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Amended Exhibit List:
Jo-Anne Sparta vs Related Aff, SA Res Pres,TRG & Michael Blumenau
#50-2023-CA012067-XXXX-MB
Ex A: Notice of a Non-Renewal of Lease. A-1: Cease and Desist to Barfield and McCain. A-2
Notice of Material Non-Compliance. A-3: Plaintiff’s Affidavit and Rebuttal of Notice of Material
Non-Compliance. A- 4: Notice of Your Residence/Plaintiff’s Rebuttal attached with letter of
Feb.20th to Landlord’s David Pearson. A-5: Plaintiff’s flyer for residents who requested help after
nearly a week. off and on. no elevator during the month of May. (Landlord claims the flyer
damaged the property. (Corroborated by Inspectors’ reports, Plaintiff’s exhibits,
contemporaneous notes). Ex A-6: Defendant’s 7-Day Notice to Vacate, issued to Plaintiff on
Aug.23, 2023. Ex A-7-Michaels Blumenau’s Reply of Aug.14, 2023, Ex A-8: Plaintiff’s
Response to Defendant Blumenau’s Reply, Ex A-9: Defendant’s WPB Code Violations given to
the Plaintiff when he asked for her help. Ex A-10: Defendant Blumenau’s threatening letter from
TRG, given to Plaintiff when he asked her to write a letter in response. Ex A-11: Letter to Ms.
Rivera given to Defendant Blumenau, at his request for help. Ex A-12: Letter to David Pearson
that Plaintiff wrote when Defendant Blumenau asked for her help. Nota-Plaintiff had Cease &
Desists against TRG & SA Res Pres staff, & had not dealt with the for months, advising
Defendant Blumenau to contact Mr. Pearson if he wanted results, since that who ultimately made
all onsite decisions.) See Exhibits L below)
Ex B. Dept. Of Health- Mr. Morales’ email. B-1-video of Plaintiff’s apt on June 20, 2022. B-2-
Landlord’s Notice of Asbestos (17 days after they notified the Dept. of Health.). B-3-Landlord’s
false email that Plaintiff had not been exposed to asbestos.
Ex C. Demand Letter, Ex C, Amended Costs, Ex C-1-Revised through May 31, 2024, & Letter,
Ex C-2, Petition For An Injunction For The Protection Of A Vulnerable Adult, Ex C-3.
Ex D. Inspectors’ Reports-HUD & WPB Code Enforcement stating failure to remediate asbestos-
months later. D-1 Report Analysis confirming asbestos/silica levels on windowsills above FDA-
acceptable levels. D-2-Video depicting Plaintiff’s windowsills and rest of damages in December
of 2022.
Ex E. Videos of Flaking dust, chronic leaks containing asbestos. Kitchen-Videos Ex E, Alcove-
Video Ex E-1.
Ex F. Citation, Ex F-1, article on elevator woes; F-2. Inspection report, Ex F-3, Plaintiff’s email
to management, Ex F-4, Video Ex F-5-Raining in the elevator on a regular and continued basis.
Ex G. Videos of roof drilling, Video Ex G, and G-1.
Ex H. -a 1.5 million-dollar fine for corruption and bribery levied against Landlord’s CEO and
V.P., H-1 Rainbow Corp, part owner, in an attempt with Landlord’s efforts to bribe and silence
Plaintiff after her dog was poisoned. Ex H-2, confirming the bribe by Landlord to Jack Hairston,
(See also Ex R-1 below for emails from 2 residents confirming Jack accepted a bribe to move out
& shut up), Ex R H3, with a listing of the many Related Companies fines, violations, citations
and more, and Ex H-4 about the common practice of harming, provoking, then threatening
residents who complain about legitimate Material Breaches of Contract.
Ex L. Landlord’s collection of harassing, threatening, frivolously aggressively letters replete with
unsubstantiated, false and defamatory, abusive allegations, in an ongoing harassment campaign
to frighten, intimidate and silence Plaintiff for requesting the Landlord to comply with their legal
obligations, and Plaintiff’s Rebuttals: L-1: Cease and Desist: Evelyn Agosto, Landlord’s
Manager. L-2: Cease and Desist: Doug Zimmer, Landlord’s Reg. Mgr. L-3: Sheila Salmon’s
Letter with Plaintiff’s rebuttal in red, concerning fabricated, aggressive, and unfounded
allegations about Plaintiff’s ESA canine. L-4: Marilyn Pascual’s letter with Plaintiff’s rebuttal in
red, concerning a plethora of alleged violations, none with evidentiary standing. L-5: Cease and
Desist for Marilyn Pascual. L-6: Letter on June 20th to Landlord. *Please view Video Ex B-1 for
the conditions prompting the letter, and review how many times Plaintiff was asked to pack her
things and leave her apt, without notice of start/finish dates.
