Mancebo brickell shores condo Cease & Desist

1. GUILLERMO M. MANCEBO
GM@MANCEBOLAW.COM
_______________________________________________________________________
MANCEBO LAW, PA
7378 SOUTH WEST 48TH STREET, SUITE B | MIAMI, FLORIDA 33155 | TEL. 305.704.8694 FAX 305.397.2861
February 5, 2018
VIA EMAIL
REGULAR MAIL
AND CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mrs. Maripaz Pereira Cordoba Mr. Ignacio Delgado
1440 Brickell Bay Drive, Unit 301 1440 Brickell Bay Drive, Unit 710
Miami, Florida 33131 Miami, Florida 33131
Mr. and Mrs. Bertrand Lecocq
1440 Brickell Bay Drive, Unit 401
Miami, Florida 33131
Re: Brickell Shores Condominium, Inc.
Dear Mrs. Cordoba, Mr. Delgado and Mr. and Mrs. Lecocq,
The undersigned law Firm represents the interests of Brickell Shores Condominium, Inc.
(“Association”). Previously, the Association individually and through counsel has written to you
regarding your habitual and continued harassment of the Association’s Board of Directors and of
the Association’s Members. Notwithstanding the fact that you have previously been placed on
notice of your violations of Florida Law as well as the Association’s Declaration of Condominium
(“Declaration”), Articles of Incorporation (“Articles”) and By-Laws (“By-Laws”), which are
recorded in Official Records Book 10159 at Page 200 of the Public Records of Miami-Dade
County, Florida (collectively, the “Governing Documents”), you continue to conduct yourselves
in an inappropriate and unlawful fashion placing yourselves and the Association at risk.
Specifically, we have been advised that you have: (1) verbally, physically and
psychologically threatened the Association’s Property Manager; (2) harassed unit owners at
inappropriate times at their residences; (3) made false and libelous statements regarding the
Association’s Board of Directors with an aim at casting them in a false light so as to disturb the
day-to-day operations of the Association; (4) verbally, physically and psychologically threatened
the Associations’ security staff, and (5) screamed and written profanities to members of the Board.
This type of rude, obnoxious, inappropriate, threatening and illegal behavior is a violation of the
Association’s Governing Documents and Florida Law and will NOT BE TOLERATED.
Article XV of the Association’s Declaration provides as follows:
XV. THE CONDOMINIUM TO BE USED FOR LAWFUL
PURPOSES. RESTRICTIONS AGAINST NUISANCES, ETC.
No immoral, improper, offensive or unlawful use shall be made of
any PRIVATE DWELLING or of the COMMON PROPERTY, nor

2. Mrs. Maripaz Pereira Cordoba
Mr. Ignacio Delgado
Mr. and Mrs. Bertrand Lecocq
February 5, 2018
Page 2 of 3
_______________________________________________________________________
MANCEBO LAW, PA
7378 SOUTH WEST 48TH STREET, SUITE B | MIAMI, FLORIDA 33155 | TEL. 305.704.8694 FAX 305.397.2861
any part thereof, and all laws, zoning ordinances and regulations of
all governmental authorities having jurisdiction of the
CONDOMINIUM shall be observed. No owner of any PRIVATE
DWELLING shall permit or suffer anything to be done or kept
in his PRIVATE DWELLING, or on the COMMON PROPERTY,
which will increase rate of insurance on the CONDOMINIUM, or
which will obstruct or interfere with th rights of other occupants
of the building or annoy them by unreasonable noises, nor shall
any such owner undertake any use or practice which shall create
and constitute a nuisance to any other owner of a PRIVATE
DWELLING, or which intereferes with the peaceful possession
and proper use of any other PRIVATE DWELLING or the
COMMON PROPERTY.
(emphasis added).
As previously stated, we have been advised of the vast and numerous disturbing, threateing
and potentially dangerous altercations that have occurred as a result of your improper, offensive
and illegal behavior where you all have engaged in a harassing, threatening and unacceptable
manner infringing on other unit owners’ and residents’ quiet and peaceful enjoyment of their
property as well as threatening Association employees. In fact, the Association has advised our
office that more than fifty (50) complaints have been received from different unit owners regarding
your harassment of them be it in the parking are, the lobby, in the elevators or at their units. In a
building where there are only eighty (80) units, where more than sixty-two percent (62%) of the
members are complaining of the conduct of a small group is extremely troubling and alarming, to
say the least. The Association cannot and will not tolerate your continued harassment of its Board
and members nor will it allow you to continually stalk homeowners in and about the common areas
and the building or disturb their quiet and peaceful enjoyment of the property.
In light of the above highlighted provision, your threatening and harassment of members
of the Association as well as your illegal, unacceptable and acrimonious behavior is a clear
violation of the Association’s Governing Documents as it is an improper use of the common
elements and is a nuisance to the other owners and residents of the Association.
Accordingly, this correspondence shall serve as the Association’s FORMAL AND FINAL
NOTICE that you must immediately CEASE AND DESIST from any further transgressions of the
Association’s Governing Documents and existing law. In the event that you should fail and refuse
to comply with the Association’s demands and not refrain from your stalking of homeowners,
threatening and harassment of Association employees, disturbing homeowners’ quiet and peaceful
enjoyment of their property or continue to be a source of nuisance and harassment, the Association
will be left with no other alternative but to pursue all available legal remedies against you,
including, but not limited to the filing of a petition with the Department of Business and

3. Mrs. Maripaz Pereira Cordoba
Mr. Ignacio Delgado
Mr. and Mrs. Bertrand Lecocq
February 5, 2018
Page 3 of 3
_______________________________________________________________________
MANCEBO LAW, PA
7378 SOUTH WEST 48TH STREET, SUITE B | MIAMI, FLORIDA 33155 | TEL. 305.704.8694 FAX 305.397.2861
Professional Regulations, Division of Condominiums pursuant to Chapter 718.1255, Florida
Statutes or the filing of a lawsuit seeking the entry of a Restraining Order against each of you. In
such event, the Association shall seek to hold you responsible for all legal fees and costs incurred
in connection therein.
We look forward to your anticipated cooperation and trust that you do not wish to be
involved in any needless and costly litigation and that the conduct which is the subject of this
correspondence will immediately cease.
PLEASE GOVERN YOURSELF ACCORDINGLY.
Very truly yours,
MANCEBO LAW, P.A.
Guillermo M. Mancebo
GMM/me
cc: Board of Directors
Property Manager