Windsor v. Coach Houses at Leesburg Condominium Lawsuit – FACTS – JULY 2019

  1. On July 2, 2019, an Order Denying Petitioner‚Äôs Motion for Rehearing (‚ÄúORDER DENYING MOTION FOR REHEARING‚ÄĚ) was filed in DBPR Case No. 2019-02-1020. [EXHIBIT 1071.]
  2. 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 ‚ÄúFUC* YOU‚ÄĚ on it.¬† EXHIBIT 1087 is the Notice that was defaced and removed by ED.
  3. On July 8, 2019, WINDSOR posted new Notices of Intent to Apply for Receivership at Coach Houses at Leesburg. [EXHIBIT 1070.]
  4. On July 8, 2019, WINDSOR sent an email to the DBPR Ombudsman asking who to contact about a complaint against DBPR Arbitrator Mahlon C. Rhaney. [EXHIBIT 1199.]
  5. On July 8, 2019, WINDSOR sent a MOTION FOR AMENDMENT TO ORDER REQUIRING RESPONSE in DBPR Case No. 2019-02-6834. [EXHIBIT 1331.]
  6. On July 13, 2019, WINDSOR wrote a Letter to Ronell James of the DBPR regarding Inspection of Records Requests. [EXHIBIT 1141.]  EXHIBIT 1067 is the certified mail receipt.  EXHIBIT 1268 is the signed certified mail receipt.  WINDSOR advised Ronell James that there is no issue before a federal court.  WINDSOR advised him that he suspected fraud and perhaps forgery.
  7. On July 13, 2019, WINDSOR wrote a Letter to Paula Bouie of the DBPR regarding Inspection of Records Requests. [EXHIBIT 1142.]  EXHIBIT 1068 is the certified mail receipt.  EXHIBIT 1269 is the signed certified mail receipt.  WINDSOR advised her that there is no proceeding before a court.  He suggested that there is fraud and perhaps forgery by the ASSOCIATION or its purported attorney.  There has been no response.
  8. On July 16, 2019, WINDSOR filed a Request for Trial De Novo with the County Court in Lake County, Florida. [EXHIBIT 1073.]  WINDSOR served it by certified mail on the DBPR and the attorney for the ASSOCIATION, the Defendants.  EXHIBIT 1074 is the Certified Mail Receipt to Mahlon C. Rhaney of the DBPR.  EXHIBIT 1075 is the Certified Mail Receipt to the attorney for the ASSOCIATION.  EXHIBIT 1076 is the postal receipt. EXHIBIT 1149 is the proof of delivery to Mahlon C. Rhaney of the DBPR.  EXHIBIT 1150 is the proof of delivery to the attorney for the ASSOCIATION.  It was assigned Case No, 35-2019-CA-001528. [EXHIBIT 1854 is the full file on this case.]
  9. On July 16, 2019, WINDSOR sent an email with notice regarding intent to file a legal action for racketeering activity. [EXHIBIT 1077.]
  10. On July 16, 2019, WINDSOR sent an email to inform members of the ASSOCIATION that he filed Case No. 2019-CA-001528 in County Court of Lake County, Florida. [EXHIBIT 1078.]
  11. On July 19, 2019, an Inspection of Records was held at SENTRY.¬† WINDSOR ‚Äės request was dated June 26, 2019. [EXHIBIT 1038.]¬† Virtually none of the requested records were produced.¬† EXHIBIT 1146 contains all of the pdf files produced on a laptop.¬† EXHIBIT 1147-1 to EXHIBIT 1147-41 contains photos that WINDSOR took of the records produced.¬† Almost all of these were produced previously and were not responsive to previous requests.¬† EXHIBIT 1109-1 to EXHIBIT 1109-29 are all the photocopies WINDSOR made during the July 19, 2019 Inspection of Records.
