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Russell E. Klemm

I’m William M. Windsor. I have had the distinct unpleasure of dealing with Russell E. Klemm of Clayton & McCulloh law firm. The following is a statement of my opinions that I made to the Florida Bar Association under penalty of perjury.

Florida Bar Complaint Against Russell E. Klemm

Part Three – Facts/ Allegations

  1. The main motivating factor for filing this Bar Complaint today is the perjury and forgery by RUSSELL E. KLEMM. (See Paragraphs 11 to 21.)  I believe he should also be investigated for perjury and conspiracy.
  2. On April 1, 2015, the law firm of Clayton & McCulloh began representing Coach Houses at Leesburg Condominium Association, Inc. (“ASSOCIATION”).
  3. On September 27, 2017, I purchased a condo at Coach Houses and became a member of the ASSOCIATION.  My monthly assessments were $300.  I am almost 73-years old, disabled, and my sole source of income is social security retirement payments.
  4. In December 2018, the purported Board of the ASSOCIATION voted to increase my assessments to $962.38.  I was OUTRAGED.  I sensed significant wrongdoing.  I began inspecting the records of the ASSOCIATION and reading the applicable Florida Statutes.  Over the next year, I discovered several hundred violations of the ASSOCIATION’S governing documents and Florida law.  Russell E. Klemm (“KLEMM”) was one of the main attorneys advising the ASSOCIATION to commit these violations.  I believe this may be the largest case of malpractice in Florida history.
  5. On January 15, 2019, a fraudulent ASSOCIATION BYLAW Amendment was filed in Lake County by Clayton & McCulloh.  It is a complete, total fraud that Russell E. Klemm has told ASSOCIATION members is valid.  All of the Records produced by the ASSOCIATION prove it is a fraud.
  6. I tried every way possible to get the ASSOCIATION to operate lawfully, but all of my efforts were fought.  When the ASSOCIATION and Clayton & McCulloh wouldn’t do anything or even respond to the violations I identified, I filed Petitions for Mandatory Non-Binding Arbitration. [DBPR Case #’s 2019-02-1020, 2019-02-6834, 2019-04-7339, and 2019-05-3927.]  KLEMM committed significant malpractice in responding to these Petitions.
  7. I think it’s possible that Russell E. Klemm [improperly arranged for] the arbitrators to rule against me because their actions were absolutely improper.
  8. I had to file Trial De Novo Appeals of the outrageous arbitration “decisions.”  These created Lake County Case #’s 2019-CA-1528, 2019-CA-1871, and 2020-CA-1647.  Russell E. Klemm has represented the ASSOCIATION in 2019-CA-1528 and 2019-CA-1871, and he has committed all types of wrongdoing.
  9. The ASSOCIATION has been charged over $250,000 (with another $50,000 budgeted for 2021) by Russell E. Klemm and Clayton & McCulloh to fight my efforts to get the ASSOCIATION to operate lawfully.  No one in their right mind would spend that kind of money unless they had something BIG to try to hide.  The ASSOCIATION has only 32 units valued at approximately $60,000 each, so the value of 5 units will be spent by year end.
  10. I have filed two derivative actions for malpractice that tell most of the story of the malpractice by Russell E. Klemm.  Lake County Case #’s 2020-CA-1438 and 2021-CA-0766.
  11. On 3/16/2021, the ASSOCIATION filed a MOTION FOR AWARD OF TAXABLE COSTS AND ATTORNEY’S FEES [DOCKET 234] in 2019-CA-1871.
  12. On 3/16/2021, the ASSOCIATION filed Notice of Filing of Affidavit of Defendant’s Attorney Regarding Fees and Costs in 2019-CA-1871.  It is unsigned. [DOCKET 235.]
  13. On 3/19/2021, the ASSOCIATION filed Notice of Filing of Amended Affidavit of Defendant’s Attorney Regarding Fees and Costs in 2019-CA-1871.  It is unsigned. [DOCKET 237.]