This can be verified by workmen. L-7: Letter from Landlord to Plaintiff, in another aggressive
bullying tactic, and Plaintiff’s rebuttal, including comments about no elevators, Plaintiff’s
residents’ petition in recognition of her and her canine’s actual comportment., and other resident
observations. L-8: Ms. Montejo’s refusal to accurately investigate the landlord’s corruption and
bullying, and subsequent false allegations accusing the Plaintiff of violating her lease with
legitimate complaints. L-9: Mary Woody’s Notice of Termination of Lease, mentioning events
that never occurred and witnessed by Annette Guilbeault, in a meeting with the Landlord, where
Landlord stated Ms. Woody was seen 2“walking towards a fire alarm”, not that she did anything.
It’s obscenely apparent the Landlord fabricated events, coerced staff to state what they saw, in an
attempt to justify an eviction of someone who complained frequently about material breaches on
the part of the Landlord. L-10: Barfield McCain’s threatening letter to Annette Guilbeault about
evicting her if she allows Plaintiff or her dog into the building. L-11: Annette Guilbeault’s
witness statement/reply to Barfield McCain’s letter.
Purely punitive and an established pattern of conduct. Nota: Plaintiff has dozens of these emails
sent to the Landlord during a period of over 2 years.
Ex M-Plaintiff’s CT Scan, showing pericardial effusion. Nota: No prior history. Commonly a
result of inflammation due to exposure to toxins according to Mayo Clinic. Ex M-1: Plaintiff’s
PCP’s Summary in March of 2024, showing weight loss, damages to her hearing from Meniere’s
attacks, and anxiety to her health. Ex M-2:Art on Asbestos & liver cancer, Ex M-3LStress
Related Results, Ex M-4:Effects of Noise Pollution (Plaintiff’s ENT staff will be called to
testify), Ex M-5-Pericardial Infusion From Toxin Exposure.
Ex N-Final video of walkaround inspection of Plaintiff’s apartment on Aug.31, 2023. Clearly
showing TRG Reg. Manager, Nicole Martinez returning Plaintiff’s security deposit with interest,
and verifying there was no damage caused by Plaintiff as TRG’s lawyer, Barfield McCain , lied
about both in the Non-Renewal of Plaintiff’s Lease & her 7-Day Notice to Vacate. Nota: These
were among several lies used to falsely accuse & evict Plaintiff. N-1: Copy of Returned Security
Deposit to Plaintiff with interest.
Ex O: Proof of Service Summons executed on CSC, Related’s Registered Agent in Tallahassee
on Aug.1, 2023. O-1: Rainbow’s check to as a “donation: towards vet fees for the toxic poisoning
& death of her dog.
Ex P: Letter to Matthew Finkle-Pres. Of Related Affordable, March 13, 2023, P-1-Letter to
David Pearson, VP of Related Affordable, Feb.20, 2023. Nota: Plaintiff has dozens of emails to
Related Affordable’s Matthew Finkle and David Pearson, sent regularly after the August 2022
meeting with David Pearson was never followed up on in any way.
Ex R. Resident Notes: Nota: Please review the fact, that rational, paying adults in an apartment
complex, are too afraid to speak up. The words “fear” and “retaliation” figure in every document,
and Plaintiff has countless more she can provide the Court. These are abnormal and illegal,
provable facts about the Landlord. R: Mike Blumenau’s Letter To Mr. Pearson he requested from
Plaintiff. (She has contemporaneous notes, emails and call logs), his Notice To Cure, given to
Plaintiff, his Violations Report cited against Landlord, also given to Plaintiff, R-1 :Emails about
Jack Hairston’s bribery, from Mike McCarty and Annette Guilbeault, R-2:From Wanda Woolums
on outside agency confirming unsafe levels of asbestos and silica to the Landlord, and her emails
on elevator violations to Channel 12 reporter. R-3: Tony Ross stopping Plaintiff to relay asbestos
info and ask for help. R-4: Mike McCarthy’s email to Plaintiff, including letter to the media for
help. R-5: Email from Plaintiff to the Landlord, including comments from other residents
complaining. R-6: Richard Harrison’s complaint. Given to Mike McCarthy and Plaintiff,
speaking of all the issues and the fear of retaliation by the Landlord, if anyone complains. R-7:
Annette Guilbeault’s emails to Plaintiff, (Plaintiff apologizes for handwritten comments, but has
no other copies), complaining about rude management, staff quitting and mentioning the
additional health concerns she’s now suffering. R-8: “Dorothy Brown’s emails to Landlord and
Plaintiff about corruption, racism, punitive retaliation, fabricated allegations, blackmail, theft and
bribery. * This existed years before the Plaintiff arrived, see Witness List. Ex R-9: Residents’
online comments. Ex R-10: John Wilson’s Ask and Response from Plaintiff.
