INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
- WILLIAM M. WINDSOR adopts and realleges Paragraphs 1 through 505.
- WINDSOR asserts this claim against all DEFENDANTS.
- DEFENDANTS have intentionally and recklessly inflicted mental suffering and emotional distress on WINDSOR. Their conduct has been outrageous. Their conduct has caused and continues to cause emotional distress to WINDSOR. The emotional distress has been and is severe.
- SOF 119, 131, 133, 134, 137, 142, 144, 146, 147, 151, 153, 154, 161, 169, 187, 188, 193, 204, 207, 222, 234, 502, 503, 504, and paragraphs 654-667 are specifically noted on this Cause of Action.
- has been viciously defamed. His fellow owners, mainly senior citizens, have falsely and maliciously been told he doesn’t know the law, is a criminal, and has threatened to kill fellow owners. An alleged Wanted Poster with Windsor’s photograph was mailed anonymously to every owner. At least two of the owners called to report Windsor to the Leesburg Police Department as a wanted man who needed to be arrested. CHARLIE ANN ALDRIDGE and SENTRY MANAGEMENT tried to have Windsor arrested for speaking at a meeting; an All-Points-Bulletin was issued for him by the Tavares Police Department. Police have been hired to attend meetings because Windsor had allegedly made threats to hurt or kill Board members. At least one of the scariest owners sat next to Windsor at a meeting with a pistol in his pocket. They’ve threatened to file liens and foreclose. One woman filed a criminal stalking complaint against him. Windsor has found shell casings next to his vehicle and a big snake in his garage. His property has been vandalized. [See SOF 190, 302.]
- CLAYTON AND MCCULLOH Attorneys have abused WINDSOR repeatedly. It has been one lie after another. Surely this must be the biggest malpractice case in history in terms of the number of issues.
- The DBPR should be a place where condominium owners can go for relief from wrongdoing. Instead the DBPR, MAHLON C. RHANEY, and LEAH SIMMS lied and violated the law repeatedly. This caused significant mental anguish. The DBPR DEFENDANTS were reckless and showed bad faith, malicious purpose, and wanton and willful conduct. There has never been an appellate decision in Florida granting immunity to the DBPR or its employees.
- Merriam-Webster defines “emotional distress” as “a highly unpleasant emotional reaction (as anguish, humiliation, or fury) which results from another’s conduct and for which damages may be sought.”
- Emotional distress should be a relative issue. Windsor is a disabled senior citizen. He is 72 years-old. He has been humiliated by the DEFENDANTS. He has developed insomnia. He can only walk short distances with a cane. He lives on the second floor and has fallen down the stairs many times. He is like a prisoner in his second-floor condo where he has become despised by most of the neighbors. Windsor has been living on an emotional roller coaster for the last two years. He has studied the law, become confident with the law and the evidence, and has attempted to get the wrongdoing with the ASSOCIATION corrected. Then there are no responses or outrageous legal responses. This causes extreme mental anguish in WINDSOR.
- MARTA CARBAJO and VICKI HEDRICK’s gun-toting husband, David Wayne Hedrick, have accused WINDSOR of being a criminal. In early 2019, WINDSOR learned that David Wayne Hedrick was telling people that WINDSOR had threatened to do bodily harm to his wife, VICKI HEDRICK. On January 26, 2019, David Wayne Hedrick sent a letter to OMAR NUSEIBEH, VICKI HEDRICK, KAREN BOLLINGER, and SENTRY MANAGEMENT in which he accused WINDSOR of “felonious actions.” This is libel. [EXHIBIT 1029.] The Legal Dictionary defines “felonious” as “done with an intent to commit a serious crime or a felony; done with an evil heart or purpose; malicious; wicked; villainous.” WINDSOR has never committed a crime other than some speeding over 20 years ago. He has never done a felonious action. He has done nothing with an evil heart, malicious, wicked, or villainous. WINDSOR considers David Wayne Hedrick to be a threat. He seems unstable, and he has guns.
- Upon information and belief, MARTA CARBAJO is responsible for a wanted poster being sent to every member of the ASSOCIATION and is one of the people who contacted the Leesburg Police Department attempting to get WINDSOR arrested for being wanted. WINDSOR is severely claustrophobic, and the thought of being locked up in a jail or prison causes extreme mental anguish.