  14. A signature is not optional.  Rule 2.515 of the Florida Rules of Judicial Administration dictates the requirement.
  15. The purported Summary of Legal Services filed in DOCKET 235 and referenced in DOCKET 237 in 2019-CA-1871, which was purported to come from the Clayton & McCulloh Billing Records, are forged.
  16. Approximately 500 pages of Clayton & McCulloh Billing Records were produced at DBPR Inspections of Records on 2/22/2021 and 4/6/2021.  (These and everything that has ever happened are available in scanned pdfs.)  Not a single one of the entries shown on the 3/11/2021 Affidavit Schedule “1” matches the same date entries on EXHIBITS 2811 and 2924 (the Billing Records produced at Inspections of Records exceed the Bar’s Complaint page limit).  The ASSOCIATION’S expert witness, Joseph C. Stayanoff, testified under oath on 6/28/2021 that he never saw the Billing Records that were produced at DBPR Inspections of Records.
  17. Paragraph 3 of the Russell E. Klemm Affidavit [DOCKET 235 and DOCKET 237] claims there is an agreement between Clayton & McCulloh and the ASSOCIATION.  The expert witness, Joseph C. Stayanoff, testified that he reviewed this document.  He identified Omar Nuseibeh as the signatory for the ASSOCIATION.  He could not verify that he was authorized to sign.  The Complaints and Affidavits in 2019-CA-1871 provide uncontested proof that Omar Nuseibeh was not authorized to sign.  Stayanoff testified that he did not review the Complaint in the case.
  18. Paragraphs 3, 4, 5, and 8 of the Affidavit of Joseph C. Stayanoff claimed he had reviewed the entire Clayton & McCulloh file and the invoices.”  But he did not.  He reviewed only [what I believe is] a forged document claiming to be a 03/11/2021 computer-generated document [EXHIBITS 2811 and 2924 exceed the Bar’s Complaint page limit].
  19. The Affidavit as to Reasonable Attorney’s Fees signed under oath before a notary by Joseph C. Stayanoff attached to the 3/6/2021 Notice of Filing [DOCKET 235] is not true and correct because Russell E. Klemm gave him [what I believe is] a forged document to review.
  20. The Affidavits signed by Russell E. Klemm [DOCKET 235 and DOCKET 237] were signed under oath before a notary.  They are not true and correct and the Schedule “1” is [what I believe is] a forged document.  [I believe] Russell E. Klemm has committed perjury.
  21. The MOTION FOR AWARD OF TAXABLE COSTS AND ATTORNEY’S FEES [DOCKET 234] was unsigned, unverified, and is false.
  22. RUSSELL E. KLEMM must be referred to the State Attorney pursuant to s. 837.06, F.S.: “whoever knowingly makes a false statement in writing with the intent to mislead a public servant in the performance of his official duty shall be guilty of a misdemeanor of the second degree, punishable as provided in s.775.082 or s.775.038, F.S.”  I have dozens of false statements made in writing by Russell E. Klemm.
  23. There has never been any evidence presented in any case to authorize Russell E. Klemm to appear on behalf of the ASSOCIATION.  There has not even been an officer or director of the ASSOCIATION who could authorize.
  24. Violation of FRPC Rule 4-1.1; Russell E. Klemm does not have the requisite knowledge and skill to deal with these  cases.
  25. Violation of FRPC Rule 4-1.1; Russell E. Klemm has proven to be incompetent in handling these matters.
  26. Violation of FRPC Rule 4-1.2 (d); Russell E. Klemm has counseled the ASSOCIATION to engage in conduct that KLEMM knew or reasonably should know is criminal or fraudulent.
  27. Violation of FRPC Rule 4-1.3; Russell E. Klemm has not acted with reasonable diligence.
  28. Violation of FRPC Rule 4-1.4 (a) (5); Russell E. Klemm had a duty to inform the ASSOCIATION that his actions in filing motions to dismiss were not permitted by the FRPC.
