Does anyone have any thoughts/experience/guidance on the following: 1) Defendant made unpermitted improvements exceeding $100k to property (no permits or NOC) 2) Unpermitted improvements (appears to be air conditioned living space) also included below flood plain grade improvemetns, thereby making the improvements ineligible for permit (some would say illegal) 3) Plaintiff placed unrelated lien on property 4) Defendant claims physical damages to property from recent storm to the "uninsured space" 5) Defendant is now claiming the inability to obtain a loan to make repairs due to plaintiff's lien My thought is that to the extent the unpermitted physical damages were incurred, those damages are void due to the illegal nature of the improvements. Any applicable statutory, common law, or local ordinance is appreciated. Thank you. Sincerely, Paul J. Kelly Paul J. Kelly, P.A. 2959 First Avenue North St. Petersburg, Florida 33713 (727) 327-3935 cid:image006153c.jpg CONFIDENTIALITY NOTICE: A law firm is sending this message; This e-mail message including attachments, if any, is intended only 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 e-mail, destroy all copies of the original message, and do not disseminate it 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. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication, unless expressly stated otherwise, was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein. P Think Green! Unless necessary, please do not print this email.