- Having SENTRY MANAGEMENT call the Tavares Police Department in an attempt to get WINDSOR arrested for exercising his legal right to speak at a purported meeting was outrageous. The Tavares Police issued an All-Points Bulletin for Windsor. [EXHIBIT 1812.] WINDSOR has a video to prove what happened. In an Inspection of Records, WINDSOR learned that NEAL MCCULLOH of CLAYTON AND MCCULLOH orchestrated this outrage. [EXHIBIT 1848.] [EXHIBIT1847.] [See SOF 302.]
- On June 29, 2019, WINDSOR sent an email to inform owners that he had been reported to the police by the ASSOCIATION or SENTRY MANAGEMENT on June 20, 2019. [EXHIBIT 1088.] [EXHIBIT 1059 at 2:50, WINDSOR asked “what about the eight open spots on the Board?” CHARLIE ANN ALDRIDGE said the meeting was adjourned. She then ordered WINDSOR to leave the building. The remainder of the video is CHARLIE ANN ALDRIDGE escorting WINDSOR out of the building. Later that day, owner Larry Lunsford informed WINDSOR that two Tavares Police Officers arrived after he left. As the video shows, there was absolutely no basis for reporting WINDSOR to the police.
- Falsely accusing WINDSOR of crimes creates severe emotional distress. WINDSOR is an honest, law-abiding citizen. He has never intentionally committed a crime. He doesn’t even have a traffic or parking ticket in the last 20 years.
- CHARLIE ANN ALDRIDGE of SENTRY MANAGEMENT repeatedly violated WINDSOR’s rights to speak and inspect records, and she routinely ensured that the ASSOCIATION violate the Florida statutes and corporate governing documents.
- Having resident Dorothy Liebl attempt to have WINDSOR arrested for stalking and attempt to get a stalking protective order was extremely devastating. Dorothy Liebl filed a complaint with the Lake County Court (Case No. 35-2009-DR-000650) in which she sought to have WINDSOR ordered to move away from Coach Houses. Dorothy Liebl lied. She failed to appear for the hearing, so the case was dismissed. While that was a relief, WINDSOR would have preferred to get her under oath and prove perjury. Dorothy Liebl’s outrageous actions will continue to damage WINDSOR. When WINDSOR needed a caregiver after a bad fall down the stairs and was in horrific pain, he was denied a caregiver because the company found Dorothy Liebl’s stalking complaint online.
- On January 9, 2019, WINDSOR was informed that one Coach Houses owner, Dave Van Leeuwen, was told that WINDSOR had physically threatened Board members. Dave Van Leeuwen had decided WINDSOR was a dangerous person and he should have nothing to do with him. [EXHIBIT 346.] WINDSOR was then told by neighbors that OMAR NUSEIBEH was telling owners that WINDSOR had threatened to kill Board Members. WINDSOR was told that VICKI Hedrick’s husband, David Wayne Hedrick, had told people that WINDSOR had threatened to kill VICKI HEDRICK. WINDSOR was told that owner MARTA Carbajo was telling owners that WINDSOR was wanted for criminal charges of fraud. Someone mailed a Wanted Poster with WINDSOR’S photo to the owners. None of this was true.
- Owner Allan Holtz informed WINDSOR about Dave Van Leeuwen. WINDSOR asked if Dave would be willing to meet with him, and he responded: “No, I’m quite sure Dave wouldn’t be willing. He literally seems to be scared of you. My impression is that he really believes that you made physical threats to the board and that you are a dangerous guy. Someone’s done a pretty good job on him….” [EXHIBIT 349.]
- On January 11, 2019, WINDSOR emailed Dave Van Leeuwen about the defamation he had heard. [EXHIBIT 347.] On January 13, 2019, Dave Van Leeuwen emailed WINDSOR to acknowledge the defamation he had heard and to apologize for sharing it. [EXHIBIT 348.]
- On March 5, 2019, a so-called “Town Hall Meeting” was held. [EXHIBIT 281.] I considered it to be an effort by CLAYTON AND MCCULLOH to dissuade owners from voting to replace OMAR, VICKI, and KAREN. [EXHIBIT 282-1, EXHIBIT 282-2, EXHIBIT 282-3, EXHIBIT 282-4, EXHIBIT 282-5, EXHIBIT 282-6, EXHIBIT 282-7 is video from the meeting.] No minutes were published for the purported meeting. [See SOF 184.]
