January 1, 2018

Delaire Country Club                                     VIA FAX 499 8625

4645 Cedar Lane

Delray Beach Fl. 33445


ATTENTION: Richard Abbey Chairman of the Grievance committee

                          Jeffrey White Secretary  of  Delaire Country Club


Pursuant to Article XIV of the Delaire Country Club’s Bylaws, this letter is a formal complaint from this Mandatory Member and partial owner of Delaire Country Club Inc. against President Curtis Karpel  that  approved the [Depletion of our Capital Improvement Fund in the amounts exceeding  ½ million dollars without the authority of a membership vote as stipulated in Article VI (G)]. Such a recklessness has been “self-confessed to” by Mr. Karpel as he was moderating the “Membership Meeting of November 12th “(recorded). The violation arose in funding the “Beautification Program” during the summer of 2017 as related by Mr. Karpel during the meeting. Continuing with his enlightenment he further stated that the transactions were approved by other board members as recorded on the CD which will be made available during the hearing.  Without the required membership vote, President Karpel & CO. approved such an illegal expenditure thereby engaging in conduct improper, likely to endanger the welfare, harmony and the congeniality of the members and is in violation of the code [misconduct] as described.  Article VI (G) states the following:

G. Make expenditures for capital projects out of funds designated on the balance sheet as “Reserve for Capital Improvements and Debt Service” limited as follows: Subject to sub-paragraph (1) below, not to excess of $50,000 for any single project and not in excess of $200,000 in the aggregate in any fiscal year for all projects unless either or both of such expenditures are approved by a written consent executed by a majority of the members voting or by resolution adopted at a meeting of the club membership by a vote of the majority members voting either in person or by mail ballot such meeting shall be duly called upon written notice specifying the nature and amount of the proposed expenditure.

On November 14 2017, this complainant forwarded a letter to Mr. Karpel and the Board, making a request for documentation authorizing such an expenditure. Up to this writing I have not been favored with a reply. Therefore, I must assume there is no authorization for such an expenditure. With the advice of my outside counsel, that leaves me without any other alternative but to charge President Karpel with the above referred to grievance complaint. The grievance charge must be adjudicated within the prescribed rulings of Article XIV as to the violation of Article VI (G) without further delay. Having submitted the correspondence of November 14th prior to this up-dated grievance charge, as per your response of 12/29/2017 to correct the procedure for filing my previous complaint, which I found trivial, I feel such a burden unnecessary. Note:  I will be filing future charges against board members that were equally responsible with violations of our bylaws and their Fiduciary Responsibilities which will be revealed either during the grievance hearings or subject to further depositions by the accused.

 It must be noted by the Chair that Mr. Karpel by his act of defiance of Article VI (G) has also violated his “Fiduciary Responsibility” to all the members of Delaire Country Club, which not only requires a hearing before the grievance committee, is also subject to civil penalties, which I am asking my attorney to follow-up. I am further requesting that this grievance charge against the named in the above be treated with the utmost “ASSIDUOUSNESS”. Mr. Karpel has already "confessed" of his wrongdoing to the entire membership and the involvement of others. The punishment to such an unlawful indiscretion must be met with a duplication of the punishment bestowed onto this writer of a 1 year suspension, even though no reason for it ever took place. See the adjudication of the WIPO.  Such a “reprehensible” episode leaves it open for future grievance charges against all that participated in the “defilement”. It must further be realized that the entire matter of Brecker v. Delaire is soon to be adjudicated with a requested Jury trial, a trial date to be forthcoming within the next 6 month.  Should your decision be found in the negative by not accepting this grievance charge, it will be an admission that Selective Enforcement (illegal in the state of Florida) is practiced at Delaire. Such a certainty will be subject to an amended complaint to my pending litigation. 

Hoping receipt of this communication will be accept within the spirit of cooperation it has been forwarded.

Warmest regards,



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