On November 01, 2012 a
Exhibit,Appendix
was filed
involving a dispute between
Robertson Trustee, Karen J,
and
Ryan Ii, Robert P,
Ryan, Mark R,
for Circuit Civil
in the District Court of Lake County.
Preview
##* FILED: LAKE COUNTY, FL NEIL KELLY, CLERK. ***
Electronically Filed 05/24/2013 06:23:41 PM ET
IN THE CIRCUIT COURT OF THE
19TH JUDICIAL CIRCUIT, IN AND
FOR LAKE COUNTY, FLORIDA
CASE NO.: 2012 CA 003843
KAREN J, ROBERTSON, Trustee of the
ROSEMARY A. RYAN REVOCABLE TRUST,
JOINED BY DIANA M. DAVENPORT,
Plaintiffs
vs.
MARK R. RYAN and ROBERT P. RYAN, II
Defendants
AMENDED DECLARATORY COMPLAINT
EXHIBITS “J THROUGH K”=
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EXHIBIT "EXHIBIT "J1-J21"Renovation expenses:
Dumpster 350.00
Carpet cleaning 65.00
Lunch for helpers and supplies 73.74
Baseboards 60.25
Bathroom mirror 85.04
Outdoor lights 96,30
Motion light 43.15
Toilet 156.88
2"™ bathroom mirror 147.25
Rent sawsalil 17.04
rent sander to sand porches 67.14
Vanity and faucet 192.17
Paint plus labor 5,113.00
Trim hedges 80.00
Refinish hardwood floors 900.00
Kitchen floor 332.00
Rest of kit floor 221.00
Flooring 136.60
Labor Tyler 100.00
Pink bathroom glaze 1,000.00
Garage door 585.00
Kit/bath countertops 1,800.00
Dishwasher 381.00
Discount carpet 1,295.65
Supplies 1,564.71
Front yard 2,147.00
Master bath vanity 192.17
Replace foggy window 78.69
Laundry drywall 225.00
new electrical panel 875.00
other electrical work 414.00
Plumbing supplies 527.00
Burns labor 6,225.00
Roof repairs 400.00.
Trim tree 100.00
Total $26,046.78
EXHIBIT "K"Improvements made to 1614 Diana Drive, Winter Park
Paint:
(work done 01/2012 -approximately 30 gallons used)
All wallpaper and borders were removed, then walls
that had wallpaper removed had to be sanded down,
primed and painted. (wallpaper was in the kitchen and
bathrooms) (borders were in the laundry room and
both back bedrooms)
Painted all interior walls (that did not have paneling )
and ceilings, inside of closets and a few doors. (inside of
closets were never painted)
All holes and cracks were patched
kitchen cabinets were sanded down and painted inside
and out, (they are birch and had the original finish)
exterior was pressure washed
The body of the house, eaves, shutters and front door
were painted.
Porches and all steps had carpet removed and all
adhesive was sanded down and painted.
Painted interior of garage
Kitchen:
New hardware on cabinets (new paint see above)
01/06/12 New dishwasher
02/06/12 New granite countertops
New baseboards
New sink cabinet (due to leak rusting out original metal
cabinet) door had to be custom made to match original
doors
Fixed leak under sink
EXHIBIT "K"New water control valves
Full Bathroom:
01/03/12 Reglazed tub, walls and floor. (Cracks were
repaired first)
New cabinet and hardware
02/06/12 New granite countertop
New mirror and light fixture
New knobs for original sink
New stems for original sink
New water control valves
Half bath:
New toilet
New sink
Regrouted shower
New water control valves
New mirror and light fixture
Flooring:
Removed carpet in hall and back two bedrooms
01/02/12 Refinished hardwood floors in hall and back
two bedrooms
Carpet: (Could not get stains out of original carpet)
2/6/12 88 sq yards of New berber carpet put in
living/family room and one bedroom.
EXHIBIT "K"New kitchen floor (Ultra Allure) lifetime residential
warranty
Electrical:
01/30/12 New Square D panel with GFI beakers (had
Federal Pacific panel made it uninsurable)
03/22/12 New switches and outlets
Two new lights on exterior of garage
Added junction box to fix electrical to front pole
New motion light at front door
New light fixture in hallway
Garage:
01/11/12 New garage door (original wooden garage door
hinges and rollers were broken) It could not be
repaired.