- On March 5, 2019, NEAL MCCULLOH of CLAYTON AND MCCULLOH distributed a letter to the owners of the ASSOCIATION. [EXHIBIT 267.] In the second paragraph on page 1, NEAL MCCULLOH of CLAYTON AND MCCULLOH claims the actions taken on December 12, 2018 were at his firm’s direction. WINDSOR believes this is proof of malpractice. In the first full paragraph on page 2, NEAL claims the directors were properly elected because “only three (3) people timely and properly submitted an intent to be a candidate for the current term.” This is false. WINDSOR has complete proof of this. In the first full paragraph on page 2, NEAL MCCULLOH falsely claims individuals were recommending self-management and elimination of professional services. WINDSOR believes this is false and malicious. In that paragraph,
- NEAL MCCULLOH of CLAYTON AND MCCULLOH also claims so many of the legal challenges (by me) are “completely wrong, in error, and in derogation of the Florida Statutes and/or the Association’s Governing Documents.” This is false and malicious.
- After the meeting ended, WINDSOR spoke with
- NEAL MCCULLOH of CLAYTON AND MCCULLOH and suggested a meeting to discuss and attempt to resolve the issues. WINDSOR expressed that this would be far less expensive to the owners. He refused. He told WINDSOR to handle it through legal filings.
- When NEAL MCCULLOH of CLAYTON AND MCCULLOH spoke to the owners at a so-called Town Hall Meeting on March 5, 2019, he defamed WINDSOR repeatedly. He falsely and maliciously made claims about the facts and the law. He indicated repeatedly that he was delighted by the legal actions because it was paying to send his son to college. This outraged WINDSOR and other owners.
- The acts of the DEFENDANTS have been outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community. The blatant violation of the law and the corporate governing documents has been outrageous. The magnitude of the wrongdoing must be seen as extremely extreme in degree. There is nothing decent about what the DEFENDANTS have done. All citizens should be able to expect that they will be treated fairly and with honesty, especially senior citizens. What the DEFENDANTS have done is intolerable in a civilized society. When WINDSOR tells people what has been done, the response is “OUTRAGEOUS.”
In most cases, claims for intentional infliction of emotional distress pertain to one or a small number of acts. In this case, the emotional distress has come from many people and organizations over a period of two years. It’s like Chinese Water Torture to WILLIAM M. WINDSOR.
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Conspiracy is one of the charges against the Defendants:
- WILLIAM M. WINDSOR adopts and realleges Paragraphs 1 through 505.
- WINDSOR asserts this claim against all DEFENDANTS.
- They have conspired to do unlawful acts or do lawful acts by unlawful means. Many overt acts have been done in pursuance of the conspiracy. WINDSOR has suffered damage as a result of the acts performed through the conspiracy.
- Upon information and belief, there has been an agreement between two or more parties to do unlawful acts or do lawful acts by unlawful means.
- One of the acts of the conspiracy is to ignore the laws of the State of Florida and the corporate governing documents to put people who were not lawfully elected in control of the ASSOCIATION. The goal of the conspiracy was to enable the ASSOCIATION to operate unlawfully. All of the DEFENDANTS have committed overt acts in pursuance of the conspiracy. OMAR NUSEIBEH, VICKI HEDRICK, and KAREN BOLLINGER agreed with the SENTRY MANAGEMENT DEFENDANTS and CLAYTON AND MCCULLOH DEFENDANTS to falsely claim the BYLAWS were amended. The CLAYTON AND MCCULLOH DEFENDANTS handled the legal work to document a BYLAW amendment that was never passed, and CLAYTON AND MCCULLOH filed it in Lake County Florida. CLAYTON AND MCCULLOH then lied about the validity of the amendment, and SENTRY MANAGEMENT covered up that there was no amendment and no minutes to substantiate a BYLAW amendment. Upon information and belief, the DBPR was brought into the conspiracy. MAHLON C. RHANEY has had ex parte discussions with RUSSELL E. KLEMM of CLAYTON AND MCCULLOH. The DBPR DEFENDANTS have issued opinions that are truly outrageous to assist the other DEFENDANTS in their wrongdoing. The CLAYTON AND MCCULLOH DEFENDANTS and SENTRY MANAGEMENT DEFENDANTS have been involved since Day One as were OMAR NUSEIBEH, VICKI HEDRICK, and KAREN BOLLINGER.
- WINDSOR anxiously awaits discovery that may show who established the agreement and concocted the scheme. Upon information and belief, it was either OMAR NUSEIBEH, CLAYTON AND MCCULLOH, or SENTRY MANAGEMENT, and it was done in an effort to conceal wrongdoing, criminal acts, improper use of ASSOCIATION assets, and malpractice by CLAYTON AND MCCULLOH and SENTRY MANAGEMENT.
