Saunders Suit

Filing # 160877688 E-Filed 11/08/2022 02:48:32 PM
IN THE CIRCUIT COURT OF THE 16TH JUDICIAL CIRCUIT

IN AND FOR MONROE COUNTY, FLORIDA
WOOLEMS, INC., a Florida For-Profit CASE NO:

Corporation, and JAMES WOOLEMS,
an individual,
Plaintiffs,
vs.
SHELLEY SAUNDERS, an individual, and

S. SAUNDERS CONSULTING SERVICES,
LLC, a Florida Limited Liability Company,
Defendants.
______________________________________/
VERIFIED COMPLAINT
Plaintiffs, WOOLEMS, INC. (“Woolems”), a Florida For-Profit Corporation, and
JAMES WOOLEMS (“Mr. Woolems, and together with Woolems, collectively, “Plaintiffs”), an
individual, by and through undersigned counsel, hereby sues Defendants, SHELLEY
SAUNDERS (“Saunders”), an individual, and S. SAUNDERS CONSULTING SERVICES,
LLC (“Saunders Consulting,” and together with Saunders, collectively, the “Defendants”), a
Florida Limited Liability Company, and alleges as follows:
JURISDICTION AND VENUE
1. This is an action for injunctive relief, equitable relief, and for damages in an amount
within the jurisdictional limits of this Court, to wit, in excess of $30,000.00, exclusive of attorney’s
fees, costs, and interest.
2. Plaintiff, Woolems, Inc., is a Florida For-Profit Corporation which has conducted
business in Monroe County, Florida, and is otherwise sui juris.
Page 1 of 12
Mansfield, Bronstein & Stone, LLP
500 E. Broward Boulevard, Suite 1400, Fort Lauderdale, Florida 33394
Phone (954) 601-5600, Fax (954) 961-4756
11/8/2022 2:48 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 1
3. Plaintiff, James Woolems, is an individual who has conducted business in the State
of Florida and in Monroe County, Florida, and is otherwise sui juris.
4. Defendant, Shelley Saunders, is an individual who has conducted business in the
State of Florida and in Monroe County, Florida, and, to wit, resides in Monroe County, Florida.
5. Defendant, S. Saunders Consulting Services, LLC, is a Florida Limited Liability
Company which has conducted business in the State of Florida and in Monroe County, Florida,
and, to wit, is headquartered in Monroe County, Florida.
6. The acts and omissions described herein and giving rise to the lawsuit occurred, in
substantial part, in Monroe County, Florida.
7. This Court therefore has personal jurisdiction over the Defendants, which
conducted business within Monroe County, Florida, subject matter jurisdiction over the claims
asserted herein, and venue is proper in Monroe County, Florida.
GENERAL ALLEGATIONS
8. Woolems is an established and reputable builder in the luxury construction market
which builds and renovates residential homes and commercial spaces. It also provides its services
with respect to historic restorations, interior condominium improvements, and clubhouse projects.
9. Woolems’ President and Chief Executive Officer is James Woolems, who has
helmed his company since he founded it in 1984.
10. Mr. Woolems holds a Certified General Contractor License, which Woolems relies
upon to conduct its business.
11. Woolems handles numerous projects simultaneously throughout South Florida, and
many of those projects are governed by multi-million dollar written agreements.
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Phone (954) 601-5600, Fax (954) 961-4756
12. Prior to incidents which are the subject of a related case filed in Palm Beach County,
Florida, Woolems, Inc., et al. v. Gavin Guinan, et al., Case No.: 50-2022-CA-008141-XXXX-MB,
Woolems typically employed eighty (80) individuals at any given time between its offices located
in Palm Beach, Florida, Miami, Florida, and Key Largo, Florida.
13. Some of the projects exemplifying the scope and scale of Woolems’ services
include, for example, a multi-million dollar project for a historic renovation of a luxury
condominium sales center located in downtown Miami, Florida, a high-value project for
construction on Harbour Island, Eleuthera, in the Bahamas, and a 26,000 square foot penthouse in
Key Biscayne, Florida.
14. Unfortunately, in late 2018, Mr. Woolems became seriously ill and was forced to
take a step back from operating Woolems to seek a diagnosis and recover his health.
15. Woolems’ Chief Operating Officer, Gavin Guinan (“Guinan”), was entrusted to
operate Woolems during Mr. Woolems’ convalescence.
16. Mr. Woolems’ condition deteriorated markedly in 2019, but doctors were unable to
pinpoint a diagnosis as of June 2019. Despite the catastrophic potential that his illness threatened
both to his personal health and Woolems’ future, Mr. Woolems was dedicated to preserving his
company and ensuring that his many valued employees would not bear the financial burden of his
illness and recovery.
17. In March of 2020, during the height of the COVID-19 pandemic, Mr. Woolems
was recommended for brain surgery on an immediate basis and was further ordered to isolate while
awaiting the same.
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Phone (954) 601-5600, Fax (954) 961-4756
18. Following brain surgery in June of 2020 and due to certain health complications
thereafter, Mr. Woolems had a long road to recovery; however, he returned to Woolems in early
2022.
19. Upon his return, Mr. Woolems discovered that Guinan had violated company policy
through his personal actions taken while employed by Woolems.
20. Amongst other actions, and against direct orders, Guinan signed a two (2) year lease
in December of 2021 for a remote office in the exclusive Ocean Reef Club, located in Key Largo,
Florida, in the amount of $120,000.00 for no legitimate purpose.
21. To wit, Guinan signed the lease for the Ocean Reef Club office so that Saunders
could work at that exclusive location.
