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UNITED STATES FEDERAL COURT

SOUTHERN DISTRICT FLORIDA

Timothy Grim, a Florida Case Number: 9:20-cv-80754

resident, Lisa Grim, a Florida 

resident, on behalf of their minor 

child, 

Plaintiffs, 

-vs.-

Residences At

Midtown Condominium 

Association, Inc., a Florida 

corporation, Peter Ploss, 

a Florida resident, 

Gary Cohan, a Florida 

resident, Sterling Winchester, 

a Florida resident, Irene Foy, 

a Florida resident, Larry Schneider, 

a Florida resident, Holly Galleher, 

a Florida resident, and Campbell 

Property Management, a Florida 

corporation,

Defendants. 

________________________________________________/ 

VERIFIED COMPLAINT

COMES NOW, Plaintiffs, Timothy and Lisa Grim, on behalf of their minor disabled child, 

by and through undersigned counsel, and file this Verified Complaint against Defendants 

Residences at Midtown Condominium Associates, Inc., et al. [collectively, “the Defendants”] and 

alleges the following in support thereof: 

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PARTIES

1. Plaintiffs Lisa and Timothy Grim are sui juris individuals who are married to each other

and are the owners of a condominium unit located in Residences at Midtown located at 4903 

Midtown Lane Unit Number 3406, Palm Beach Gardens, FL 33418. 

2. Plaintiffs are the parents of their minor daughter, a person with a qualifying-disability

under the Fair Housing Act, and is otherwise sui juris. 

3. Defendant, Residences at Midtown Condominium Association, Inc. is a Florida nonprofit corporation, licensed to and doing business in Palm Beach County, Florida and operates a 

condominium building located at 4901 Midtown Lane in Palm Beach Gardens, Florida 33418. 

4. At all times relevant to this litigation, Defendants, Peter Ploss, Gary Cohan, Sterling

Winchester, Irene Foy and Larry Schneider were all members of the Board of Directors for 

Residences at Midtown Condominium Association, Inc., are all residents of Palm Beach County

and were personally involved in each and every discriminatory act alleged herein. 

5. Defendant, Campbell Property Management, Inc. is a Florida corporation and at all times

relevant to this litigation, was an authorized agent for Defendants, who personally implemented 

the discriminatory and retaliatory scheme.

6. Defendant Holly Galleher, Licensed Community Association Manager was at all times

relevant to this litigation, acting as an agent for Campbell Property Management, Inc. and 

Residences at Midtown Condominium Association, Inc., is a resident of the state of Florida and

was personally involved in each and every discriminatory act alleged herein in the county in which 

a substantial portion of events took place. 

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JURISDICTION AND VENUE

7. This Court has original jurisdiction pursuant to 11 U.S.C. § 1331, 42 U.S.C. § 3613,

because this lawsuit is brought under the Fair Housing Act, 42 U.S.C. § 3601 et seq. 

8. This Court has supplemental jurisdiction under 28 U.S.C. § 1367 over Plaintiff’s claims

under the Florida Fair Housing Act Fla. Stat. § 760.20 et seq.

9. Venue is proper under 28 U.S.C. § 1391(b)(1) (“a judicial district in which any defendant

resides, if all defendants are residents of the State in which the district is located” and 28 U.S.C. § 

1391(b)(2) (the “judicial district in which a substantial part of the events or omissions giving rise 

to the claim occurred.”)

FACTUAL BACKGROUND

10. In 2018, Plaintiffs’ minor daughter, was hospitalized for high blood pressure and

accelerated heart rate. During her 10-day hospital stay, the minor child was diagnosed with 

postural orthostatic tachycardia syndrome [“POTS”] which is a form of orthostatic intolerance, 

whereby the autonomic nervous system fails to work in the usual way. Patients diagnosed with 

this condition experience extreme heat intolerance, fatigue, chest pain, syncope, confusion, blurry 

vision, dizziness, anxiety, nausea, heart palpitations, migraines among other symptoms. Because 

of her condition, she is unable stand for any length of time and cannot attend school; instead she 

is tutored in her home. Oftentimes she is unable get out of bed due to extreme fatigue and is unable 

to go outside without ventilation.

