Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
vs.
BAY PORT COLONY PROPERTY OWNERS
ASSOCIATION, INC., a Florida Corporation, and
QUALIFIED PROPERTY MANAGEMENT, INC., a
Florida Corporation,
Defendants.
________________________________________/
FIRST AMENDED COMPLAINT
COMES NOW, Plaintiffs, RUGH CLINE, an Individual, ELIZABETH
CLINE, an Individual, KIMBERLY DURHAM, an Individual, RODNEY
DURHAM, an Individual, and STEVE FEHR, an Individual, by and through the
undersigned counsel, files this, Amended Complaint against Defendants, BAY
PORT
COLONY
PROPERTY
OWNERS
ASSOCIATION,
INC.
and
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pursuant to Chapter 86, Florida Statutes; and for damages in excess of $15,000.
2.
wife and residents of Hillsborough County, Florida, and are over the age of 18
years.
3.
husband and wife and residents of Hillsborough County, Florida, and are over the
age of 18 years.
4.
Defendant,
BAY
PORT
COLONY
PROPERTY
OWNERS
This Court has jurisdiction over this action because this complaint
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located in Hillsborough County, Florida, and (ii) the causes of action at issue
accrued in this County.
GENERAL ALLEGATIONS
9.
The Bay Port Colony Phase II, Unit II subdivision (Bay Port Colony
subdivision) was originally platted in or about 1977. See Plat Book 48, Page 6,
of the Public Records of Hillsborough County, Florida.
10.
The Bay Port Colony subdivision contains 137 home lots situated
south of West Hillsborough Avenue, with its entrance road being Longboat
Boulevard in Hillsborough County, Florida. A site map of the subdivision is
attached as Exhibit A.
11.
the subdivision that lead to Channel A and the navigable waters of Tampa Bay.
12.
Tampa, Inc.
13.
Walter J. Wright.
14.
the Declaration of Restrictions for the Bay Port Colony Subdivision in Official
-3-
The Grantor Declarations applied to all lots in the Bay Port Colony
subdivision and provided that [a]ll easements hereafter granted for such purposes
by the undersigned shall be strictly observed and shall not be in any manner
obstructed so as to hinder any such easements.
17.
Plaintiffs each own a home lot in the Bay Port Colony subdivision.
18.
owners of a home located at 5805 Galleon Way, Tampa, FL 33615. The legal
description of their home is as follows:
Lot 59, Bayport Colony Phase II, Unit II, According to the Map or Plat
Thereof, Recorded in Plat Book 48, Page 6, of the Public Records of
Hillsborough County, Florida.
The warranty deed conveying title to Plaintiffs Cline is located Official Records
Book 21397, Page 1937 in the Public Records of Hillsborough County, Florida.
19.
Alfred Howard, on or about July 25, 1977, through a warranty deed issued by
W.J.W. Company of Tampa, Inc. See Official Records Book 3262, Page 60 in the
Public Records of Hillsborough County, Florida.
-4-
20.
owners of a home located at 6102 Schooner Way, Tampa, FL 33615. The legal
description of the home is as follows:
Lot 125, Bayport Colony Phase II, Unit II, According to the Map or Plat
Thereof, Recorded in Plat Book 48, Page 6, of the Public Records of
Hillsborough County, Florida.
The warranty deed conveying title to Plaintiffs Durham is located Official Records
Book 11833, Page 1185 in the Public Records of Hillsborough County, Florida.
21.
interest, James Dee, on or about June 29, 1979, though a warranty deed issued by
W.J.W. Company of Tampa, Inc. See Official Records Book 3530, Page 1981 in
the Public Records of Hillsborough County, Florida.
22.
-5-
Company of Tampa, Inc. See Official Records Book 3471, Page 1174 in the
Public Records of Hillsborough County, Florida.
24.
grantor, and subject to the restrictions of record at that time, which would have
been the Grantor Declarations.
25.
property.
26.
The land boundaries for Plaintiffs lots extend to the ordinary mean-
Plaintiffs lots extend into the waterways, and Plaintiffs have title to
The plat of the subdivision reflects that the waterways are designated
Waterway Drainage Easement. See attached Exhibit B, Plat Book 48, Page 6,
of the Public Records of Hillsborough County, Florida. The plat specifically
states that all rights-of-way, canals, ditches, and other easements are
dedicated to public use. These waterways connect to Channel A that then runs to
the navigable waters of Tampa Bay.