Windows:
05/15/12 Replaced foggy dual-pane window
Roof:
1/16/12 Replaced 15 missing shingles and repaired one
hole
6/14/12 Repaired 2 holes over living room
Lawn and Shrubs:
Cut back shrubs (it had grown to roofline in back of
house)
EXHIBIT "K"Removed vegetation from wall of back of house that
had grown to roofline
4/11/12 Removed dead lawn, regraded ground and
replaced with St Augustine grass
6/6/12 Repaired sprinkler heads
07/10/12 Trimmed back live oak where limbs were
touching roof
New sprinkler control box (other one was broken)
EXHIBIT "K"Burns renovation work at 1614 Diana Drive, W.P. FL
2011-2012
2011
October 20" 10-3 5 hours B 5
October 21" 10-3 5 hours B 5
October 25" 10-3 5 hours B 5
October 26" 10-2 4 hours B 4
(Oct 19hrs)
October 27th, 28th, 29° and November 11" and 12" Estate Sale
dates (work not included)
November 8" 1 hour B 1 (Nov 3 hrs)
November 9" 2 hours B 2
December 5" 9:45-12:30 B 2.75 (Dec 42.25hr)
Dec. 6" 9:45-11:45 B 2
Dec 7" 10-2 B 4
Dec 22™ B 11-4 5
Dec 26" 9-5 B 8
Dec 27" 9-5 B 8
Dec 28" 9-5 B 8
Dec 29" 1:30-6 4 % hrs B 4
2012
Jan 2" 10-3B
Jan 3" 9:30-1:30 B
Jan 6" 11:30-1:30 B
Jan 7" 10-12 and 2-3 B
Jan 9" 6 hrsB
Jan 10" 7 hrs
Jan 11" 7 hrs B+ Burns only 4 % hrs
Jan 12" 5 1/2 hrs B 5.5
Jan 13"8 % hrs B 8.5
Jan 20" 2 hrs B 2
Jan 30" 3 brs B 3
Jan 31“ 3hrs B 3
(Jan 60.5 hrs)
TFuanernaean
in
EXHIBIT "K"Feb 6" 3hrs B
Feb 8" 3hrs B
Feb 13" 1-8 7hrs B
Feb 14" Burns 9-5
Feb 17" Burns 3 hrs
Feb 20" 6.5 hrs B
Feb 234 Burns 9-7:30
Feb 26" 3-6 B
Mar 2™ 8:30-3:30 Burns
Mar 3" 12;30-9 B
Mar 10" Burns 9 hrs
Mar 12" 9:30-3 B
Mar 13" Burns 10-3
Mar 16" Burns 10-3
Mar 19" Burns 2-8,
Mar 20" Burns 2-8
Mar 21 Burns 1-8
Mar 22™ Burns 2-8
Mar 23” Burns 3-9
Mar 24" Burns 3-9
Mar 30" Burns 1 hour
Mar 31" Burns | hour
April 2" Burns 10-3
April 3 Burns 8-5
April 6" Burns 1 br
April 10 Burns 1 hr
April 11" Burns 10-7
April 14" Burns 6 % hrs
April 15" Burns 3 hrs
April 17" Burns 3 % hrs.
April 20" Burns 2 hrs
EXHIBIT "K"
3 (Feb 44 hrs)
3
7
8
3
6.5
10.5
3
7 (Mar 79 hrs)
(April 40 hrs)
5
9
i
1
9
6.5
3
3.5
2May 16" Burns 4 hrs
May 17" Burns 2 hrs
May 21% Burns 2 hrs
May 30" 1 hrs B
June hours
June 2" 2 hours B
June 6" 10-3:30 B 5.5 hrs
June 30" B 1 hr
July 1* 2 hrs B
July 2"! B 4hrs
2
5.