  29. Violation of FRPC Rule 4-1.4 (5) (a) (2); Russell E. Klemm did not reasonably consult with the ASSOCIATION about the means he was using.  The ASSOCIATION could not have sufficient information to participate intelligently concerning the objectives of the representation and the means by which they are to be pursued.
  30. Violation of FRPC Rule 4-1.13; Russell E. Klemm failed to recognize me, a shareholder in the ASSOCIATION, as a client. I have been denied records, the opportunity to meet to attempt to resolve issues before petitions had to be filed, and more.
  31. Violation of FRPC Rule 4-2.1; Russell E. Klemm did not render competent advice to the
  32. ASSOCIATION, and Russell E. Klemm certainly did not consider the moral and economic implications to the ASSOCIATION of his actions.
  33. Violation of FRPC Rule 4-3.1; Russell E. Klemm filed motions without a hint of a meritorious contention.
  34. Violation of FRPC Rule 4-3.1; Russell E. Klemm has abused legal procedure.
  35. Violation of FRPC Rule 4-3.2; Russell E. Klemm has done nothing to expedite litigation consistent with the interests of the ASSOCIATION.
  36. Violation of FRPC Rule 4-3.3 (a) (1); Russell E. Klemm made false statements of fact to the Arbitrators and to the judges and has failed to correct false statements made to the Arbitrators and judges.
  37. Violation of FRPC Rule 4-3.3 (a) (2); Russell E. Klemm has made false statements of fact to the Arbitrators and judges to assist fraudulent acts by the ASSOCIATION.
  38. Violation of FRPC Rule 4-3.3 (a) (3); Russell E. Klemm failed to disclose legal authority he has cited was adverse to the position of the ASSOCIATION and that there is no legal authority to support his motions.
  39. Violation of FRPC Rule 4-3.3 (a) (4); Russell E. Klemm has offered evidence that he knows to be false.
  • Violation of FRPC Rule 4-3.3 (b); KLEMM knows that the ASSOCIATION has engaged in fraudulent conduct related to the proceeding by failing to admit the fraud in the alleged BYLAW amendment.
  • Violation of FRPC Rule 4-3.3; KLEMM has made a huge number of assertions to the Arbitrator and Judges that are not on his own knowledge and has never presented an authenticated exhibit. 
  • Violation of FRPC Rule 4-3.3; KLEMM has made legal arguments that are knowingly false representations of the law. This constitutes dishonesty toward the tribunal. KLEMM undoubtedly has directly adverse authority that has not been disclosed.
  • Violation of FRPC Rule 4-3.4; KLEMM has obstructed the PETITIONER’s access to evidence.
  • Violation of FRPC Rule 4-3.4; KLEMM has intentionally failed to comply with legally proper Requests for Inspection of Records. Upon information and belief, evidence has been falsified, which is a criminal offense.
  • Violation of FRPC Rule 4-3.5; KLEMM has sought to influence, and has influenced, the Arbitrator and Judges by raising false claims of vexatious actions. KLEMM has presented false purported evidence and has made legal arguments that are not the law. KLEMM has perverted the arbitration process.
  • Violation of FRPC Rule 4-8.4 (a); KLEMM has violated the FRPC.
  • Violation of FRPC Rule 4-8.4 (b); KLEMM has committed criminal acts by repeatedly making statements in filings that he knew were false.  Florida caselaw prohibits lawyers from presenting false testimony or evidence.
  • Violation of FRPC Rule 4-8.4 (c), KLEMM has engaged in conduct involving dishonesty, fraud, deceit, and misrepresentation.
  • Violation of FRPC Rule 4-8.4 (d); KLEMM has engaged in conduct that is prejudicial to the administration of justice.