29.
waterways to exercise their riparian rights and for boat access to the waters of
Tampa Bay from their home lots.
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30.
Before Plaintiffs can reach the waters of Tampa Bay from their home
lots, their boats must travel under the public road of Longboat Boulevard and
through a boatlift located next to that road.
31.
For the past 35 years, Plaintiffs and their predecessors have enjoyed
the use of the boatlift for ingress and egress to the waters of Tampa Bay from their
individual home lots within the Bay Port Colony subdivision.
32.
In 1978, the Bay Port Colony Property Owners Association, Inc. (the
35.
36.
began the process of having the 137 home lots in the Bay Port Colony subdivision
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obtained joinder agreements for approximately 98 of the 137 home lots in the Bay
Port Colony subdivision. There were 39 home lots that never executed a joinder
agreement with the Association, and thus, those lots were never made subject to
the Association Declarations.
38.
Plaintiffs each own one of the 39 unencumbered home lots in the Bay
Notwithstanding the fact that 39 home lots never entered into joinder
agreements, the Association and its agents have repeatedly represented that the
lots are bound by the Association Declarations.
40.
Over the years, the Association has charged HOA fees, imposed fines,
renew its Declarations and Articles of Incorporation. This effort was prompted by
the requirements of Chapter 712, Florida Statutes (otherwise known as the
Marketable Record Title Act (MRTA)).
-8-
42.
Board of Directors became aware that 39 lots within the Bay Port Colony
subdivision had never been bound by the Declarations.
43.
Despite its actual knowledge in 2011 that 39 lots were not bound by
the Association Declaration, the Association withheld this information and, either
directly or through its agents, continued to charge HOA fees, impose fines,
demand repairs and alterations to properties, and foreclose on property relating to
these 39 lot owners.
44.
Association in collecting HOA fees, imposing fines, and demanding repairs and
alterations relating to these 39 lot owners, as well as operating the boatlift.
46.
In or about January 2014, the Association and its agent, for the first
time, disclosed to the 39 lot owners that their property was not actually
encumbered by the Declarations.
47.
deed restriction violations or assess payments against the 39 lot owners, and thus,
the Association demanded that the 39 lot owners execute joinder agreements to
make them subject to the Associations authority.
-9-
Joinder, Consent and Easement, See also attached Exhibit D, January 31, 2014,
Letter from Law Offices of Cianfrone & De Furio, Exhibit E, February 18, 2014,
Letter from Law Offices of Cianfrone & De Furio, Exhibit F, undated Letter
from BPCPOA, Inc., and Exhibit G, August 20, 2014, Letter from Qualified
Property Management, Inc.
48.
As was their right to do, Plaintiffs elected not to execute the Joinder,
The undersigned hereby grants to Bay Port Colony Property Owners Association
and each of its members, and its and their heirs, personal representative,
successors and assigns, a perpetual easement for boating and other recreational
purposes over that portion of the above described real property which is presently
devoted to use as a canal, as shown on the aforesaid plat and designated as
Waterway Drainage Easement thereon.
50.
Easement, Association members continue to utilize their easement for boating and
other recreational purposes over Plaintiffs submerged real property.
51.
and Easement, or to join the Association, the Association made the decision to
change the key lock for the boatlift situated off of the public street of Longboat
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Boulevard, and the Association has refused to grant Plaintiffs a key unless and
until they agree to execute the Joinder, Consent and Easement agreement or
otherwise join the Association.
52.
through the waterways to Channel A and the navigable waters of Tampa Bay,
which interferes with the exercise of Plaintiffs riparian rights and their ability to
conduct maintenance to the rear of their property.
COUNT I
EASEMENT BY IMPLICATION FROM WRITTEN INSTRUMENT
53.
Since the inception of the Bay Port Colony subdivision, Plaintiffs and
their predecessors in interest have used the waterways and boatlift in the
subdivision to access the navigable waters of Tampa Bay.
55.
Plaintiffs properties (Lots 18, 59, and 125) were granted an easement
Longboat Boulevard and the land where the boatlift is located to the public as
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boatlift. While Plaintiffs are not bound by these Declarations, the Association
Declarations reflect the grantors intent that the boatlift would be considered part
of the waterways reflected on the plat and would be available for use by all lot
owners within the subdivision.