11. Plaintiffs, Lisa and Timothy Grim and their minor daughter reside in the Residences at

Midtown. 

12. Lisa and Timothy Grim bring this action against Defendants for themselves and on

behalf of their minor disabled daughter alleging that Defendants violated the Fair Housing Act, 42 

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U.S.C. § 3601 et seq. by failing to reasonably accommodate the minor child’s disability. The Fair 

Housing Act bars housing discrimination based on disability. Under Section 3604(f), 

“discrimination includes,” among other things, a refusal to make reasonable accommodations in 

rules, policies, practices, or services, when such accommodations may be necessary to afford such 

person equal opportunity to use and enjoy a dwelling[.] 

13. Due to the minor child’s condition, she experiences extreme heat intolerance, so

Plaintiffs must keep their dwelling as cold as possible. Since the minor child is home schooled, 

she rarely leaves the interior of her dwelling. One of the only ways that the minor child can be 

outside is on her balcony, but to alleviate the heat intolerance caused by her disability, she requires 

a fan for ventilation, otherwise she runs the risk of experiencing dizziness, lightheadedness, and/or 

fainting spells.

14. Defendants have a Regulation that states in pertinent part:

To maintain a uniform and pleasing appearance of the exterior of the 

Condominium building, no awnings, canopy, screens, air 

conditioning unit, glass enclosures, or other projections shall be 

attached to, hung, displayed or placed upon the porches, outside 

walls, doors, windows or to the patio roof or other portions of the 

Building or on the Common Elements. Patios and balconies must 

be kept neat and clean.

15. Since as early October 2019, Plaintiffs have been requesting that the Defendants make

a reasonable accommodation for their minor daughter, by allowing a ceiling fan on their balcony 

which was necessary to afford her an opportunity to enjoy their dwelling. [See Exhibit “A”]

16. Defendants have unduly delayed either granting or denying a modification to its

existing policies and practices to accommodate the minor child’s disability. The ceiling fan would 

eliminate the barrier that prevents the minor child from full enjoyment of the premises and 

importantly, the ceiling fan would otherwise not create a displeasing appearance of the exterior. 

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17. The Plaintiffs paid for and installed the ceiling fan at their own expense to help

accommodate their disabled minor child to afford her full enjoyment of their dwelling. Plaintiffs 

agree to remove the fan if they sell the premises to restore the balcony to its former condition. 

18. After receiving extensive documentation from the minor child’s healthcare providers

specifically detailing how her condition causes a deregulation in her body temperature that results 

in extreme heat fatigue, whereby the minor child cannot enjoy the balcony unless there is 

ventilation and that problem would be alleviated by a simple ceiling fan, the Defendants continued 

to delay and ultimately suggested an unreasonable alternative. 

19. In or around March 2020, instead of granting the reasonable accommodation, the

Defendants, with full knowledge that the minor child is disabled, with symptoms that include, but 

are not limited to dizziness and fainting, suggested that she plug a pole fan inside the dwelling, 

and then drag the pole fan onto and off of the balcony if she wants to have full enjoyment the 

balcony. 

20. Plaintiffs have supplied information far beyond which was necessary for the

Defendants to determine the minor child’s disability and need for a ceiling fan for ventilation. 

After receiving a verbal request from Plaintiffs, a written request from Plaintiffs and 

acknowledging receipt of two letters from health care providers which were both rejected as 

insufficient to establish the need for reasonable accommodation, in or around February 2020, the 

attorney representing the Defendants then requested that Plaintiffs produce: 

“Specific detail as to the accommodation requested, specific detail and 

supportive documentation as to how Ms. Grim is a person with a 

disability pursuant to the fair housing laws, specific detail and supportive 

documentation as to how such disability substantially limits a major life 

activity, specific detail and supportive documentation as to how the 

requested accommodation would alleviate the effects of such disability, 

specific detail and supportive documentation as to how the requested 

accommodation would alleviate the effects of such disability, specific 

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detail and supportive documentation as to how the requested 

documentation is necessary to afford the Owner an equal opportunity to 

use and enjoy the dwelling. For example, why is it necessary to install a 

ceiling fan as opposed to a pole or stand-up fan, documentation and 

supporting evidence from a treating physician providing specific 

detail and supportive documentation as to the treating physician’s 

individual qualifications, background, and, and treatment history 

with Ms. Grim.” 

