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

  1. On March 1, 2019, WINDSOR sent an email to OMAR, VICKI, and KAREN, the attorneys with CLAYTON & MCCULLOH, and CHARLIE ANN, BRAD and ART at SENTRY. [EXHIBIT 238.]   WINDSOR advised them that the ASSOCIATION was not operating legally because of the name.  Paragraph 1 of the DECLARATION says “The name by which this condominium is to be identified is COACH HOUSES AT LEESBURG.”  This violates Florida statute 718.104 (4) (b) requires that “the name by which the condominium property is to be identified, which shall include the word ‘condominium’ or be followed by the words ‘a condominium.’”  WINDSOR also noted that the ASSOCIATION only has 16 voting members according to the DECLARATION 13.3.  WINDSOR again demanded that OMAR, VICKI, and KAREN cease pretending to be the officers and directors.  There was no response.
  2. On March 1, 2019, ART of SENTRY, emailed in response to WINDSOR’s email to say the issues would be reviewed by the association’s attorney. [EXHIBIT 239.]  There was no response from the ASSOCIATION or the CLAYTON & MCCULLOH DEFENDANTS.
  3. On March 2, 2019, WINDSOR sent an email to OMAR, VICKI, and KAREN; BRIAN with CLAYTON & MCCULLOH; and BRAD, ART, and CHARLIE ANN at SENTRY. [EXHIBIT 252.]   WINDSOR expressed that he did not consider the announced March 22, 2019 meeting to be a valid meeting of the ASSOCIATION.
  4. On March 5, 2019, a so-called “Town Hall Meeting” was held. [EXHIBIT 281.]  WINDSOR considered it to be an effort by CLAYTON & 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. 
  5. On March 5, 2019, NEAL McCulloh of CLAYTON & MCCULLOH distributed a letter to the owners of the ASSOCIATION. [EXHIBIT 267.]  In the second paragraph on page 1, NEAL claims the actions taken on December 12, 2018 were at his firm’s direction.  I believe 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.  This has been documented above.  In the first full paragraph on page 2, NEAL falsely claims individuals were recommending self-management and elimination of professional services.  I believe this is false and malicious.  In that paragraph, NEAL 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.
  6. After the meeting ended, WINDSOR spoke with NEAL and suggested a meeting to discuss and attempt to resolve the issues.  WINDSOR expressed that this would be far less expensive to the owners.  NEAL refused.  He told WINDSOR to handle it through legal filings.
  7. On March 5, 2019, Dorothy Liebl of B2 told people in attendance that WINDSOR had harassed her.  [EXHIBIT 282-1, EXHIBIT 282-2, EXHIBIT 282-3, EXHIBIT 282-4, EXHIBIT 282-5, EXHIBIT 282-6, EXHIBIT 282-7, EXHIBIT 282-8, EXHIBIT 282-9.]  This was slander.
  8. Unknown to WINDSOR until several weeks later when he called the police to see if anything had been filed against him, WINDSOR learned that on March 14, 2019. Dorothy Liebl in Unit B2 tried to get the police to arrest him for the crimes of harassment and threats. [EXHIBIT 417.]  This was an absolute outrage.  This is a false police report that is a violation of Florida law.  Dorothy Liebl is a major supporter of OMAR, VICKI, and KAREN.  The police never contacted WINDSOR.
  9. On March 14, 2019, WINDSOR emailed OMAR, VICKI, and KAREN, CHARLIE ANN and ART of SENTRY, and BRIAN of CLAYTON & MCCULLOH saying they had failed to respond to him on the ability of Donna Dailey and Donna *** to vote.  WINDSOR asked them to confirm how much Donna Hey allegedly owed as he would pay it so she could vote. [EXHIBIT 292.]  They never responded to this Request for Inspection of Records.  WINDSOR had offered to loan the money to Donna ***.  She was scared that she would lose her home in foreclosure and become homeless.
  10. On March 15, 2019, the ASSOCIATION sent a Notice of Intent to Foreclose to Donna ***, Unit H2. [EXHIBIT 426.]  The Notice appears to have added approximately $1,700 in legal fees.  Donna *** has provided records to me to show that she was not past due.  This foreclosure notice was sent a week before the purported election of March 22, 2019 at which Donna *** was a candidate seeking to replace OMAR, VICKI, and KAREN.  PLEASE NOTE the letter that starts EXHIBIT 426 was not mailed, but it accurately summarizes the financial situation.
  11. On March 15, 2019, Nancy Camp of Unit C2 sent a letter to SENTRY enclosing a Quit Claim deed and an Affidavit of Trust.  She wrote: “I feel I was bullied by the board into transferring the subject property out of my parents trust into our individual interest.” [EXHIBIT 425.]