  • Klemm has committed negligence, malpractice, and breaches of fiduciary duties to the ASSOCIATION, including in the following regard:
  • By maintaining a fraudulent BYLAW Amendment filed on January 15, 2019 in Lake County, Florida;
  • By falsely and maliciously claiming the BYLAW regarding the annual meeting was amended on August 1, 2017 (as proven by the ASSOCIATION’s Records) and by having the ASSOCIATION act as if the BYLAW was amended;
  • By failing to explain the law to the ASSOCIATION;
  • By failing to explain the terms of the ARTICLES OF INCORPORATION, DECLARATION, and BYLAWS and the impact to the ASSOCIATION;
  • By failing to ensure that the ASSOCIATION held lawful annual meetings and elections;
  • By concocting schemes to keep OMAR Nuseibeh, VICKI Hedrick, and KAREN Bollinger as the Officers and Directors as part of an effort to conceal legal malpractice;
  • By providing false legal information to ASSOCIATION owners, including me;
  • By running up legal fees in various ways, including refusing to meet with me to resolve matters; by failing to notify the D&O insurance carrier of litigation so insurance would have covered the litigation costs; by ignoring at least 24 notices sent by me in an effort to avoid further litigation; by encouraging me to sue rather than agree to meet to try to resolve issues; by stalling in a variety of ways rather than address the legal issues efficiently; by pretending the BYLAWS were amended when he knew approval of all holders of first mortgage liens were required; by failing to accept my offer to withdraw my actions against the ASSOCIATION if Clayton & McCulloh and SENTRY MANAGEMENT refunded to the ASSOCIATION all money paid by to them from 2016 to 2019; and by failing to accept my offer to withdraw my actions against the ASSOCIATION if the ASSOCIATION admitted and corrected all the wrongdoing;
  • By allowing the ASSOCIATION to charge exorbitant amounts for filing a Notice of Lien;
  • By allowing the ASSOCIATION to violate the Fair Credit Collection Act;
  • By allowing the ASSOCIATION to violate Florida Administrative Code Section 61B-23.002 (6) regarding Designated Voter Certificates;
  • By allowing the ASSOCIATION to violate Florida Administrative Code 61B-23.002 (8) regarding proxies;
  • By allowing the ASSOCIATION to violate Florida Administrative Code 61B-23.002 (9) by denying members the right to speak at meetings with respect to all designated agenda items;
  • By allowing the ASSOCIATION to violate Florida Administrative Code Section 61B-23.0021 (4) by failing to give proper notice of elections;
  • By allowing the ASSOCIATION to violate Florida Administrative Code Section 61B-23.0021 (8) by failing to give proper notice of elections;
  • By allowing the ASSOCIATION to violate Florida Administrative Code Section 61B-23.0021 (8) by failing to enforce the envelope procedure required at the purported March 22, 2019 election;
  • By allowing the ASSOCIATION to violate Florida Administrative Code Section 61B-23.001 (1) (d) by failing to notify owners of unfilled board positions;
  • By allowing the ASSOCIATION to violate Florida Administrative Code Section 61B-23.0021 (8) by failing to notify owners of unfilled board positions;
  • By allowing the ASSOCIATION to violate Florida Administrative Code Section 61B-23.0021 (8) by failing to send an amended notice in 2017 following the withdrawal of Wendy Krauss;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112(2)(d) by failing to correct the problem after Wendy Krauss removed herself as a Board candidate in 2017;
  • By claiming I did not have the right to seek judicial proceedings pursuant to Section 718.1255 of the Florida Administrative Code Section 61B-45.043;
  • By allowing the ASSOCIATION to violate Florida Statute 718.104(4)(b) regarding its illegal name;
  • By allowing the ASSOCIATION to violate Florida Statute 718.111(c)(3) with improper claims of attorney-client privilege;
