Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
3Activity
0 of .
Results for:
No results containing your search query
P. 1
1st Amended Complaint

1st Amended Complaint

Ratings: (0)|Views: 142 |Likes:
Published by John Carroll
This is the Amended Complaint I filed in Carroll v WaterSound Beach, et al for Tortious Interference, Fraud, Libel, Breach of Contract and other claims. In essence we argue that Chambers Street Builders, Inc. and John Carroll have a competitive advantage as builders that the Defendants sought to slow up or damage for competitive and other reasons.
This is the Amended Complaint I filed in Carroll v WaterSound Beach, et al for Tortious Interference, Fraud, Libel, Breach of Contract and other claims. In essence we argue that Chambers Street Builders, Inc. and John Carroll have a competitive advantage as builders that the Defendants sought to slow up or damage for competitive and other reasons.

More info:

Published by: John Carroll on Mar 25, 2010
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as DOC, PDF, TXT or read online from Scribd
See more
See less

10/02/2013

pdf

text

original

 
IN THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUITIN AND FOR WALTON COUNTY, FLORIDACIVIL DIVISIONJOHN P. CARROLL,Plaintiff,Case No.: 09CA002021v.WATERSOUND BEACH COMMUNITY ASSOCIATION, INC.,
 Florida Corporation
DAVID LILIENTHAL,
individuallyand as Director,
MARY JOULE
,
SANDRA MATTESON,RONALD VOELKER,WATERCOLOR COMMUNITY ASSOCIATION, INC.JOHN DOE and JANE DOEDefendants. ____________________________________________/FIRST AMENDED COMPLAINT FOR EQUITABLE AND OTHER RELIEFParties, Jurisdiction and Venue
1.Plaintiff, John P. Carroll (
Carroll
”), sues Defendants, WaterSoundBeach Community Association, Inc. (“
WaterSound
”), David Lilienthal (“
Lilienthal
”),Mary Joule (“
Joule
”), Sandra Matteson (“
Matteson
”), Ronald Voelker (“
Voelker
”),Watercolor Community Association, Inc. (“
Watercolor
“)
 
John Doe (“
John Doe
”) andJane Doe (“
Jane Doe
”)
 
as follows:2.Carroll is a Florida resident with his principal place of business andresidence in Walton County, Florida. Carroll is a Florida licensed Building Contractor.Carroll owns and controls Chambers Street Builders, Inc. a Walton County, FloridaCorporation. Carroll owns and controls J.M.B., L.L.C a Florida LLC.3.WaterSound is a Florida Corporation with its place of business in Walton
1
 
County, Florida.4.Lilienthal is a Florida resident with his personal residence in WaltonCounty, Florida, is a Realtor with his principle place of business in WaterSound andWatercolor in Walton County, Florida, is a salesperson for Dune Construction andDevelopment, Inc. owned by his son in WaterSound and is a Director of WaterSoundlocated in Walton County, Florida.5.Joule resides in Walton County, Florida, describes herself as a Floridalicensed Building Contractor, works in and for WaterSound and Watercolor, and theactions that are the subject matter of this suit occurred in Walton County, Florida.6.Matteson resides in Walton County, Florida, works in and for WaterSoundand Watercolor in Walton County, and the actions that are the subject matter of this suitoccurred in Walton County, Florida.7.Voelker resides and works in Walton County, Florida and the actions thatare the subject matter of this suit occurred in Walton County, Florida.8.Watercolor is a Florida Corporation with its principal place of business inWalton County, Florida.9.John Doe and Jane Doe have been included on knowledge and belief,Defendants conspired among themselves and with other non- party co-conspirators, asmore particularly described below, to undermine and damage Carroll, as well as the businesses he has interests in. Accordingly, in the furtherance of this conspiracy or enterprise, the primary purpose being to impair and boycott the Plaintiff, to impair Chambers Street Builders, Inc. and to convert its business to their own pecuniary benefitand advantage and to impair and to convert J.M.B., L.L.C.’s business to their own
2
 
 pecuniary benefit and advantage, the act or omission of one Defendant co-conspirator while active in the concerted activity constitutes the act or omission of all other co-conspirators and vice versa. Not all participants in the conspiracy are known to thePlaintiff. For that reason, Plaintiff has designated John Doe and Jane Doe asrepresentatives of other persons, unknown to Plaintiff at this time, who conspired withthe other Defendants and non-party co-conspirators to accomplish the unlawful purposesof the conspiracy enterprise, as herein alleged.10.Venue is proper in this Court because the real property that is the subjectof this Complaint is located in Walton County, Florida, the Defendants reside or arelocated in Walton County, Florida and all actions forming the basis of this Complainttook place in Walton County, Florida.
General Allegations of Defendants’ Interference
11.Carroll was put on the approved builder list in 2002. The Chairman of theDesign Review Board put Chambers Street Builders, Inc. (“
CSB
”) on the fully approved builder list in 2003 which was provided to all Owners and potential Owners. (Exhibit A)From 2002 through 2009 Carroll engaged in advertising, acquisition of Real Estate andassembling business arrangements in WaterColor, WaterSound, Windmark Beach, TheRetreat and Rivercamps. CSB remained on the approved builder list continuouslythrough April 2006.12.At some point in about April 2006 CSB’s name and contact informationwere silently and covertly removed from the approved builder list. Neither CSB or Carroll were notified of this and there were no complaints or notices of any kind againstCSB or Carroll. Any customer of CSB and Carroll inquiring was told that CSB was not
3

Activity (3)

You've already reviewed this. Edit your review.
1 thousand reads
1 hundred reads
moniquearmstrong liked this

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->