22. Guinan resigned from Woolems on May 19, 2022, after being confronted and asked
questions about many of his acts taken during his tenure as Woolems’ Chief Operating Officer.
23. While several employees of Woolems resigned from Woolems commencing on or
about the same date as Guinan through July of 2022, and, to wit, commenced employment with a
competitor under Guinan’s direction, Saunders continued to work for Woolems while concealing
her true efforts.
24. Instead of working solely for Woolems while at its offices, Saunders operated her
own entity, Saunders Consulting, and ran it out of Woolems’ Ocean Reef Club office at Woolems’
expense, using Woolems’ credentials, and without Woolems’ knowledge or authorization.
25. In furtherance of her own personal business interests with Saunders Consulting,
Saunders personally forged Mr. Woolems’ signature on at least several occasions to apply for and
obtain building permits under Mr. Woolems’ name and Certified General Contractor License.
26. Saunders concealed her actions from Woolems and Mr. Woolems.
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Phone (954) 601-5600, Fax (954) 961-4756
27. Saunders’ forgeries and other improper actions were discovered only through
Woolems’ diligence.
28. Upon discovery of Saunders’ improper actions, she was immediately terminated on
August 19, 2022.
Saunders’ Forgery of Multiple Applications for Monroe County Building Permits
29. The first such instance of Saunders personally forging Mr. Woolems’ signature was
discovered just prior to her termination on August 19, 2022, regarding Monroe County, Florida,
Building Permit 22400009 (“Permit 22400009”). A true and correct copy of the application
signature page for Permit 22400009 is attached hereto and incorporated by reference herein as
Exhibit “A.”
30. While reviewing Saunders’ company emails, Mr. Woolems learned that she had
been in communication, purportedly on behalf of Woolems, with an owner of a property since
January of 2022, and had executed a contract between the owner and Woolems for a $1.1 million
dollar addition to a property located at 18 Card Sound Road, Key Largo, Florida, which required
the application for a permit.
31. At all material times, Woolems’ internal policy has been that before an application
for a permit is issued, a project with a “contract/job number” is created within Woolems’
construction management software system so the project information and employee’s billable time
and materials may be tracked on the job from preconstruction all the way through project
completion.
32. Not only was this project not entered into the system, but it had also been purposely
deleted from Woolems’ permit tracker spreadsheet that is reviewed weekly.
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Phone (954) 601-5600, Fax (954) 961-4756
33. Additionally, the underlying contract was concealed from Woolems’ project
management and accounting staff.
34. Mr. Woolems did not sign the application for Permit 22400009 – it is a forgery.
35. It appears Saunders, who is personally known to Mr. Woolems, notarized his forged
signature on the application.
36. Upon information and belief, it was Saunders’ intent to use Woolems and Mr.
Woolems’ name and Certified General Contractor License to get the application approved and then
transfer it to another general contractor or perform the work under Woolems and Mr. Woolems’
name and license.
37. Given Saunders’ failure to obtain Mr. Woolems’ consent and active efforts to
conceal the application for a permit, it appears these efforts were done at Woolems’ expense and
for Saunders’ personal benefit.
38. To wit, once the permit was approved, Saunders could easily transfer the permit to
another general contractor or perform the work under Mr. Woolems’ license without him having
knowledge of it.
39. Shortly thereafter, Mr. Woolems discovered two other forged applications for a
permit, regarding Permit 22400008 and Permit 20400144. A true and correct copy of the
application signature page for Permit 22400008 is attached hereto and incorporated by reference
herein as Exhibit “B.” A true and correct copy of the application signature page for Permit
20400144 is attached hereto and incorporated by reference herein as Exhibit “C.”
40. Similar to Permit 22400009, Mr. Woolems did not sign the applications for Permits
22400008 or 20400144 – they are forgeries.
Page 6 of 12
Phone (954) 601-5600, Fax (954) 961-4756
41. To wit, Saunders notarized Mr. Woolems’ forged signature on all three of the
attached applications. See Exhibits “A, B, and C.”
42. Upon discovery of Saunders’ actions, Mr. Woolems notified Monroe County
Sheriff’s Department, which is currently investigating the forgeries and related matters under case
number MCSO22OFF006613.
43. Mr. Woolems also notified Monroe County’s Building Department to have the
fraudulently obtained permits voided.
44. On August 22, 2022, Mr. Woolems further filed a complaint with the Office of the
Governor, Notary Section, regarding Saunders’ repeated forgeries.
45. The complaint was acknowledged by the Office of the Governor on September 14,
2022, addressing the matter as “Investigation of Notary Public Shelley Saunders,” and thereafter,
Saunders’ notary status was suspended. A true and correct copy of the Commission Detail
regarding Saunders’ notary status (HLD, meaning on hold or suspended) is attached hereto and
incorporated by reference herein as Exhibit “D.”
46. While Woolems and Mr. Woolems were attempting to address Saunders’
fraudulent and improper actions, Saunders sought to retaliate by attempting to delete Woolems’
Facebook Page and by deleting its Linked-In Page. A true and correct copy of the Facebook email