21. The Defendants have neither approved nor denied the reasonable accommodation yet

they fined the Plaintiffs $1,000 for the violation of having a ceiling fan on their balcony. Plaintiff 

alleges that the $1,000 fine was demanded in a letter stating that it was a “Late Fee” when that was 

the first demand sent for the alleged violation. 

22. In order to be in compliance with the Board’s Rules and Regulations, Plaintiffs have

paid the violation fine of $1,000. 

23. Plaintiffs have retained the undersigned to represent them in this cause and have agreed

to pay them a reasonable fee for their services.

24. Plaintiff has complied with all necessary conditions precedent to the filing of this

action, or such conditions precedent have been waived. 

PLAINTIFFS’ TIMELINE ATTEMPTS 

TO SEEK REASONABLE ACCOMMODATION

EXHIBIT DATE DESCRIPTION OF 

CORRESPONDENCE

SUBSTANCE OF 

CORRESPONDENCE

Late October 2019 Verbal request from 

Plaintiffs to Holly 

Galleher, LCAM of 

Campbell Property 

Management

Plaintiffs allege that 

they verbally requested 

from Ms. Galleher an 

accommodation for their 

disabled daughter to 

have a ceiling fan 

because their minor 

child is unable to 

regulate her body 

temperature due to her 

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disability and the ceiling

fan helps her body keep 

cooler. Ms. Galleher

allegedly replied that a 

ceiling fan is against the 

rules even if it is for 

your daughter’s 

disability. She further 

stated that the Board 

will make you take it 

down and they will fine 

you $1,000 and if you 

fight this, you will lose. 

You do not know what 

these people are capable 

of.

Composite 

Exhibit “A” 

Photos of the subject of 

the reasonable 

accommodation; a 

ceiling fan installed on 

the balcony of 

Plaintiffs’ dwelling.

Plaintiffs have 

repeatedly informed 

Defendants that they 

would remove the 

ceiling fan if they 

moved.

Exhibit “B” November 13, 2019 

at 10:41a.m. 

Letter from Holly 

Galleher, LCAM of 

Campbell Property 

Management acting as 

an agent for the 

association on behalf of 

the Board of Directors 

for Residences at 

Midtown Condominium 

Association, Inc. to the 

Plaintiff property 

owners regarding 

removal of their ceiling 

fan.

The ceiling fan violates 

the Rules of the HOA. 

The purpose of the rule 

is to maintain a uniform 

and pleasing appearance 

of the exterior of the 

condominium building, 

no awnings, canopy, 

screens, air conditioning 

unit, glass enclosures, or 

other projections shall 

be attached to hung, 

displayed or placed 

upon the porches, 

outside walls, doors, 

windows or to the patio, 

roof or other portions of 

the building or on the 

common elements. 

Patios and balconies 

must be kept neat and 

clean.

Exhibit “C” November 13, 2019 

at 2:56 p.m.

Letter from Plaintiffs to 

Holly Galleher directed 

Plaintiffs reply to the 

Board of Directors and 

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to the Board Members 

requesting a reasonable 

accommodation for 

their disabled minor 

child.

request a reasonable 

accommodation for the 

ceiling fan because their 

daughter is disabled and 

requires a fan.

Exhibit “D” November 13, 2019 

at 4:00 p.m. 

Reply from Holly 

Galleher, LCAM of 

Campbell Property just 

a little over one hour 

after Plaintiffs 

requested a reasonable 

accommodation for 

their disabled minor 

child. 

Board of Directors has 

denied request for 

variance in the rule 

stating that Plaintiff’s 

must take down ceiling 

fan.

[This decision was made 

by the Defendants in one 

hour. There was no 

request for further 

information.]

Exhibit “E’ November 19, 2020, Plaintiffs filed a request 

for Congressman Brian 

Mast’s assistance.