1
2
4
4 (May 9 hrs)
2
2
1
(June 14.5 hrs)
5
Total hours 311.25 X $20.00 hr = $6,225.00
Total trips 69+
EXHIBIT "K"
Document Filed Date
May 24, 2013
Case Filing Date
November 01, 2012
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##* FILED: LAKE COUNTY, FL NEIL KELLY, CLERK. *** Electronically Filed 05/24/2013 06:23:41 PM ET IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT, IN AND FOR LAKE COUNTY, FLORIDA CASE NO.: 2012 CA 003843 KAREN J, ROBERTSON, Trustee of the ROSEMARY A. RYAN REVOCABLE TRUST, JOINED BY DIANA M. DAVENPORT, Plaintiffs vs. MARK R. RYAN and ROBERT P. RYAN, II Defendants AMENDED DECLARATORY COMPLAINT EXHIBITS “J THROUGH K”= N ? = E a xz 38 WwEXHIBIT "J1-J21"72 © of py “IY 4G wap) stoped “yy he IsTyp-O 28 OF ap EXHIBIT "J1-J21"XHIBIT "J1-J2a me ™ guTN ol mM EXHIBIT "J1-J21"EXHIBITDray YON. raam Mpa EXHIBIT "J1-J21"EXHIBIT "J1-J21"EXHIBIT| puv pai prez Looud EXHIBIT "EXHIBIT "J1-J21"Renovation expenses: Dumpster 350.00 Carpet cleaning 65.00 Lunch for helpers and supplies 73.74 Baseboards 60.25 Bathroom mirror 85.04 Outdoor lights 96,30 Motion light 43.15 Toilet 156.88 2"™ bathroom mirror 147.25 Rent sawsalil 17.04 rent sander to sand porches 67.14 Vanity and faucet 192.17 Paint plus labor 5,113.00 Trim hedges 80.00 Refinish hardwood floors 900.00 Kitchen floor 332.00 Rest of kit floor 221.00 Flooring 136.60 Labor Tyler 100.00 Pink bathroom glaze 1,000.00 Garage door 585.00 Kit/bath countertops 1,800.00 Dishwasher 381.00 Discount carpet 1,295.65 Supplies 1,564.71 Front yard 2,147.00 Master bath vanity 192.17 Replace foggy window 78.69 Laundry drywall 225.00 new electrical panel 875.00 other electrical work 414.00 Plumbing supplies 527.00 Burns labor 6,225.00 Roof repairs 400.00. Trim tree 100.00 Total $26,046.78 EXHIBIT "K"Improvements made to 1614 Diana Drive, Winter Park Paint: (work done 01/2012 -approximately 30 gallons used) All wallpaper and borders were removed, then walls that had wallpaper removed had to be sanded down, primed and painted. (wallpaper was in the kitchen and bathrooms) (borders were in the laundry room and both back bedrooms) Painted all interior walls (that did not have paneling ) and ceilings, inside of closets and a few doors. (inside of closets were never painted) All holes and cracks were patched kitchen cabinets were sanded down and painted inside and out, (they are birch and had the original finish) exterior was pressure washed The body of the house, eaves, shutters and front door were painted. Porches and all steps had carpet removed and all adhesive was sanded down and painted. Painted interior of garage Kitchen: New hardware on cabinets (new paint see above) 01/06/12 New dishwasher 02/06/12 New granite countertops New baseboards New sink cabinet (due to leak rusting out original metal cabinet) door had to be custom made to match original doors Fixed leak under sink EXHIBIT "K"New water control valves Full Bathroom: 01/03/12 Reglazed tub, walls and floor. (Cracks were repaired first) New cabinet and hardware 02/06/12 New granite countertop New mirror and light fixture New knobs for original sink New stems for original sink New water control valves Half bath: New toilet New sink Regrouted shower New water control valves New mirror and light fixture Flooring: Removed carpet in hall and back two bedrooms 01/02/12 Refinished hardwood floors in hall and back two bedrooms Carpet: (Could not get stains out of original carpet) 2/6/12 88 sq yards of New berber carpet put in living/family room and one bedroom. EXHIBIT "K"New kitchen floor (Ultra Allure) lifetime residential warranty Electrical: 01/30/12 New Square D panel with GFI beakers (had Federal Pacific panel made it uninsurable) 03/22/12 New switches and outlets Two new lights on exterior of garage Added junction box to fix electrical to front pole New motion light at front door New light fixture in hallway Garage: 01/11/12 New garage door (original wooden garage door hinges and rollers were broken) It could not be repaired. Windows: 05/15/12 Replaced foggy dual-pane window Roof: 1/16/12 Replaced 15 missing shingles and repaired one hole 6/14/12 Repaired 2 holes over living room Lawn and Shrubs: Cut back shrubs (it had grown to roofline in back of house) EXHIBIT "K"Removed vegetation from wall of back of house that had grown to roofline 4/11/12 Removed dead lawn, regraded ground and replaced with St Augustine grass 6/6/12 Repaired sprinkler heads 07/10/12 Trimmed back live oak where limbs were touching roof New sprinkler control box (other one was broken) EXHIBIT "K"Burns renovation work at 1614 Diana Drive, W.P. FL 2011-2012 2011 October 20" 10-3 5 hours B 5 October 21" 10-3 5 hours B 5 October 25" 10-3 5 hours B 5 October 26" 10-2 4 hours B 4 (Oct 19hrs) October 27th, 28th, 29° and November 11" and 12" Estate Sale dates (work not included) November 8" 1 hour B 1 (Nov 3 hrs) November 9" 2 hours B 2 December 5" 9:45-12:30 B 2.75 (Dec 42.25hr) Dec. 6" 9:45-11:45 B 2 Dec 7" 10-2 B 4 Dec 22™ B 11-4 5 Dec 26" 9-5 B 8 Dec 27" 9-5 B 8 Dec 28" 9-5 B 8 Dec 29" 1:30-6 4 % hrs B 4 2012 Jan 2" 10-3B Jan 3" 9:30-1:30 B Jan 6" 11:30-1:30 B Jan 7" 10-12 and 2-3 B Jan 9" 6 hrsB Jan 10" 7 hrs Jan 11" 7 hrs B+ Burns only 4 % hrs Jan 12" 5 1/2 hrs B 5.5 Jan 13"8 % hrs B 8.5 Jan 20" 2 hrs B 2 Jan 30" 3 brs B 3 Jan 31“ 3hrs B 3 (Jan 60.5 hrs) TFuanernaean in EXHIBIT "K"Feb 6" 3hrs B Feb 8" 3hrs B Feb 13" 1-8 7hrs B Feb 14" Burns 9-5 Feb 17" Burns 3 hrs Feb 20" 6.5 hrs B Feb 234 Burns 9-7:30 Feb 26" 3-6 B Mar 2™ 8:30-3:30 Burns Mar 3" 12;30-9 B Mar 10" Burns 9 hrs Mar 12" 9:30-3 B Mar 13" Burns 10-3 Mar 16" Burns 10-3 Mar 19" Burns 2-8, Mar 20" Burns 2-8 Mar 21 Burns 1-8 Mar 22™ Burns 2-8 Mar 23” Burns 3-9 Mar 24" Burns 3-9 Mar 30" Burns 1 hour Mar 31" Burns | hour April 2" Burns 10-3 April 3 Burns 8-5 April 6" Burns 1 br April 10 Burns 1 hr April 11" Burns 10-7 April 14" Burns 6 % hrs April 15" Burns 3 hrs April 17" Burns 3 % hrs. April 20" Burns 2 hrs EXHIBIT "K" 3 (Feb 44 hrs) 3 7 8 3 6.5 10.5 3 7 (Mar 79 hrs) (April 40 hrs) 5 9 i 1 9 6.5 3 3.5 2May 16" Burns 4 hrs May 17" Burns 2 hrs May 21% Burns 2 hrs May 30" 1 hrs B June hours June 2" 2 hours B June 6" 10-3:30 B 5.5 hrs June 30" B 1 hr July 1* 2 hrs B July 2"! B 4hrs 2 5. 1 2 4 4 (May 9 hrs) 2 2 1 (June 14.5 hrs) 5 Total hours 311.25 X $20.00 hr = $6,225.00 Total trips 69+ EXHIBIT "K"