  12. On July 19, 2019, WINDSOR sent a letter to the ASSOCIATION and BRIAN of CLAYTON & MCCULLOH about the failure to produce the requested records in response to Inspection of Records Requests. [EXHIBIT 1092.]  Virtually none of the requested records were produced.
  13. On July 19, 2019, WINDSOR sent a Fifth Notice of Intent to File Petition for Arbitration and/or Lawsuit due to Failure to Produce Records for Inspection to the ASSOCIATION and BRIAN of CLAYTON & MCCULLOH. [EXHIBIT 1093.]
  14. 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 CLAYTON & MCCULLOH; BRAD, ART, and CHARLIE ANN of SENTRY.  This was regarding fraud charges against Coach Houses, purported Directors, SENTRY, and C&M. [EXHIBIT 1095.]  The email detailed dozens of requests for any minutes of the purported August 2017 meeting where some claim the BYLAWS were amended.  The Minutes do not indicate that the BYLAWS were amended.  THERE ARE NO MINUTES OF ANY MEETING OF COACH HOUSES TO AMEND THE BYLAWS TO CHANGE THE DATE OF THE ANNUAL MEETING AND ELECTION.  The March 22, 2019 meetings and election were a fraud, and we have no lawfully-elected directors or officers.  August 1, 2017 violations were detailed.[See SOF 331.]
  15. On July 19, 2019, WINDSOR sent an email to the ASSOCIATION, SENTRY, and CLAYTON & MCCULLOH regarding the July 19, 2019 Inspection of Records. [EXHIBIT 1296.]
  16. On July 19, 2019, WINDSOR sent an email with copies of all July 19, 2019 letters to the ASSOCIATION, SENTRY, and CLAYTON & MCCULLOH. [EXHIBIT 1096.]
  17. On July 22, 2019, a purported Board Meeting was held. [EXHIBIT 1280.]  No minutes were published for the purported meeting.  Video of the meeting is EXHIBIT 1135-1, EXHIBIT 1135-2, EXHIBIT 1135-3, EXHIBIT 1135-4, EXHIBIT 1135-5, EXHIBIT 1135-6, EXHIBIT 1135-7.  There was no quorum, and CHARLIE ANN refused to justify how the meeting could be held.  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.
  18. 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.
  19. On July 25, 2019, WINDSOR sent an email to the ASSOCIATION informing all that he is seeking $12,000 pursuant to Florida statutes for failure to produce records for inspection. [EXHIBIT 1274.]
  20. On July 27, 2019, WINDSOR’s Petition for Mandatory Non-Binding Arbitration for Failure to Produce Records for Inspection was sent to the DBPR for filing.  It was assigned DBPR Case No. 2019-03-8814. [EXHIBIT 1190.]
  21. On July 27, 2019, WINDSOR sent an email to the ASSOCIATION about the owners who are being allowed to illegally rent their condos. [EXHIBIT 1283.]
  22. On July 28, 2019, WINDSOR sent an email to the ASSOCIATION about the failure to remove the ‚Äúenhancement‚ÄĚ outside Unit B2. [EXHIBIT 1282.]
  23. On July 29, 2019, WINDSOR’s Petition for Mandatory Non-Binding Arbitration for Failure to Produce Records for Inspection was filed by the DBPR.  It was assigned DBPR Case No. 2019-03-8814. [EXHIBIT 1190.]
  24. On July 30, 2019, WINDSOR sent his Mandatory Non-Binding Petition Form Regarding Failure to Require Udo and Dorothy Liebl to Remove Unauthorized Appurtenances and Clean Carpets. [EXHIBIT 1191.]  This was assigned Case No. 2019-04-0349.
  25. On July 31, 2019, the Arbitrator issued a FINAL ORDER OF DISMISSAL in DBPR Case No. 2019-02-6834. [EXHIBIT 1184.]  WINDSOR was served a copy by email on August 1, 2019. [EXHIBIT 1243.]

