Windsor v. Coach Houses at Leesburg Condominium Lawsuit – BREACH OF CONTRACT

COUNT FOUR

BREACH OF CONTRACT

  1. WINDSOR adopts and realleges Paragraphs 1 through 505.
  2. WINDSOR asserts this claim against the ASSOCIATION.
  3. DECLARATION, ARTICLES OF INCORPORATION, BYLAWS, RULES, and FLORIDA STATUTES is breach of contract and breach of governing documents. [EXHIBITS A, B, D, and E.]
  4. The ASSOCIATION has been operating unlawfully.  Many violations have been repeated again and again.  The Statement of Facts is filled with evidence.
  5. Dues and assessments have been levied against WINDSOR and other Owners without legal authority.  WINDSOR, one of the 32 owners, believes he is owed at least $15,000 due to excessive charges.
  6. The ASSOCIATION, COACH HOUSES MEMBER DEFENDANTS, CLAYTON & MCCULLOH DEFENDANTS, and SENTRY DEFENDANTS are responsible for the breaches.

The ASSOCIATION’s corporate charter should be revoked due to failure of the ASSOCIATION to comply with the DECLARATION, ARTICLES OF INCORPORATION, BYLAWS, RULES, and FLORIDA STATUTES.

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