- The torts include Breach of Fiduciary Duty, Breach of Contract, Breach of Corporate Governing Documents, Fraud, Intentional Infliction of Emotional Distress, Malpractice, and more. Upon information and belief, criminal acts have been committed.
- The COACH HOUSES MEMBER DEFENDANTS have conspired with the ASSOCIATION and each other. The COACH HOUSES MEMBER DEFENDANTS, the ASSOCIATION, the CLAYTON AND MCCULLOH DEFENDANTS, the SENTRY MANAGEMENT DEFENDANTS, and the DBPR DEFENDANTS have conspired with each other. All of the issues applicable to mandatory non-binding arbitration have already been addressed with the DBPR.
- Each of the COACH HOUSES MEMBER DEFENDANTS has falsely claimed the BYLAWS were amended and that various people who were never lawfully elected were the Officers and Directors. The ASSOCIATION has participated in virtually all of the acts of the conspiracy. The CLAYTON AND MCCULLOH DEFENDANTS and the SENTRY MANAGEMENT DEFENDANTS have facilitated all of the wrongful acts. ALL of the DEFENDANTS have ignored efforts to get state law and corporate governing documents honored.
- The DBPR DEFENDANTS have violated Article 1, Section 21 of the Florida Constitution as part of the conspiracy. [See SOF 369.] There has never been an appellate decision in Florida granting immunity to the DBPR or its employees.
- The DBPR, MAHLON C. RHANEY, and LEAH SIMMS acted in the clear absence of all jurisdiction. They violated the law, committed perjury, acted corruptly, and intentionally violated WINDSOR’s rights. There is no immunity for criminal conduct and conspiracy by a government agency or attorneys who want to pretend to be “judges.” They showed bad faith, malicious purpose, and wanton and willful conduct. [See SOF 502, 503, 504.]
- A significant effort of the conspiracy has been to wrongfully declare BYLAW 2.2 was amended on August 1, 2017. The records produced by the ASSOCIATION at Inspections of Records prove that the BYLAW was not amended. The Minutes of the meeting do not even mention efforts to amend the BYLAW. [EXHIBIT 1287.]
- WINDSOR has been damaged as a result of the acts done under the conspiracy. WINDSOR had to withdraw as a candidate for the Board. WINDSOR lost an $80,000 contract to sell his condo. WINDSOR has spent many thousands of dollars fighting the wrongful acts. The ASSOCIATION has spent over $130,000 with CLAYTON AND MCCULLOH battling WINDSOR’s efforts, and WINDSOR has been forced to pay 1/32 of that amount. WINDSOR has been forced to pay monthly assessments that are dramatically higher than the last lawfully-approved assessment. WINDSOR has been forced to endure emotional distress.
The DEFENDANTS developed a “peculiar power of coercion” possessed by the conspirators by virtue of their combination, which WINDSOR acting alone does not possess. Here it was the concerted nature of the actions of these DEFENDANTS that caused the resulting losses to WINDSOR.
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IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL DISTRICT
IN AND FOR LAKE COUNTY, FLORIDA
William M. Windsor,
Case No. 35-2020-CA-001438
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,
SECOND AMENDED COMPLAINT
PLAINTIFF hereby files this Second Amended Complaint (“SECOND AMENDED COMPLAINT”) 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.
Jurisdiction and Venue
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 – FAILURE TO KEEP COMMON AREAS CLEAN
COUNT SEVEN — CONSPIRACY
COUNT EIGHT — PROFESSIONAL NEGLIGENCE
COUNT NINE — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
Prayer for Relief
- On August 1, 2019, WINDSOR served his Request for Findings of Fact and Conclusions of Law in DBPR Case No. 2019-02-6834 on Mahlon C. Rhaney, Jr. and the ASSOCIATION. [EXHIBIT 1188.]
- On August 1, 2019, WINDSOR sent by email a Request for Findings of Fact and Conclusions of Law in DBPR Case No. 2019-02-6834 to the DBPR and the ASSOCIATION. [EXHIBIT 1187.]
- On August 2, 2019, the Arbitrator issued another FINAL ORDER OF DISMISSAL in DBPR Case No. 2019-02-6834. [EXHIBIT 1185.] It appears to be identical to the July 31, 2019 “FINAL ORDER OF DISMISSAL,” and no explanation was provided as to why there are two final orders of dismissal.
