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Post by Admin on Nov 11, 2014 6:52:21 GMT -5
...comes the Admissions, Interrogatories, Request for Production of Documents and Judicial Notice. These documents were filed yesterday (Nov 10) and SLohA must comply by Dec 10, 2014. These documents followed the almost-identical documents in the case of Lawsuit #2, which case has many important overlapping complaints. Teague admissions.pdf (141.9 KB) Teague interrogatories.doc (38 KB) Teague request to produce.pdf (114.36 KB) Teague ReqJudNot.pdf (131.48 KB) Frd explained in an email how busy he had gotten with a recent MRTA case: To Frd I say --as long as you are winning MRTA cases, I don't mind being a little behind on filing. The content in these documents is identical, in many instances, to Gngr and Lra's case. Their Interrogatory had 19 items; mine had 16. The difference is due to the written permission BOD issued to site their home. I am not going to repeat the content here; it is all in the attachments or readers can simply refer to Lawsuit #2. There is one more document that I am not posting or commenting on yet as I need some clarification from Frd so that I understand it. But, it is an important item. The cadre of SLohA attorneys is going to be busy! Warm up your wallets, send your BOD a kiss and wish 'em luck--they're gonna need it. |
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Post by pestcontrol on Nov 11, 2014 7:35:42 GMT -5
...comes the Admissions, Interrogatories, Request for Production of Documents and Judicial Notice. These documents were filed yesterday (Nov 10) and SLohA must comply by Dec 10, 2014. These documents followed the almost-identical documents in the case of Lawsuit #2, which case has many important overlapping complaints. Frd explained in an email how busy he had gotten with a recent MRTA case: To Frd I say --as long as you are winning MRTA cases, I don't mind being a little behind on filing. The content in these documents is identical, in many instances, to Gngr and Lra's case. Their Interrogatory had 19 items; mine had 16. The difference is due to the written permission BOD issued to site their home. I am not going to repeat the content here; it is all in the attachments or readers can simply refer to Lawsuit #2. There is one more document that I am not posting or commenting on yet as I need some clarification from Frd so that I understand it. But, it is an important item. The cadre of SLohA attorneys is going to be busy! Warm up your wallets, send your BOD a kiss and wish 'em luck--they're gonna need it. Add to that the misdeeds, harassments, intimidation and assaults this MANBOD has engaged in that have been documented through this FORUM, I would have to say that the legal bill for defending this Board's bad decisions is going to cost S-bag owners a pretty penny. |
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Post by Clap on Clap off on Nov 11, 2014 10:58:36 GMT -5
clappers should start clapping now and clap real loud and dont stop
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Deleted
Deleted Member
Posts: 0
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Post by Deleted on Dec 29, 2014 20:57:29 GMT -5
Watts status of Motion for SJ?
Got a hearing/appearance date yet?
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Post by Lra on Mar 9, 2015 3:11:53 GMT -5
Preliminary Mediation Settlement Agreement on lawsuit #1.
Susan Tg v. S-bag Lake Owners Association,Inc.
Susan Tg agrees that all issues in her lawsuit are now moot and sH all not be litigated except for whether S-bag's 1986 and 1989 amended covenants and declarations are valid amendments to be included as part of Revitalization.
S-bag agrees to cease its current Revitalization procedure and not submit its current "consents" to DEO.
To determine whether S-bag's 1986 and 1989 amended covenants and declarations are valid amendments to be included as part of Revitalization, Tg and S-bag agree to submit this singular issue for determination by the Court via competing cross - motions for Summary Judgement. Each side sH all file it's initial motion/memo within 21 days and then each side sH all have 14 days thereafter to respond to the motion. A hearing on the issue sH all be set as expeditiously as possible. The trial court's ruling is final and sH all not be appealed by any party. The Order sH all be recorded in the official records of Polk County, Florida.
After receiving the trial court's Order, Revitalization sH all then commence as prescribed by the Florida Statues and DEO. If the court determines the 1986 and 1989 amendments to be valid, then S-bag sH all include these amendments as part of its Revitalization package/documents to be revived (in addition to applicable original declarations). If the court determines the 1986 and 1989 to be invalid, then S-bag sH all not include these amendments as part of the Revitalization/documents to be revived (and sH all only include the applicable original declarations).
S-bag further agrees to ensure that it utilizes separate consent forms individualized to Units 1, 2 and 3. Susan Tg agrees to support, and not cH allenge, S-bag's covenant revitalization to be done consistent with the terms set forth herein.
Susan Tg and Frd O'N eel (Attny), ESQ agree to accept $45,000 to settle their claims for attorneys' fees and costs in the instant suit regardless of the outcome on the competing cross - motions for Summary Judgement. If Tg/O'N eel (Attny) are successful and the 1986 and 1989 amendments are deemed invalid then Tg/O'N eel (Attny) sH all receive an additional $10,000 in attorneys' fees/costs. If S-bag is successful and the 1986 and 1989 amendments are deemed valid, then Tg/O'N eel (Attny) are due no additional compensation for attorneys' fees and costs.
After the Order referenced above is entered by the trial court, Tg sH all dismiss this lawsuit with prejudice and sH all not cH allenge the Revitalization to be done by S-bag consistent with the terms identified herein.
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