Last Updated
Purpose:
To document the timeline of interior unit access requests made by the Association and its vendors, and to demonstrate that Shawn Martin cooperated reasonably while being subjected to retaliatory and coercive conduct by Association counsel and representatives.
Timeline of Events
Early April 2025 – Legal Retaliation Pattern
Prior to the April 17–30 access conflict, Mr. Martin submitted a formal supplemental complaint to the Department of Business and Professional Regulation (DBPR) on April 13, 2025, titled “Supplemental Complaint – Legal Misconduct and Records Obstruction by HOA Counsel Rhonda Hollander.”
This message detailed how Association counsel’s actions since 2023—using legal communications to obstruct records access, escalate costs, and target a whistleblowing owner—had already been reported to the DBPR, the Florida Bar, and multiple oversight officials.
- 📄 Supporting File: “RICO Hollander Supplemental Complaint 4-13-25.pdf”
Key points summarized in that correspondence:
- Delayed records access and excessive legal fees imposed after a lawful owner records request.
- Direct involvement by Attorney Rhonda Hollander in correspondence and meetings that appeared intended to intimidate or discredit the complainant.
- Reference to Florida Statute § 718.1224 (Anti-SLAPP) noting that the association may not use funds to retaliate against an owner for exercising protected rights.
- Cross-references to supporting videos and filings documenting confrontations, attorney communications, and Florida Bar Complaint RFA No. 24-13708.
This April 13 complaint lays the groundwork for the retaliation theme carried through the remainder of April—culminating in the access conflict (April 17–21) and subsequent escalation to state authorities (April 30).
- April 13, 2025 – Access Notice Placed
Austro Construction representative Dorin Frai placed a written notice on Mr. Martin’s door requesting interior entry. - April 17, 2025 – Email Request and Complaint Withdrawal Attempt
Mr. Frai emailed Mr. Martin requesting access to photograph drywall and asking that he withdraw his active DBPR complaint.
This created an apparent conflict between vendor cooperation and owner rights.
📄 Supporting File: “Dorin Email 4-18-25.pdf” - April 17 – 19 – Owner Response and Conditions
Mr. Martin confirmed access under reasonable conditions: proper identification, minimal personnel, and permission to record the inspection for safety documentation. - April 21, 2025 – Morning Confirmation
Mr. Martin reiterated in person to Dorin Frai that access would be granted under the same reasonable parameters. - April 21, 2025 – Afternoon Legal Escalation
Association attorney Rhonda Hollander issued a broad email to over twenty recipients alleging obstruction and fiduciary breach despite prior confirmation of access.
The tone and scope of that message appeared retaliatory and disproportionate.
📄 Supporting File: “Dorin to Hollander to State Authorities Issue 4-21-25 Official.pdf” - Monday, April 21, 2025 (Afternoon)
Association Attorney Rhonda Hollander sends a threatening, retaliatory email to Mr. Martin and more than 20 copied parties, falsely accusing him of obstructing access, breaching fiduciary duty, and causing project delays.- Her message included misuse of case law and exaggerated claims (e.g., “18 emails sent today”), inflaming the situation rather than resolving it.
- Following April 20, 2025
In response to Hollander’s hostile escalation and legal threats, Mr. Martin indicated he may seek judicial clarification regarding the scope and conditions of entry — a defensive measure prompted by retaliation, not obstruction. - April 21, 2025 – Owner Response to Authorities
Mr. Martin notified DBPR, the Inspector General, and legislative offices of the incident, providing his inspection boundaries document and video footage showing that access had been granted but not used by Austro’s crew. - April 30, 2025 – Formal Oversight Escalation
Mr. Martin followed up with state and federal oversight agencies summarizing continuing retaliation and absence of corrective action.
📄 Supporting File: “Gmail – Re Escalation of Legal Investigations 4-30-25.pdf”
Video Evidence
Summary
- Mr. Martin never denied access and repeatedly acted in good faith.
- Association counsel and vendors escalated through group emails and pressure tactics inconsistent with fair governance.
- Documentation shows a continuous line of communication to oversight authorities, reinforcing lawful whistleblower conduct and transparency.
These supporting files substantiate that Exhibit G reflects both cooperation and retaliation during April 2025, forming a cornerstone for the broader record of owner rights violations and governance failure at Omega Villas.