  12. On March 20, 2019, WINDSOR sent an email to OMAR, VICKI, and KAREN; CHARLIE AND, ART, and BRAD of SENTRY; and BRIAN of CLAYTON & MCCULLOH objecting to the apparent plan to appoint a chairman of the purported March 22, 2019 members’ meeting rather than elect the chairman. [EXHIBIT 257.]  WINDSOR’s email was ignored.
  13. On March 20, 2019, a Lake County Sheriff’s Deputy appeared at WINDSOR’s door and served him with an Order setting a hearing on a Petition for Injunction against Stalking that was sworn to by Dorothy Liebl in Unit B2. [EXHIBIT 416.]  This was an absolute outrage.  Her sworn affidavit is filled with perjury.  WINDSOR never stalked her, harassed her, threatened her, or did anything to her.  For much of the next 13 days, WINDSOR prepared for the April 2, 2019 trial.
  14. On March 21, 2019, WINDSOR sent a letter to OMAR, VICKI, KAREN, CHARLIE ANN of SENTRY, and BRIAN of CLAYTON & MCCULLOH objecting to the apparent plan to appoint a chairman of the purported March 22, 2019 members’ meeting rather than elect the chairman. [EXHIBIT 258.]  His letter was ignored.
  15. A purported March 22, 2019 meeting was purported to include the annual election for the ASSOCIATION, but that date is based on fraud by claiming an amendment changed the date in August 2017.
  16. On March 22, 2019, purported meetings and a purported election were held.  EXHIBIT 311 is video from the meetings (EXHIBIT 311-1, EXHIBIT 311-2, EXHIBIT 311-3, EXHIBIT 311-4, EXHIBIT 311-5, and EXHIBIT 311-6).  No minutes were published for the purported meeting.
  17. There were 30 Outer Envelopes and 13 were invalid.  The Outer Envelopes are supposed to show the name of the Owners on the first line and be signed by the valid Designated Voter.  13 had problems with one or both of these requirements.
  18. There were 13 Designated Voter Certificates produced, and 6 were invalid.  The Designated Voter Certificate for Meade/Chandler was not produced, but it was delivered to SENTRY before the meeting began on March 22, 2019. [EXHIBIT 158.]  It is valid.
  19. There were 19 Proxy forms presented, and 4 were invalid.
  20. There were 24 Limited Proxy forms presented, and 5 were invalid.
  21. With exclusion of any of the votes that WINDSOR says are invalid, Denise King and WINDSOR would have been elected.
  22. At the March 22, 2019 meetings, BRIAN of CLAYTON & MCCULLOH refused to allow WINDSOR to see the Designated Voter Certificates, and the Election Monitor told him that those were not in his possession and were not part of his duties.  WINDSOR told them both that he had evidence that several of the voters did not have valid Designated Voter Certificates.  WINDSOR was told he would have to appeal.  WINDSOR had the evidence with him that A4 and B2 did not qualify.  He also had evidence with him that B1 and F3 likely didn’t qualify and evidence that E3 and G4 might fail to qualify.
  23. On March 22, 2019, Joseph L. Lunsford submitted a request to inspect all of the voting documents from March 22, 2019.  WINDSOR went with him on April 8, 2019, and they copied every document. [EXHIBIT 159.]
  24. OMAR, VICKI, and KAREN hired an armed policeman, Officer Pincus, to attend the March 22, 2019 meetings, and they paid BRIAN of CLAYTON & MCCULLOH, $1,100 to be there.  WINDSOR believes the police have been hired for show to support the defamatory claims that he threatened to kill purported Board members.  They know there is absolutely no truth to this, so there is no other logical explanation for such bizarre behavior.  At 12:20 into EXHIBIT 142-C, OMAR said the police were there because of threats to the Board.
  25. Jason Chandler and WINDSOR videoed most of the March 22, 2019 meetings until his battery died. [EXHIBIT 142-A, EXHIBIT 142-B, EXHIBIT 142-C, EXHIBIT 142-D, EXHIBIT 142-E, EXHIBIT 142-F.]
  26. CLAYTON & MCCULLOH, SENTRY, and those purporting to be the Board violated the BYLAWS by allowing Omar Nuseibeh to appoint himself to be the chairman of the meetings.  BYLAW 2.9 b. provides that the chairman is to be elected by a vote.  The Notice of the Meeting posted on the Bulletin Boards at Coach Houses said there would be an election. [EXHIBIT 241.]  Then the Notice was changed to delete the word “Election” and change it to “Appointment.” [EXHIBIT 242.]  WINDSOR raised the issue at 4:40 into EXHIBIT 142-A, and he was told the purported Board had decided who would be chairman.  WINDSOR believes this was done to block his access to the Designated Voter Certificates.
