bidder was half that amount. [See SOF 158, 166.]  This is a breach of fiduciary duty.
21. OMAR, VICKI, KAREN, and the COACH HOUSES MEMBER Defendants caused the ASSOCIATION to incur exorbitant legal fees by requiring that WINDSOR’s communication with the ASSOCIATION had to be by United States Postal Service to C&M. [See SOF 124.]
22. OMAR, VICKI, and KAREN conducted an illegal meeting on February 4, 2019 in an effort to block others from becoming lawfully-elected directors. [See SOF 154.]
23. OMAR, VICKI, and KAREN did not have legal authority to schedule or conduct meetings on March 22, 2019.
24. OMAR, VICKI, and KAREN violated Florida law by failing to file petitions for recall arbitration. [See SOF 155.]
25. On December 28, 2018, OMAR, VICKI, and KAREN signed a fraudulent affidavit stating that the BYLAWS were amended on August 1, 2017.  It was prepared by BRIAN of C&M. [EXHIBIT C.]  This was done secretly. [See SOF 127, 137.]
26. [See SOF 42, 138, 156, 163, and many others.]
27. ISABEL, SERGIO, ED, MARTA, WENDY, HOWIE, SHEHNEELA, and SUE ignored demands to cease pretending to be officers and directors. [See SOF 43 and others.]
28. OMAR and KAREN executed a $165,000 Promissory Note for the ASSOCIATION without authorization. [See SOF 109.]  They put the ASSOCIATION in significant debt.
29. OMAR deceived owners about assessments and repairs. [See SOF 111.]
30. The ASSOCIATION has failed to hold annual meetings and elections on the date established by the BYLAWS, so there has not been a lawful election of directors or officers.  Actions taken by purported Officers and Directors have been ultra vires and void. [See SOF 41.]  The ASSOCIATION and COACH HOUSES MEMBER Defendants have been notified of this repeatedly since December 2018.
31. The ASSOCIATION failed to post meeting notices in a conspicuous place despite Florida law and BYLAW 2.4. [See SOF 54, 111, 117.]
32. When WINDSOR was considering the purchase of a condo, OMAR, VICKI, and KAREN told him to anticipate a cost-of-living increase annually, but that proved to be a fraudulent representation on or about Monday, November 26, 2018 when a huge increase was presented. [See SOF 116.]
33. OMAR, VICKI, and KAREN disregarded the votes and proxies in violation of Florida law and the governing documents and conducted a vote that excluded those not in attendance on December 12, 2018. [See SOF 120.]
34. OMAR, VICKI, and KAREN, CHARLIE ANN of SENTRY, and BRIAN of C&M ignored their obligation to advise what was needed to accept the signatures of Nancy Camp and Jane O’Steen for the Nielsen Trust. [See SOF 147.]  This was done in an effort to deny one vote that would have been sufficient to remove OMAR, VICKI, and KAREN.
35. To discourage owners from supporting WINDSOR’s efforts, OMAR and others began telling owners that WINDSOR had threatened to kill Board members.  Owners were subsequently told that WINDSOR was a criminal and was wanted for the crime of fraud.  A Wanted Poster of WINDSOR was mailed anonymously to the owners.  None of this was true, and the COACH HOUSES MEMBER Defendants did nothing about it. [See SOF 130, 132, 133, 134, 136, 141, 143, 145, 146, 152, 153.]
36. SHEHNEELA, ISABEL, ED, SERGIO, OMAR), ART and CHARLIE ANN of SENTRY, and BRIAN of C&M failed to hold the April 4, 2019 meeting in violation of the law. [See SOF 140, 142, 218-220, 224, 235, 495, 498.]
37. SHEHNEELA ignored issues about the fraudulent March 22, 2019 meetings. [See SOF 220, 221.]
38. A purported Special Board Meeting was properly scheduled for April 11, 2019. And then improperly canceled. [See SOF 225, 228-233, 242, 243.]
39. 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. [See SOF 226.]
40. Purported President Shehneela improperly denied WINDSOR the right to communicate with her as the purported Board. [See SOF 234.]
41. On April 10, 2019, WINDSOR sent the ASSOCIATION a Notice of Intent to Challenge the April 4, 2019 meeting. [EXHIBIT 437.] [See SOF 235.]
42. 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.] [See SOF 236.]
43. On April 10, 2019, WINDSOR emailed a Notice of Intent to Challenge the February 19, 2019 Recall / Election to the ASSOCIATION. [EXHIBIT 446.] [See SOF 237.]
44. On April 10, 2019 at 7:29 pm, WINDSOR emailed a Condominium Complaint to the ASSOCIATION, BRIAN and NEAL of C&M; ART and CHARLIE ANN of SENTRY. [EXHIBIT ­­­­­1541.] [See SOF 238.]
45. On April 10, 2019 at 8:09 pm, WINDSOR emailed a Condominium Complaint to the ASSOCIATION, BRIAN and NEAL of C&M; ART and CHARLIE ANN of SENTRY. [EXHIBIT ­­­­­1539.] [See SOF 240.]
46. On April 12, 2019, WINDSOR sent an email and letter to BRIAN and NEAL of C&M 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.) [See SOF 244.]
47. 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.] [See SOF 245.]
48. On April 23, 2019, WINDSOR conducted an Inspection of Records at SENTRY.  It was scheduled by C&M 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. [See SOF 249.]
49. WINDSOR has found the attorneys with C&M 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. [See SOF 252.]
50. On June 6, 2019, a purported Board Meeting was held. [EXHIBIT 973.] [EXHIBIT 1367 is the Minutes.]  ISABEL, SERGIO, and ED 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. [See SOF 282.]
51. On June 6, 2019, WINDSOR sent an email to the purported Board, C&M, and SENTRY regarding the Board Meeting. [EXHIBIT 822.]  [See SOF 283.]
52. On June 7, 2019, WINDSOR sent an email to the purported Board, SENTRY, and C&M charging Breach of Fiduciary Duty. [See SOF 286.]
53. On June 9, 2019 at 9:54 a.m., WINDSOR emailed ISABEL, SERGIO, and ED advising them of his intent to sue them for breach of fiduciary duty. [EXHIBIT 819.]  [See SOF 288.]
54. On June 17, 2019, the buyers of WINDSOR’s 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.] [See SOF 295.]
55. 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 and CHARLIE ANN.  There was no discussion of quorum (0:00 to 0:42 in the video.)  CHARLIE ANN 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 said the meeting was adjourned.  She then ordered me to leave the building.  The remainder of the video is CHARLIE ANN escorting WINDSOR out of the building.  Later that day, owner Larry Lunsford informed WINDSOR that two Leesburg Police Officers arrived after he left.  As the video shows, there was absolutely no basis for reporting WINDSOR to the police. [See SOF 302.]
56. 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. [See SOF 309.]
57. 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 “FUCK YOU” on it.  EXHIBIT 1087 is the Notice that was defaced and removed by ED. WINDSOR has determined that this outrageous act was by HOWIE. [See SOF 319.]
58. On June 29, 2019, WINDSOR sent an email to inform owners that he had been reported to the police by the ASSOCIATION or SENTRY on June 20, 2019. [See SOF 315.]
59. The ASSOCIATION and COACH HOUSES MEMBER DEFENDANTS violated Florida law and the corporate governing documents by making a mockery of Inspections of Records.  Fraudulent records were produced.  Many requests were ignored. Non-responsive Records were produced.  The ASSOCIATION lied to and/or conspired with the DBPR. [See SOF 328.]
60. The ASSOCIATION and COACH HOUSES MEMBER DEFENDANTS have defamed WINDSOR and allowed others to do so without taking any action. [See SOF 222, 228, 229.]
61. On July 19, 2019, an Inspection of Records was held at SENTRY.  Virtually none of the requested records were produced. [See SOF 328.]  The wrongdoing with Inspections of Records is detailed in EXHIBIT 1853 – 2019-05-3927-Florida-DBPR-Arbitration-Petition-Inspections-2019-09-09.
62. 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 C&M; BRAD, ART, and CHARLIE ANN of SENTRY.  This was regarding fraud charges against Coach Houses, purported Directors, SENTRY, and C&M. [See SOF 331.]
63. On July 22, 2019, a purported Board Meeting was held. There was no quorum.  There are no minutes.  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. [See SOF 334.]
64. 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. [See SOF 335.]
65. On July 25, 2019, WINDSOR sent an email to the ASSOCIATION regarding damages. [See SOF 336.]
66. On July 27, 2019, WINDSOR sent an email to the ASSOCIATION about the owners who are being allowed to illegally rent their condos. [See SOF 338.]  Nothing has been done.
67. On October 24, 2020, WINDSOR sent a Request for Inspection of Records to BRIAN of C&M by certified mail.  There has been no response, in violation of Florida law and the corporate governing documents. [See SOF 493.]