Request to review their 

difficulty regarding a 

reasonable 

accommodation from 

their Board of Directors 

for the HOA for their 

disabled daughter.

Exhibit “F” November 20, 2019, Email from Jordan R. 

Sejour, Constituent 

Services Representative 

for Congressman Brian 

Mast’s Office to 

Plaintiffs.

Jordan R. Sejour, 

acknowledges that he is

to advocate on behalf of 

the Plaintiffs.

Exhibit “G” November 26, 2019, Letter from 

Congressman Brian 

Mast to the Assistant 

Attorney General, 

Office of Legislative 

Affairs, Stephen Boyd

Letter regarding 

Plaintiff’s situation 

regarding the denial of 

an accommodation for 

the Plaintiffs’ disabled 

minor child.

Exhibit “H” November 26, 2019 Letter from Mr. Sejour, 

from Congressman 

Brian Mast’s office to 

Holly Galleher, 

Campbell Property. 

Mr. Sejour indicates that 

he is advocating for 

Plaintiff regarding a 

reasonable 

accommodation for their 

disabled child. 

Mr. Sejour indicates that 

they have medical 

documents indicating 

that the ceiling fan is 

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required to 

accommodate the child’s 

disability.

Exhibit “I” November 27, 2019 Letter from Holly 

Galleher, LCAM of 

Campbell Property to 

Mr. Sejour, from 

Congressman Brian 

Mast’s office.

The Board suggested 

that the family use a 

portable fan that they 

can bring in when not on 

the patio. 

Exhibit “J” December 2, 2019 Letter from Steven G. 

Rappaport, Sachs Sax 

Caplan, Attorneys at 

Law to Mr. Sejour, 

from Congressman 

Brian Mast’s office.

The letter requesting 

that Plaintiffs provide 

documentation to 

confirm that Plaintiff’s 

child, is in fact, 

disabled, and that the 

request for the 

accommodation is 

medically necessary in 

order to address her 

disability. 

Further alleging that as 

of the date of the letter 

no documentation or 

evidence of a disability 

or that the requested 

accommodation is 

necessary to treat or 

alleviate has been 

provided, claiming that 

the Board could not 

conduct a meaningful 

investigation into this 

request.

Exhibit “K” January 27, 2020 Letter from Melanie 

Powlis, PBC Office of 

Equal Opportunity with 

photographic 

attachments of alleged 

accommodations for 

other units (with and 

without disabilities)

Acknowledging receipt 

of Plaintiffs complaint 

regarding the denial of a 

reasonable 

accommodation for their 

minor disabled child 

from Palm Beach 

County Office of Equal 

Opportunity.

Exhibit “L” February 18, 2020 Agenda for the 

Committee Meeting for 

Residences at Midtown 

Plaintiff’s ceiling fan 

(unauthorized 

architectural 

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Condominium 

Association, Inc.

modification) was listed 

for discussion and 

decision.

Exhibit “M” February 19, 2020 Email from Mr. Sejour 

to Holly Galleher, 

Campbell Property

Manager.

Mr. Sejour forwards two 

medical professionals’ 

letters from Dr. Vastola 

and Emily Johnson, NP 

regarding Plaintiff’s 

minor disabled child’s 

request for a reasonable 

accommodation.

Exhibit “N” February 19, 2020 Plaintiffs sent a letter 

from Emily L. Johnson, 

NP, NYU Fink 

Pediatrics Cardiology 

Associates to the Board 

of Directors.

Dated: November 14, 

2019 

Emily Johnson, NP 

wrote that Plaintiff’s 

daughter has a medical 

condition whereby a 

ceiling fan would 

greatly benefit her 

symptoms. Further 

recommending that 

Plaintiff’s daughter 

should be able to keep 

the fan. 

Exhibit “O” February 19, 2020 Plaintiffs sent a letter 

from Dr. David L. 

Vastola, Board 

Certified Internal 

Medicine and 

Gastroenterology, to the 

Board of Directors.

Dated: November 15, 

2019 

Dr. Vastola requested a 

reasonable 

accommodation stating 

that Plaintiff’s daughter 

suffers from a medical 

illness explaining that 

the ventilation from the 

fan would help her 

temperature exchange 

problems from her 

medical condition.

