Amended Witness List-July 2024

Amended Witness List-July 2024, updated 8/8/24, 4:48 PM

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Jo-Anne Sparta vs Related Aff, SA Res Pres,TRG & Michael Blumenau
#50-2023-CA012067-XXXX-MB

Witness List In The Complaint Action: Plaintiff Pro Se Jo-Anne Sparta v Related Companies et al, Defendants
Willing Witnesses: Who Are Still In Touch & Keeping Updated


1. Annette Guilbeault 208 Fern Street, Apt 1509, West Palm Beach, FL 33401 Cell: 561-346-9002 She has been
present for much of what has happened to the Plaintiff & another 15th fl resident who is also being evicted on
false allegations, Mary Woody. She has witnessed the state of Plaintiff’s apt, plus been present at many events
that the Landlord lied about, in their attempts to tyrannize & bully residents who complained. She can also confirm
Jack Hairston was paid to move out & shut up, after many altercations with the Landlord. See Ex R-1
2.) Mary Woody 208 Fern Street, Apt 1510, West Palm Beach, FL 33401 Cell:443-812-2236 She is being evicted
bogus charges. Annette Guilbeault and the Plaintiff have witnessed her trying to pay her rent for months, with the
Landlord refusing, then sending a 7-Notice To Vacate for Non-Payment of Rent. When the Plaintiff went to
witness her last attempt to pay, with the police there, to document the event, Plaintiff received her Notice of Non-
Renewal shortly thereafter. One of the “good causes” was being a witness to the continued terrorization of Ms.
Woody. See Ex L-9.
3.) Rhonda Lundy-also a resident for many years. Cell:561-667-0829, Ms. Lundy can speak to the corruption,
retaliation, racism & harassment by the previous Manager, Evelyn Agosto, whom the Landlord kept on when they
bought the property. She also tried to organize a Residents’ Association, but said the Landlord took down their
flyers, interfering with the right to organize and assemble. That’s a violation of the Hud & FL tenant rights. She
can also attest to Evelyn Agosto & Doug Zimmer lying about events, the projecting, insisting the resident is lying.
Plaintiff has multiple emails with Ms. Lundy about the Landlord’s horrific tactics and ongoing harassment. See
Plaintiff’s Contemporaneous Notes From May 4, 2022.