WINDSOR identified over 180 issues and violations by the ASSOCIATION that he presented in a petition to the DBPR.  The ASSOCIATION has operated unlawfully for many years, violating numerous Florida statutes and the ASSOCIATION’s DECLARATION, BYLAWS, and ARTICLES of Incorporation.  Elections have not been properly conducted.  Adequate notice of meetings and other actions have not been given.  Meetings have not been properly conducted.  Inspection of books and records has been denied.  The ASSOCIATION has consistently failed to conduct meetings properly, including annual meetings and elections.  Purported meetings on December 12, 2018, February 19, 2019, and March 22, 2019 were not properly conducted.  Florida statutes have been violated repeatedly.  The ASSOCIATION, SENTRY, and C&M committed fraud regarding the attempt to amend the BYLAWS at the meeting on August 1, 2017.  People purporting to be Directors of the ASSOCIATION were not legally holding office so they had no authority to act as officers and directors.  An April 4, 2019 Special Member’s Meeting requested by 10 owners by certified mailwas not held.  An April 11, 2019 meeting should have been held, but was not.  There has not been an annual meeting or annual election in over a year, and there are no legally elected officers or directors of the ASSOCIATION.  Voting interests have been incorrectly calculated.  Proper records have not been maintained, and more. [See SOF 495.]