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Windsor v. Coach Houses at Leesburg Condominium Lawsuit ‚Äď FACTS – JUNE 2019

  1. On June 5, 2019, the ASSOCIATION filed Respondent’s Motion to Dismiss for Failure to State a Cause of Action (DBPR Case No. 2019-02-1020). [EXHIBIT 796.]
  2. On June 5, 2019, investigator Ron James from the DBPR called to discuss WINDSOR’s second Complaint regarding failure to produce documents (DBPR Complaint No. 2019028466).  He sent WINDSOR a letter dated June 5, 2019. [EXHIBIT 994.]
  3. On June 5, 2019, WINDSOR entered into a contract to sell his Coach Houses Unit B3 for $80,000. [EXHIBIT 1015.]
  4. On June 6, 2019, a purported Board Meeting was held. [EXHIBIT 973.] [EXHIBIT 1367 is the Minutes.]  ISABEL CAMPBELL, SERGIO NAUMOFF, and ED BROOM 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.
  5. On June 6, 2019, WINDSOR sent an email to the purported Board, CLAYTON & MCCULLOH, and SENTRY MANAGEMENT regarding the Board Meeting. [EXHIBIT 822.]  He said:

‚ÄúI hereby request to be named a Board Member.¬† If we have openings, you are required by statute to notify the owners, and you didn’t.¬† You want an odd number, though that is not in our Bylaws or the Florida statutes.¬† But, now I’m Board Member #5.¬† 37 years of Minutes show this is what is done when there are openings pre-Omar.

For the record, today’s meeting was invalid.¬† The March election was invalid.¬† I didn’t raise a Point of Order as owners don’t have such a right at a Board Meeting.¬†

A very intelligent request was made today by an owner to have special expenses treated through Special Assessments.  CHARLIE ANN ALDRIDGE told all at the meeting that the attorneys said our BYLAWS prohibit this.  There is NOTHING in our BYLAWS that prohibits special assessments.  I asked for the Bylaw to be identified, and CHARLIE ANN ALDRIDGE told me to hire an attorney.   I came home and read the BYLAWS for about the hundredth time.  I am preparing to file another Petition that will list this as another violation.  Florida law specifically permits Special Assessments (Section 718.112(2)(c)1, Florida Statutes): http://www.condo-owner.com/article/special-assessments-do-it-right-or-pay-the-price/

By the way, Florida Statutes take precedence over bylaws.

I have an eyewitness to the Libel dog soiling the carpets in Building B.  Ask Jason and Karen Chandler.  Mrs. DOROTHY LIEBL (Libel) claimed her dog never did any such thing.  WRONG!

Unfortunately, your new Board has chosen to fight me legally.¬†¬†At today’s meeting, I offered to withdraw my actions against the Association.¬† I am willing to do this if CLAYTON & MCCULLOH and SENTRY MANAGEMENT refund to the Association all money paid by the Association to them from 2016 to 2019.

The people responsible for our outrageous legal fees are OMAR NUSEIBEH, VICKI HEDRICK, KAREN BOLLINGER, CHARLIE ANN ALDRIDGE, SENTRY MANAGEMENT, BRIAN HESS, NEAL MCCULLOH.‚ÄĚ

  • On June 7, 2019, WINDSOR sent a certified letter to attorney BRIAN HESS of CLAYTON AND MCCULLOH for the ASSOCIATION. WINDSOR enclosed a Letter from Karen Chandler about B3 Carpet; Email from him about Breach of Fiduciary Duty, Liebls, and Lawyers; Letter from him agreeing to be a Director; Email from WINDSOR about Board Meeting; Email from WINDSOR about Vandalism in Building B; Email from WINDSOR with Notice of Intent to file Third Petition for Arbitration; Notice of Intent for his Third Petition, pre-arbitration letter and Exhibits AA, BB, CC, DD, EE, and FF; Email from WINDSOR with Notice of Intent to file Third Petition Part 1 of 3; Email from WINDSOR with Notice of Intent to file Third Petition Part 2 of 3; Email from WINDSOR with Notice of Intent to file Third Petition Part 3 of 3. [EXHIBIT 991.]¬† The certified mail receipt is EXHIBIT 992.¬† WINDSOR also hand-delivered a copy to SENTRY; Richard accepted the envelope.
  • On June 7, 2019, Karen Chandler from Unit B4 wrote a letter with evidence that the Liebl‚Äôs dog in B2 was responsible for staining the carpets in Building B. [EXHIBIT 821.]¬† She gave the letter to WINDSOR, and he emailed it to the purported Board, SENTRY MANAGEMENT, and CLAYTON AND MCCULLOH.
  • On June 7, 2019, WINDSOR sent an email to the purported Board, SENTRY MANAGEMENT, and CLAYTON & MCCULLOH charging Breach of Fiduciary Duty. [EXHIBIT 823.]¬† The email says:

‚ÄúKaren Chandler in Unit B4 will speak to the Board and sign an affidavit stating that the Libels dog caused the carpet mess in Building B.¬† She has seen the dog do it.¬† She has seen Dorothy Libel with the dog when the dog did it.¬† Dorothy Libel has told Karen and Jason that the dog has “bladder issues.”

Karen cared for the dog when the Liebels were out of town, and the dog peed on the carpet at the top of the stairs.  Karen obviously observed this.

Just like the Old Board, the New Board is not requiring Dorothy Libel to clean the carpets, and this is imposing an expense on the owners that is wrongful.  23 spots have been documented with photos.

Have Libels pay, or I will sue.  Consider this Notice of Intent to file a Petition and sue.

ALSO, the Minutes of the ASSOCIATION establish that carpets have been replaced at various times.  Building B is the newest.  There is no reason to not stagger this work over the years.  It should be a budgeted Reserves item.  Building B simply needs the 23 spots of pee and poo cleaned.  Doing all buildings at one time hurts all owners.

Your approval of payments to CLAYTON AND MCCULLOH constitutes breach of fiduciary duty, in my opinion.

Your approval of fighting my first Petition also constitutes breach of fiduciary duty, in my opinion.  And if a letter from Monalene Werner magically appears after months of requests, I believe this constitutes fraud.  You better believe I will pursue that in court.

Thank you for establishing a rule yesterday that limits owners to three minutes per agenda item.  This helps enforce the fact that my rights and the rights of others were violated prior to this alleged Board enactment when CHARLIE ANN ALDRIDGE and OMAR NUSEIBEH claimed there was such a rule.  No such rule in the Rules or Minutes over the last 37 years.

  • On June 9, 2019, WINDSOR emailed attorney RUSSELL KLEMM (‚ÄúRUSSELL‚ÄĚ) of CLAYTON AND MCCULLOH, attorney BRIAN HESS, attorney NEAL MCCULLOH of CLAYTON AND MCCULLOH, and the ASSOCIATION asking them to withdraw the sham Motion to Dismiss for Failure to State a Cause of Action. [EXHIBIT 818.]
  • On June 9, 2019 at 9:54 a.m., WINDSOR emailed ISABEL CAMPBELL, SERGIO NAUMOFF, and ED BROOM advising them of his intent to sue them for breach of fiduciary duty. [EXHIBIT 819.]¬† The email said:

I intend to sue ISABEL CAMPBELL, SERGIO NAUMOFF, and ED BROOM for breach of fiduciary duty and other causes of action.  Please notify your insurance carrier, and ask the insurance folks to call me.

I will allege that you folks have failed¬†to¬†take the necessary actions¬†to¬†operate legally; you have spent money improperly; you are using dishonest attorneys and a dishonest management company and have been provided with massive proof.¬† You have presented false information¬†to¬†the owners about BYLAWS and special assessments.¬† You have concealed wrongdoing with Reserve funds.¬† You have failed¬†to¬†get the fraudulent BYLAW filing removed from Lake County Records.¬† You have¬†told owners that all work must be done at the same time so some owners don’t feel slighted.¬† That’s a load¬†of¬†you-know-what.¬† You have not enforced the letter sent several years ago¬†to¬†the Libels.¬† You have evidence that the Libels are guilty, but you want all owners¬†to¬†pay¬†to¬†clean it up.¬† You have not had the Libels “installation” removed, though they were ordered¬†to¬†do so years ago.¬† And more…

It took you 76 days to hold a meeting in which ISABEL CAMPBELL essentially recited information that I had prepared back in February.