regarding Saunders’ attempt to delete Woolems’ Facebook Page is attached hereto and
incorporated by reference herein as Exhibit “E.”
Saunders Continues to Notarize Documents and Interfere with Woolems’ Projects Despite
that Her Notary Status has been Suspended
47. Despite that Saunders’ notary status was placed on hold, she continues to notarize
documents and interfere with Woolems’ projects.
Page 7 of 12
Phone (954) 601-5600, Fax (954) 961-4756
48. For example, Woolems asked one of its customers, a project owner, to provide
Woolems with an executed and notarized Pre-Power Request and Agreement for Electrical
Service, which was reasonably necessary for continued construction at the associated property.
49. To wit, Saunders attempted to notarize the document on October 28, 2022, despite
her notary status being suspended. A true and correct copy of the Pre-Power Request and
Agreement for Electrical Service, reflecting, to wit, Saunders’ attempted notarization of the same,
is attached hereto and incorporated by reference herein as Exhibit “F.”
50. As a result, when the owner submitted the executed document which was
purportedly notarized by Saunders, Woolems was unable to accept the same.
51. Woolems notified the owner shortly after receipt of the document on October 31,
2022; however, Saunders’ improper notarization of the document had clearly already caused an
unnecessary delay.
52. To wit, Saunders personally enriched herself and Saunders Consulting at Woolems
and Mr. Woolems’ expense through her improper actions.
53. Plaintiffs are still in the process of learning the extent of Defendants’ actions made
to the detriment of Plaintiffs.
54. Defendants’ conduct has required Plaintiffs to retain the undersigned law firm and
Plaintiffs are obligated to pay a reasonable fee for its services.
55. All conditions precedent to the filing of this Complaint, if any, have occurred or
been waived.
COUNT I – INJUNCTION
(Woolems and Mr. Woolems vs. Saunders and Saunders Consulting)
56. Plaintiffs repeat and reincorporate Paragraphs 1 through 55 as if fully set forth
herein.
Page 8 of 12
Phone (954) 601-5600, Fax (954) 961-4756
57. This is an equitable action for temporary and permanent injunctive relief by
Woolems and Mr. Woolems against Saunders and Saunders Consulting.
58. Plaintiffs request the entry of an Order as follows: i) Ordering Defendants to
immediately provide Plaintiffs with a copy of all documents Saunders notarized under Woolems’
name or Mr. Woolems’ name, ii) Ordering Defendants to disclose and provide Plaintiffs with the
names, addresses, phone numbers, and email addresses for all individuals and entities Saunders
notarized documents for under Woolems’ name or Mr. Woolems’ name, iii) enjoining Saunders
from notarizing any documents under Woolems’ name or Mr. Woolems’ name; and iv) enjoining
Defendants from conducting any further business in Woolems’ name, in Mr. Woolems’ name, or
on Woolems’ projects.
59. Saunders operated her own entity, Saunders Consulting, and ran it out of Woolems’
Ocean Reef Club office at Woolems’ expense, using Woolems’ credentials, and without Woolems’
knowledge or authorization.
60. Saunders personally forged Mr. Woolems’ signature on at least several occasions
to apply for and obtain building permits under Mr. Woolems’ name and Certified General
Contractor License. See Exhibits “A, B, and C.”
61. Saunders concealed her actions from Woolems and Mr. Woolems.
62. Saunders has further taken and attempted to take inappropriate actions on behalf of
Woolems without its authorization by, for example, deleting its LinkedIn page and attempting to
delete Woolems’ Facebook page after her termination. See Exhibit “E.”
63. Woolems has suffered and continues to suffer irreparable harm as a result of
Saunders’ actions. The damage and injury caused by Saunders is of such a nature that Woolems’
monetary damages cannot be calculated and the true scope of Saunders’ forgeries is unknown.
Page 9 of 12
Phone (954) 601-5600, Fax (954) 961-4756
64. Woolems has a clear legal right to the requested injunctive relief as it has the sole
legal right to use and benefit from its own name and Certified General Contractor License.
65. Woolems has no adequate remedy at law to compensate for the harm caused to it
by Saunders, whose actions continue to injure Woolems.
66. The requested injunction would serve the interest of the public generally given that
Saunders continues to attempt to notarize documents while suspended and she continues interfere
with Woolems’ projects. Saunders’ actions have caused and will continue to cause injury to
unaware members of the general public whose construction projects have been delayed or who
may apply for a building permit using a fraudulent application. See Exhibits “A, B, C, and F.”
WHEREFORE, Plaintiffs, WOOLEMS, INC. and JAMES WOOLEMS, requests that
the Court enter a preliminary injunction, thereafter to be made permanent, as follows: i) Ordering
Defendants to immediately provide Plaintiffs with a copy of all documents Saunders notarized
under Woolems’ name or Mr. Woolems’ name, ii) Ordering Defendants to disclose and provide
Plaintiffs with the names, addresses, phone numbers, and email addresses for all individuals and
entities Saunders notarized documents for under Woolems’ name or Mr. Woolems’ name, iii)
enjoining Saunders from notarizing any documents under Woolems’ name or Mr. Woolems’ name;
and iv) enjoining Defendants from conducting any further business in Woolems’ name, in Mr.
Woolems’ name, or on Woolems’ projects. Woolems further requests such other and further relief
as this Court deems just and proper.
COUNT II – FORGERY PURSUANT TO § 772.104, FLORIDA STATUTES