1. Fraudulent documents have been filed with the Florida Secretary of State, and WINDSOR believes the ASSOCIATION’s corporate charter should be revoked for a number of violations. [See SOF 496.]
2. Upon information and belief, despite clear requirements in the D&O Insurance policies, the ASSOCIATION did not notify the insurance carriers of litigation and threatened litigation with WINDSOR dating back as far as early 2019. [See SOF 497.]
3. WINDSOR repeatedly communicated to the ASSOCIATION, owners, C&M DEFENDANTS, and SENTRY DEFENDANTS that there has been malpractice.  The AFFIDAVIT OF WILLIAM M. WINDSOR DATED OCTOBER 27, 2020 (“AFFIDAVIT-2020-10-27 “) is filled with communications and information about the wrongdoing, malpractice, and demands for action to correct issues. [See SOF 498.]  The ASSOCIATION and the COACH HOUSES MEMBER DEFENDANTS ignored the malpractice in gross breach of fiduciary duty.
4. 73.              The ASSOCIATION and COACH HOUSES MEMBER Defendants have breached their fiduciary duty.
5. The breaches of duty by the ASSOCIATION and COACH HOUSES MEMBER Defendants have been the proximate cause of damages to WINDSOR. 

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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 C&M 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 C&M, 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 C&M, 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 C&M, 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 C&M a Notice of Intent to Challenge Violations in Building B. [EXHIBIT 1154.]
13. On May 15, 2019, WINDSOR emailed the ASSOCIATION, Sentry, and C&M 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 C&M 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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1. Coach Houses at Leesburg Condominium Association, Inc. (“ASSOCIATION”) was incorporated with Articles of Incorporation (“ARTICLES”) on August 27, 1980. [EXHIBIT A.] [1]
2. The ASSOCIATION is a 32-unit condominium project in Leesburg, Florida with 32 members/owners. 
3. The Bylaws of the ASSOCIATION (“BYLAWS”) were enacted September 1, 1980.  [EXHIBIT B.]  EXHIBIT C is a fraudulent BYLAW amendment.
4. The Declaration of Condominium Ownership (“DECLARATION”) was dated November 20, 1980 and was filed November 21, 1980. [EXHIBIT D.]

All known Rules and Regulations (“RULES”) are EXHIBIT E.

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[1] All EXHIBITS are on the Flash Drive EXHIBIT K-1.

 