  • By allowing OMAR Nuseibeh, VICKI Hedrick, and KAREN Bollinger to violate Florida Statute Section 718.111 (1) (q) and 718.111 (1) (d)regarding fiduciary duty;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.111 (12) (6) by failing to maintain minutes of all meetings;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.111 (12) (7) by failing to maintain current rosters;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.111 (12) (15) by failing to maintain written records;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112 by failing to give at least 14 days’ notice of the annual meeting;
  • By causing and allowing the ASSOCIATION to violate Florida Statute Section 718.112 (1) (a) by not being governed as required by law;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112 (1) (c) (1) by failing to post notice of meetings in a conspicuous place;
  • By causing the ASSOCIATION to violate Florida Statute Section 718.112(2)(a)(2) regarding written inquiries and by providing false responses to written inquiries;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112 (2) (b) by failing to require a quorum;
  • By causing and allowing the ASSOCIATION to violate Florida Statute Section 718.112(2)(c) by not allowing me the right to speak at meetings with regard to all designated agenda items;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112(2)(c)(1) by failing to post notice of the December 12, 2018 meeting and by claiming compliance with the statute;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112(2)(d) by failing to hold annual meetings;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112(2)(d) by failing to post notice of the December 12, 2018 meeting and by claiming compliance with the statute;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112(2)(d)(4) by failing to provide notice regarding annual elections in 2015, 2016, 2017, 2018, 2019, or 2020;
  • By causing the ASSOCIATION to violate Florida Statute Section 718.112(2)(e)(11) regarding notice of proposed budgets;
  • By allowing the ASSOCIATION to violate Florida Statute by improperly denying an election / recall 718.112(2)(j)2;
  • Florida Statute Section 718.303 (5) by improperly suspending voting rights;
  • By allowing the ASSOCIATION to violate ARTICLES of Incorporation of the ASSOCIATION Article IV, Section 4.2 by failing to obtain certified copies of deeds;
  • By allowing the ASSOCIATION to violate ARTICLES of Incorporation of the ASSOCIATION Article VI, Officers by failing to elect Directors;
  • By allowing the ASSOCIATION to violate BYLAW 1.1 by showing a bogus address for the ASSOCIATION;
  • By allowing the ASSOCIATION to violate BYLAW 2.1 by failing to maintain current rosters;
  • By allowing the ASSOCIATION to violate BYLAW 2.1 by failing to obtain certified copies of deeds;
  • By allowing the ASSOCIATION to violate BYLAW 2.2 regarding the annual meeting and election;
  • By allowing the ASSOCIATION to violate Florida Law and BYLAW 2.2 by failing to hold annual meeting and annual election in 2020;
  • By allowing the ASSOCIATION to violate BYLAW 2.2 regarding the term for Directors;
  • By allowing the ASSOCIATION to violate BYLAW 2.3 regarding special members’ meetings;
  • By allowing the ASSOCIATION to violate BYLAW 2.4 regarding conspicuous posting of notice of meetings;
  • By allowing the ASSOCIATION to violate BYLAW 2.4 regarding notice of meetings;
  • By allowing the ASSOCIATION to violate BYLAW 2.5 regarding quorum;
  • By causing the ASSOCIATION to violate BYLAW 2.6 regarding voting;
  • By allowing the ASSOCIATION to violate BYLAW 2.6 regarding Designated Voters and quorum;
  • By causing and allowing the ASSOCIATION to violate BYLAW 2.9 (b) regarding election of a Chairman;
  • By allowing the ASSOCIATION to violate BYLAW 2.9 (j) regarding election of Directors;
  • By allowing the ASSOCIATION to violate BYLAW 3.1 regarding the number of Directors;
  • By allowing the ASSOCIATION to violate BYLAW 3.2 regarding failure to consider nominations from the floor;
  • By allowing the ASSOCIATION to violate BYLAW 3.2 a regarding election of Directors;
  • By allowing the ASSOCIATION to violate BYLAW 3.2 b regarding use of a nominating committee;
  • By allowing the ASSOCIATION to violate BYLAW 3.3 regarding term of service for Directors;
  • By allowing the ASSOCIATION to violate BYLAW 3.4 regarding organizational meetings;