59.
Plaintiffs lots include title to land that extends to the ordinary high
watermark of the navigable water, and thus, riparian rights attach to their land.
60.
The plat and the conveyance documents reflect the grantors intent to
create an easement to the waterways running through Bay Port Colony subdivision
and through the boatlift to provide access to the navigable waters of Tampa Bay.
This intent was to apply to all lot owners of the Bay Port Colony subdivision.
61.
The plat and the conveyance documents reflect the grantors intent to
grant Plaintiffs riparian rights of ingress, egress, boating, bathing, and fishing and
such other rights that have been or may be defined by law to all of the navigable
waterways running through Bay Port Colony subdivision and through the boatlift
to provide access to the navigable waters of Tampa Bay.
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62.
Plaintiffs use of its easement by rekeying the boatlift and failing to provide
Plaintiffs with new keys.
64.
of Plaintiffs rights, Plaintiffs have suffered in the past, and will continue to suffer
in the future, direct and consequential damages, including but not limited to, the
loss of the ability to exercise its easement and full riparian rights.
WHEREFORE, Plaintiffs respectfully pray that this Court grant declaratory
and injunctive relief requested herein and award compensatory damages as well as
attorneys fees and costs and such other relief this Court deems just and proper.
COUNT II
STATUTORY WAY OF NECESSITY
65.
The original grantor of Bay Port Colony subdivision intended that the
subdivision residents would have access to the waters of Tampa Bay through the
waterways and boatlift.
67.
predecessors in interest have used the waterways in the Bay Port Colony
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Plaintiffs properties (Lots 18, 59, and 125) were granted an easement
Longboat Boulevard and the land where the boatlift is located to the public as
reflected on Exhibit H, Plat Book 48, Page 4, of the Public Records of
Hillsborough County, Florida.
There is a unity of title to the lands upon which the waterways and
boatlift sit and Plaintiffs lot, until such time as title was separated by the grantor
through the original conveyance of Plaintiffs lots to their predecessors in interest.
71.
The plat and the conveyance documents reflect the grantors intent to
create an easement to the waterways running through Bay Port Colony subdivision
and through the boatlift to provide access to the navigable waters of Tampa Bay.
72.
Plaintiffs property to the navigable waters of Tampa Bay is through the boatlift
constructed by the Grantor.
- 14 -
73.
The only reasonable and practicable way of egress or ingress for work
barges is through the boat lift, and same is reasonably necessary for the beneficial
use or enjoyment of Plaintiffs lots.
75.
the boatlift to access the waters of Tampa Bay from their property for purposes of
exercising their riparian rights and to allow access of work barges to make repairs
to the rear of Plaintiffs lots.
76.
Plaintiffs use of its easement by rekeying the boatlift and failing to provide
Plaintiffs with new keys.
77.
of Plaintiffs rights, Plaintiffs have suffered in the past, and will continue to suffer
in the future, direct and consequential damages, including but not limited to, the
loss of the ability to utilize their easement.
WHEREFORE, Plaintiffs respectfully pray that this Court grant declaratory
and injunctive relief requested herein and award compensatory damages as well as
attorneys fees and costs and such other relief this Court deems just and proper.
COUNT III
RIGHT TO USE BOATLIFT PURSUANT TO STATE LICENSE
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AGREEMENT
78.
predecessors in interest have used the waterways in the Bay Port Colony
subdivision to access the navigable waters of Tampa Bay.
80.
their predecessors in interest have utilized the boatlift to access the navigable
waters of Tampa Bay.
81.
Agreement between Hillsborough County and Bay Port Colony Property Owners
Association Relating to the Use of County Rights-of-Way. See attached Exhibit
I, License Agreement.
82.
on findings that the lands served by Longboat Boulevard . . . are uniquely situated
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with access to fresh and salt water canals, that the roadways involved serve the
Bay Port Colony Subdivision without providing for through access and that the
Facilities will not unduly interfere with the purpose, function, or integrity of the
public right-of-ways . . .
84.
County contemplated that the public would have a right of access to fresh and
salt water canals through the land adjacent to Longboat Boulevard.
85.