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1. WILLIAM M. WINDSOR (“WINDSOR” or “PLAINTIFF”) is a resident of Lake County, Florida.  He resides at 100 East Oak Terrace Drive Unit B3, Leesburg, Florida 34748, billwindsor1@outlook.  He is one of the owners of the ASSOCIATION.  He has been an owner and member of the ASSOCIATION continuously since September 27, 2017.
2. , christina.gierke@csklegal.com.  This is a not-for-profit corporation.  The Registered Agent is SENTRY MANAGEMENT, 2180 W. SR 434 Suite 5000, Longwood, Florida 32779.
3. christina.gierke@csklegal.com.  He also resides part of the year at 13037 Wilmington Hills Drive, Aurora, Indiana 47001-9306.  He purported to be a Director and Officer of the ASSOCIATION.
4. hdwvicki@gmail.com.  She is one of the owners of the ASSOCIATION and purported to be a Director and Officer of the ASSOCIATION.
5. christina.gierke@csklegal.com.
6. is a resident of Lake County, Florida.  She resides at 100 East Oak Terrace Drive Unit D2, Leesburg, Florida 34748, christina.gierke@csklegal.com.  She is one of the owners of the ASSOCIATION and purported to be a Director and Officer of the ASSOCIATION.
7. christina.gierke@csklegal.com.
8. christina.gierke@csklegal.com.  He is one of the owners of the ASSOCIATION and has purported to be a Director of the ASSOCIATION.
9. christina.gierke@csklegal.com.  She resides at 6754 Crescent Lake Drive, Lakeland, Florida 33813.  She is one of the owners of the ASSOCIATION and has purported to be a Director and Officer of the ASSOCIATION.
10. christina.gierke@csklegal.com.  He is one of the owners of the ASSOCIATION and has purported to be a Director and Officer of the ASSOCIATION.
11. christina.gierke@csklegal.com.  He is a part owner of the ASSOCIATION and has purported to be a Director and Officer of the ASSOCIATION.
12. christina.gierke@csklegal.com.  She is one of the owners of the ASSOCIATION and has purported to be a Director of the ASSOCIATION. 
13. christina.gierke@csklegal.com.  She is one of the owners of the ASSOCIATION and has purported to be a Director of the ASSOCIATION.  Omar Nuseibeh, Vicki Hedrick, Karen Bollinger, Shehneela Arshi, Marta Carbajo, Howard Solow, Isabel Campbell, Sergio Naumoff, Ed Broom, Jr., Sue Yokley, Wendy Krauss are jointly “COACH HOUSES MEMBER DEFENDANTS”
14. Sentry Management is the management company for the ASSOCIATION in Lake County, Florida.  Sentry Management, Inc., 1928 Salk Avenue, Tavares, FL 32778, christina.gierke@csklegal.com.  EXHIBIT 430 is the November 1, 2014 contract between SENTRY and the ASSOCIATION.
15. 1928 Salk Avenue, Tavares, FL 32778, christina.gierke@csklegal.com.
16. 2180 W SR 434 Suite 5000, Longwood, FL 32779, christina.gierke@csklegal.com.
17. 1928 Salk Avenue, Tavares, FL 32778, christina.gierke@csklegal.com.  Sentry Management, Inc., Charlie Ann Aldridge, Art Swanton, and Brad Pomp are jointly “SENTRY DEFENDANTS.”
18. .  The CLAYTON & MCCULLOH Building, 1065 Maitland Center Commons Blvd., Maitland, FL 32751, mkrause@goldbergsegalla.com.  EXHIBIT 1538 is the April Fool’s Day 2015 contract between CLAYTON & MCCULLOH and the ASSOCIATION.
19. CLAYTON & MCCULLOH, P.A., The Clayton & McCulloh Building, 1065 Maitland Center Commons Blvd., Maitland, FL 32751, mkrause@goldbergsegalla.com.
20. CLAYTON & MCCULLOH, P.A., The Clayton & McCulloh Building, 1065 Maitland Center Commons Blvd., Maitland, FL 32751, mkrause@goldbergsegalla.com.
21. CLAYTON & MCCULLOH, P.A., The Clayton & McCulloh Building, 1065 Maitland Center Commons Blvd., Maitland, FL 32751, mkrause@goldbergsegalla.com.  CLAYTON & MCCULLOH, P.A., Brian Hess, Neal McCulloh, and Russell Klemm are jointly “C&M DEFENDANTS.”
22. (“DBPR”) is the state entity that manages condominium developments.  DBPR, 2601 Blair Stone Road, Tallahassee, FL 32301, David.Asti@MyFloridaLegal.com.
23. 2601 Blair Stone Road, Tallahassee, FL 32301, David.Asti@MyFloridaLegal.com.
24. 2601 Blair Stone Road, Tallahassee, FL 32301, arbitration. David.Asti@MyFloridaLegal.com.  Florida Department of Business and Professional Regulation, Mahlon C. Rhaney, and Leah Simms are jointly “DBPR DEFENDANTS.”

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Prayer for Relief

WHEREFORE, the PLAINTIFF, WILLIAM M. WINDSOR, demands judgment for damages against DEFENDANTS and for other such relief as may be just and equitable and otherwise deemed proper by the Court.  The PLAINTIFF asks the Court to order:

1. that OMAR, VICKI, KAREN, SHEHNEELA, ISABEL, SERGIO, ED, MARTA, WENDY, HOWIE, and SUE have breached their fiduciary duty and caused damages to the Plaintiff;
2. that the ASSOCIATION, Clayton & McCulloh DEFENDANTS, SENTRY DEFENDANTS, AND OMAR, VICKI, AND KAREN have committed fraud;
3. that ISABEL, SERGIO, ED, SHEHNEELA, NEAL, DBPR, MARTA, WENDY, HOWIE, and SUE have participated in the fraud;
4. that Clayton & McCulloh and the Clayton & McCulloh DEFENDANTS have committed malpractice;
5. that SENTRY and the SENTRY DEFENDANTS have committed malpractice;
6. that SENTRY and the SENTRY DEFENDANTS have committed breach of contract;
7. that the ASSOCIATION has failed to operate according to the DECLARATION, ARTICLES OF INCORPORATION, BYLAWS, RULES, and FLORIDA STATUTES is breach of contract;
8. that the ASSOCIATION has committed breach of contract by failing to keep common areas clean;
9. that the ASSOCIATION, COACH HOUSES MEMBER DEFENDANTS, SENTRY DEFENDANTS, and Clayton & McCulloh DEFENDANTS have breached governing documents;
10. that the DEFENDANTS have participated in a conspiracy;
11. that the Clayton & McCulloh Defendants, the SENTRY DEFENDANTS, and the DBPR DEFENDANTS have committed professional negligence;
12. that the ASSOCIATION, COACH HOUSES MEMBER DEFENDANTS, SENTRY DEFENDANTS, and Clayton & McCulloh DEFENDANTS have not properly conducted elections; have not given adequate notice of meetings or other actions; have not properly conducted meetings; have not properly allowed inspection of books and records; have violated dozens of laws, rules, BYLAWS, and statutes, and these violations must be legally identified through declaratory judgments;
13. that the corporate charter of the ASSOCIATION should be revoked;
14. that DEFENDANTS have intentionally and recklessly inflicted mental suffering and emotional distress on the Plaintiff;
15. injunctive relief;
16. an award of punitive damages to the Plaintiff;
17. an award attorneys’ fees and costs to the Plaintiff; and
18. such other relief as may be proper.

Dated in Leesburg, Florida this 24th day of November, 2020.

_______________________________
William M. Windsor

DEMAND FOR JURY TRIAL

Plaintiff, WILLIAM M. WINDSOR, demands a jury trial on all issues so triable of each and every one of the Counts set forth above.

RESPECTFULLY submitted and dated this 24th day of November, 2020,

_______________________________

William M. Windsor

100 East Oak Terrace Drive, Unit B3

Leesburg, Florida 34748 – 352-577-9988

billwindsor1@outlook.com – bill@billwindsor.com

VERIFICATION

Personally appeared before me, the undersigned Notary Public duly authorized to administer oaths, William M. Windsor, who after being duly sworn deposes and states that he is authorized to make this verification and that the facts alleged in the foregoing are true and correct based upon his personal knowledge, except as to the matters herein stated to be alleged on information and belief, and that as to those matters he believes them to be true.

I declare under penalty of perjury that the foregoing is true and correct based upon my personal knowledge.

This 24th day of November, 2020,

                                                                        ___________________________

                                                                        William M. Windsor

Sworn and subscribed before me this 24th day of November, 2020, by means of physical presence.

____________________________

Notary Public

CERTIFICATE OF SERVICE

I hereby certify that I have served a true and correct copy of the foregoing by Electronic Mail:

Vicki Hedrick, Karen Bollinger, Shehneela Arshi, Ed Broom, Jr., Marta Carbajo, Sue Yokley, Wendy Krauss, Howard Solow, Omar Nuseibeh, Isabel Campbell, Sergio Naumoff,

Coach Houses at Leesburg Condominium Association, Inc., Sentry Management, Inc., Art Swanton, Charlie Ann Aldridge, and Brad Pomp:

c/o Christina Bredahl Gierke

COLE, SCOTT & KISSANE, P.A.

Counsel for Board Member Defendants

Tower Place, Suite 400, 1900 Summit Tower Boulevard, Orlando, Florida 32810

Telephone 321-972-0025, Facsimile 321-972-0099

christina.gierke@csklegal.com

victoria.mcfarland@csklegal.com, kirbie.caruso@csklegal.com

Clayton & McCulloh, P.A., Brian Hess, Neal McCulloh, Russell Klemm:

c/o Maura F. Krause

GOLDBERG SEGALLA, LLP

800 N. Magnolia Ave., Suite 450, Orlando, FL 32803

407-458-5600

mkrause@goldbergsegalla.com, jkovecses@goldbergsegalla.com

sherndon@goldbergsegalla.com, psouza@goldbergsegalla.com

Florida Department of Business and Professional Regulation, Mahlon C. Rhaney, Leah Simms:

c/o David Asti

Office of the Attorney General

501 E. Kennedy Blvd., Suite 1100, Tampa, Florida 33602-5242

Telephone: 813-233-2880, Facsimile: 813-233-2886

David.Asti@MyFloridaLegal.com

Wendy.Estevez@MyFloridaLegal.com

Christina.Santacroce@MyFloridaLegal.com

This 30th day of November, 2020.