  27. OMAR spoke negatively about WINDSOR much of the time on March 22, 2019, and he got into arguments with several others seeking to have him removed from the Board.
  28. OMAR, VICKI, and KAREN did not have legal authority to schedule or conduct the meetings.
  29. CHARLIE ANN claimed all ASSOCIATION documents had been produced.  She said there was nothing else to produce, but that proved to be absolutely false on June 23, 2019 when some August 1, 2017 records were produced.  There is still a great deal that has not been produced.  She said the August 2017 Baywood Condominiums minutes that were produced was an error. [EXHIBIT 142-D @ 2:00 into the video.]  She never corrected this “error.”
  30. The purported March 22, 2019 election was invalid as it was not held on the first Tuesday in August.  It was called by people with no legal authority.  Only three members had complied with BYLAW 2.1.  BYLAW 2.9 b was violated.  Fraudulent information was provided to the Election Monitor.
  31. On March 25, 2019, WINDSOR sent a letter to SHEHNEELA of the ASSOCIATION requesting an Inspection of Records that had never been produced. [EXHIBIT 243.]
  32. On March 25, 2019, WINDSOR sent an email and evidence to the purported New Board (including COACH HOUSE MEMBER DEFENDANTS SHEHNEELA, ISABEL, SERGIO) identifying wrongdoing on March 22, 2019. [EXHIBIT 352.]  There was no response.
  33. On March 26, 2019, WINDSOR received an email from SHEHNEELA, the purported New Board President, claiming that SENTRY had ALL of the ASSOCIATION’s records. [EXHIBIT 301.]
  34. On March 26, 2019 at 11:59 am, the ASSOCIATION manager, CHARLIE ANN, stated that all of the records of the ASSOCIATION were being produced for WINDSOR at an Inspection of Records on March 27, 2019.  CHARLIE ANN also claimed WINDSOR had been provided every document within the possession of SENTRY on multiple occasions.  In a separate email at 8:39 am, she stated that Sentry had all of the ASSOCIATION’S documents.  She lied.  WINDSOR was never provided all the documents, and they most definitely were not provided on March 27, 20-19. [EXHIBIT 49.]  CHARLIE ANN knew she was continuing to conceal these records from WINDSOR.
  35. On March 26, 2019, WINDSOR sent an email to the purported New Board (SHEHNEELA, ISABEL, SERGIO), CHARLIE ANN of SENTRY, and BRIAN of C&M in response to an email from the purported New Board President, Shehneela Arshi, confirming that all of the ASSOCIATION’S documents were in the possession of SENTRY. [EXHIBIT 296.]  This was very important because it meant that key documents did not exist – no letter from Monalene Werner and no documentation that OMAR, VICKI, and KAREN were ever lawfully elected.  WINDSOR also sent an Inspection of Records Request for emails. [EXHIBIT 298.]
  36. On March 27, 2019, WINDSOR inspected records at SENTRY for eight hours. [EXHIBIT 326 – 1 to 17 are photos of the Inspection.]  EXHIBIT 326-4 shows the August 2017 minutes of Baywood Condominiums that were produced as the August 2017 minutes for the ASSOCIATION.  EXHIBIT 329 contains the files produced for Inspection on the laptop.  [EXHIBIT 1220.]
  37. WINDSOR has been ignored on many requests for inspection of records.  WINDSOR filed two Complaints with the Division of Condominiums. [EXHIBIT 54.] [EXHIBIT 55.]  WINDSOR finally filed a Petition for Arbitration over all Inspection of Records issues. [EXHIBIT 1190.]
  38. On March 28, 2019, WINDSOR sent an email to ART and CHARLIE ANN of SENTRY, BRIAN of C&M, and SHEHNEELA complaining of malpractice over the failure to schedule and conduct an April 4, 2019 meeting. [EXHIBIT 368.]  They did nothing.
  39. On March 28, 2019, WINDSOR sent two emails to the purported New Board (including SHEHNEELA, ISABEL, ED, SERGIO, OMAR) and BRIAN of CLAYTON & MCCULLOH objecting to the fraud in the purported March 22, 2019 election.  WINDSOR gave notice that he would file a petition if not resolved.  He provided some proof of the fraud. [EXHIBIT 255.]
  40. On March 28, 2019, WINDSOR sent a letter to the purported New Board (including SHEHNEELA, ISABEL, ED, SERGIO, OMAR), ART and CHARLIE ANN of SENTRY, and BRIAN of CLAYTON & MCCULLOH objecting to the failure to hold the April 4, 2019 meeting. [EXHIBIT 256.]
  41. On March 29, 2019, WINDSOR emailed the purported New President, SHEHNEELA, with issues about the fraudulent March 22, 2019 meetings. [EXHIBIT 398.]

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