Exhibit “P” February 21, 2020 Letter Steven G. 

Rappaport, Sachs Sax 

Caplan, Attorneys at 

Law to Mr. Sejour, 

from Congressman 

Brian Mast’s office.cc 

Ms. Galleher.

Acknowledging receipt 

of two letters from 

healthcare providers 

indicating that they feel 

that the installation of 

such fan would be in 

minor child’s best 

interest.

Rejecting both letters, 

Defendants requested

further information

including but not limited 

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to: supporting evidence 

from a treating 

physician providing 

specific detail and 

supportive 

documentation as to the 

treating physician’s 

individual qualifications, 

background, and, and 

treatment history with 

Ms. Grim.

Exhibit “Q” February 26, 2020 Letter from Holly 

Galleher, Campbell 

Property Management 

to Plaintiffs with cc to 

Mr. Sejour. 

The Architectural 

Review Committee 

recommended to defer 

the application until 

additional 

documentation has been 

received.

Exhibit “R” February 26, 2020 Second Letter from 

Emily L. Johnson, NP 

Third Letter from 

healthcare provider. 

POTS causes abnormal 

elevation in heart rate 

upon standing which 

often results in 

palpitations, 

lightheadedness, 

dizziness and sometimes 

syncope. Ms. Grim 

experiences 

dysregulation of the 

autonomic nervous 

system causing fatigue, 

temperature 

dysregulation and 

excessive sweating 

which make it difficult 

for Ms. Grim to perform 

and function basic 

activities on a daily 

basis. She is homeschooled. The fan 

would allow Ms. Grim 

to spend some time 

outdoors without 

excessive sweating 

instead of remaining in 

the house at all times. 

This would allow her to 

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participate in basic 

activities of daily living 

like getting fresh air.

She is treated with 

medication which aims 

to increase blood 

pressure to prevent her 

symptoms such as heat 

intolerance and 

excessive sweating, but 

the medication has 

demonstrated minimal 

response. Attachments: 

minor disabled child’s 

medical charts from 

2018.

Exhibit “S” March 3, 2020 Letter from Steven C. 

Rappaport, Sachs Sax 

Caplan, Attorneys at 

Law to Mr. Sejour, 

from Congressman 

Brian Mast’s office. cc: 

Holly Galleher, 

Campbell Property 

Management.

Acknowledging receipt 

of letter establishing 

need for a fan due to 

Plaintiff’s daughter’s 

disability. Requesting 

why a ceiling fan is 

required as opposed to a 

standing/pole fan. This 

letter stating not 

disapproving, but 

continuing to delay.

Exhibit “T” March 12, 2020 Late Notice: Even 

though the previous 

communication stated 

that they are not 

disapproving, they 

issued a fine. To the 

best of Plaintiff’s 

knowledge, the first 

indication of a fine was 

a late notice.

From Campbell property 

$1,000 fine for the 

ceiling fan.

Exhibit “U” April 10, 2020 Receipt of payment Plaintiffs paid the 

$1,000 fine for the 

alleged violation of 

having a ceiling fan.

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COUNT 1 – FAILURE TO REASONABLY ACCOMMODATE

(42 U.S.C. § 3604(f)(3)(B): Fla. Stat. §760.23(9)(b)) 

25. Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 24

above as though fully set forth herein. 

26. After Plaintiffs made a verbal request, and a written request for a reasonable

accommodation for their disabled minor child in or around October 2019-November 2019, 

Defendants requested extensive documentation from healthcare providers to demonstrate that a 

qualifying-disability existed and that the requested accommodation was necessary to afford the 

Plaintiffs’ daughter with an opportunity to enjoy the dwelling. 

27. After receipt of documentation from healthcare providers, Defendants acknowledged

that the Plaintiff’s minor daughter has a qualifying-disability within the meaning of 42 U.S.C. § 

3602(h), a disability which causes symptoms to include, but not be limited to, extreme heat 

intolerance, lightheadedness, dizziness and fainting spells. 

28. Defendants also acknowledged that there was a relationship between the minor child’s

disability and the need for the ceiling fan to provide ventilation which would provide her the ability 

to enjoy the balcony. 

