Lawsuit Documents – Public

JUMP TO: Plaintiff’s Documents and Exhibits (By Laws, Rules, etc.) | Defendants’ Documents

These documents are available in the Anne Arundel County Circuit Courthouse in Annapolis, MD for anyone to view. They are public documents. The case number is 02-C-08-132379 IJ.

You can conveniently view them here in PDF form so you don’t have to hike down to the courthouse. I will try to scan and post Defendants’ filed and public court documents, as well. Then you can easily read both sides, and review the defense purchased with your money.

1. Complaint for Injunction – First Complaint

2. Ex Parte Motion for Temporary Restraining Order

3. Plaintiff’s Motion to Substitute Service of Process, Affirm Sufficiency of Evaded Service of Process and Request for Expedited Summary Relief

4. Response and Opposition to Defendant Association’s Motion to Dismiss for Insufficiency of Service of Process

5. Response and Opposition to Defendant Frankhouser’s Motion to Dismiss Complaint

6. Request for Discovery of Documents to All Directors

7. Request for Discovery of Documents – Association, Comanco, Ruth Angell

8. Interrogatories to All Directors and the Association

9. Interrogatories to Comanco and Ruth Angell

10. Request for Expedited Ruling on Ripe Motions, Declaratory Judgement and Default Judgement, with Supplementary Brief to Plaintiff’s Motion to Substitute

11. Amended Complaint for Injunctive Relief

12. Motion for Sanctions and to Compel Discovery

13. Motion to Strike Frankhouser Discovery and Interrogatories

14. Motion for Receiver

15. Request for Default Judgement on Motion for Sanctions and to Compel Discovery

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Here are some exhibits that are in the public record.

1. Charing Cross By-laws

2. Charing Cross Rules & Regulations

3. Charing Cross Articles of Incorporation

4. Charing Cross Condominium Declaration

 

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This is what our money is buying us. I represent myself (pro se), but I’m paying for their defense right along with the rest of you. Remember, President Joe said at the
9/23/08 meeting that we’re also paying for Comanco’s and Ruth Angell’s lawyer, Callahan & Callahan. Pretty surreal just to compel this Board to respect and honor our governing laws…

1. Motion to Dismiss for Insufficiency of Service of Process (Read my Response)

2. Answer to Plaintiff’s Complaint – Comanco (Counsel Callahan for Comanco…according to Pres. Joe, we’re paying for this)

3. Answer to Plaintiff’s Complaint – Ruth Angell (Counsel Callahan for Manager Ruth Angell…according to Pres. Joe, we’re paying for this)

4. Defendant Carol Frankhouser’s Motion to Dismiss Complaint (Assoc. Counsel Curley) Read my response here.

5. Board’s Attorney’s June 10, 2009 Letter Detailing Failure to Insure Association (their reason why members have to pay their legal expenses above and beyond the annual assessment)