Jo-Anne Sparta vs Related Aff, SA Res Pres,TRG & Michael Blumenau
#50-2023-CA012067-XXXX-MB
Ex A: Notice of a Non-Renewal of Lease. A-1: Cease and Desist to Barfield and McCain. A-2
Notice of Material Non-Compliance. A-3: Plaintiff’s Affidavit and Rebuttal of Notice of Material
Non-Compliance. A- 4: Notice of Your Residence/Plaintiff’s Rebuttal attached with letter of
Feb.20th to Landlord’s David Pearson. A-5: Plaintiff’s flyer for residents who requested help after
nearly a week. off and on. no elevator during the month of May. (Landlord claims the flyer
damaged the property. (Corroborated by Inspectors’ reports, Plaintiff’s exhibits,
contemporaneous notes). Ex A-6: Defendant’s 7-Day Notice to Vacate, issued to Plaintiff on
Aug.23, 2023. Ex A-7-Michaels Blumenau’s Reply of Aug.14, 2023, Ex A-8: Plaintiff’s
Response to Defendant Blumenau’s Reply, Ex A-9: Defendant’s WPB Code Violations given to
the Plaintiff when he asked for her help. Ex A-10: Defendant Blumenau’s threatening letter from
TRG, given to Plaintiff when he asked her to write a letter in response. Ex A-11: Letter to Ms.
Rivera given to Defendant Blumenau, at his request for help. Ex A-12: Letter to David Pearson
that Plaintiff wrote when Defendant Blumenau asked for her help. Nota-Plaintiff had Cease &
Desists against TRG & SA Res Pres staff, & had not dealt with the for months, advising
Defendant Blumenau to contact Mr. Pearson if he wanted results, since that who ultimately made
all onsite decisions.) See Exhibits L below)
Ex B. Dept. Of Health- Mr. Morales’ email. B-1-video of Plaintiff’s apt on June 20, 2022. B-2-
Landlord’s Notice of Asbestos (17 days after they notified the Dept. of Health.). B-3-Landlord’s
false email that Plaintiff had not been exposed to asbestos.
Ex C. Demand Letter, Ex C, Amended Costs, Ex C-1-Revised through May 31, 2024, & Letter,
Ex C-2, Petition For An Injunction For The Protection Of A Vulnerable Adult, Ex C-3.
Ex D. Inspectors’ Reports-HUD & WPB Code Enforcement stating failure to remediate asbestos-
months later. D-1 Report Analysis confirming asbestos/silica levels on windowsills above FDA-
acceptable levels. D-2-Video depicting Plaintiff’s windowsills and rest of damages in December
of 2022.
Ex E. Videos of Flaking dust, chronic leaks containing asbestos. Kitchen-Videos Ex E, Alcove-
Video Ex E-1.
Ex F. Citation, Ex F-1, article on elevator woes; F-2. Inspection report, Ex F-3, Plaintiff’s email
to management, Ex F-4, Video Ex F-5-Raining in the elevator on a regular and continued basis.
Ex G. Videos of roof drilling, Video Ex G, and G-1.
Ex H. -a 1.5 million-dollar fine for corruption and bribery levied against Landlord’s CEO and
V.P., H-1 Rainbow Corp, part owner, in an attempt with Landlord’s efforts to bribe and silence
Plaintiff after her dog was poisoned. Ex H-2, confirming the bribe by Landlord to Jack Hairston,
(See also Ex R-1 below for emails from 2 residents confirming Jack accepted a bribe to move out
& shut up), Ex R H3, with a listing of the many Related Companies fines, violations, citations
and more, and Ex H-4 about the common practice of harming, provoking, then threatening
residents who complain about legitimate Material Breaches of Contract.
Ex L. Landlord’s collection of harassing, threatening, frivolously aggressively letters replete with
unsubstantiated, false and defamatory, abusive allegations, in an ongoing harassment campaign
to frighten, intimidate and silence Plaintiff for requesting the Landlord to comply with their legal
obligations, and Plaintiff’s Rebuttals: L-1: Cease and Desist: Evelyn Agosto, Landlord’s
Manager. L-2: Cease and Desist: Doug Zimmer, Landlord’s Reg. Mgr. L-3: Sheila Salmon’s
Letter with Plaintiff’s rebuttal in red, concerning fabricated, aggressive, and unfounded
allegations about Plaintiff’s ESA canine. L-4: Marilyn Pascual’s letter with Plaintiff’s rebuttal in
red, concerning a plethora of alleged violations, none with evidentiary standing. L-5: Cease and
Desist for Marilyn Pascual. L-6: Letter on June 20th to Landlord. *Please view Video Ex B-1 for
the conditions prompting the letter, and review how many times Plaintiff was asked to pack her
things and leave her apt, without notice of start/finish dates.
This can be verified by workmen. L-7: Letter from Landlord to Plaintiff, in another aggressive
bullying tactic, and Plaintiff’s rebuttal, including comments about no elevators, Plaintiff’s
residents’ petition in recognition of her and her canine’s actual comportment., and other resident
observations. L-8: Ms. Montejo’s refusal to accurately investigate the landlord’s corruption and
bullying, and subsequent false allegations accusing the Plaintiff of violating her lease with
legitimate complaints. L-9: Mary Woody’s Notice of Termination of Lease, mentioning events
that never occurred and witnessed by Annette Guilbeault, in a meeting with the Landlord, where
Landlord stated Ms. Woody was seen 2“walking towards a fire alarm”, not that she did anything.
It’s obscenely apparent the Landlord fabricated events, coerced staff to state what they saw, in an
attempt to justify an eviction of someone who complained frequently about material breaches on
the part of the Landlord. L-10: Barfield McCain’s threatening letter to Annette Guilbeault about
evicting her if she allows Plaintiff or her dog into the building. L-11: Annette Guilbeault’s
witness statement/reply to Barfield McCain’s letter.
Purely punitive and an established pattern of conduct. Nota: Plaintiff has dozens of these emails
sent to the Landlord during a period of over 2 years.
Ex M-Plaintiff’s CT Scan, showing pericardial effusion. Nota: No prior history. Commonly a
result of inflammation due to exposure to toxins according to Mayo Clinic. Ex M-1: Plaintiff’s
PCP’s Summary in March of 2024, showing weight loss, damages to her hearing from Meniere’s
attacks, and anxiety to her health. Ex M-2:Art on Asbestos & liver cancer, Ex M-3LStress
Related Results, Ex M-4:Effects of Noise Pollution (Plaintiff’s ENT staff will be called to
testify), Ex M-5-Pericardial Infusion From Toxin Exposure.
Ex N-Final video of walkaround inspection of Plaintiff’s apartment on Aug.31, 2023. Clearly
showing TRG Reg. Manager, Nicole Martinez returning Plaintiff’s security deposit with interest,
and verifying there was no damage caused by Plaintiff as TRG’s lawyer, Barfield McCain , lied
about both in the Non-Renewal of Plaintiff’s Lease & her 7-Day Notice to Vacate. Nota: These
were among several lies used to falsely accuse & evict Plaintiff. N-1: Copy of Returned Security
Deposit to Plaintiff with interest.
Ex O: Proof of Service Summons executed on CSC, Related’s Registered Agent in Tallahassee
on Aug.1, 2023. O-1: Rainbow’s check to as a “donation: towards vet fees for the toxic poisoning
& death of her dog.
Ex P: Letter to Matthew Finkle-Pres. Of Related Affordable, March 13, 2023, P-1-Letter to
David Pearson, VP of Related Affordable, Feb.20, 2023. Nota: Plaintiff has dozens of emails to
Related Affordable’s Matthew Finkle and David Pearson, sent regularly after the August 2022
meeting with David Pearson was never followed up on in any way.
Ex R. Resident Notes: Nota: Please review the fact, that rational, paying adults in an apartment
complex, are too afraid to speak up. The words “fear” and “retaliation” figure in every document,
and Plaintiff has countless more she can provide the Court. These are abnormal and illegal,
provable facts about the Landlord. R: Mike Blumenau’s Letter To Mr. Pearson he requested from
Plaintiff. (She has contemporaneous notes, emails and call logs), his Notice To Cure, given to
Plaintiff, his Violations Report cited against Landlord, also given to Plaintiff, R-1 :Emails about
Jack Hairston’s bribery, from Mike McCarty and Annette Guilbeault, R-2:From Wanda Woolums
on outside agency confirming unsafe levels of asbestos and silica to the Landlord, and her emails
on elevator violations to Channel 12 reporter. R-3: Tony Ross stopping Plaintiff to relay asbestos
info and ask for help. R-4: Mike McCarthy’s email to Plaintiff, including letter to the media for
help. R-5: Email from Plaintiff to the Landlord, including comments from other residents
complaining. R-6: Richard Harrison’s complaint. Given to Mike McCarthy and Plaintiff,
speaking of all the issues and the fear of retaliation by the Landlord, if anyone complains. R-7:
Annette Guilbeault’s emails to Plaintiff, (Plaintiff apologizes for handwritten comments, but has
no other copies), complaining about rude management, staff quitting and mentioning the
additional health concerns she’s now suffering. R-8: “Dorothy Brown’s emails to Landlord and
Plaintiff about corruption, racism, punitive retaliation, fabricated allegations, blackmail, theft and
bribery. * This existed years before the Plaintiff arrived, see Witness List. Ex R-9: Residents’
online comments. Ex R-10: John Wilson’s Ask and Response from Plaintiff.