HOA Justice Now

Keystone Complaint – 2024 DBPR Filing That Exposed Systemic HOA Misconduct and Millions in City Fines


Summary

This Keystone Complaint, formally submitted to the Florida Department of Business and Professional Regulation (DBPR) in April 2024, exposed more than $400,000 in concealed fines in October 2023 Board Meeting on video, unlicensed contractor activity dating back to 2007, and active retaliation by Omega Villas Board members. Supporting exhibits and attached correspondence reveal not only HOA misconduct, but systemic regulatory failure by both the City of Plantation and the State of Florida.

This page documents the supporting evidence that traces back to unlicensed contractor work in 2008 β€” and government complaints dating as far back as 2007 β€” including attached correspondence that highlights regulatory failure by both City and State authorities. It reveals a pattern of cover-ups, retaliation, and financial mismanagement that has created serious legal exposure for the community. These broken systems and behaviors persist through 2024. The projected fines for just one subdivision (Phase 2) could exceed $2 million by the time renovations are complete.

This page serves as the foundation for all future disclosures, exhibits, and legal actions tied to this case.

This archive exists to help residents, oversight agencies, and financial institutions understand the scope of the harm and push for state or federal investigation.


Formal Complaint Overview

  • Filed: April 11, 2024
  • Complainant: Shawn Martin, MBA
  • Target: 2023–2024 Omega Villas Condominium Board
  • Key Allegations:
    • Failure to disclose ongoing City liens and fines
    • Retaliatory actions against a whistleblower
    • Use of unlicensed contractors leading to fines
    • Waste of HOA funds and legal overreach
    • Violation of Florida Condominium Law and due process

Documents:


Exhibit Archive

Each exhibit listed below was submitted in support of the 2024 DBPR complaint. Direct links to each document, video, or supporting file can be embedded here as appropriate.

Exhibit 1: Connecting All the Dots

An index summary explaining the entire body of evidence submitted with the complaint.

  • Exhibit 1A – Overview of Florida Condominium Law violations and HOA financial growth from $500,000 to over $1.3 million in annual income. Link
  • Exhibit 1B – Board meeting video footage with summaries of each video. Link
  • Exhibit 1C – Evidence from 2008–2009 of unlicensed contractors and improper permitting that led to City fines. Link
  • Exhibit 1D – Financial documents showing roof repair spending that failed to correct the damage. Link
  • Exhibit 1E – Evidence packets sent to owners in 2023 detailing years of mismanagement and WhatsApp group interference by Board officers. Link
  • Exhibit 1F – Ongoing issues with Austro Construction and coercion involving window replacements. Link
  • Exhibit 1G – Notices and communications to law enforcement and regulatory agencies from 2023 to 2024. Link
  • Exhibit 1H – CPA and Board attempts to undermine whistleblower actions, including a misinformation letter mailed to owners. Link

Exhibit 2: 2007 Legal Correspondence

Attorney letters related to unlicensed work by Gould Roofing, including the Board’s failure to remedy cited work despite commitments to do so. Link

Exhibit 3: City of Plantation Citations

Full set of code violations and corresponding documentation from 2009–2010. Includes check images signed by Board members. Link

Exhibit 4: Fine Breakdown Analysis

A comparative summary showing the disparity in daily fines assessed to each phase of the community. Phase 2 is projected to owe $1.1 to $1.7 million of the total $2.1 million in fines. Link

Exhibit 5: State Attorney Engagement

Records of communication with the Broward County State Attorney’s Office regarding the history of roof damage, retaliation, and recommendations to file a police report for potential financial crimes. Link

Exhibit 6: Discovery of Active Liens

Evidence that liens from the City of Plantation were being incurred since 2022, and that the Board failed to disclose them until after being publicly confronted in October 2023. Link


Whistleblower Statement

β€œI filed this complaint because the pattern of deception, retaliation, and financial misconduct has gone unchecked for over 15 years. The failure to address known code violations and unlicensed work has endangered owners financially and structurally. The time for transparency and accountability is long overdue.”
β€” Shawn Martin, MBA


Additional Resources