- On August 2, 2019 at 8:37 p.m., WINDSOR sent an email to the owners of the ASSOCIATION complaining about false advertising by OMAR and Dorothy Liebl. [EXHIBIT 1273.] There was no response.
- On August 3, 2019 at 6:32 p.m., WINDSOR sent an email to the owners of the ASSOCIATION, SENTRY, and CLAYTON & MCCULLOH complaining about cleaning of the common area carpets. [EXHIBIT 1279.]
- On August 5, 2019, the Arbitrator issued an ORDER DENYING MOTION FOR REHEARING in DBPR Case No. 2019-02-6834 regarding the March 22, 2019 election. [EXHIBIT 1211.] WINDSOR did not file a motion for rehearing. MAHLON claimed a request for findings of fact and conclusions of law was a motion for rehearing. WINDSOR received a copy of the ORDER by email from Tia King of DBPR. [EXHIBIT 1271.]
- On August 6, 2019, the Arbitrator issued a FINAL ORDER OF DISMISSAL in DBPR Case No. 2019-03-8814 regarding inspection of books and records. [EXHIBIT 1192.]
- On August 9, 2019, MAHLON of the DBPR issued a FINAL ORDER OF DISMISSAL in Case No. 2019-04-0349, the petition regarding Building B at Coach Houses. [EXHIBIT 1196.]
- On August 9, 2019 at 1:32 p.m., WINDSOR received an email from Tia King at the DBPR with a FINAL ORDER OF DISMISSAL in Case No. 2019-04-0349, the petition regarding Building B at Coach Houses. [EXHIBIT 1197.]
- On August 9, 2019 at 5:15 p.m., WINDSOR sent an email to Ms. Tia King at DBPR regarding ex parte communication by MAHLON. [EXHIBIT 1195.]
- On August 14, 2019, WINDSOR mailed for filing a Notice of Order, Motion for Recusal, Affidavit, and Certificate of Counsel in in DBPR Case No. 2019-03-8814, 2019-02-1020, 2019-02-6834, and 2019-04-0349. [EXHIBIT 1236.] He also emailed it to the DBPR and Russell Klemm. [EXHIBIT 1237.] The Affidavit in Support of Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-02-1020 is EXHIBIT 1246. The Affidavit in Support of Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-02-6834 is EXHIBIT 1247. The Affidavit in Support of Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-03-8814 is EXHIBIT 1248. The Affidavit in Support of Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-04-3349 is EXHIBIT 1249. The Certificate of Counsel of Record in DBPR Case No, 2019-02-1020 is EXHIBIT 1250. The Certificate of Counsel of Record in DBPR Case No, 2019-02-6834 is EXHIBIT 1251. The Certificate of Counsel of Record in DBPR Case No, 2019-03-8814 is EXHIBIT 1252. The Certificate of Counsel of Record in DBPR Case No, 2019-04-3349 is EXHIBIT 1253. The Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-02-1020 is EXHIBIT 1254. The Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-02-6834 is EXHIBIT 1255. The Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-03-8814 is EXHIBIT 1256. The Motion for Recusal of Mahlon C. Rhaney, Jr. in DBPR Case No, 2019-04-3349 is EXHIBIT 1257.
- On August 15, 2019 at 12:19 a.m., WINDSOR sent an email to the DBPR and Russell Klemm with copies of the Motion for Rehearing in DBPR Case No. 2019-02-6834 that was mailed on August 14, 2019. [EXHIBIT 1235.]
- On August 15, 2019 at 9:49 a.m., WINDSOR received five emails from Tia King of DBPR saying electronic filings are not acceptable. [EXHIBIT 1218.]
- On August 15, 2019 at 1:43 p.m., Tia King of DBPR provided WINDSOR with the contact information for Alison Parker, the DBPR Deputy General Counsel who would be handling his complaint against MAHLON. [EXHIBIT 1234.]
- On August 15, 2019 at 1:54 p.m., WINDSOR sent an email to Alison Parker of DBPR. It was a formal complaint against MAHLON. [EXHIBIT 1224.] WINDSOR sent a copy to Russell E. Klemm of CLAYTON & MCCULLOH. [EXHIBIT 1233.]
- On August 17, 2019, WINDSOR sent by certified mail his August 16, 2019 letter identifying the Records that were not produced at the Inspection of Records on August 16, 2019. [EXHIBIT 1228.]