  • By allowing the ASSOCIATION to violate BYLAW 3.5 regarding organizational meetings;
  • By allowing the ASSOCIATION to violate BYLAW 3.6 regarding special meetings;
  • By allowing the ASSOCIATION to violate BYLAW 3.12 regarding election of officers;
  • By allowing the ASSOCIATION to violate BYLAW 5.1 by failing to elect an Assistant Secretary;
  • By allowing the ASSOCIATION to violate BYLAWS 6.1 and 6.2 regarding accounts classification;
  • By allowing the ASSOCIATION to violate BYLAW 8.2 regarding Bylaw amendment;
  • By allowing the ASSOCIATION to violate BYLAW 8.3 regarding consent of mortgage holders;
  • By allowing the ASSOCIATION to violate DECLARATION Paragraph 13.3 regarding the number of Voting Interests;
  • By allowing the ASSOCIATION to violate DECLARATION Paragraph 18.1 regarding amendment;
  • By claiming the ASSOCIATION had Rules limiting the right to speak;
  • By allowing the ASSOCIATION to unlawfully increase assessments to the members;
  • By allowing the ASSOCIATION to vote to unlawfully increase assessments to the members to as much as $962.38 per month at the purported December 12, 2018 meeting;
  • By facilitating repeated violations of the corporate governing documents and Florida statutes;
  • By counseling purported officers and directors to ignore demands for them to cease pretending to be officers and directors;
  • By failing to update the corporate governing documents;
  • By allowing the ASSOCIATION to pretend the BYLAW was amended on August 25, 2018 after Russell E. Klemm sent a letter to the ASSOCIATION c/o CHARLIE ANN Aldridge of SENTRY MANAGEMENT in which he stated amendments require approval of all holders of first mortgage liens;
  • Russell E. Klemm has committed many violations of the Florida Rules of Professional Conduct while fighting me; he has committed perjury, fraud on the court, and many other violations;
  • By allowing the ASSOCIATION to violate Florida Law and the governing documents by failing to hold annual meeting and annual election in 2017 when there was not a quorum;
  • OMAR Nuseibeh, VICKI Hedrick, and KAREN Bollinger were not lawfully elected, so they had no authority to schedule meetings;
  • By denying owners a special meeting to consider a substitute budget;
  • By allowing the ASSOCIATION to hire police to attend ASSOCIATION meetings by falsely claiming police were needed because I had made threats to do physical harm or kill people;
  • By authorizing the ASSOCIATION to disregard the votes and proxies submitted in advance by owners on December 12, 2018;
  • By authorizing the ASSOCIATION to conduct the purported December 12, 2018 meeting when it was void for a variety of reasons;
  • By authorizing the ASSOCIATION to conduct a purported January 16, 2019 meeting that was not legal because OMAR Nuseibeh, VICKI Hedrick, and KAREN Bollinger were not legally elected as directors;
  • By causing the value of the condos of ASSOCIATION members to decline due to the legal problems;
  • By ignoring requests from an ASSOCIATION member in an effort to determine what was needed to accept the signatures of Nancy Camp and Jane O’Steen for the Nielsen Trust;
  • By claiming the BYLAWS provide that reserves are to be allocated to a specific use;
  • By claiming the BYLAWS restrict ASSOCIATION owners to speak three minutes total at meetings;
  • By causing the ASSOCIATION to violate the BYLAWS by disregarding valid proxies;
  • By claiming DECLARATION 12.2 gives the Board the power to increase dues for repairs and maintenance;
  • By causing and/or allowing the ASSOCIATION, OMAR, VICKI, and KAREN to violate Florida Statue Section 617.0830 and 617.0834 by committing the crime of fraud and perhaps other crimes;
  • By authorizing the ASSOCIATION to disregard the defamation directed at me;
  • By failing to comply with the Florida Rules of Professional Conduct;
  • By failing to comply with the Florida Rules of Civil Procedure;
  • By allowing the ASSOCIATION to repeatedly produce a bogus set of minutes for a purported meeting for August 2017; 
  • By causing the ASSOCIATION and various members to ignore at least 87 notices of violations and wrongdoing and demands to rectify;
