St Aug Shores Defendant Files Answer & Countersuit!

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Saint Augustine Shores Service Corp HOA Spends $6,000.00 on Lawyers Already! LAWSUIT Against Shores Resident!

Summer Lee Reed of Jacksonville Florida, one of the Attorneys for the St Augustine Shores HOA, recently stated on 6/24/24 to Defendant Paul during a recent phone call - regarding a possible settlement offer, saying: "The legal fees associated with the new Lawsuit so far amounted to approximately $6,000.00 already!
During that conversation she said there may be an opportunity for a settlement agreement to end the expensive Lawsuit which had just recently started. As of 6-28-24 Defendant Paul has received a settlement offer from Ms. Summer Reed by email.
UPDATE: The "Offer" was rescinded shortly after Attorney Summer Reed discovered that Defendant Paul had filed a 41 Page Answer with Counterclaims and also put this website back online.

Summer L. Reed

St Augustine Shores Service Corp HOA / Lawyers in an attempt to silence a St Augustine Shores Resident has recently filed:
CASE NO.: CA24-0717 DIVISION: 55, St Johns County, FL signed by Hans C. Wahl and Summer L. Reed Attorneys for the Plaintiff. The Plaintiff's Complaint / Injunction seeks damages of $50,000. - $75,000. against Defendant Paul whereby the Plaintiff claims defamation and / or libel for taking in-public photos and the posting of those photos of current President Mary Jenson and Treasurer Brad Smith and others, on this website known as:

» Defendant Paul Files » 41 Page Response

Q). First of all, how did Defendant Paul come to obtain these interesting photos of Mary Jenson and Brad Smith?

A). On a Sunday afternoon, someone in the neighborhood decided to make a phone call to Mary Jenson or Brad Smith.  Was it Jeff Bailey, Lauren Bailey, Mary Vella, or Stan the man?
It's important that we find out since it was a group effort.

The following information has been written and explained by: Defendant Paul; AKA: "Mr. Frank"

1). Defendant Paul was building a 6' feet tall wood picket fence on the side of his residence - installing 4x6 posts in concrete.

2). President Mary Jenson and Treasurer Brad Smith showed up and parked their vehicle across the street on the swale, on the East side of Defendant Paul's residence.

3). About 10 - 15 minutes earlier, Defendant Paul noticed a man (Brad Smith) walking with Lauren and Jeffrey Bailey on their sidewalk, on the South side of the Bailey residence directly across the street from where Defendant Paul was building his fence.

4). After a little while, from a distance of about 75' feet, Defendant Paul noticed a man (Brad Smith) inconspicuosly taking video and/or photos of Defendant Paul, his 2 helpers, a work truck, etc., all which would of been in the view of the scope of the camera.

5). Seeing this, Defendant Paul briskly walked across the front yard of his residence towards Brad Smith (as Brad Smith quickly went to hiding his camera phone in his right pocket.) As Defendant Paul got closer, Mr. Smith said "Francis" with a smile. So obviously, he already knew who I was since I had never met him before.

6). Since I had seen a picture or two of Mr. Brad Lee Smith on the St Aug Shores HOA website I replied: "Brad Smith." He did not deny that was his name. I was correct that it was him (Brad Smith).

7). At that point the two of them (Mary and Brad) were only about 20' feet apart; Brad Smith still in the street, Mary Jenson mostly on the swale with the black dog.

8). As I continued to walk toward both Mary and Brad, I said:
"If you can take pictures - I can take pictures too..."

9). As I approached taking pictures (staying back at least 15-20' feet) the woman (Mary Jenson) with the dog, as she was standing behind the car with a phone in her hand. At that point I said to her: "And you are...?"

10). In reply she said "Get away from me, you're threatening me!" She also said: "I'm calling the Police...!"

11). Brad Smith said : Yes, I'm a witness and you threatened her..."

12). I replied: "No I didn't!  I didn't threaten her and you know it ..."

13). I immediately walked away back to the fence building job and soon thereafter the Sheriff showed up, questioned me, telling me:
"The taking of pictures has to be in public," which it was and I did. "On the street and on the swale is okay too," the Sheriff said.

Q). Who was it? Which one of the neighbors called Mary Jenson & Brad Smith that Sunday afternoon?

What was the Shores HOA President Mary Jenson and the Shores HOA Treasurer Brad Smith doing taking pictures of me and my fence building job? They showed up before we got one hole dug!

When Mary & Brad were both right there in front of the Bailey's new fence (violation), why didn't they also take pictures of the Bailey's New 6' feet tall / 36' feet length of new wood picket fence?

Why was no mention made that the Bailey's did not complete the ACC application, and provide a required survey and drawings to obtain the HOA permit and approval to build their fence?

Why was nothing said to the Bailey's that their new commercial work truck (leaks oil) is always parked next to their home on a regular basis and is also a Deed Restrictions Violation?

A). Is it because they all have become friends and continue to bond as friends all because of Defendant Paul?
Hey Guys! Is it fun to be Drama Queens?

Past Shores HOA President Paul Racicot Chimes In:
In a recent phone conversation between St Augustine Shores resident Paul Racicot (Past President of the St Augustine Shores HOA) and Defendant Paul, regarding the Sunday Afternoon visit by Mary Jenson and Brad Smith showing up, meeting with neighbors, filming video and/or taking pictures of the Defendant and the fence building job...

Past President Racicot said: The Sunday Afternoon visit by The Shores HOA President Mary C. Jenson & Treasurer Brad L. Smith incident was "unprecedented." Mr. Racicot said 1 : "Mary Jenson is a bulldog" and 2 : "No-one even at the office likes her" and 3 : "If you go to a meeting and she doesn't like what you are saying; she bangs down the gavel to silence you and will then have the paid Police Officer remove you from the meeting and building..."

Neighbors who may of possibly called Mary Jenson & Brad Smith on that Sunday afternoon include : Mary F. Vella, Jeffrey Bailey, Lauren Bailey and/or Stanley Lozinski, all of whom are not on good terms or speaking terms with Neighbor/Defendant Paul and have not been for years. There have been many unfriendly incidents between the said neighbors and Defendant Paul over the course of several years.

Defendant Paul has the right to believe that some or all of the neighbors named above have become friends with and colluded together with The St Augustine Shores HOA President Mary Jenson, Treasurer Brad Smith, Manager Shanna Fredrickson, Assistant Manager Christine Hart, Director Nicolas Arocha, and/or other board members. The 4 neighbors named above are all good friends and are frequently seen together.

As a part of the Response to The Lawsuit by Defendant Paul which will include a Countersuit and Counterclaim(s), it shall also include and require each and every one of those named above and below:

The St Augustine Shores Service Corp HOA;
President Mary Jenson,
Treasurer Brad Smith (now Ex-Treasurer),
Manager Shanna Fredrickson,
Assistant Manager Christine Hart,
Director Nicolas Arocha,
and/or other board members,
Saint Augustine Shores Residents;
Mary F. Vella
Jeffrey Bailey
Lauren Bailey
Stanley Lozinski
and others;

To submit to a formal Legal Deposition whereby Defendant Paul and/or Defendant Paul's Lawyer will ask a series of questions to each one named to determine how and why the Shores HOA has colluded with certain neighbors to target Defendant Paul in recent months with said Lawsuit and other specific incidents even before the Lawsuit was filed. Those select incidents are described in and part of the Response by Defendant Paul, which includes several documented incidents and issues, with more documented events coming forth as time allows.

Defendant Paul » Pro Se » Countersuit / Counterclaim(s)
Filed / 6-30-2024

» Defendant Paul / 41 Page Response » PDF

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