SOUTHPOINT CONDOMINIUM ASSOCIATION, INC. -- COMPLAINT

In 1990, a committee headed by Richard Gabrielle appointed Robert John Rozema, hereinafter known as RJR, who was at that time a member of Southpoint’s Board, to become the Southpoint Building Manager. Also at this time, RJR’s wife was an employee of Richard Gabrielle as a real estate sales agent. The position of manager was not advertised, and this was a secret appointment.

This appointment is an obvious conflict of interest, for it placed RJR in a position whereby he controlled his own compensation. The fact RJR’s wife was an employee of Richard Gabrielle is a conflict of interest.

Rozema Compensation.

This appointment was made without a contract. At the time of his illegal appointment, RJR was on disability from New Jersey, preventing his working and receiving a salary. Those making the illegal appointment of RJR conspired with him to avoid payment of Federal Income Taxes by paying him from the Southpoint petty cash fund. Southpoint’s complicity allowed them to avoid paying into the Florida unemployment trust fund, and the employer’s portion of the Social Security Trust fund.

Rozema Collusion and Conspiracy.

During these fourteen (14) years, Robert John Rozema has been in collusion with several other Owners and members of the Board for the purpose of defrauding the Federal government, the state of Florida, Southpoint Condominium Association, and profiting from that fraud.

Co-conspirators with Robert John Rozema include Richard Gabrielle, Murray Moskovitz, Marty Glazer, Morris Baum, Michael J. Longo, Dumont St. Martin, Teddy Spatz, Patricia Pastor, Delores French, Harold Krauss, and Lois Ginsberg. All of these individuals were fully aware of the Federal Income Tax evasion and rather than correct the problem, they participated in other financial frauds for personal gain.

Rozema “Volunteer” Fiction.

RJR and the members of the Southpoint Board of Directors created and maintained a fraudulent story that Robert John Rozema was a volunteer manager who received no compensation from Southpoint. Robert John Rozema is no volunteer, for he has taken about $500,000.

Rozema Reimbursements.

As part of his deception and fraud, Robert John Rozema has been illegally reimbursed for the following items:

· Condominium Maintenance Fees (in excess of $25,000).

· Replacement of his apartment’s windows ($5,259.00).

· Health Insurance.

· Car insurance.

· Gasoline.

· Electric service.

· Telephone.

· America On Line.

· Property Taxes on his apartment.

· Maintenance on his apartment.

· Assessments on his apartment.

· American Express credit card.

· Costco credit card charges.