_______________________________
William M. Windsor

 

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1. This court has jurisdiction on this matter pursuant to Florida Statutes.  This Court has personal jurisdiction over WINDSOR and residents of Lake County.  This Court has personal jurisdiction over CLAYTON & MCCULLOH, BRIAN, RUSSELL, BRAD, SENTRY, DBPR, MAHLON, and LEAH as they have done business in and have had legally meaningful contact with Lake County.
2. Venue in Lake County, Florida is proper as the Plaintiff and most of the Defendants are located in Lake County.  The others have done business in and have had legally meaningful contact with Lake County.

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1. This action is filed by William M. Windsor (“WINDSOR” or “PLAINTIFF”), one of the owners of Coach Houses at Leesburg Condominium Association, Inc. (“ASSOCIATION”).
2. The ASSOCIATION is a 32-unit condominium project in Leesburg, Florida with 32 owners.  The ASSOCIATION has failed to comply with the requirements of the Condominium Act, the ASSOCIATION’s Declaration, Articles of Incorporation, Bylaws, Rules, and Florida law.
3. The ASSOCIATION is incorporated under Chapter 617, Florida Statutes, the “Florida Not for Profit Corporation Act,” and is subject to its laws.  Florida Statutes Section 617.07401 authorizes members to bring lawsuits in the right of their non-for-profit corporation.  Windsor took his complaints to the ASSOCIATION, the purported Board members, the attorneys acting for the ASSOCIATION, and the ASSOCIATION management company.  The corporation was given every opportunity over the last two years to conduct an independent and reasonable investigation to determine if a lawsuit against the attorneys and management company was in the best interests of the corporation.

 Section 718.303(1), Florida Statutes, provides a cause of action for damages or equitable relief that may be pursued by either an association or unit owner.