(Mr. Woolems vs. Saunders)
67. Mr. Woolems repeats and reincorporates Paragraphs 1 through 55 as if fully set
forth herein.
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Phone (954) 601-5600, Fax (954) 961-4756
68. This is an action for forgery pursuant to § 772.104, Florida Statutes, by Mr.
Woolems against Saunders.
69. Saunders has repeatedly personally forged Mr. Woolems’ signature and falsely
notarized documents involving his Certified General Contractor License (collectively, the
“Incidents of Criminal Activity”). See Exhibits “A, B, and C.”
70. The Incidents of Criminal Activity perpetrated by Saunders had the same or similar
intent, to benefit her financially, and were conducted in a similar manner.
71. The Incidents of Criminal Activity perpetrated by Saunders occurred within five
(5) years of one another and were not isolated incidents.
72. Mr. Woolems has suffered damages as a result of Saunders’ actions.
WHEREFORE, Plaintiff, JAMES WOOLEMS, demands judgment against Defendant,
SHELLEY SAUNDERS, for monetary damages, treble damages, attorneys’ fees, costs, and such
other and further relief as this Court deems just and proper.
DATED: this 8th day of November, 2022.
Respectfully submitted,
/s/ Gary N. Mansfield

ROBERT J. MANSEN, ESQ.
FBN: 102737
DAVID STONE, ESQ.
FBN: 400432
GARY N. MANSFIELD, ESQ.
FBN: 61913
MANSFIELD, BRONSTEIN & STONE, LLP
Counsel for Plaintiff, Woolems, Inc., and
James Woolems
500 E. Broward Boulevard, Suite 1400
Fort Lauderdale, Florida 33394
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Phone (954) 601-5600, Fax (954) 961-4756
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EXHIBIT
“E”
From: Robert Mansen
To: Robert Mansen
Subject: FW: Your Facebook Page has been scheduled for deletion
Date: Thursday, November 3, 2022 5:41:33 PM
From: Facebook <security@facebookmail.com>

Sent: Sunday, August 21, 2022 8:54 AM
To: Vendor Accounts <vendors@woolemsinc.com>
Subject: Your Facebook Page has been scheduled for deletion
Hi Woolems, Shelley Saunders has scheduled the Page " Woolems, Inc. " for deletion. You have 14 days to restore the page before the page is deleted permanently. You are receiving this message because you are an admin of this page. View Page Status Thanks, The Facebook Team
Important change to your Page
Hi Woolems,
Shelley Saunders has scheduled the Page "Woolems, Inc." for deletion. You have 14 days to
restore the page before the page is deleted permanently.
You are receiving this message because you are an admin of this page.

