Windsor v. Coach Houses at Leesburg Condominium Lawsuit – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

emotional distress 300x159 - Windsor v. Coach Houses at Leesburg Condominium Lawsuit – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

COUNT NINE

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

  1. WILLIAM M. WINDSOR adopts and realleges Paragraphs 1 through 505.
  2. WINDSOR asserts this claim against all DEFENDANTS.
  3. 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.
  4. 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.
  5. 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.]
  6. 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.
  7. 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.
  8. 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.”
  9. 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.
  10. 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.
  11. 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.
  12. 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.]
  13. 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.
  14. 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.
  15. 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.
  16. 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.
  17. 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.
  18. 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.]
  19. 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.]
  20. 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.]
  21. 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,
  22. 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.
  23. After the meeting ended, WINDSOR spoke with
  24. 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.
  25. 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.
  26. 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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Windsor v. Coach Houses at Leesburg Condominium Lawsuit – 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:

I 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.”

  • 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’s 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:

“Karen 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 (“RUSSELL”) 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 (“SECOND FINAL ORDER OF DISMISSAL”) 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 “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.]
  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 “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 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 – 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 “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.
  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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