Hillsborough County contemplated that the residents of Bay Port Colony would
have a right of access to the public waters of Tampa Bay from their waterfront
homes.
86.
The Association and its agent have violated the License Agreement by
of Plaintiffs rights, Plaintiffs have suffered in the past, and will continue to suffer
in the future, direct and consequential damages, including but not limited to, the
loss of their ability to fully utilize the easement.
WHEREFORE, Plaintiffs respectfully pray that this Court grant declaratory
and injunctive relief requested herein and award compensatory damages as well as
attorneys fees and costs and such other relief this Court deems just and proper.
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COUNT IV
RIGHT TO USE BOATLIFT-EASEMENT BY GRANT
88.
Since the inception of the subdivision, for over 35 years, Plaintiffs and
their predecessors in interest have continuously used the waterways and boatlift in
the Bay Port Colony subdivision to access the navigable waters of Tampa Bay.
90.
Plaintiffs and its predecessors use of the boatlift has been with the
understanding that they have an easement right to use the waterways and boatlift
in the subdivision.
91.
93.
94.
Plaintiffs use of its easement by rekeying the boatlift and failing to provide
Plaintiffs with new access keys.
96.
of Plaintiffs rights, Plaintiffs have suffered in the past, and will continue to suffer
in the future, direct and consequential damages, including but not limited to, the
loss of their ability to fully utilize the easement.
97.
At all material times, the Association knew or should have known that
100.
actions and words, false statements regarding its authority to impose fees and fines
against the Plaintiffs.
102.
The Association knew that its representations were false when made
detriment.
104.
At all material times, the Association knew or should have known that
properties within the Bay Port Colony subdivision, the Association owed a duty to
Plaintiffs to confirm its authority to impose fees and fines against Plaintiffs prior
to it actually demanding payment.
110.
properties within the Bay Port Colony subdivision, the Association owed a duty to
Plaintiffs to confirm its authority to demand repairs and alterations to properties
prior to it actually making such demands.
111.
properties within the Bay Port Colony subdivision, the Association owed a duty to
Plaintiffs to confirm its authority to foreclose on property relating to Plaintiffs
lots prior to it actually taking such actions.
112.
continued representing that the Declarations bound the Plaintiffs when it knew or
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detriment.
114.
At all material times, the Association knew or should have known that
properties within the Bay Port Colony subdivision, the Association owed a duty to
- 22 -
Plaintiffs to confirm its authority to impose fees and fines against Plaintiffs prior
to it actually demanding payment.
117.
properties within the Bay Port Colony subdivision, the Association owed a duty to
Plaintiffs to confirm its authority to demand repairs and alterations to properties
prior to it actually making such demands.
118.
properties within the Bay Port Colony subdivision, the Association owed a duty to
Plaintiffs to confirm its authority to foreclose on property relating to Plaintiffs
lots prior to it actually taking such actions.
119.
continued representing that the Declarations bound the Plaintiffs when it knew or
should have known that this representation was untrue.
120.
HOA fees, imposed fines, demanded repairs and alterations to properties, and
foreclosure on property relating to Plaintiffs lots.
121.
122.
123.
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124.
detriment.
125.
At all material times, the Association knew or should have known that
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publication to third persons against the Plaintiffs property that the Association
knew or reasonably should have known were false.
132.
The Association also sent letters to other lot owners making false
Law Offices of Cianfrone & De Furio, Exhibit E, February 18, 2014, Letter from
Law Offices of Cianfrone & De Furio, Exhibit F, undated Letter from BPCPOA,
Inc., and Exhibit G, August 20, 2014, Letter from Qualified Property
Management, Inc.
133.
properties, the Association sent letters to other lot owners claiming that the
waterways over Plaintiffs submerged lands are a community amenity for the
exclusive use of Association members.
134.
induced others to believe that the properties were subject to the Associations false
instruments and that Plaintiffs were not allowed to exercise their riparian and
easement rights conveyed with their property.
135.
against the properties when it knew or should have known that it lacked the
authority to do so.
136.
owners claiming use of the waterways over Plaintiffs submerged land is restricted
to Association Members when it knew or should have known that it lacked the
authority to make such a claim.
137.
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Plaintiffs have suffered damages, including, but not limited to, special damages in
the form of attorneys fees incurred in removing the cloud from the title to their
property.
