Windsor v. Coach Houses at Leesburg Condominium Lawsuit – PRAYER FOR RELIEF

Prayer for Relief

WHEREFORE, the PLAINTIFF, WILLIAM M. WINDSOR, demands judgment for damages against DEFENDANTS and for other such relief as may be just and equitable and otherwise deemed proper by the Court.  The PLAINTIFF asks the Court to order:

  1. that OMAR, VICKI, KAREN, SHEHNEELA, ISABEL, SERGIO, ED, MARTA, WENDY, HOWIE, and SUE have breached their fiduciary duty and caused damages to the Plaintiff;
  2. that the ASSOCIATION, Clayton & McCulloh DEFENDANTS, SENTRY DEFENDANTS, AND OMAR, VICKI, AND KAREN have committed fraud;
  3. that ISABEL, SERGIO, ED, SHEHNEELA, NEAL, DBPR, MARTA, WENDY, HOWIE, and SUE have participated in the fraud;
  4. that Clayton & McCulloh and the Clayton & McCulloh DEFENDANTS have committed malpractice;
  5. that SENTRY and the SENTRY DEFENDANTS have committed malpractice;
  6. that SENTRY and the SENTRY DEFENDANTS have committed breach of contract;
  7. that the ASSOCIATION has failed to operate according to the DECLARATION, ARTICLES OF INCORPORATION, BYLAWS, RULES, and FLORIDA STATUTES is breach of contract;
  8. that the ASSOCIATION has committed breach of contract by failing to keep common areas clean;
  9. that the ASSOCIATION, COACH HOUSES MEMBER DEFENDANTS, SENTRY DEFENDANTS, and Clayton & McCulloh DEFENDANTS have breached governing documents;
  10. that the DEFENDANTS have participated in a conspiracy;
  11. that the Clayton & McCulloh Defendants, the SENTRY DEFENDANTS, and the DBPR DEFENDANTS have committed professional negligence;
  12. that the ASSOCIATION, COACH HOUSES MEMBER DEFENDANTS, SENTRY DEFENDANTS, and Clayton & McCulloh DEFENDANTS have not properly conducted elections; have not given adequate notice of meetings or other actions; have not properly conducted meetings; have not properly allowed inspection of books and records; have violated dozens of laws, rules, BYLAWS, and statutes, and these violations must be legally identified through declaratory judgments;
  13. that the corporate charter of the ASSOCIATION should be revoked;
  14. that DEFENDANTS have intentionally and recklessly inflicted mental suffering and emotional distress on the Plaintiff;
  15. injunctive relief;
  16. an award of punitive damages to the Plaintiff;
  17. an award attorneys’ fees and costs to the Plaintiff; and
  18. such other relief as may be proper.

Dated in Leesburg, Florida this 24th day of November, 2020.

_______________________________
William M. Windsor

DEMAND FOR JURY TRIAL

Plaintiff, WILLIAM M. WINDSOR, demands a jury trial on all issues so triable of each and every one of the Counts set forth above.

RESPECTFULLY submitted and dated this 24th day of November, 2020,

_______________________________

William M. Windsor

100 East Oak Terrace Drive, Unit B3

Leesburg, Florida 34748 – 352-577-9988

billwindsor1@outlook.com – bill@billwindsor.com

VERIFICATION

Personally appeared before me, the undersigned Notary Public duly authorized to administer oaths, William M. Windsor, who after being duly sworn deposes and states that he is authorized to make this verification and that the facts alleged in the foregoing are true and correct based upon his personal knowledge, except as to the matters herein stated to be alleged on information and belief, and that as to those matters he believes them to be true.

I declare under penalty of perjury that the foregoing is true and correct based upon my personal knowledge.

This 24th day of November, 2020,

                                                                        ___________________________

                                                                        William M. Windsor

Sworn and subscribed before me this 24th day of November, 2020, by means of physical presence.

____________________________

Notary Public

CERTIFICATE OF SERVICE

I hereby certify that I have served a true and correct copy of the foregoing by Electronic Mail:

Vicki Hedrick, Karen Bollinger, Shehneela Arshi, Ed Broom, Jr., Marta Carbajo, Sue Yokley, Wendy Krauss, Howard Solow, Omar Nuseibeh, Isabel Campbell, Sergio Naumoff,

Coach Houses at Leesburg Condominium Association, Inc., Sentry Management, Inc., Art Swanton, Charlie Ann Aldridge, and Brad Pomp:

c/o Christina Bredahl Gierke

COLE, SCOTT & KISSANE, P.A.

Counsel for Board Member Defendants

Tower Place, Suite 400, 1900 Summit Tower Boulevard, Orlando, Florida 32810

Telephone 321-972-0025, Facsimile 321-972-0099

christina.gierke@csklegal.com

victoria.mcfarland@csklegal.com, kirbie.caruso@csklegal.com

Clayton & McCulloh, P.A., Brian Hess, Neal McCulloh, Russell Klemm:

c/o Maura F. Krause

GOLDBERG SEGALLA, LLP

800 N. Magnolia Ave., Suite 450, Orlando, FL 32803

407-458-5600

mkrause@goldbergsegalla.com, jkovecses@goldbergsegalla.com

sherndon@goldbergsegalla.com, psouza@goldbergsegalla.com

Florida Department of Business and Professional Regulation, Mahlon C. Rhaney, Leah Simms:

c/o David Asti

Office of the Attorney General

501 E. Kennedy Blvd., Suite 1100, Tampa, Florida 33602-5242

Telephone: 813-233-2880, Facsimile: 813-233-2886

David.Asti@MyFloridaLegal.com

Wendy.Estevez@MyFloridaLegal.com

Christina.Santacroce@MyFloridaLegal.com

This 30th day of November, 2020.

_______________________________
William M. Windsor

 

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