Should a letter from Monalene Werner magically appear next week, I will also charge you with fraud.  If allowed by Florida law or federal law, I will charge you with criminal racketeering (RICO).

Please keep all emails and other communications safe as they will be evidence in the case.  Please do not delete anything.  I will seek a forensic audit of your electronic devices, if necessary.

The D&O Insurance carrier was not notified.  This email was also sent to BRAD POMP, ART SWANTON, and CHARLIE ANN ALDRIDGE with SENTRY MANAGEMENT and BRIAN HESS and NEAL MCCULLOH with CLAYTON AND MCCULLOH.

  1. On June 10, 2019, WINDSOR emailed the ASSOCIATION, ISABEL, SERGIO, and ED, SENTRY, and CLAYTON AND MCCULLOH advising them of his intent to petition for arbitration regarding failure to enforce the Rules. [EXHIBIT 875.]
  2. On June 11, 2019, WINDSOR sent an email to the owners, purported Board, SENTRY, and CLAYTON AND MCCULLOH.  WINDSOR said payables must be frozen so C&M will not be paid $80,000 in legal fees. [EXHIBIT 988.]
  3. On June 11, 2019, WINDSOR sent a Notice of Intent to File Petition for Arbitration regarding Violations of Corporate Documents, Rules, and Florida Statutes, purported Board, SENTRY, and CLAYTON AND MCCULLOH.  WINDSOR also mailed a copy to attorney BRIAN. [EXHIBIT 989.]
  4. On June 11, 2019, DBPR investigator Paula Bouie sent WINDSOR a letter about the Complaint he filed over failure to produce records for January 9, 2019, February 5, 2019, February 22, 2019, and February 27, 2019 in response to Inspection of Records Requests. [EXHIBIT 1014.]
  5. On June 13, 2019, a second Final Order of Dismissal (‚ÄúSECOND FINAL ORDER OF DISMISSAL‚ÄĚ) was filed in DBPR Case No. 2019-02-1020. [EXHIBIT 1008.]
  6. On June 14, 2019, SUE Yokley purchased Unit C3 from Medea Minnich.  She paid $48,000. [EXHIBIT 1426.]
  7. On June 17, 2019, the buyers of his Unit B3 condo canceled the purchase agreement.¬† They canceled because of the excessive monthly ‚Äúdues‚ÄĚ 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.]
  8. On June 17, 2019, WINDSOR sent an email to the ASSOCIATION demanding that the Building B carpets be cleaned. [EXHIBIT 1041.]
  9. On June 18, 2019, WINDSOR sent the ASSOCIATION an email stating that the potential buyers for his condo were repulsed by the carpets and the failure to have the Liebls clean the carpets undoubtedly contributed to the loss of a sale. [EXHIBIT 1156.]
  10. On June 18, 2019, the MOTION FOR REHEARING in DBPR Case No. 2019-02-1020 was executed, served, and sent to DBPR for filing. [EXHIBIT 1018.] 
  11. On June 18, 2019, the FOURTH AFFIDAVIT in DBPR Case No. 2019-02-1020 was executed, served, and sent to DBPR for filing. [EXHIBIT H.] 
  12. On June 18, 2019, the THIRD AFFIDAVIT in DBPR Case No. 2019-02-1020 was executed, served, and sent to DBPR by email. [EXHIBIT G.] 
  13. On June 18, 2019, PETITIONER’S RESPONSE TO RESPONDENT’S MOTION TO DISMISS AND MOTION TO STRIKE RESPONDENT’S MOTION TO DISMISS in DBPR Case No. 2019-02-1020 was executed, served, and sent to DBPR for filing. [EXHIBIT 1022.]