138.
At all material times, the Association knew or should have known that
against the title of Plaintiffs property that the Association knew or should have
known was false.
144.
The original grantor of Bay Port Colony subdivision intended that the
subdivision residents would have access to the waters of Tampa Bay through the
waterways and boatlift.
149.
predecessors in interest have used the waterways in the Bay Port Colony
subdivision to access the navigable waters of Tampa Bay.
- 30 -
150.
Plaintiffs properties (Lots 18, 59, and 125) were granted an easement
Longboat Boulevard and the land where the boatlift is located to the public as
reflected on Exhibit H, Plat Book 48, Page 4, of the Public Records of
Hillsborough County, Florida.
There is a unity of title to the lands upon which the waterways and
boatlift sit and Plaintiffs lot, until such time as title was separated by the grantor
through the original conveyance of Plaintiffs lots to their predecessors in interest.
153.
The plat and the conveyance documents reflect the grantors intent to
create an easement to the waterways running through Bay Port Colony subdivision
and through the boatlift to provide access to the navigable waters of Tampa Bay.
154.
Plaintiffs property to the navigable waters of Tampa Bay is through the boatlift
constructed by the Grantor.
155.
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The only reasonable and practicable way of egress or ingress for work
barges is through the boat lift, and same is reasonably necessary for the beneficial
use or enjoyment of Plaintiffs lots.
157.
grant of way of necessity to use the boatlift to access the waters of Tampa Bay
from their property for purposes of exercising their riparian rights and to allow
access of work barges to make repairs to the rear of Plaintiffs lots.
158.
Plaintiffs use of its easement by rekeying the boatlift and failing to provide
Plaintiffs with new keys.
159.
of Plaintiffs rights, Plaintiffs have suffered in the past, and will continue to suffer
in the future, direct and consequential damages, including but not limited to, the
loss of the ability to utilize their easement.
WHEREFORE, Plaintiffs respectfully pray that this Court grant declaratory
and injunctive relief requested herein and award compensatory damages as well as
attorneys fees and costs and such other relief this Court deems just and proper.
COUNT XI
VICARIOUS LIABILITY AGAINST THE ASSOCIATION
- 32 -
160.
At all material times, Qualified Property was acting within the course
and scope of its duties as managing agent of the properties governed by the
Association.
162.
To the extent any of the actions alleged in the above Counts I, II, III,
IV, V, VI, VII, VIII, IX, and X were committed by Qualified Property, those
actions were committed with the permission of and at the direction of the
Association.
163.
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a)
Defendants are in violation of Plaintiffs rights to utilize the easement across the
boatlift;
b)
Plaintiffs title regarding the Association Declarations and declare that Plaintiffs
lots are not bound by those Declarations; and
c)
order requiring Defendants to provide Plaintiffs with access to the boatlift and
prohibiting Defendants from imposing HOA fees or fines against Plaintiffs.
DEMAND FOR JURY TRIAL
Plaintiffs demand a trial by jury on all issues so triable by right.
Dated: November 20, 2015
/s/Henry G. Gyden
Henry G. Gyden, Esq.
Florida Bar No.: 158127
GYDEN LAW GROUP, P.A.
1228 East 7th Ave.
Suite 200
Tampa, Florida 33605
Telephone: (813) 493-4181
Facsimile: (813) 337-0244 FAX
hgyden@gydenlaw.com
Attorney for Plaintiffs
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by filing with ePortal this 20st day of November, 2015, to:
Gregory D. Jones, Esq.
Garrett M. Brown, Esq.
Rywant, Alvarez, Jones, Russo & Guyton, P.A.
109 N. Brush Street
Suite 500
Tampa, FL 33602
gjones@rywantalvarez.com
gbrown@rywantalvarez.com
mkeni@rywantalvarez.com
acalderon@rywantalvarez.com
- 35 -
BARRIER
Exhibit A
EXHIBIT B
EXHIBIT B
EXHIBIT C
LAW OFFICES OF
Dan@.attomcvioe.com
January 3 I , 2014
To Owners Within Bay Port Colony Phase II, Unit II
Dear Owners:
Our firm represents Bay Port Colony Property Owners Association, Inc., the Homeowners
Association created to operate the residential community of Bay Port Colony.
