Windsor v. Coach Houses at Leesburg Condominium Lawsuit – FACTS – SEPTEMBER 2020

  1. On September 2, 2020, WINDSOR filed a Second Motion to Strike and Motion for Sanctions in Case No. 35-2019-CA-001528. [EXHIBIT 1678.]
  2. On September 4, 2020, WINDSOR filed a Notice of Filing Federal Court Order in Case No. 35-2019-CA-001871. [EXHIBIT 1745.]
  3. On March 24, 2020, WINDSOR served a Request for Production in Case No. 35-2019-CA-001528. [EXHIBIT 1710.]
  4. On September 4, 2020, WINDSOR filed a Complaint in the Fifth Judicial Circuit in Lake County, Florida.  It was assigned Case No. 35-2020-001438. [EXHIBIT 1660.]  [EXHIBIT 1856 is the full file on Case No. 2020-CA-001438.]
  5. On September 4, 2020, WINDSOR filed a First Amended Complaint in Case No. 35-2020-001438 in the Fifth Judicial Circuit in Lake County, Florida. [EXHIBIT 1659.]
  6. On September 4, 2020, WINDSOR filed a Third Motion to Strike the Motion to Dismiss in Case No. 35-2020-001438. [EXHIBIT 1713.]
  7. On September 4, 2020, WINDSOR filed a Notice of Filing Federal Court Order in Case No. 35-2019-CA-001528. [EXHIBIT 1723.]
  8. On September 4, 2020, WINDSOR filed a Motion to Strike in Case No. 35-2019-CA-001871. [EXHIBIT 1746.]
  9. On September 6, 2020, WINDSOR mailed a complaint to the Florida Department of State seeking to have the ASSOCIATION’s charter revoked. [EXHIBIT 1799.]
  10. On September 6, 2020, WINDSOR emailed all of the owners of the ASSOCIATION; BRAD, Debra Zimmerman, Katie Ciccotelli, CHARLIE ANN, and ART with SENTRY; NEAL, RUSSELL, and BRIAN with CLAYTON & MCCULLOH; and DBPR. [EXHIBIT 1798.]  WINDSOR enclosed a copy of his letter to the Secretary of State.  Windsor wrote: “I demand that Russell Klemm cease pretending to represent the ASSOCIATION in legal matters in Lake County or with the DBPR.  He has no authority, and he just lies all the time.”  He enclosed his letter seeking to have the corporate charter revoked.  WINDSOR also said: “Please do not pay any money to Sentry or CLAYTON & MCCULLOH until this is resolved.  I will consider so to be a breach of fiduciary duty.”
  11. On September 6, 2020, WINDSOR filed an Amended Third Motion to Strike the Motion to Dismiss in Case No. 35-2020-001438. [EXHIBIT 1714.]
  12. On September 6, 2020, WINDSOR filed an Amended Third Motion to Strike Defendant’s Motions to Dismiss; Plaintiff’s Motion for Sanctions; and Plaintiff’s Motion to Disqualify Russell E. Klemm in Case No. 35-2019-CA-001871. [EXHIBIT 1746.]
  13. On September 11, 2020, the Court issued an Order in Case No. 35-2019-CA-001528. [EXHIBIT 1707.]  The Motion to Dismiss was denied, but the Motion for More Definitive Statement was Granted.
  14. On September 11, 2020, WINDSOR filed Notices of Filing Exhibits – Parts 1 to 5 in Case No. 35-2019-CA-001528. [EXHIBIT 1695.] [EXHIBIT 1696.] [EXHIBIT 1697.] [EXHIBIT 1698.] [EXHIBIT 1699.]
  15. On September 11, 2020, WINDSOR filed a Second Amended Complaint in Case No. 35-2019-CA-001528. [EXHIBIT 1700.]
  16. On September 14, 2020, RUSSELL Klemm filed a Motion for Protective Order for the ASSOCIATION in Case No. 35-2019-CA-001871. [EXHIBIT 1750.]
  17. On September 14, 2020, RUSSELL Klemm filed a Response to Request for Production for the ASSOCIATION in Case No. 35-2019-CA-001871. [EXHIBIT 1751.]
  18. On September 18, 2020, a Memorandum of Law and Request for Judicial Notice was filed in Case No. 35-2019-CA-001871. [EXHIBIT 1753.]
  19. On September 18, 2020, WINDSOR filed a Motion for Summary Judgment in Case No. 35-2019-CA-001871. [EXHIBIT 1754.] EXHIBIT A is his Affidavit in Support of Motion for Summary Judgment. [EXHIBIT 1755.] [EXHIBIT 1756.] [EXHIBIT 1757.] [EXHIBIT 1758.] [EXHIBIT 1759.] [EXHIBIT 1760.] [EXHIBIT 1761.] [EXHIBIT 1762.] [EXHIBIT 1763.] [EXHIBIT 1764.] [EXHIBIT 1765.] [EXHIBIT 1766.]  EXHIBIT B is the Verified Affidavit of William M. Windsor dated September 18, 2020. [EXHIBIT 1767.] [EXHIBIT 1768.] [EXHIBIT 1769.] [EXHIBIT 1770.] [EXHIBIT 1771.]
  20. On September 23, 2020, WINDSOR filed a Motion for Summary Judgment in Case No. 35-2019-CA-001528. [EXHIBIT 1679.]
  21. On September 23, 2020, WINDSOR filed an Affidavit in Support of Motion for Summary Judgment in Case No. 35-2019-CA-001528. [EXHIBIT 1680.]

Click here for links to the entire lawsuit, by section