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1. On October 1, 2020, RUSSELL Klemm filed a Motion to Dismiss Second Amended Complaint for the ASSOCIATION in Case No. 35-2019-CA-001528. [EXHIBIT 1726.]
2. On October 1, 2020, WINDSOR filed a Request for Judicial Notice in Case No. 35-2020-001438. [EXHIBIT 1715.]
3. On October 5, 2020, Christie Gierke filed a Notice of Appearance in Case No. 35-2020-001438 in the Fifth Judicial Circuit in Lake County, Florida. [EXHIBIT 1663.]
4. On October 6, 2020, a letter from a Coach Houses owner was filed in Case No. 2020-CA-1871. [EXHIBIT 1775.]
5. On October 6, 2020, Christie Gierke filed a Motion to Dismiss Claim for Punitive Damages in Case No. 35-2020-001438 in the Fifth Judicial Circuit in Lake County, Florida. [EXHIBIT 1664.]
6. On October 6, 2020, Christie Gierke filed a Motion to Dismiss Counts 1, 2, 6, 7, 8 in Case No. 35-2020-001438 in the Fifth Judicial Circuit in Lake County, Florida. [EXHIBIT 1665.]
7. On October 6, 2020, Christie Gierke filed a Motion to Dismiss Count 3 in Case No. 35-2020-001438 in the Fifth Judicial Circuit in Lake County, Florida. [EXHIBIT 1666.]
8. On October 7, 2020, 2020, WINDSOR filed a Motion for Default Judgment in Case No. 35-2020-001438 in the Fifth Judicial Circuit in Lake County, Florida. [EXHIBIT 1667.]
9. On October 7, 2020, 2020, WINDSOR filed a Motion to Strike Motion to Dismiss in Case No. 35-2020-001438 in the Fifth Judicial Circuit in Lake County, Florida. [EXHIBIT 1668.]
10. On October 10, 2020, WINDSOR filed a Complaint for Trial De Novo against the Association.  It was assigned Case No. 2020-CA-1647 in the Fifth Judicial Circuit in Lake County, Florida. [EXHIBIT 1779.] [EXHIBIT 1780.] [EXHIBIT 1781.] [EXHIBIT 1782.] [EXHIBIT 1783.] [EXHIBIT 1784.] [EXHIBIT 1785.]  This regards DBPR Case Nos. 2019-03-8814 and 2019-04-7339.  [EXHIBIT 1857 is the full file on Case No. 2020-CA-01647.]
11. On October 14, 2020, an Order was entered setting a Hearing for October 28, 2020 in Case No. 2020-CA-1871. [EXHIBIT 1776.]
12. On October 17, 2020, WINDSOR emailed Christie Gierke with a CONFIDENTIAL SETTLEMENT COMMUNICATION.  There was no response.
13. On October 21, 2020, notice of a purported Board Meeting appeared on the front door of Building B. [EXHIBIT 1795.] 
14. On October 21, 2020 at 10:25 a.m., WINDSOR sent an email to Debra Zimmerman and BRAD Pomp of SENTRY. [EXHIBIT 1793.]  He asked them to identify legal authority for the purported October 23, 2020 meeting.  There was no response.  WINDSOR said there are no directors, so there can’t be a Board Meeting.  WINDSOR noted that there was no annual meeting or election in 2020 or 2018, and the 2019 election is void.
15. On October 21, 2020 at 4:00 p.m., WINDSOR received an email from Debra Zimmerman about a purported Board Meeting on October 23, 2020. [EXHIBIT 1794.]
16. On October 21, 2020, Christie Gierke (“GIERKE”) filed a Motion to Stay Discovery in Case No. 35-2020-001438 in the Fifth Judicial Circuit in Lake County, Florida. [EXHIBIT 1669.]
17. On October 22, 2020 at 3:13 p.m., WINDSOR sent an email to Debra Zimmerman, BRAD, BRIAN, NEAL, RUSSELL, and GIERKE.  I said: “You have not responded to my email questioning how you can hold a meeting without officers or directors.”  There was no response. [EXHIBIT 1797.] 
18. On October 22, 2020, Christie GIERKE filed a Notice of Appearance in Case No. 35-2020-001438 in the Fifth Judicial Circuit in Lake County, Florida. [EXHIBIT 1670.]
19. On October 22, 2020 at 3:30 p.m., WINDSOR sent an email to GIERKE, BRIAN, NEAL, and RUSSELL, purportedly attorneys for the Association, expressing distress over the plans to hold a “meeting” on October 23, 2020. [EXHIBIT 1796.]  WINDSOR said Coach Houses has no officers or directors.  WINDSOR asked them to postpone the so-called meeting.  There was no response. 
20. On October 23, 2020, a meeting was held that ISABEL claimed was a Board Meeting.  WINDSOR filmed the entire meeting. [EXHIBIT 1789.]  WINDSOR explained that there were no directors, so there could be no board meeting.  Five people who purported to be directors were there (SERGIO, WENDY, ISABEL, SUE, and ED); the ASSOCIATION has 11 board seats, so five was not a quorum.  ISABEL has taken control of the ASSOCIATION’s assets, and she is independently deciding how money is spent.  She has no authority to do this.  ISABEL announced that SENTRY would no longer be the management company on Halloween.  No explanation was given, but WINDSOR suspects SENTRY quit.  Arise Property Management was identified as the new management company.  Tanya Suarez was the purported new manager.  The Agenda [EXHIBIT 1788] notes “Approval of Minutes: None.”  WINDSOR asked about this, and the response was that there were no minutes from a prior board meeting.  This is true; this wasn’t a legal Board Meeting, and there have been no legal Board Meetings prior to this.  WINDSOR asked ISABEL if there had been secret meetings, and she defiantly said “NO!”  WINDSOR knows there have been secret meetings, but if ISABEL is taken at her word, that means she has independently seized control of the ASSOCIATION and its assets.
21. On October 24, 2020, WINDSOR sent a Request for Inspection of Records to BRIAN of C&M by certified mail. [EXHIBIT 1791.]  [EXHIBIT 1790 is the certified mail receipt.]
22. On October 26, 2020, Maura F. Krause of Goldberg Segalla, LLP filed a Notice of Appearance and Designation of Email Addresses for Clayton & McCulloh, P.A., Brian Hess, Neal McCulloh, Russell Klemm in Case No. 35-2020-001438. [EXHIBIT 1671.]