As you know, membership in the Bay Port Colony Property Owners Association provides
numerous benefits, including use of the community's amenities such as boat lift, waterways,
expedited electronic gate access, participation in Association events and clubs; and use of the
tennis courts, dog run, pig roast area, and play grounds. Your annual assessment to the
Association pays not only for these amenities, but also for around the clock gate services,
manicured entry ways and common areas, a professional property manager, enforcement of the
deed restrictions, and maintenance of the canal and lake. These amenities and services serve to
enhance and preserve the value of your home and the homes that surround you, and make your
residence in the community more enjoyable. In addition, only Association members may vote in
the annual election and on critical issues affecting the community. For these reasons, and many
others, the Association wants to encourage your assistance in ensuring that the Association's
governing documents bind and/or remain in place as to all lots within Bay Port Colony.
An organizing committee has been established to ensure that the governing documents for Bay
Port properly include every lot and continue to do so. The names, addresses, and telephone
numbers of the owners making up the organizing committee are as follows:
Name
Address
Name
Address
Name
Address
Phone
Phone
Phone
Encl0i5ed please find a copy of the applicable Declaration of Covenants, Conditions and
Restrictions of Bay Port Colony Property Owners Association, along with the Articles of
Incorporation and By-Laws for Bay Port Colony Property Owners Association, Inc., and any
recorded amendments relative to same, and any other documents required by law.
In accordance with Chapter 712, Florida Statutes, or general real estate law, as applicable,
written consents or joindcrs, as applicable are being sought from the owners within enclosed plat.
A written consent or joinder form, as applicable, is enclosed for your use. Please fully complete
and have the record owners of your Lot sign and date the enclosed consent or joinder form,
indicating your approval to continue and/or bind the restrictions to the relevant lots. Please then
Exhibit D
IVcserve1-yrcserver3\Wl'Docsfilcr31BayPor1Co/onyPOA. /nclRevitalizalion\Ownerl,lr.llayl'orl.doc
Exhibit D
EXHIBIT E
EXHIBIT E
Dear Homeowner,D 0
The Homeowners Association just completed the process of correcting a defect that was
discovered in our governing documents. Out of the 137 homes in the BayPort
subdivision, 98 needed to undergo what is called 11revitalization 11 in order to keep our
deed restrictions and governing documents in force and legally binding. These 98 homes
are now back in the Association after a majority of homeowners voted in favor of the
revitalization.
In the process of correcting this defect, Association attorneys discovered that 39
additional lots, of which you are one, were never !")roperly bound to th.e original
governing documents at the very first sale. The:.;e lots could not correct the defect
through revitalization, and must opt-in by signing a Joinder and Consent. Please know
this error occurred with the original developer and came to light only after exhaustive due
diligence was performed. Simply put, this was a filing error, and your lot has always
been assumed to be part of the Association for the past 30+ years.
These 39 lots have changed hands (in some cases, multiple times) over the years. At each
closing, the governing document may have been bound to the deed. We believe that
through ex.pensive and time-consuming title searches, we could perhaps bring the
majority of these lots back into the Assoc. However; that would be after significant cost
to the community in legal e:>..-pense. Rather than incurring more fees, the Board asks that
you please complete the enclosed Joinder & Consent that will bring you into the
Association.
By opting out of the Association, please understand the increased burden this places on
your neighbors and community. It also threatens you and your neighbors, property
value. Deed restricted comm.unities offer greater certainty in the appearance and
maintenance of surrounding homes, entrances and common areas. The cost of
maintaining these assets is fixed, so nonpayment by some puts a greater burden on the
rest. Prospective buyers may reconsider purchasing homes in BayPort, since the ability
to enforce deed restrictions is now more difficult Uncertainty over homes that may or
may not be part of the Association runs counter to how this community has existed for
over 30 years. In addition, only members oftbe Association can only use the waterways,
boatlift, and other amenities. The Board of Directors has a responsibility to enforce the
rules and protect its membership.
Please help your community avoid the e>,,."tra costs and enforcement work by completing
the attached document and returning it to the address shown.
Thank you,
Board of Directors
BPCPOA, Inc.
EXHIBIT F
EXHIBIT G
EXHIBIT H
EXHIBIT I
EXHIBIT I
EXHIBIT I
EXHIBIT I
EXHIBIT I