View Page Status
Thanks,
The Facebook Team
This message was sent to vendors@woolemsinc.com at your request.

Meta Platforms, Inc., Attention: Community Support, 1 Facebook Way, Menlo Park, CA 94025
To help keep your account secure, please don't forward this email. Learn more
This email has been scanned for spam and viruses by Proofpoint Essentials. Click here to
report this email as spam.
EXHIBIT
“F”

Saunders Suit

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Filing # 160877688 E-Filed 11/08/2022 02:48:32 PM

IN THE CIRCUIT COURT OF THE 16TH JUDICIAL CIRCUIT

WOOLEMS, INC., a Florida For-Profit CASE NO:

SHELLEY SAUNDERS, an individual, and

Plaintiffs, WOOLEMS, INC. (“Woolems”), a Florida For-Profit Corporation, and

individual, by and through undersigned counsel, hereby sues Defendants, SHELLEY

SAUNDERS (“Saunders”), an individual, and S. SAUNDERS CONSULTING SERVICES,

Florida Limited Liability Company, and alleges as follows:

JURISDICTION AND VENUE

fees, costs, and interest.

2. Plaintiff, Woolems, Inc., is a Florida For-Profit Corporation which has conducted

business in Monroe County, Florida, and is otherwise sui juris.

of Florida and in Monroe County, Florida, and is otherwise sui juris.

4. Defendant, Shelley Saunders, is an individual who has conducted business in the

5. Defendant, S. Saunders Consulting Services, LLC, is a Florida Limited Liability

and, to wit, is headquartered in Monroe County, Florida.

substantial part, in Monroe County, Florida.

asserted herein, and venue is proper in Monroe County, Florida.

8. Woolems is an established and reputable builder in the luxury construction market

helmed his company since he founded it in 1984.

upon to conduct its business.

many of those projects are governed by multi-million dollar written agreements.

in Palm Beach, Florida, Miami, Florida, and Key Largo, Florida.

Key Biscayne, Florida.

operate Woolems during Mr. Woolems’ convalescence.

illness and recovery.

awaiting the same.

through his personal actions taken while employed by Woolems.

Florida, in the amount of $120,000.00 for no legitimate purpose.

could work at that exclusive location.

23. While several employees of Woolems resigned from Woolems commencing on or

her true efforts.

expense, using Woolems’ credentials, and without Woolems’ knowledge or authorization.

August 19, 2022.

Saunders’ Forgery of Multiple Applications for Monroe County Building Permits

been in communication, purportedly on behalf of Woolems, with an owner of a property since

the application for a permit.

deleted from Woolems’ permit tracker spreadsheet that is reviewed weekly.

management and accounting staff.

signature on the application.

name and license.

for Saunders’ personal benefit.

20400144 is attached hereto and incorporated by reference herein as Exhibit “C.”

22400008 or 20400144 – they are forgeries.

attached applications. See Exhibits “A, B, and C.”

fraudulently obtained permits voided.

Governor, Notary Section, regarding Saunders’ repeated forgeries.

incorporated by reference herein as Exhibit “D.”

incorporated by reference herein as Exhibit “E.”

documents and interfere with Woolems’ projects.

is attached hereto and incorporated by reference herein as Exhibit “F.”

purportedly notarized by Saunders, Woolems was unable to accept the same.

and Mr. Woolems’ expense through her improper actions.

to the detriment of Plaintiffs.

Plaintiffs are obligated to pay a reasonable fee for its services.

Woolems and Mr. Woolems against Saunders and Saunders Consulting.

58. Plaintiffs request the entry of an Order as follows: i) Ordering Defendants to

Contractor License. See Exhibits “A, B, and C.”

by Saunders, whose actions continue to injure Woolems.

WHEREFORE, Plaintiffs, WOOLEMS, INC. and JAMES WOOLEMS, requests that

as this Court deems just and proper.

COUNT II – FORGERY PURSUANT TO § 772.104, FLORIDA STATUTES