1. WINDSOR identified over 180 issues and violations by the ASSOCIATION that he presented in a petition to the DBPR. The ASSOCIATION has operated unlawfully for many years, violating numerous Florida statutes and the ASSOCIATION’s DECLARATION, BYLAWS, and ARTICLES of Incorporation. Elections have not been properly conducted. Adequate notice of meetings and other actions have not been given. Meetings have not been properly conducted. Inspection of books and records has been denied. The ASSOCIATION has consistently failed to conduct meetings properly, including annual meetings and elections. Purported meetings on December 12, 2018, February 19, 2019, and March 22, 2019 were not properly conducted.  Florida statutes have been violated repeatedly.  The ASSOCIATION, SENTRY, and C&M committed fraud regarding the attempt to amend the BYLAWS at the meeting on August 1, 2017. People purporting to be Directors of the ASSOCIATION were not legally holding office so they had no authority to act as officers and directors. An April 4, 2019 Special Member’s Meeting requested by 10 owners by certified mail was not held.  An Aril 11, 2019 meeting should have been held, but was not.  There has not been an annual meeting or annual election in over a year, and there are no legally elected officers or directors of the ASSOCIATION.  Voting interests have been incorrectly calculated.  Proper records have not been maintained, and more.
2. Fraudulent documents have been filed with the Florida Secretary of State, and WINDSOR believes the ASSOCIATION’s corporate charter should be revoked for a number of violations.
3. Upon information and belief, despite clear requirements in the D&O Insurance policies, the ASSOCIATION never notified the insurance carriers of litigation and threatened litigation with WINDSOR dating back as far as early 2019.
4. WINDSOR repeatedly communicated to the ASSOCIATION, owners, C&M DEFENDANTS, and SENTRY DEFENDANTS that there was malpractice.  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.  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 C&M objecting to the failure to hold the April 4, 2019 meeting. [EXHIBIT 256.]  WINDSOR expressed this was a violation and malpractice.  EXHIBIT 1095 is a demand dated July 19, 2019.  The July 19, 2019 demand was sent to owners of the ASSOCIATION, purported Directors of the ASSOCIATION, ISABEL, ED, SERGIO; BRIAN, NEAL, and RUSSELL of C&M; BRAD, ART, and CHARLIE ANN of SENTRY.  This was regarding fraud charges against the ASSOCIATION, purported Directors, SENTRY, and C&M.  The AFFIDAVIT OF WILLIAM M. WINDSOR DATED OCTOBER 27, 2020 (“AFFIDAVIT-2020-10-27”) is filled with communications and information about the wrongdoing, malpractice, and demands for action to correct issues.
5. RUSSELL has committed many violations of the Florida Rules of Professional Conduct while fighting WINDSOR.  He has committed perjury, fraud on the court, and many other violations.  Meanwhile, C&M has obtained over $130,000 in legal fee payments from the ASSOCIATION. [EXHIBITS 1850, 1851, 1852, 1853.]
6. The contract with SENTRY [EXHIBIT 430] required that “Agent shall act in accordance with Association’s recorded governing documents, applicable statutes and legal directives….”  SENTRY violated this agreement.
7. WINDSOR recently learned that the land and buildings of the ASSOCIATION have been appraised at over $5 million dollars.  WINDSOR wonders whether part of what may have been at play with all the wrongdoing is an attempt to “steal” the land and buildings.  If someone bought each of the 32 units for the going rate of $60,000, a $1,920,000 investment would give an asset that could be flipped for over $5 million.  Perhaps the plan was to force members to sell, but when WINDSOR discovered all the wrongdoing, it blew the scheme.
8. The DBPR, MAHLON, and LEAH acted in bad faith and with malicious purpose.  They acted in a manner exhibiting wanton and willful disregard of human rights and property.  MAHLON and LEAH acted outside the scope of their employment.  MAHLON and LEAH acted with wanton or willful disregard to Plaintiff’s rights.  MAHLON AND LEAH knowingly violated various laws and case law.  MAHLON and LEAH knowingly ignored the facts and lied about the facts.  The conduct of the DBPR DEFENDANTS was intentional and reckless.  Their conduct was outrageous as poor condominium owners have been falsely led to believe that they can turn to the DBPR for relief from corruption and wrongdoing.  Windsor suspects DBPR DEFENDANTS were bribed to act as they did.  MAHLON and LEAH should have recused themselves for their gross bias and illegal intent.  The DBPR, MAHLON, and LEAH have caused severe emotional distress to Windsor.
9. Both MAHLON and LEAH are liars.  They lied about the facts, and they lied about the law.  They have committed acts that are not duties of DBPR employees.  There is no immunity for criminal acts, and MAHLON and LEAH have committed crimes.  DBPR, MAHLON, and LEAH have acted in the absence of all jurisdiction. 
10. The wrongdoing of the DBPR, MAHLON, and LEAH is shown in EXHIBITS 1850, 1851, 1852, and 1853, referenced and incorporated herein.  Special note is made of Petitioner’s Motion for Reconsideration of April 8, 2020 Order in DBPR Case Nos. 2019-05-3927 and 2019-04-7339; Motion for Rehearing in DBPR Case No. 2019-02-1020; and Motion for Recusal and Affidavit in Support in DBPR Case No. 2019-02-1020.
11. WINDSOR has presented the claim to the Department of Financial Services in compliance with Florida Statute 768.28.

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