  • By causing the ASSOCIATION to deny the election / recall on February 4, 2019 and February 19, 2019;
  • By causing the ASSOCIATION to fail to produce Records requested for Inspection;
  • By allowing the ASSOCIATION to hold a purported March 22, 2019 meeting and election due to fraud as well as other violations;
  • By ignoring a February 23, 2019 certified letter from me advising Clayton & McCulloh of a variety of wrongful acts;
  • By concealing Designated Voter Certificates at the purported March 22, 2019 meetings that would have shown several to be invalid;
  • By falsifying information sent to the DBPR;
  • By Russell E. Klemm holding himself out as an attorney for the ASSOCIATION but not representing the best interests of the ASSOCIATION;
  • By taking large sums of money from the ASSOCIATION;
  • By allowing ISABEL Campbell, ED Broom, SUE Yokley, SERGIO Naumoff, WENDY Krauss, and GARY Hansen to violate Florida Statute Section 718.111 (1) (d) regarding fiduciary duty;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112 by failing to give at least 14 days’ notice of the annual meeting;
  • By causing and allowing the ASSOCIATION to violate Florida Statute Section 718.112 (1) (a) by not being governed as required by law;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112 (1) (c) (1) by failing to post notice of meetings in a conspicuous place;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112 (2) (b) by failing to require a quorum;
  • By causing and allowing the ASSOCIATION to violate Florida Statute Section 718.112(2)(c) by not allowing me the right to speak at meetings with regard to all designated agenda items;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112(2)(c)(1) by failing to post notice of the December 12, 2018 meeting and by claiming compliance with the statute;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112(2)(d) by failing to post notice of the December 12, 2018 meeting and by claiming compliance with the statute;
  • By allowing the ASSOCIATION to violate Florida Statute Section 718.112(2)(d)(4) by failing to provide notice regarding annual elections in 2015, 2016, 2017, 2018, 2019, or 2020;
  • By causing the ASSOCIATION to violate Florida Statute Section 718.112(2)(e)(11) regarding notice of proposed budgets;
  • By allowing the ASSOCIATION to violate ARTICLES of Incorporation of the ASSOCIATION Article VI, Officers by failing to elect Directors;
  • By allowing the ASSOCIATION to violate BYLAW 1.1 by showing a bogus address for the ASSOCIATION;
  • By allowing the ASSOCIATION to violate BYLAW 2.1 by failing to maintain current rosters;
  • By allowing the ASSOCIATION to violate BYLAW 2.2 regarding the annual meeting and election;
  • By allowing the ASSOCIATION to violate Florida Law and BYLAW 2.2 by failing to hold annual meeting and annual election in 2020;
  • By allowing the ASSOCIATION to violate BYLAW 2.2 regarding the term for Directors;
  • By allowing the ASSOCIATION to violate BYLAW 2.3 regarding special members’ meetings;
  • By allowing the ASSOCIATION to violate BYLAW 2.4 regarding conspicuous posting of notice of meetings;
  • By allowing the ASSOCIATION to violate BYLAW 2.4 regarding notice of meetings;
  • By allowing the ASSOCIATION to violate BYLAW 2.5 regarding quorum;
  • By causing the ASSOCIATION to violate BYLAW 2.6 regarding voting;
  • By allowing the ASSOCIATION to violate BYLAW 2.6 regarding Designated Voters and quorum;
  • By causing and allowing the ASSOCIATION to violate BYLAW 2.9 (b) regarding election of a Chairman;
  • By allowing the ASSOCIATION to violate BYLAW 2.9 (j) regarding election of Directors;
  • By allowing the ASSOCIATION to violate BYLAW 3.1 regarding the number of Directors;
  • By allowing the ASSOCIATION to violate BYLAW 3.2 regarding failure to consider nominations from the floor;
  • By allowing the ASSOCIATION to violate BYLAW 3.2 a regarding election of Directors;
  • By allowing the ASSOCIATION to violate BYLAW 3.2 b regarding use of a nominating committee;
  • By allowing the ASSOCIATION to violate BYLAW 3.3 regarding term of service for Directors;