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4.) John McGowen-also a resident; Apt 1404. Cell:602-405-6529. John can speak to renovations and repairs being
requested and never effectuated for months, and to the general dysfunctional conditions of the elevators, a/c and
more. He has also been a witness to the residents who hate dogs and systematically complain no matter how well-
behaved they are.
5.) John Wilson-Also a resident; Apt 1207. Mr. Wilson appears in Plaintiff’s contemporaneous notes from June
10, 2022, when Plaintiff still didn’t know his name. He spoke of TRG Manager telling him he’d “forgotten where
he put” things he knew had been stolen. Then, in June of this year, 2023-He asked Plaintiff for information of his
breathing problems, saying he’d asked TRG Management about the black dust all over everything in his apartment
& had been ignored for a year. Plaintiff gave him the names of the HUD and WPB Code Enforcement Inspectors.
The next time Plaintiff saw Mr. Wilson, he was very upset at the increasing problems he was having breathing,
and asked again for assistance. Plaintiff advised him to recontact Mr. Vaughn and Mr. Williams, his PCP-for a
lung scan, and to take photos of the flaking asbestos from the ceiling just outside his apt, and to photograph the
black dust. Plaintiff also gave him a copy of the analysis, Ex D-1, confirming the dangerous levels of toxic dust
confirmed by an outside agency, that we have all lived with for months & many still do.
Company Employees With Info Who Have Made Statements To Plaintiff Confirming Issues
Related Construction-Jeff Allen, sent from NYC by David Pearson, when he received Plaintiff’s Dec.2022 video
depicting the uninhabitable, unsafe, unhealthy conditions she lived in for more than 8 months, that the Landlord
failed to repair, remediate and finish. He told Plaintiff: “It never should have happened.” “This should have been
finished months ago.”
ETC-Construction: Marcus Giles, Dave Rosario-These men are very aware, having dealt with Plaintiff and her
apartment, of Plaintiff’s demeanor and responses, and the veracity of all the problems she complained to the
Landlord about.
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It is typical of the Landlord, that Marcus Giles was very polite and helpful to residents, like providing small cups
of paint
to
residents whose apartments had not been cleaned or
finished properly. He
was reprimanded in an email by Management for accommodating residents and warned to stop immediately. Dave
Rosario will attest to the horrific lack of updating and communication from the Landlord, that has caused delays,
invasions of privacy, inaccurate info and chronic missed deadlines on promised projects for months.
Austin Builders-Justin can attest to residents being abusive to Plaintiff and her dog in the elevator, for no apparent
reason, but that they don’t want pets here. Her dog was seated & quiet by her side and is friendly and says hello
to some of the workers who love dogs. Lobby videos confirm Plaintiff’s handling of her dog and his behavior.
Cool Water-Ivan has confided he knows he will retire early, because the Landlord never alerted them of the
asbestos & silica dust. He is sure he will eventually succumb to ill health because there was no warning from the
Landlord, and they were never given any protective gear.
*John and Omar from Urban Elevators, Sonya from Smooth Transitions, and people from each contractor onsite
will attest to Plaintiff’s behavior, and the Landlord’s continued inability to organize, communicate and effectuate
safe, timely and properly legal renovations and repairs. Plaintiff has additional emails, photos, texts, and videos.
Hostile Witnesses Who Contacted Me First-Then Backed Out & Wouldn’t Step Up
Nota: Plaintiff has their emails, apt numbers & cell numbers, proving they contacted Plaintiff willingly, then got
intimidated
or
were
contacted
by
the
Landlord,
and
backed
down.
1.) Accomplice Jack Hairston, Initially knocked on Plaintiff’s door to discuss June 20th exposure & other horrific
events he experienced with Evelyn Agosto, the Manager. He abruptly stopped speaking to Plaintiff & became
insistent that he no longer cared what happened here and would not speak up. It was a 180 from the man who
came and knocked on Plaintiff’s door.
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He is an Accomplice in the Landlord conspiracy, and was paid to do so, to cover up the initial asbestos exposure
on June 20th, 2022. See email confirmation, Ex R-1 from Annette Guilbeault and Mike McCarthy. Nota: Mr.
Hairston died July 7, 2023. Plaintiff seeks verification of bribe and NDA from his estate.
2.) Mike McCarthy-Sent Plaintiff an email . See Ex R-1 stating that Jack Hairston told him he was paid a “tidy
sum” to move out and stop talking. See also Ex R-4, Mike’s initial email to the press about the horrific conditions
here, which he forwarded to Plaintiff to ask her for help.
3.) Tony Ross-Initially stopped Plaintiff in the parking lot to show Plaintiff asbestos related points of interest &
to ask if Plaintiff would contact outside agencies for help. He also asked Plaintiff to contact other residents, saying
they had info and wanted to move forward trying to protect and defend ourselves. The parties have since declined
to proceed with anything out of fear of retaliation from the Landlord. See Ex R-3.
4.) Accomplice Mike Blumenau, came and asked Plaintiff, after giving her the supposed second Notice To Cure,
and his Code Enforcement Violations, cited against the Landlord, asking her what to do, and could Plaintiff
provide a letter and contact info for Related NYC. His Notices and the letter Plaintiff gave him, addressed to
David Pearson, of Related Affordable are included. See Ex R.Plaintiff explained she has not dealt with onsite
Landlord, Mr. Zimmer and Ms. Agosto, for many months, since they do not have final authority, and since she
sent them Cease and Desists; Ms. Agosto in Jan. of 2022 and Mr. Zimmer, in Dec. of 2022. See Ex L-1, L-2. This
lends credible proof to refute the Landlord’s lies, that Plaintiff forged Mr. Blumenau’s signature and slipped the
letter under Ms. Agosto’s door. See also Ex R, given to Plaintiff by Mr. Blumenau, when he first began receiving
violations and Notices. Nota: The Landlord has refused to provide a copy of the alleged forged signature, or the
lobby video footage requested, which would show who put the letter under the Manager’s door. Both would
exonerate Plaintiff. Plaintiff directs everything to Mr. Finkle & Mr. Pearson in NYC, and always by email.