29. Yet after receipt of documentation that should have been dispositive, in or around

March 2020, the Defendants’ recommendation that the disabled minor child drag a pole fan on and 

off the balcony was in reckless disregard of Plaintiffs’ rights and indifferent to the medical 

conditions or needs of Plaintiffs’ minor disabled child. They failed to grant Plaintiff’s request for 

accommodation. 

30. Plaintiff paid for the ceiling fan themselves, therefore, such accommodation was not

an undue financial or administrative burden to Defendants. Plaintiffs would remove the ceiling fan 

if they sold or moved away from the property as it is not a permanent fixture. 

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31. Defendants have unduly delayed in making a decision yet assessed a late fine of $1,000

to the homeowners. The late fine was sent without any prior request for payment. 

32. As a direct and proximate result of Defendants’ failure to accommodate the minor

child’s qualifying-disability, the continued inquiry has caused the minor child and the Plaintiffs to 

suffer irreparable loss and injury to include, but not be limited to financial loss, humiliation, 

emotional distress, and deprivation of a right to equal housing opportunities regardless of 

disability.

33. Such refusal to make reasonable accommodations in rules, policies, practices, or

services when such accommodations may be necessary to afford a person an equal opportunity to 

use and enjoy a dwelling, is in violation of the Florida Fair Housing Act Fla. Stat. Chapter 760 and 

Federal Fair Housing Act 42 U.S.C. § 3604(f)(3)(B). 

WHEREFORE, Plaintiffs demand judgment against the Defendants, its officers, 

employees, agents, successors and all other persons in active concert or participation with it to 

declare that their have violated the Fair Housing Amendments Act, and the Florida Fair Housing 

Act by discriminating against persons with disabilities; enjoin Defendants, its officers, employees, 

agents, successors and all other persons in active concert or participation with it from fining 

Plaintiffs based on the discriminatory practices alleged herein, enjoining Defendants, its officers, 

employees, agents, successors and all other persons in active concert or participation with it from 

any future discriminatory conduct against the Plaintiffs based on the unlawful housing practices 

as described herein and to award Plaintiffs compensatory relief in the amount of $1,000 and 

punitive damages and attorneys’ fees and costs as well as any such further relief this Court deems 

just and equitable. 

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 Respectfully Submitted:

Dawn M. Alba

Alba Law Office, PA

Attorney for Plaintiffs

303 Evernia Street, Suite 300 West 

Palm Beach, FL 33401

Dawn@Albalawoffice.com

(561) 584-0023 

Signed: 

Florida Bar Number 112814

Case 9:20-cv-80754-DMM Document 1 Entered on FLSD Docket 05/07/2020 Page 15 of 17
VERIFICATION OF LISA GRIM 

BEFORE ME, the undersigned authorized duly authorized to administer oaths, personally 

appeared LISA GRIM, who states that she has personal knowledge of th� facts set forth in this 

Verified Complaint and that they are true and correct. 

By: �) _____ : ____ _

Lisa dnrr1··---�

STATE OF FLORIDA 

COUNTY OF PALM BEACH 

The foregoing instrument was acknowledged before me this _(J) A�__ day of May 2020 by Lisa 

Grim, personally known to me. 

Notary Signature: 1t.Ra1JmJm � 

NOTARY PUBLIC 

Page 16 of 17

Case 9:20-cv-80754-DMM Document 1 Entered on FLSD Docket 05/07/2020 Page 16 of 17
VERIFICATION OF TIMOTHY GRIM 

BEFORE ME, the undersigned authorized duly authorized to administer oaths, personally 

appeared TIMOTHY GRIM, who states that she has personal knowledge of the facts set forth in 

this Verified Complaint and that they are true and correct. ¥· 1 fl/, 

By: cf�� 

Timothy Grim 

STATE OF FDORIDA 

COUNTY OF PALM BEACH I A 

The foregoing instrument was acknowledged before me this _(g_ -_ day of May 2020 by Lisa 

Grim, personally known to me. 

Notary Signature: iJcuuJtn� 

NOTARY PUBLIC 

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