  • By allowing the ASSOCIATION to violate BYLAW 3.4 regarding organizational meetings;
  • By allowing the ASSOCIATION to violate BYLAW 3.5 regarding organizational meetings;
  • By allowing the ASSOCIATION to violate BYLAW 3.6 regarding special meetings;
  • By allowing the ASSOCIATION to violate BYLAW 3.12 regarding election of officers];
  • By allowing the ASSOCIATION to violate BYLAW 5.1 by failing to elect an Assistant Secretary;
  • By allowing the ASSOCIATION to violate BYLAWS 6.1 and 6.2 regarding accounts classification;
  • By allowing the ASSOCIATION to violate BYLAW 8.2 regarding Bylaw amendment;
  • By allowing the ASSOCIATION to violate BYLAW 8.3 regarding consent of mortgage holders;
  • By allowing the ASSOCIATION to violate DECLARATION Paragraph 13.3 regarding the number of Voting Interests;
  • By allowing the ASSOCIATION to violate DECLARATION Paragraph 18.1 regarding amendment;
  • By claiming the ASSOCIATION had Rules limiting the right to speak;
  • By allowing the ASSOCIATION to unlawfully increase assessments to the members;
  • By allowing the ASSOCIATION to vote to unlawfully increase assessments to the members to as much as $962.38 per month at the purported December 12, 2018 meeting;
  • By facilitating repeated violations of the corporate governing documents and Florida statutes;
  • By counseling purported officers and directors of the ASSOCIATION to ignore demands for them to cease pretending to be officers and directors;
  • By failing to update the corporate governing documents;
  • By allowing the ASSOCIATION to violate Florida Law and the governing documents by failing to hold annual meeting and annual election in 2017 when there was not a quorum;
  • OMAR Nuseibeh, VICKI Hedrick, and KAREN Bollinger were not lawfully elected, so they had no authority to schedule meetings;
  • ISABEL Campbell, ED Broom, SUE Yokley, SERGIO Naumoff, WENDY Krauss, and GARY Hansen were not lawfully elected, so they had no authority to schedule meetings, but KLEMM authorized it;
  • By allowing the ASSOCIATION to hire police to attend ASSOCIATION meetings by falsely claiming police were needed because of purported threats by me to do physical harm or kill people. I did no such thing;
  • By authorizing the ASSOCIATION to conduct meetings in 2018, 2019, 2020, and 2021;
  • By causing and/or allowing the ASSOCIATION, OMAR Nuseibeh, VICKI Hedrick, and KAREN Bollinger to violate Florida Statue Section 617.0830 and 617.0834 by committing the crime of fraud and perhaps other crimes;
  • By authorizing the ASSOCIATION to disregard the defamation directed at me;
  • By ignoring a February 23, 2019 certified letter from me advising Clayton & McCulloh of a variety of wrongful acts;
  • By falsifying information sent to the DBPR;
  • By taking large sums of money from the ASSOCIATION for malpractice and risking the viability of the ASSOCIATION;
  • By failing to provide the ASSOCIATION with the minimum standard of care.
  • By failing to sign at least 32 documents that Russell E. Klemm filed with the courts;
  • By failing to provide evidence to the courts;
  • By allowing a paralegal to practice law without a license;
  • By making false statements to the courts;
  • By refusing to communicate with me in regard to legal matters;
  • I have another 75 specific violations that I could cite, but the Bar Complaint page limit will not allow it.  I have all of my evidence organized in pdf files.  I will provide whatever the Bar Association needs.  Just ask.
  • I believe Russell E. Klemm is either grossly incompetent, corrupt, or mentally ill.  No honest attorney in his right mind would do what he has done.  Russell E. Klemm could be [XXXXXXXXXXXXXXXXXXXXXXXXXXX].  This should be investigated.  Russell E. Klemm should be disbarred. 

VERIFICATION

Pursuant to Florida Statute 92.525, under penalties of perjury, I declare that I have read the foregoing document and that all facts in it are true.

Dated in Leesburg, Florida this 30th day of June, 2021,

_______________________________
William Michael Windsor

100 East Oak Terrace Drive, Unit B3

Leesburg, Florida 34748

352-577-9988

windsorderivative@gmail.com