[CLC-Discussion] Pro bono assistance - 90 year old client -Alachua lien foreclosure - Three Rivers Legal Services

[RPPTL CLC-Discussion]

 Three Rivers Legal Services is looking for a pro bono construction
attorney volunteer to assist with the defense of a lien foreclosure action
for a 90 year old woman (Ernestine Stokes) who co-owns her home with her
daughter in Alachua County.   The solar installation company (Solar
Installation, Inc/Christopher Green) is attempting to enforce a lien in
excess of 70K for a 1000 square foot home.  The work is not complete and
appears to have been performed without a permit and was solicited in a door
to door sale.  For conflict purposes, the roofing company on the permit is
360 Degreez Consulting, LLC/Ulysees Rushing.

Three Rivers is currently representing the client, so this volunteer role
could either be mentoring the staff attorney, appearing as co-counsel, or
taking over the case.  Three Rivers narrative follows and a copy of the
complaint is attached hereto.

Please contact Samantha Howell, the Pro Bono Director of Three Rivers Legal
Services at
samantha.howell at trls.org with a copy to  *pamela at anastasialaw.net
<pamela at anastasialaw.net>* for the CLC Pro Bono Initiative or contact me
directly with any questions regarding the Pro Bono Initiative.

*"The client and her daughter hired a roofing company to replace
their roof. While the company was waiting for supplies to arrive,
a solar panel company came to the home and asked the client's daughter to
sign a Notice of Commencement. The daughter did so, thinking that the
person was with the roofing company. The solar company replaced
the roof and left unconnected solar panels on the roof. The next day, the
roofing company called the client advising that the supplies had arrived.
The client was confused, as she thought the roofing company was who had
been working on the roof. The roofing company had already received a check
from the insurance company for the work and had pulled permits.  The roof
permit estimated the cost of work at appx $7500. The solar panel company is
now suing the client for over $70k.*

*The issues that we see include: client did not sign the Notice of
Commencement; the Complaint for Construction Lien/*
*Foreclosure does not include a contract between either named party and
the solar panel company; the roofing company did not return the insurance
money. The client asked the court for an extension to file an answer on
7/31/23 (Judge Moseley), but there has not been an order issued yet. The
Plaintiffs filed a Motion for [Clerk's] Default on 8/18/23. [Three Rivers
filed an answer before a clerk's default was entered].*

Pam Holcombe
Chair, CLC Pro Bono Initiative
-- 
Pamela M.M. Holcombe, Esq.
*Anastasia Law, PL*
107 A 11th Street
Saint Augustine, FL 32080
office: (904) 236-6243
fax:    (904) 239-5505
email: pamela at anastasialaw.net
www.anastasialaw.net
-- 

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*There is no attorney-client relationship with Anastasia Law, P.L. unless
there is an express representation agreement between the firm and the
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