IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL DISTRICT
IN AND FOR LAKE COUNTY, FLORIDA
William M. Windsor,
Plaintiff,
Case No. 35-2020-CA-001438
vs.
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,
Defendants.
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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.
Statement of Facts:
CAUSES OF ACTION
COUNT ONE — BREACH OF FIDUCIARY DUTY
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 EIGHT — PROFESSIONAL NEGLIGENCE
COUNT NINE — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS