Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
Three Rivers Legal Services is looking for a pro bono construction
attorney volunteer to assist with the defense of a lien foreclosure action
for a 90 year old woman (Ernestine Stokes) who co-owns her home with her
daughter in Alachua County. The solar installation company (Solar
Installation, Inc/Christopher Green) is attempting to enforce a lien in
excess of 70K for a 1000 square foot home. The work is not complete and
appears to have been performed without a permit and was solicited in a door
to door sale. For conflict purposes, the roofing company on the permit is
360 Degreez Consulting, LLC/Ulysees Rushing.
Three Rivers is currently representing the client, so this volunteer role
could either be mentoring the staff attorney, appearing as co-counsel, or
taking over the case. Three Rivers narrative follows and a copy of the
complaint is attached hereto.
Please contact Samantha Howell, the Pro Bono Director of Three Rivers Legal
Services at
samantha.howell@trls.org with a copy to pamela@anastasialaw.net
pamela@anastasialaw.net for the CLC Pro Bono Initiative or contact me
directly with any questions regarding the Pro Bono Initiative.
"The client and her daughter hired a roofing company to replace
their roof. While the company was waiting for supplies to arrive,
a solar panel company came to the home and asked the client's daughter to
sign a Notice of Commencement. The daughter did so, thinking that the
person was with the roofing company. The solar company replaced
the roof and left unconnected solar panels on the roof. The next day, the
roofing company called the client advising that the supplies had arrived.
The client was confused, as she thought the roofing company was who had
been working on the roof. The roofing company had already received a check
from the insurance company for the work and had pulled permits. The roof
permit estimated the cost of work at appx $7500. The solar panel company is
now suing the client for over $70k.
The issues that we see include: client did not sign the Notice of
Commencement; the Complaint for Construction Lien/
Foreclosure does not include a contract between either named party and
the solar panel company; the roofing company did not return the insurance
money. The client asked the court for an extension to file an answer on
7/31/23 (Judge Moseley), but there has not been an order issued yet. The
Plaintiffs filed a Motion for [Clerk's] Default on 8/18/23. [Three Rivers
filed an answer before a clerk's default was entered].
Pam Holcombe
Chair, CLC Pro Bono Initiative
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243
fax: (904) 239-5505
email: pamela@anastasialaw.net
www.anastasialaw.net
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY BE
A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR,
ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS
STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN
E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR
YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless
there is an express representation agreement between the firm and the
client. Absent such express agreement, submission of information by email
does not constitute attorney-client communication nor does the firm's
receipt of email create an attorney-client relationship. Please do not
send any confidential information unless we have first agreed to be your
attorney such information may not be protected from disclosure.
I can try to help.
Bob
Robert P. Butts, Esq.
Board Certified as a Specialist in Construction Law
WARNER, SECHREST & BUTTS, P.A.
5200 S.W. 91st Terrace, Suite 101
Gainesville, FL 32608
Telephone: (352) 373-5922
Facsimile: (352) 373-5921
Electronic mail: rbutts@fbswlaw.commailto:rbutts@fbswlaw.com; bob@floridaconstructionlaw.netmailto:bob@floridaconstructionlaw.net
The preceding electronic mail message (including any attachments) contains information the sender deems confidential and constitutes non-public information. It is intended to be conveyed only to the designated recipient(s). If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete it from your system. Any use, dissemination, distribution, or reproduction of the foregoing electronic mail (including any attachments) by unintended recipients is not authorized by the sender and may be unlawful. Thank you for your cooperation.
From: clc-discussion-bounces@lists.flabarrpptl.org clc-discussion-bounces@lists.flabarrpptl.org On Behalf Of RPPTL CLC-Discussion
Sent: Tuesday, October 31, 2023 12:03 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
Three Rivers Legal Services is looking for a pro bono construction attorney volunteer to assist with the defense of a lien foreclosure action for a 90 year old woman (Ernestine Stokes) who co-owns her home with her daughter in Alachua County. The solar installation company (Solar Installation, Inc/Christopher Green) is attempting to enforce a lien in excess of 70K for a 1000 square foot home. The work is not complete and appears to have been performed without a permit and was solicited in a door to door sale. For conflict purposes, the roofing company on the permit is 360 Degreez Consulting, LLC/Ulysees Rushing.
Three Rivers is currently representing the client, so this volunteer role could either be mentoring the staff attorney, appearing as co-counsel, or taking over the case. Three Rivers narrative follows and a copy of the complaint is attached hereto.
Please contact Samantha Howell, the Pro Bono Director of Three Rivers Legal Services at
samantha.howell@trls.orgmailto:samantha.howell@trls.org with a copy to pamela@anastasialaw.netmailto:pamela@anastasialaw.net for the CLC Pro Bono Initiative or contact me directly with any questions regarding the Pro Bono Initiative.
"The client and her daughter hired a roofing company to replace their roof. While the company was waiting for supplies to arrive, a solar panel company came to the home and asked the client's daughter to sign a Notice of Commencement. The daughter did so, thinking that the person was with the roofing company. The solar company replaced the roof and left unconnected solar panels on the roof. The next day, the roofing company called the client advising that the supplies had arrived. The client was confused, as she thought the roofing company was who had been working on the roof. The roofing company had already received a check from the insurance company for the work and had pulled permits. The roof permit estimated the cost of work at appx $7500. The solar panel company is now suing the client for over $70k.
The issues that we see include: client did not sign the Notice of Commencement; the Complaint for Construction Lien/Foreclosure does not include a contract between either named party and the solar panel company; the roofing company did not return the insurance money. The client asked the court for an extension to file an answer on 7/31/23 (Judge Moseley), but there has not been an order issued yet. The Plaintiffs filed a Motion for [Clerk's] Default on 8/18/23. [Three Rivers filed an answer before a clerk's default was entered].
Pam Holcombe
Chair, CLC Pro Bono Initiative
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243tel:%28904%29%20236-6243
fax: (904) 239-5505tel:%28904%29%20239-5505
email: pamela@anastasialaw.netmailto:pamela@anastasialaw.net
www.anastasialaw.nethttp://www.anastasialaw.net/
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless there is an express representation agreement between the firm and the client. Absent such express agreement, submission of information by email does not constitute attorney-client communication nor does the firm's receipt of email create an attorney-client relationship. Please do not send any confidential information unless we have first agreed to be your attorney such information may not be protected from disclosure.
We’ve had companies doing this kind of thing in Tallahassee. Our City Commission has brought it up at a recent meeting. They were overpricing and financing and causing people to lose their homes. I’m going to try to find some information about this that might be helpful.
Sent from my iPhone
On Oct 31, 2023, at 3:41 PM, RPPTL CLC-Discussion clc-discussion@lists.flabarrpptl.org wrote:
I can try to help.
Bob
Robert P. Butts, Esq.
Board Certified as a Specialist in Construction Law
WARNER, SECHREST & BUTTS, P.A.
5200 S.W. 91st Terrace, Suite 101
Gainesville, FL 32608
Telephone: (352) 373-5922
Facsimile: (352) 373-5921
Electronic mail: rbutts@fbswlaw.commailto:rbutts@fbswlaw.com; bob@floridaconstructionlaw.netmailto:bob@floridaconstructionlaw.net
The preceding electronic mail message (including any attachments) contains information the sender deems confidential and constitutes non-public information. It is intended to be conveyed only to the designated recipient(s). If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete it from your system. Any use, dissemination, distribution, or reproduction of the foregoing electronic mail (including any attachments) by unintended recipients is not authorized by the sender and may be unlawful. Thank you for your cooperation.
From: clc-discussion-bounces@lists.flabarrpptl.org clc-discussion-bounces@lists.flabarrpptl.org On Behalf Of RPPTL CLC-Discussion
Sent: Tuesday, October 31, 2023 12:03 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
Three Rivers Legal Services is looking for a pro bono construction attorney volunteer to assist with the defense of a lien foreclosure action for a 90 year old woman (Ernestine Stokes) who co-owns her home with her daughter in Alachua County. The solar installation company (Solar Installation, Inc/Christopher Green) is attempting to enforce a lien in excess of 70K for a 1000 square foot home. The work is not complete and appears to have been performed without a permit and was solicited in a door to door sale. For conflict purposes, the roofing company on the permit is 360 Degreez Consulting, LLC/Ulysees Rushing.
Three Rivers is currently representing the client, so this volunteer role could either be mentoring the staff attorney, appearing as co-counsel, or taking over the case. Three Rivers narrative follows and a copy of the complaint is attached hereto.
Please contact Samantha Howell, the Pro Bono Director of Three Rivers Legal Services at
samantha.howell@trls.orgmailto:samantha.howell@trls.org with a copy to pamela@anastasialaw.netmailto:pamela@anastasialaw.net for the CLC Pro Bono Initiative or contact me directly with any questions regarding the Pro Bono Initiative.
"The client and her daughter hired a roofing company to replace their roof. While the company was waiting for supplies to arrive, a solar panel company came to the home and asked the client's daughter to sign a Notice of Commencement. The daughter did so, thinking that the person was with the roofing company. The solar company replaced the roof and left unconnected solar panels on the roof. The next day, the roofing company called the client advising that the supplies had arrived. The client was confused, as she thought the roofing company was who had been working on the roof. The roofing company had already received a check from the insurance company for the work and had pulled permits. The roof permit estimated the cost of work at appx $7500. The solar panel company is now suing the client for over $70k.
The issues that we see include: client did not sign the Notice of Commencement; the Complaint for Construction Lien/Foreclosure does not include a contract between either named party and the solar panel company; the roofing company did not return the insurance money. The client asked the court for an extension to file an answer on 7/31/23 (Judge Moseley), but there has not been an order issued yet. The Plaintiffs filed a Motion for [Clerk's] Default on 8/18/23. [Three Rivers filed an answer before a clerk's default was entered].
Pam Holcombe
Chair, CLC Pro Bono Initiative
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243tel:%28904%29%20236-6243
fax: (904) 239-5505tel:%28904%29%20239-5505
email: pamela@anastasialaw.netmailto:pamela@anastasialaw.net
www.anastasialaw.nethttp://www.anastasialaw.net/
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless there is an express representation agreement between the firm and the client. Absent such express agreement, submission of information by email does not constitute attorney-client communication nor does the firm's receipt of email create an attorney-client relationship. Please do not send any confidential information unless we have first agreed to be your attorney such information may not be protected from disclosure.
CLC-Discussion mailing list
CLC-Discussion@lists.flabarrpptl.org
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Can you circulate a copy of the lien for input on any potential deficiencies.
Sincerely,
Barry Kalmanson
500 N. Maitland Avenue
Suite 305
Maitland, Fl. 32751
407-645-4500 x 215
From: clc-discussion-bounces@lists.flabarrpptl.org clc-discussion-bounces@lists.flabarrpptl.org On Behalf Of RPPTL CLC-Discussion
Sent: Tuesday, October 31, 2023 3:52 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: Re: [CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
We’ve had companies doing this kind of thing in Tallahassee. Our City Commission has brought it up at a recent meeting. They were overpricing and financing and causing people to lose their homes. I’m going to try to find some information about this that might be helpful.
Sent from my iPhone
On Oct 31, 2023, at 3:41 PM, RPPTL CLC-Discussion <clc-discussion@lists.flabarrpptl.orgmailto:clc-discussion@lists.flabarrpptl.org> wrote:
I can try to help.
Bob
Robert P. Butts, Esq.
Board Certified as a Specialist in Construction Law
WARNER, SECHREST & BUTTS, P.A.
5200 S.W. 91st Terrace, Suite 101
Gainesville, FL 32608
Telephone: (352) 373-5922
Facsimile: (352) 373-5921
Electronic mail: rbutts@fbswlaw.commailto:rbutts@fbswlaw.com; bob@floridaconstructionlaw.netmailto:bob@floridaconstructionlaw.net
The preceding electronic mail message (including any attachments) contains information the sender deems confidential and constitutes non-public information. It is intended to be conveyed only to the designated recipient(s). If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete it from your system. Any use, dissemination, distribution, or reproduction of the foregoing electronic mail (including any attachments) by unintended recipients is not authorized by the sender and may be unlawful. Thank you for your cooperation.
From: clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org <clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org> On Behalf Of RPPTL CLC-Discussion
Sent: Tuesday, October 31, 2023 12:03 PM
To: clc-discussion@lists.flabarrpptl.orgmailto:clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
Three Rivers Legal Services is looking for a pro bono construction attorney volunteer to assist with the defense of a lien foreclosure action for a 90 year old woman (Ernestine Stokes) who co-owns her home with her daughter in Alachua County. The solar installation company (Solar Installation, Inc/Christopher Green) is attempting to enforce a lien in excess of 70K for a 1000 square foot home. The work is not complete and appears to have been performed without a permit and was solicited in a door to door sale. For conflict purposes, the roofing company on the permit is 360 Degreez Consulting, LLC/Ulysees Rushing.
Three Rivers is currently representing the client, so this volunteer role could either be mentoring the staff attorney, appearing as co-counsel, or taking over the case. Three Rivers narrative follows and a copy of the complaint is attached hereto.
Please contact Samantha Howell, the Pro Bono Director of Three Rivers Legal Services at
samantha.howell@trls.orgmailto:samantha.howell@trls.org with a copy to pamela@anastasialaw.netmailto:pamela@anastasialaw.net for the CLC Pro Bono Initiative or contact me directly with any questions regarding the Pro Bono Initiative.
"The client and her daughter hired a roofing company to replace their roof. While the company was waiting for supplies to arrive, a solar panel company came to the home and asked the client's daughter to sign a Notice of Commencement. The daughter did so, thinking that the person was with the roofing company. The solar company replaced the roof and left unconnected solar panels on the roof. The next day, the roofing company called the client advising that the supplies had arrived. The client was confused, as she thought the roofing company was who had been working on the roof. The roofing company had already received a check from the insurance company for the work and had pulled permits. The roof permit estimated the cost of work at appx $7500. The solar panel company is now suing the client for over $70k.
The issues that we see include: client did not sign the Notice of Commencement; the Complaint for Construction Lien/Foreclosure does not include a contract between either named party and the solar panel company; the roofing company did not return the insurance money. The client asked the court for an extension to file an answer on 7/31/23 (Judge Moseley), but there has not been an order issued yet. The Plaintiffs filed a Motion for [Clerk's] Default on 8/18/23. [Three Rivers filed an answer before a clerk's default was entered].
Pam Holcombe
Chair, CLC Pro Bono Initiative
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243tel:%28904%29%20236-6243
fax: (904) 239-5505tel:%28904%29%20239-5505
email: pamela@anastasialaw.netmailto:pamela@anastasialaw.net
www.anastasialaw.nethttp://www.anastasialaw.net/
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless there is an express representation agreement between the firm and the client. Absent such express agreement, submission of information by email does not constitute attorney-client communication nor does the firm's receipt of email create an attorney-client relationship. Please do not send any confidential information unless we have first agreed to be your attorney such information may not be protected from disclosure.
CLC-Discussion mailing list
CLC-Discussion@lists.flabarrpptl.orgmailto:CLC-Discussion@lists.flabarrpptl.org
http://mailman.fsr.com/mailman/listinfo/clc-discussion
Thank you to Robert Butts for offering to assist with this matter.
We see the same issues here in St. Johns County, so I look forward to the
Tallahassee information.
Thank you
Pam Holcombe
On Tue, Oct 31, 2023 at 3:52 PM RPPTL CLC-Discussion <
clc-discussion@lists.flabarrpptl.org> wrote:
We’ve had companies doing this kind of thing in Tallahassee. Our City
Commission has brought it up at a recent meeting. They were overpricing and
financing and causing people to lose their homes. I’m going to try to find
some information about this that might be helpful.
Sent from my iPhone
On Oct 31, 2023, at 3:41 PM, RPPTL CLC-Discussion <
clc-discussion@lists.flabarrpptl.org> wrote:
I can try to help.
Bob
Robert P. Butts, Esq.
Board Certified as a Specialist in Construction Law
WARNER, SECHREST & BUTTS, P.A.
5200 S.W. 91st Terrace, Suite 101
Gainesville, FL 32608
Telephone: (352) 373-5922
Facsimile: (352) 373-5921
Electronic mail: rbutts@fbswlaw.com; bob@floridaconstructionlaw.net
The preceding electronic mail message (including any attachments) contains
information the sender deems confidential and constitutes non-public
information. It is intended to be conveyed only to the designated
recipient(s). If you are not an intended recipient of this message, please
notify the sender by replying to this message and then delete it from your
system. Any use, dissemination, distribution, or reproduction of the
foregoing electronic mail (including any attachments) by unintended
recipients is not authorized by the sender and may be unlawful. Thank you
for your cooperation.
From: clc-discussion-bounces@lists.flabarrpptl.org <
clc-discussion-bounces@lists.flabarrpptl.org> *On Behalf Of *RPPTL
CLC-Discussion
Sent: Tuesday, October 31, 2023 12:03 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Pro bono assistance - 90 year old client
-Alachua lien foreclosure - Three Rivers Legal Services
Three Rivers Legal Services is looking for a pro bono construction
attorney volunteer to assist with the defense of a lien foreclosure action
for a 90 year old woman (Ernestine Stokes) who co-owns her home with her
daughter in Alachua County. The solar installation company (Solar
Installation, Inc/Christopher Green) is attempting to enforce a lien in
excess of 70K for a 1000 square foot home. The work is not complete and
appears to have been performed without a permit and was solicited in a door
to door sale. For conflict purposes, the roofing company on the permit is
360 Degreez Consulting, LLC/Ulysees Rushing.
Three Rivers is currently representing the client, so this volunteer role
could either be mentoring the staff attorney, appearing as co-counsel, or
taking over the case. Three Rivers narrative follows and a copy of the
complaint is attached hereto.
Please contact Samantha Howell, the Pro Bono Director of Three Rivers
Legal Services at
samantha.howell@trls.org with a copy to pamela@anastasialaw.net
pamela@anastasialaw.net for the CLC Pro Bono Initiative or contact me
directly with any questions regarding the Pro Bono Initiative.
"The client and her daughter hired a roofing company to replace
their roof. While the company was waiting for supplies to arrive,
a solar panel company came to the home and asked the client's daughter to
sign a Notice of Commencement. The daughter did so, thinking that the
person was with the roofing company. The solar company replaced
the roof and left unconnected solar panels on the roof. The next day, the
roofing company called the client advising that the supplies had arrived.
The client was confused, as she thought the roofing company was who had
been working on the roof. The roofing company had already received a check
from the insurance company for the work and had pulled permits. The roof
permit estimated the cost of work at appx $7500. The solar panel company is
now suing the client for over $70k.
The issues that we see include: client did not sign the Notice of
Commencement; the Complaint for Construction Lien/Foreclosure does not
include a contract between either named party and the solar panel company;
the roofing company did not return the insurance money. The client asked
the court for an extension to file an answer on 7/31/23 (Judge Moseley),
but there has not been an order issued yet. The Plaintiffs filed a Motion
for [Clerk's] Default on 8/18/23. [Three Rivers filed an answer before a
clerk's default was entered].
Pam Holcombe
Chair, CLC Pro Bono Initiative
--
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243
fax: (904) 239-5505
email: pamela@anastasialaw.net
www.anastasialaw.net
--
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY
BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR,
ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS
STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN
E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR
YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless
there is an express representation agreement between the firm and the
client. Absent such express agreement, submission of information by email
does not constitute attorney-client communication nor does the firm's
receipt of email create an attorney-client relationship. Please do not
send any confidential information unless we have first agreed to be your
attorney such information may not be protected from disclosure.
CLC-Discussion mailing list
CLC-Discussion@lists.flabarrpptl.org
http://mailman.fsr.com/mailman/listinfo/clc-discussion
CLC-Discussion mailing list
CLC-Discussion@lists.flabarrpptl.org
http://mailman.fsr.com/mailman/listinfo/clc-discussion
--
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243
fax: (904) 239-5505
email: pamela@anastasialaw.net
www.anastasialaw.net
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY BE
A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR,
ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS
STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN
E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR
YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless
there is an express representation agreement between the firm and the
client. Absent such express agreement, submission of information by email
does not constitute attorney-client communication nor does the firm's
receipt of email create an attorney-client relationship. Please do not
send any confidential information unless we have first agreed to be your
attorney such information may not be protected from disclosure.
Florida Statute 825.103 – Exploitation of an Elderly Person may also be applicable
Paul J. Kelly
Paul J. Kelly, P.A.
2959 First Avenue North
St. Petersburg, Florida 33713
[Board Certified Construction Logo]
Confidentiality Notice: A law firm is sending this message. This email message including attachments, if any, is intended for the person or entity to which it is addressed and may contain confidential and or privileged material. Any unauthorized review, use, disclosure, or distribution or use of the contents of this information is prohibited. If you are not the intended recipient, please contact the sender by reply email, destroy all copies of the original message, and do not disseminate further. This message may not be reviewed, printed, displayed, or re-transmitted, without the sender's consent. All rights protected. There may be no further distribution or publication of this communication or its contents without the express consent of this law firm.
From: clc-discussion-bounces@lists.flabarrpptl.org clc-discussion-bounces@lists.flabarrpptl.org On Behalf Of RPPTL CLC-Discussion
Sent: Tuesday, October 31, 2023 12:03 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
Three Rivers Legal Services is looking for a pro bono construction attorney volunteer to assist with the defense of a lien foreclosure action for a 90 year old woman (Ernestine Stokes) who co-owns her home with her daughter in Alachua County. The solar installation company (Solar Installation, Inc/Christopher Green) is attempting to enforce a lien in excess of 70K for a 1000 square foot home. The work is not complete and appears to have been performed without a permit and was solicited in a door to door sale. For conflict purposes, the roofing company on the permit is 360 Degreez Consulting, LLC/Ulysees Rushing.
Three Rivers is currently representing the client, so this volunteer role could either be mentoring the staff attorney, appearing as co-counsel, or taking over the case. Three Rivers narrative follows and a copy of the complaint is attached hereto.
Please contact Samantha Howell, the Pro Bono Director of Three Rivers Legal Services at
samantha.howell@trls.orgmailto:samantha.howell@trls.org with a copy to pamela@anastasialaw.netmailto:pamela@anastasialaw.net for the CLC Pro Bono Initiative or contact me directly with any questions regarding the Pro Bono Initiative.
"The client and her daughter hired a roofing company to replace their roof. While the company was waiting for supplies to arrive, a solar panel company came to the home and asked the client's daughter to sign a Notice of Commencement. The daughter did so, thinking that the person was with the roofing company. The solar company replaced the roof and left unconnected solar panels on the roof. The next day, the roofing company called the client advising that the supplies had arrived. The client was confused, as she thought the roofing company was who had been working on the roof. The roofing company had already received a check from the insurance company for the work and had pulled permits. The roof permit estimated the cost of work at appx $7500. The solar panel company is now suing the client for over $70k.
The issues that we see include: client did not sign the Notice of Commencement; the Complaint for Construction Lien/Foreclosure does not include a contract between either named party and the solar panel company; the roofing company did not return the insurance money. The client asked the court for an extension to file an answer on 7/31/23 (Judge Moseley), but there has not been an order issued yet. The Plaintiffs filed a Motion for [Clerk's] Default on 8/18/23. [Three Rivers filed an answer before a clerk's default was entered].
Pam Holcombe
Chair, CLC Pro Bono Initiative
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243tel:%28904%29%20236-6243
fax: (904) 239-5505tel:%28904%29%20239-5505
email: pamela@anastasialaw.netmailto:pamela@anastasialaw.net
www.anastasialaw.nethttp://www.anastasialaw.net/
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless there is an express representation agreement between the firm and the client. Absent such express agreement, submission of information by email does not constitute attorney-client communication nor does the firm's receipt of email create an attorney-client relationship. Please do not send any confidential information unless we have first agreed to be your attorney such information may not be protected from disclosure.
You will likely also find grounds to rescind the loan documents. The lender needs to be placed on notice of her claims.
[cid:image002.jpg@01DA0C1C.35436DC0]
Sherry A. Lambson-Eisele
Partner- Business Litigation Practice Group Leader
Boyd & Jenerette, P.A.
2290 Lucien Way, Suite 260
Maitland, FL 32751
Office: (407) 309-4760 x621
Direct: (407) 309-4758
Cell: (407) 405-8801
www.boydjen.comhttp://www.boydjen.com
Download vCardhttp://www.boydjen.com/wp-content/uploads/2019/05/Sherry-A-Eisele.vcf
From: clc-discussion-bounces@lists.flabarrpptl.org clc-discussion-bounces@lists.flabarrpptl.org On Behalf Of RPPTL CLC-Discussion
Sent: Tuesday, October 31, 2023 4:53 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: Re: [CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
Florida Statute 825.103 – Exploitation of an Elderly Person may also be applicable
Paul J. Kelly
Paul J. Kelly, P.A.
2959 First Avenue North
St. Petersburg, Florida 33713
[Board Certified Construction Logo]
Confidentiality Notice: A law firm is sending this message. This email message including attachments, if any, is intended for the person or entity to which it is addressed and may contain confidential and or privileged material. Any unauthorized review, use, disclosure, or distribution or use of the contents of this information is prohibited. If you are not the intended recipient, please contact the sender by reply email, destroy all copies of the original message, and do not disseminate further. This message may not be reviewed, printed, displayed, or re-transmitted, without the sender's consent. All rights protected. There may be no further distribution or publication of this communication or its contents without the express consent of this law firm.
From: clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org <clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org> On Behalf Of RPPTL CLC-Discussion
Sent: Tuesday, October 31, 2023 12:03 PM
To: clc-discussion@lists.flabarrpptl.orgmailto:clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
Three Rivers Legal Services is looking for a pro bono construction attorney volunteer to assist with the defense of a lien foreclosure action for a 90 year old woman (Ernestine Stokes) who co-owns her home with her daughter in Alachua County. The solar installation company (Solar Installation, Inc/Christopher Green) is attempting to enforce a lien in excess of 70K for a 1000 square foot home. The work is not complete and appears to have been performed without a permit and was solicited in a door to door sale. For conflict purposes, the roofing company on the permit is 360 Degreez Consulting, LLC/Ulysees Rushing.
Three Rivers is currently representing the client, so this volunteer role could either be mentoring the staff attorney, appearing as co-counsel, or taking over the case. Three Rivers narrative follows and a copy of the complaint is attached hereto.
Please contact Samantha Howell, the Pro Bono Director of Three Rivers Legal Services at
samantha.howell@trls.orgmailto:samantha.howell@trls.org with a copy to pamela@anastasialaw.netmailto:pamela@anastasialaw.net for the CLC Pro Bono Initiative or contact me directly with any questions regarding the Pro Bono Initiative.
"The client and her daughter hired a roofing company to replace their roof. While the company was waiting for supplies to arrive, a solar panel company came to the home and asked the client's daughter to sign a Notice of Commencement. The daughter did so, thinking that the person was with the roofing company. The solar company replaced the roof and left unconnected solar panels on the roof. The next day, the roofing company called the client advising that the supplies had arrived. The client was confused, as she thought the roofing company was who had been working on the roof. The roofing company had already received a check from the insurance company for the work and had pulled permits. The roof permit estimated the cost of work at appx $7500. The solar panel company is now suing the client for over $70k.
The issues that we see include: client did not sign the Notice of Commencement; the Complaint for Construction Lien/Foreclosure does not include a contract between either named party and the solar panel company; the roofing company did not return the insurance money. The client asked the court for an extension to file an answer on 7/31/23 (Judge Moseley), but there has not been an order issued yet. The Plaintiffs filed a Motion for [Clerk's] Default on 8/18/23. [Three Rivers filed an answer before a clerk's default was entered].
Pam Holcombe
Chair, CLC Pro Bono Initiative
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243tel:%28904%29%20236-6243
fax: (904) 239-5505tel:%28904%29%20239-5505
email: pamela@anastasialaw.netmailto:pamela@anastasialaw.net
https://link.edgepilot.com/s/4f82b26b/SWRnkftnAUSj1pKPkDh8QQ?u=http://www.anastasialaw.net/
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless there is an express representation agreement between the firm and the client. Absent such express agreement, submission of information by email does not constitute attorney-client communication nor does the firm's receipt of email create an attorney-client relationship. Please do not send any confidential information unless we have first agreed to be your attorney such information may not be protected from disclosure.
Boyd & Jenerette utilizes spam and junk email filtration applications in its email information systems. These systems may prevent or delay delivery of certain email communications. If you do not receive a timely response to an email communication, please contact the intended recipient via phone.
CONFIDENTIALITY NOTICE: The information and all attachments contained in this electronic communication are legally privileged and confidential information, subject to the attorney-client privilege and intended only for the use of the intended recipients. If the reader of this message is not an intended recipient, you are hereby notified that any review, use, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately of the error by return email and please permanently remove any copies of this message from your system and do not retain any copies, whether in electronic or physical form or otherwise.
Thanks all for the input. I ensure all these additional excellent points
are provided to counsel.
A copy of the claim of lien is attached as an exhibit B on the last page of
the complaint, which is attached hereto for ease of reference.
On Tue, Oct 31, 2023 at 5:05 PM RPPTL CLC-Discussion <
clc-discussion@lists.flabarrpptl.org> wrote:
You will likely also find grounds to rescind the loan documents. The
lender needs to be placed on notice of her claims.
Sherry A. Lambson-Eisele
Partner- Business Litigation Practice Group Leader
Boyd & Jenerette, P.A.
2290 Lucien Way, Suite 260
Maitland, FL 32751
Office: (407) 309-4760 x621
Direct: (407) 309-4758
Cell: (407) 405-8801
Download vCard
http://www.boydjen.com/wp-content/uploads/2019/05/Sherry-A-Eisele.vcf
From: clc-discussion-bounces@lists.flabarrpptl.org <
clc-discussion-bounces@lists.flabarrpptl.org> *On Behalf Of *RPPTL
CLC-Discussion
Sent: Tuesday, October 31, 2023 4:53 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: Re: [CLC-Discussion] Pro bono assistance - 90 year old client
-Alachua lien foreclosure - Three Rivers Legal Services
Florida Statute 825.103 – Exploitation of an Elderly Person may also be
applicable
Paul J. Kelly
Paul J. Kelly, P.A.
2959 First Avenue North
St. Petersburg, Florida 33713
[image: Board Certified Construction Logo]
Confidentiality Notice: A law firm is sending this message. This email
message including attachments, if any, is intended for the person or entity
to which it is addressed and may contain confidential and or privileged
material. Any unauthorized review, use, disclosure, or distribution or use
of the contents of this information is prohibited. If you are not the
intended recipient, please contact the sender by reply email, destroy all
copies of the original message, and do not disseminate further. This
message may not be reviewed, printed, displayed, or re-transmitted, without
the sender's consent. All rights protected. There may be no further
distribution or publication of this communication or its contents without
the express consent of this law firm.
From: clc-discussion-bounces@lists.flabarrpptl.org <
clc-discussion-bounces@lists.flabarrpptl.org> *On Behalf Of *RPPTL
CLC-Discussion
Sent: Tuesday, October 31, 2023 12:03 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Pro bono assistance - 90 year old client
-Alachua lien foreclosure - Three Rivers Legal Services
Three Rivers Legal Services is looking for a pro bono construction
attorney volunteer to assist with the defense of a lien foreclosure action
for a 90 year old woman (Ernestine Stokes) who co-owns her home with her
daughter in Alachua County. The solar installation company (Solar
Installation, Inc/Christopher Green) is attempting to enforce a lien in
excess of 70K for a 1000 square foot home. The work is not complete and
appears to have been performed without a permit and was solicited in a door
to door sale. For conflict purposes, the roofing company on the permit is
360 Degreez Consulting, LLC/Ulysees Rushing.
Three Rivers is currently representing the client, so this volunteer role
could either be mentoring the staff attorney, appearing as co-counsel, or
taking over the case. Three Rivers narrative follows and a copy of the
complaint is attached hereto.
Please contact Samantha Howell, the Pro Bono Director of Three Rivers
Legal Services at
samantha.howell@trls.org with a copy to pamela@anastasialaw.net
pamela@anastasialaw.net for the CLC Pro Bono Initiative or contact me
directly with any questions regarding the Pro Bono Initiative.
"The client and her daughter hired a roofing company to replace
their roof. While the company was waiting for supplies to arrive,
a solar panel company came to the home and asked the client's daughter to
sign a Notice of Commencement. The daughter did so, thinking that the
person was with the roofing company. The solar company replaced
the roof and left unconnected solar panels on the roof. The next day, the
roofing company called the client advising that the supplies had arrived.
The client was confused, as she thought the roofing company was who had
been working on the roof. The roofing company had already received a check
from the insurance company for the work and had pulled permits. The roof
permit estimated the cost of work at appx $7500. The solar panel company is
now suing the client for over $70k.
The issues that we see include: client did not sign the Notice of
Commencement; the Complaint for Construction Lien/Foreclosure does not
include a contract between either named party and the solar panel company;
the roofing company did not return the insurance money. The client asked
the court for an extension to file an answer on 7/31/23 (Judge Moseley),
but there has not been an order issued yet. The Plaintiffs filed a Motion
for [Clerk's] Default on 8/18/23. [Three Rivers filed an answer before a
clerk's default was entered].
Pam Holcombe
Chair, CLC Pro Bono Initiative
--
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243
fax: (904) 239-5505
email: pamela@anastasialaw.net
https://link.edgepilot.com/s/4f82b26b/SWRnkftnAUSj1pKPkDh8QQ?u=http://www.anastasialaw.net/
--
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY
BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR,
ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS
STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN
E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR
YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless
there is an express representation agreement between the firm and the
client. Absent such express agreement, submission of information by email
does not constitute attorney-client communication nor does the firm's
receipt of email create an attorney-client relationship. Please do not
send any confidential information unless we have first agreed to be your
attorney such information may not be protected from disclosure.
Boyd & Jenerette utilizes spam and junk email filtration applications in
its email information systems. These systems may prevent or delay delivery
of certain email communications. If you do not receive a timely response to
an email communication, please contact the intended recipient via phone.
CONFIDENTIALITY NOTICE: The information and all attachments contained in
this electronic communication are legally privileged and confidential
information, subject to the attorney-client privilege and intended only for
the use of the intended recipients. If the reader of this message is not an
intended recipient, you are hereby notified that any review, use,
dissemination, distribution, or copying of this communication is strictly
prohibited. If you have received this communication in error, please notify
us immediately of the error by return email and please permanently remove
any copies of this message from your system and do not retain any copies,
whether in electronic or physical form or otherwise.
CLC-Discussion mailing list
CLC-Discussion@lists.flabarrpptl.org
http://mailman.fsr.com/mailman/listinfo/clc-discussion
--
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243
fax: (904) 239-5505
email: pamela@anastasialaw.net
www.anastasialaw.net
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY BE
A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR,
ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS
STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN
E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR
YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless
there is an express representation agreement between the firm and the
client. Absent such express agreement, submission of information by email
does not constitute attorney-client communication nor does the firm's
receipt of email create an attorney-client relationship. Please do not
send any confidential information unless we have first agreed to be your
attorney such information may not be protected from disclosure.
Happy to assist. Please feel free to give me a call.
Ryan A. Weiss
Corporate Counsel | OKO Group, LLC
4100 NE 2nd Avenue
Suite 307
Miami, Florida 33137
rweiss@okogroup.commailto:rweiss@okogroup.com
Tel: +1 (305) 800-1000 ext. 317
Cell: +1 (561) 632-3090
From: clc-discussion-bounces@lists.flabarrpptl.org clc-discussion-bounces@lists.flabarrpptl.org on behalf of RPPTL CLC-Discussion clc-discussion@lists.flabarrpptl.org
Date: Tuesday, October 31, 2023 at 5:44 PM
To: clc-discussion@lists.flabarrpptl.org clc-discussion@lists.flabarrpptl.org
Subject: Re: [CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
CAUTION:Message from external sender
Thanks all for the input. I ensure all these additional excellent points are provided to counsel.
A copy of the claim of lien is attached as an exhibit B on the last page of the complaint, which is attached hereto for ease of reference.
On Tue, Oct 31, 2023 at 5:05 PM RPPTL CLC-Discussion <clc-discussion@lists.flabarrpptl.orgmailto:clc-discussion@lists.flabarrpptl.org> wrote:
You will likely also find grounds to rescind the loan documents. The lender needs to be placed on notice of her claims.
[cid:ii_18b87a068e85b006a1]
Sherry A. Lambson-Eisele
Partner- Business Litigation Practice Group Leader
Boyd & Jenerette, P.A.
2290 Lucien Way, Suite 260
Maitland, FL 32751
Office: (407) 309-4760 x621
Direct: (407) 309-4758
Cell: (407) 405-8801
www.boydjen.comhttp://www.boydjen.com
Download vCardhttp://www.boydjen.com/wp-content/uploads/2019/05/Sherry-A-Eisele.vcf
From: clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org <clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org> On Behalf Of RPPTL CLC-Discussion
Sent: Tuesday, October 31, 2023 4:53 PM
To: clc-discussion@lists.flabarrpptl.orgmailto:clc-discussion@lists.flabarrpptl.org
Subject: Re: [CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
Florida Statute 825.103 – Exploitation of an Elderly Person may also be applicable
Paul J. Kelly
Paul J. Kelly, P.A.
2959 First Avenue North
St. Petersburg, Florida 33713
[Board Certified Construction Logo]
Confidentiality Notice: A law firm is sending this message. This email message including attachments, if any, is intended for the person or entity to which it is addressed and may contain confidential and or privileged material. Any unauthorized review, use, disclosure, or distribution or use of the contents of this information is prohibited. If you are not the intended recipient, please contact the sender by reply email, destroy all copies of the original message, and do not disseminate further. This message may not be reviewed, printed, displayed, or re-transmitted, without the sender's consent. All rights protected. There may be no further distribution or publication of this communication or its contents without the express consent of this law firm.
From: clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org <clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org> On Behalf Of RPPTL CLC-Discussion
Sent: Tuesday, October 31, 2023 12:03 PM
To: clc-discussion@lists.flabarrpptl.orgmailto:clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services
Three Rivers Legal Services is looking for a pro bono construction attorney volunteer to assist with the defense of a lien foreclosure action for a 90 year old woman (Ernestine Stokes) who co-owns her home with her daughter in Alachua County. The solar installation company (Solar Installation, Inc/Christopher Green) is attempting to enforce a lien in excess of 70K for a 1000 square foot home. The work is not complete and appears to have been performed without a permit and was solicited in a door to door sale. For conflict purposes, the roofing company on the permit is 360 Degreez Consulting, LLC/Ulysees Rushing.
Three Rivers is currently representing the client, so this volunteer role could either be mentoring the staff attorney, appearing as co-counsel, or taking over the case. Three Rivers narrative follows and a copy of the complaint is attached hereto.
Please contact Samantha Howell, the Pro Bono Director of Three Rivers Legal Services at
samantha.howell@trls.orgmailto:samantha.howell@trls.org with a copy to pamela@anastasialaw.netmailto:pamela@anastasialaw.net for the CLC Pro Bono Initiative or contact me directly with any questions regarding the Pro Bono Initiative.
"The client and her daughter hired a roofing company to replace their roof. While the company was waiting for supplies to arrive, a solar panel company came to the home and asked the client's daughter to sign a Notice of Commencement. The daughter did so, thinking that the person was with the roofing company. The solar company replaced the roof and left unconnected solar panels on the roof. The next day, the roofing company called the client advising that the supplies had arrived. The client was confused, as she thought the roofing company was who had been working on the roof. The roofing company had already received a check from the insurance company for the work and had pulled permits. The roof permit estimated the cost of work at appx $7500. The solar panel company is now suing the client for over $70k.
The issues that we see include: client did not sign the Notice of Commencement; the Complaint for Construction Lien/Foreclosure does not include a contract between either named party and the solar panel company; the roofing company did not return the insurance money. The client asked the court for an extension to file an answer on 7/31/23 (Judge Moseley), but there has not been an order issued yet. The Plaintiffs filed a Motion for [Clerk's] Default on 8/18/23. [Three Rivers filed an answer before a clerk's default was entered].
Pam Holcombe
Chair, CLC Pro Bono Initiative
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243tel:%28904%29%20236-6243
fax: (904) 239-5505tel:%28904%29%20239-5505
email: pamela@anastasialaw.netmailto:pamela@anastasialaw.net
https://link.edgepilot.com/s/4f82b26b/SWRnkftnAUSj1pKPkDh8QQ?u=http://www.anastasialaw.net/https://link.edgepilot.com/s/4f82b26b/SWRnkftnAUSj1pKPkDh8QQ?u=http://www.anastasialaw.net/
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless there is an express representation agreement between the firm and the client. Absent such express agreement, submission of information by email does not constitute attorney-client communication nor does the firm's receipt of email create an attorney-client relationship. Please do not send any confidential information unless we have first agreed to be your attorney such information may not be protected from disclosure.
Boyd & Jenerette utilizes spam and junk email filtration applications in its email information systems. These systems may prevent or delay delivery of certain email communications. If you do not receive a timely response to an email communication, please contact the intended recipient via phone.
CONFIDENTIALITY NOTICE: The information and all attachments contained in this electronic communication are legally privileged and confidential information, subject to the attorney-client privilege and intended only for the use of the intended recipients. If the reader of this message is not an intended recipient, you are hereby notified that any review, use, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately of the error by return email and please permanently remove any copies of this message from your system and do not retain any copies, whether in electronic or physical form or otherwise.
CLC-Discussion mailing list
CLC-Discussion@lists.flabarrpptl.orgmailto:CLC-Discussion@lists.flabarrpptl.org
http://mailman.fsr.com/mailman/listinfo/clc-discussionhttp://mailman.fsr.com/mailman/listinfo/clc-discussion
--
Pamela M.M. Holcombe, Esq.
Anastasia Law, PL
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243tel:%28904%29%20236-6243
fax: (904) 239-5505tel:%28904%29%20239-5505
email: pamela@anastasialaw.net
www.anastasialaw.nethttp://www.anastasialaw.net
NOTICE TO RECIPIENT: THIS E-MAIL IS FOR INTENDED RECIPIENT ONLY AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVE THIS E-MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND DELETE THE MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION.
There is no attorney-client relationship with Anastasia Law, P.L. unless there is an express representation agreement between the firm and the client. Absent such express agreement, submission of information by email does not constitute attorney-client communication nor does the firm's receipt of email create an attorney-client relationship. Please do not send any confidential information unless we have first agreed to be your attorney such information may not be protected from disclosure.