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Mr. Blumenau does not have a computer and no email accounts and as such, his relay of the letter could only be
onsite or by snail mail, which is not how Plaintiff interacts with anyone, and is well-documented as per her pattern
of conduct. Notices from the Landlord, stating Plaintiff had forged Mr. Blumenau’s signature and slipped the
letter under Ms. Agosto’s door prove Mr. Blumenau conspired with the Landlord, lying to implicate the Plaintiff.
This will be easily disproven as yet another aggressive bullying tactic, synonymous with the Landlord’s
established, pattern of conduct.
 Current Staff Manager, Jackie Perez, was the former Service Director-through Rainbow Corporation. She
did not answer anyone’s pleas for help, even though May Woody & I contacted her several times.
 standrewsmanager@relatedgroup.com is the last email I have for her.
Named/Unnamed Residents-Plaintiff can provide text messages on her phone from several residents, expressing
support, but stating they will not put their names on anything for fear of retaliation, & commenting on the great
training my dog has exhibited. There are several other residents who’ve contacted the Plaintiff for information
and assistance. She can provide apartment numbers and descriptions. The flyer Plaintiff is accused of posting that
“damaged” the property, Ex L-3, was because so many people stopped her, desperate for help when the elevators
were out off and on for nearly a week in May of 2023, on top of only one operating elevator for the entire near 3-
years Plaintiff has lived at Landlord’s property. #1107-who puts notes on his door warning the Landlord’s staff
not to enter without permission-, (Plaintiff has copy), #406-who had vermin, leaks and no closet bars for months.
The Landlord ignored her. A woman named Lulu, who asked Plaintiff how to protect herself from another resident
who had verbally and physically assaulted her. (Plaintiff has emails). Workmen from ETC can also attest that this
same woman accused of assault, also threw boiling water on one of them. Said resident is still on property.
Ex-Staff- In addition to the list of staff members who have quit or been fired, see “Dorothy Brown” emails, Ex
R-8, Plaintiff also lists: Pablo Mirabal, Joseph Carbonnell, and Miguel Castillo. There are others, like Bryana
Guerrido, Vlad Pajkanovic, and Mr. Brown. The number of staff in turnover is indicative of the Landlord’s abusive
management, requests to provide false testimony, and other aggressive actions, like following residents around to
photograph them, as Jack Hairston stated. at the Landlord’s request.
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Unless they have also been menaced or bribed, many named can attest to the Plaintiff’s good faith efforts vis-à-
vis the Landlord, and to her harassment on a regular basis.
Officials: Mr. Mike Williams, WPB Code Enforcement, who has cited the failed inspections in Plaintiff’s apt.,
and stated “He doesn’t know what to expect from these people”, in reference to the unsatisfactory exchanges with
the Landlord. Mr. Vaughn, HUD’s Inspector, citing several failed inspections in Plaintiff’s apt, concerning flaking
asbestos, leaks and mold. Plaintiff has contemporaneous notes from his visit that she forwarded to LaTasha
Bennett at HUD, noting: Mr. Vaughn said the Landlord was “stonewalling” responses and it was unacceptable.
That the work done was shoddy, “just this side of illegal”. *The next time Mr. Vaughn came, he reprimanded
Plaintiff for relaying this important info about the Landlord to people she thought could help.
The WPB Elevator Inspector was onsite several times. Plaintiff did not get his name, but he can attest to the
chronic inoperative state of any elevator onsite and to the proper, friendly comportment of Plaintiff and her ESA
canine. Nota: Plaintiff has spoken with the Inspector, Mr. Robert Stark from the Florida Dept. of Business and
professional Regulation on August 15, 2023. He confirmed there was still water leaking in the elevator as of last
month, July, 2023. Plaintiff alerted him to the still leaking 15th floor. Plaintiff has dated photos, as well as
contemporaneous notes. Mr. Stark, can also confirm that Plaintiff’s ESA canine is playful and friendly. He has
been onsite regularly for months, and can attest to the myriad violations, malfunctions and more with the only
one-at-a-time elevator for more than 400 residents, pets, walkers, wheelchairs, maintenance and equipment, but
has not been the Inspector for the whole 2 year debacle.
*It is clear, the Landlord’s pattern of conduct, taken in its’ entirety, rewards those who obey and punish those who
complain about violations, breaches, and unsafe, unhealthy, uninhabitable property.








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