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Date Posted: 06:59:30 07/27/07 Fri
Author: Tolu
Subject: unethical and unprofessional involvements in this gross fragrant fraud

Count 3
Legal Malpractice

(1.) Harassment as evidenced by attempts at public intimidation and plaintiffs’ illegal
removal from FCCAs’ board. [See exhibit nos.3; 4; 12; 13].

(2.) Ms. Tolu had been a resident in good financial standing of the Frenchman's Creek
condo association since 1996.
(3.) In the fall of 2004, plaintiff became acutely aware of the poor financial health of FCCA
(FCCA could not pay the gas bills and the gas for all the units was to be turned off at which
point the former illegal president Andre assessed all 604 unit $ 350 for the gas to be paid
within 30 days.) and the apparent long term and systemic nature of the problem and
decided the only way to work toward change and improving the problem was to become
directly involved by running for a position on the FCCA board of directors.

(4.) In addition to the mismanagement of funds, Frenchman’s Creek had suffered from
illegally elected FCCA board members using the board to improve their personal
financial positions, illegal board elections and board appointments, failure to keep regular
minutes of meetings as the Maryland Condo Act prescribes, abuse and misuse of the proxy
votes, voter intimidation and voter fraud, and harassment and intimidation of homeowners
who try to advance a position of that other than the board leadership and the retaliatory
acts taken against them, and finally the disturbing primary role played by Attorney
Linda Mericle in all these questionable actions.
In fact, you can find Attorney Mericles’ fingerprints and sanctioning on almost all these
actions.
Since Attorney Linda S. Mericle is an officer of the court this defendant must be held
accountable for her unethical and unprofessional involvements in this gross fragrant fraud
by the defendants.



(6.) Gbenoba was not that he was illegally elected otherwise, and that he tried to administer
his office as if he was the only board member as opposed to one of five members.
Announcing at the first board meeting that only he would have a key or access to the
Condo office and overruled plaintiffs’ objection to this absurd nonsense but that was only
the beginning to years of the ‘King and I’, Mr. Gbenoba being ‘king’ and all other 603
condo unit owners’ being ‘I’.
There was a direct clash in goals in that Ms. Tolu's goal was to try to move FCCA toward a
Financial healthy, well managed community and improving the quality of life for all unit
owners and Paul Gbenoba's goal was to advance the finances, power, prestige, and quality
of life of the illegal Paul Gbenoba.
It is out of this conflict between the two that Paul Gbenoba began his harassing tactics.

(7.) On a number of occasions both public and private, he assailed, screamed, yelled, and
attempted to intimidate Ms. Tolu leading to the thus far ultimate retaliatory step detailed
extensively in this lawsuit, namely placing a fraudulent lien against Ms. Tolu's property.

One public display of harassment occurred at a FCCA board meeting when
Ms. Tolu and Paul Gbenoba disagreed over the illegal election of several (3) board
members as well as the fact that attorney Linda Mericle could keep bleeding the
Association into bankruptcy by her fees coming out of the Associations Reserves Funds.
No one knows (but Gbenoba) the actual amount of FCCA money Reserves which could be
less than $100,000.
However for FCCA to be financially healthy its’ Reserves Funds should be at least
$1,812,000 million dollars.
Paul Gbenoba then rose from his seat in the board meeting calling Ms. Tolu among other
things, “a dumb, stupid woman, “then lacing Ms Tolu with obscenities including the B
word. “ During that incident, Gbenoba also approached her in a menacing manner.
Gbenoba asserted, "you are nobody and I don't acknowledge your presence"
but Ms. Tolu continued her campaign to clean up FCCA’s act.
Plaintiff continued to be interested in ridding the condo association of illegal and
ineffective office holders, but most importantly, she wanted the FCCA to get in the Black
financially and to be managed properly.
It is not a great leap to understand that if the FCCA had non-management types, interested
only in their personal financial situation that the FCCA's affairs would be in disarray,
disorder and debt.
Gbenoba saw his illegal access to the unit owners money as his personal bank account to
thrush himself ahead from tittering on Bankruptcy

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