 

  1. 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 NAUMOFF and CHARLIE ANN ALDRIDGE OF SENTRY MANAGEMENT (shown above).¬† There was no discussion of quorum (0:00 to 0:42 in the video.)¬† CHARLIE ANN ALDRIDGE denied WINDSOR’s right to speak on the subject of ‚Äúreorganization of the Board.‚ÄĚ [EXHIBIT 1059 from 1:04 to 1:30.]¬† At 2:50, WINDSOR asked ‚Äúwhat about the eight open spots on the Board?‚Ä̬† 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.
  2. On June 21, 2019, WINDSOR sent a Notice of Intent to File Petition for Arbitration and/or a Lawsuit Regarding Violations of Corporate Documents, Rules, and Florida Statutes to BRIAN HESS of CLAYTON AND MCCULLOH. [EXHIBIT 1080.]  EXHIBIT 542 is the certified mail receipt.
  3. On June 21, 2019, the MOTION FOR REHEARING in Case No. 2019-02-1020 was executed, served, and sent to DBPR by mail. [EXHIBIT 1018.]  The Microsoft Word version of this filing is EXHIBIT 1019.  EXHIBIT 476 is the Certified Mail Receipt.
  4. On June 21, 2019, the FOURTH AFFIDAVIT in Case No. 2019-02-1020 was executed, served, and sent to DBPR by mail. [EXHIBIT H.]  The Microsoft Word version of this filing is EXHIBIT 1024.
  5. On June 21, 2019, the THIRD AFFIDAVIT in Case No. 2019-02-1020 was executed, served, and sent to DBPR by mail. [EXHIBIT G.]
  6. On June 21, 2019, PETITIONER’S RESPONSE TO RESPONDENT’S MOTION TO DISMISS AND MOTION TO STRIKE RESPONDENT’S MOTION TO DISMISS in Case No. 2019-02-1020 was executed, served, and sent to DBPR by mail. [EXHIBIT 1022.]  EXHIBIT 1037 is the certified mail receipt for the THIRD AFFIDAVIT, FOURTH AFFIDAVIT, PETITIONER’S RESPONSE TO RESPONDENT’S MOTION TO DISMISS AND MOTION TO STRIKE RESPONDENT’S MOTION TO DISMISS, and MOTION FOR REHEARING in DBPR Case No. 2019-02-1020 that was served on KLEMM.  [EXHIBIT 522 is the certified mail receipt.]
  7. On June 23, 2019, WINDSOR sent a Notice of Intent to Apply for Receivership to the ASSOCIATION. [EXHIBIT 569.]
  8. 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.
  9. On June 25, 2019, Ronell James of DBPR sent WINDSOR a letter saying the ASSOCIATION provided documentation to show his issue in Case No. 2019028466 was before federal court in Atlanta, Georgia. [EXHIBIT 1139.]  This is absolutely false, and WINDSOR suspects forgery.
  10. On June 25, 2019, WINDSOR served his Motion for Default and Motion for Fees and Costs in DBPR Case No. 2019-02-6384. [EXHIBIT 1186.]
  11. On June 27, 2019, WINDSOR received RESPONDENT’S MOTION TO DISMISS FOR FAILURE TO STATE A CAUSE OF ACTION in DBPR Case No. 2019-02-6834. [EXHIBIT 1042.]
  12. On June 28, 2019, WINDSOR sent a Motion for Leave to file Condominium Arbitration Complaints to the U.S. District Court for the Northern District of Georgia ‚Äď Case No. 1-11-CV-01923-TWT. [EXHIBIT 1202.]
  13. On June 29, 2019, WINDSOR paid Stanley Steemer $83.75 to clean the carpets in Building B. [EXHIBIT 1062.]
  14. 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, I asked ‚Äúwhat about the eight open spots on the Board?‚Ä̬† 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.
  15. On June 29, 2019, WINDSOR sent for filing his Response to Respondent’s Motion to Dismiss and Motion to Strike Respondent’s Motion to Dismiss in DBPR Case No. 2019-02-6834. [EXHIBIT 1089.]
  16. On June 29, 2019, WINDSOR sent the DBPR and RUSSELL KLEMM of CLAYTON and MCCULLOH an email with his Motion to Strike the Motion to Dismiss in DBPR Case No. 2019-02-6834. [EXHIBIT 1090.]

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