- On August 17, 2019, WINDSOR sent by certified mail his Sixth Notice of Intent to File Petition for Arbitration and/or Lawsuit due to Failure to Produce Records for Inspection. [EXHIBIT 1230.]
- On August 17, 2019, WINDSOR sent by email his Sixth Notice of Intent to File Petition for Arbitration and/or Lawsuit due to Failure to Produce Records for Inspection and the letters that he mailed by certified mail that day. [EXHIBIT 1227.]
- On August 19, 2019, WINDSOR received an email from Alison Parker of DBPR saying she would look into the complaint against MAHLON. [EXHIBIT 1225.]
- On August 19, 2019, WINDSOR sent an email to Alison Parker of DBPR saying he would provide the requested information promptly. [EXHIBIT 1226.]
- On August 20, 2019, WINDSOR sent BRIAN of CLAYTON & MCCULLOH by certified mail a Notice of Intent to File a Petition for Arbitration regarding the August 2017 meetings. [EXHIBIT 1239.] EXHIBIT 1278 is the signed receipt. WINDSOR emailed it to the ASSOCIATION, SENTRY, and the attorneys at C&M. [EXHIBIT 1240.] [EXHIBIT 1263 is the signed certified mail receipt.]
- On August 21, 2019, WINDSOR sent an email to Alison Parker of DBPR saying he would be sending a flash drive. [EXHIBIT 1270.]
- On August 22, 2019, MAHLON filed a Notice After Order Denying Petitioner’s Motion for Rehearing and Petitioner filing for Trial De Novo. [EXHIBIT 1261.]
- On August 22, 2019, WINDSOR sent an email to Alison Parker of DBPR. He told her that MAHLON C. Rhaney, Jr. had refused to recuse himself and did not address the facts. WINDSOR told her that he would have to sue MAHLON and the DBPR. [EXHIBIT 1277.]
- On August 23, 2019, Mahlon C. Rhaney, Jr. filed an ORDER DENYING MOTION FOR REHEARING in DBPR Case No. 2019-02-6384. [EXHIBIT 1276.] He did not address two other motions, but he included them in his order.
- On August 26, 2019, WINDSOR emailed Alison Parker of DBPR to say that Mahlon had refused to recuse himself and that he was convinced he is corrupt. [EXHIBIT 1299.]
- On August 27, 2019, WINDSOR emailed Alison Parker of DBPR to cite Article 1, Section 21 of the Florida Constitution as a fundamental law that Mahlon had violated. [EXHIBIT 1319.]
- On August 27, 2019, Alison Parker of DBPR emailed WINDSOR to say she would have a response to him shortly. [EXHIBIT 1319.]
- On August 27, 2019, WINDSOR filed a FIRST AMENDED REQUEST FOR TRIAL DE NOVO in Case No. 2019-CA-001528 in County Court of Lake County, Florida. Mahlon and Russell Klemm were served with copies. [EXHIBIT 1473.]
- On August 27, 2019, WINDSOR emailed Alison Parker of DBPR to say he had two more petitions to file, and he expressed that he did not want Mahlon to be the arbitrator. [EXHIBIT 1320.]
- On August 28, 2019, Alison Parker, Deputy General Counsel of DBPR, sent WINDSOR a letter ignoring the issues in his complaint against Mahlon. [EXHIBIT 1288.]
- On August 28, 2019, WINDSOR emailed Ray Treadwell, General Counsel of DBPR, to say “I need to speak with you about incompetence and/or corruption on your staff.” [EXHIBIT 1298.].
- On August 29, 2019, WINDSOR filed a First Amended Request for Trial De Novo in Case No, 35-2019-CA-001528. [EXHIBIT 1854.]
- On August 29, 2019, WINDSOR filed a Request for Trial De Novo in Lake County Court. [EXHIBIT 1289.] It was assigned Case No. 2019-CA-1871. On August 29, 2019, I served Mahlon and Russell E. Klemm of CLAYTON & MCCULLOH by email. [EXHIBIT 1292.] WINDSOR served Mahlon and Russell E. Klemm of CLAYTON & MCCULLOH by certified mail. EXHIBIT 1290 is the certified mail receipt for MAHLON, and EXHIBIT 1291 is the certified mail receipt for Russell E. Klemm of CLAYTON & MCCULLOH. EXHIBIT 1351 is the signed certified mail receipt for Russell of CLAYTON & MCCULLOH. EXHIBIT 1336 is a signed certified mail receipt for MAHLON. [EXHIBIT 1855 is the full file on Case No. 2019-CA-001871.]
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