Windsor v. Coach Houses at Leesburg Condominium Lawsuit ‚Äď 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.

Click here for links to the entire lawsuit, by section

Windsor v. Coach Houses at Leesburg Condominium Lawsuit

IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL DISTRICT

IN AND FOR LAKE COUNTY, FLORIDA

William M. Windsor,

Plaintiff,

                                                                                    Case No. 35-2020-CA-001438

vs.

Coach Houses at Leesburg Condominium Association, Inc., Omar Nuseibeh, Vicki Hedrick, Karen Bollinger, Shehneela Arshi, Isabel Campbell, Sergio Naumoff, Ed Broom, Jr., Marta Carbajo, Sue Yokley, Wendy Krauss, Howard Solow, Sentry Management, Inc., Charlie Ann Aldridge, Art Swanton, Brad Pomp, Clayton & McCulloh, P.A., Brian Hess, Neal McCulloh, Russell Klemm, Florida Department of Business and Professional Regulation, Mahlon C. Rhaney, Leah Simms, and Does 1-20,

Defendants.

____________________________________________________________________________

SECOND AMENDED COMPLAINT

PLAINTIFF hereby files this Second Amended Complaint (‚ÄúSECOND AMENDED COMPLAINT‚ÄĚ) and shows the Court the following:

PLEASE BE ADVISED: Everything you are about to read regarding the BIG LAWSUIT is the actual lawsuit Complaint. It was sworn under penalty of perjury before a notary to be true and correct based upon William M. Windsor’s knowledge. It is on file in Lake County Circuit Court for anyone to read.

Introduction

Jurisdiction and Venue

Parties

Legal Background

Statement of Facts:

Facts — 2018

Facts — January 2019

Facts — February 2019

Facts — March 2019

Facts — April 2019

Facts — May 2019

Facts — June 2019

Facts — July 2019

Facts — August 2019

Facts — September 2019

Facts — October 2019

Facts — November 2019

Facts — December 2019

Facts — January 2020

Facts — February 2020

Facts — March 2020

Facts — May 2020

Facts — June 2020

Facts — July 2020

Facts — August 2020

Facts — September 2020

Facts — October 2020

CAUSES OF ACTION

COUNT ONE —¬†BREACH OF FIDUCIARY DUTY

COUNT TWO —¬†FRAUD

COUNT THREE —¬†DERIVATIVE ACTION FOR LEGAL MALPRACTICE

COUNT FOUR —¬†BREACH OF CONTRACT

COUNT FIVE —¬†DERIVATIVE ACTION FOR MALPRACTICE AND BREACH OF CONTRACT

COUNT SIX —¬†BREACH OF CONTRACT ‚Äď FAILURE TO KEEP¬†COMMON AREAS CLEAN

COUNT SEVEN —¬†CONSPIRACY

COUNT EIGHT —¬†PROFESSIONAL NEGLIGENCE

COUNT NINE —¬†INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

PUNITIVE DAMAGES

Prayer for Relief