Professional Documents
Culture Documents
Find it here...
Site Search
Home / Records Search / Court Records / Public Inquiry / Search Results - A LL / C ase - 112009C C 0026170001XX
apps.collierclerk.com/…/Case.aspx?UC… 1/4
9/16/2010 Public Inquiry
THIS AC TIO N/MO TIO N TO STR IKE ASSO C PLEADINGS AS SHAM
08/27/2009 MO TIO N
& NO TIC E O F PUBLICATIO N O F PLAINTIFF C RO SS C LAIMANTS C O NCLUSIVE
EVIDENC E O F FR AUD O N THE C O UR T & FR AUDULANT C LAIM/AC TIO N BY GR ANADA
08/27/2009 MO TIO N
& NO TIC E EMER GENC Y FO R DISC LO SUR E O F ASSO C IATIO NS AC C O UNTING REC O R DS
BY ANY & ALL AC C O UNTING ENTITIES P UR SUANT TO C H 718 FLA STAT
08/27/2009 R EQ UEST FO R ADMISSIO NS TO JULIA N JAC KSO N
08/27/2009 MO TIO N TO C O MPEL BY DR JO R GE BUSSE
08/27/2009 NO TIC E
O F JO INDER O F JULIA N JAC KSO N/EMER GENC Y MO TIO N TO STR IKE ASSO C IATIO N
PLEADINGS/NO TIC E O F ASSO C IATIO N FR AUD O N C O UR T
08/27/2009 NO TIC E
O F FR AUD AND FALSE PR ETENSES O F NO N PAYMENT O F C O NDO FEES/MEMO R ANDUM
IN SUPPO R T O F ASSO C IATIO N FR AUD O N C O UR T
08/27/2009 NO TIC E
O F JO INDER O F JULIA N JAC KSO N/EMER GENC Y MO TIO N TO STR IKE/NO TIC E O F
FR AUD
08/31/2009 AFFIDAVIT O F NO N-SER VIC E O F SUMMO NS DR JO R GE R BUSSE
08/31/2009 AFFIDAVIT O F NO N-SER VIC E O F SUMMO NS DR JO R GE BUSSE
12/11/2009 AFFIDAVIT O F NO N-SER VIC E O F SUMMO NS JANE DO E
12/11/2009 AFFIDAVIT O F NO N-SER VIC E O F SUMMO NS JR BUSSE
12/11/2009 AFFIDAVIT O F NO N-SER VIC E O F SUMMO NS UNKNO W N TENANT
01/29/2010 AFFIDAVIT O F DILIGENT SEAR C H/C O NSTR UC TIVE SER VIC E
JR BUSSE/JANE DO E AS UNKNO W N SPO USE O F JR BUSSE/UNKNO W N TENANTS
01/29/2010 MO TIO N
FO R APPO INTMENT O F GUARDIAN ATTO RNEY AND ADMINISTR ATO R AD LITEM BY
GR ANADA C O NDO HO MES INC
02/08/2010 NO TIC E O F SER VIC E
O F MO TIO NS & O BJEC TIO NS 02/01/2010 UPO N HO NO R ABLE MIC HAEL J PR O VO ST
02/08/2010 NO TIC E
O F PLAINTIFF'S FR AUDULENT LIEN/O BJECTIO NS TO PLAINTIFF'S MO TIO N &
AFFIDAVIT/MO TIO NS TO DISMISS & FO R SANC TIO NS BY DR JO RG BUSSE
02/08/2010 NO TIC E
O F PLAINTIFF'S FR AUDULENT LIEN/O BJECTIO NS TO PLAINTIFF'S MO TIO N &
AFFIDAVIT/MO TIO NS TO DISMISS & FO R SANC TIO NS BY DR JO RG BUSSE
02/08/2010 MO TIO N FO R SANC TIO NS BY DR JO RG BUSSE
02/08/2010 PLAINTIFF FR AUD & FO R GER Y-EVIDENC E O F BY DR JO R G BUSSE
02/08/2010 NO TIC E
O F PR EVIO US FILING O F BUSINESS R EC O R DS & EVIDENC E O F FR AUD BY
DR JO R G BUSSE
02/08/2010 NO TIC E O F FILING
O F BUSINESS R EC O R DS AND EVIDENC E O F DEFENDANT'S FR AUDULENT AC C O UNTING
02/08/2010 NO TIC E O F PLAINTIFF FR AUD / FILED BY DR JO RG BUSSE
02/08/2010 NO TIC E
O F PLAINTIFF'S FR AUD AND FR AUD O N C O UR T / FILED BY DR JO R G BUSSE
02/11/2010 O R DER O F R EASSIGNMENT TO EUGENE C TUR NER
02/11/2010 C O RR ESPO NDENCE FR O M C O UNSEL TO JUDGE
W ITH C O P Y O F MO TIO N TO APPO INT GUAR DIAN ATTO RNEY & ADMINISTR ATO R
AD LITEM
02/11/2010 O R DER O F R EC USAL O F JUDGE MIC HAEL J P RO VO ST S/PR O VO ST 02/11/10
02/15/2010 O R DER APPO INTING ATTO R NEY AD LITEM, GUAR DIAN AD LI
02/16/2010 MO TIO N TO DISMISS AS FR ADULENT & FR IVO LO US AND FO R EXPENSES
02/16/2010 NO TIC E O F SER VIC E
O F MO TIO N UPO N R EASSIGNED JUDGE EUGENE C TUR NER /MO TIO N TO DISMISS
AS FR ADULENT AND FR IVO LO US AND FO R EXPENSES
02/16/2010 NO TIC E
O F PLAINTIFFS FR AUD O N THE C O URT NO TIC E O F SER VIC E O F MO TIO NS UPO N
R EASSIGNED JUDGE MO TIO N TO DISMISS AS FRADULENT & FR IVO LO US & EXP ENSES
02/16/2010 NO TIC E
O F PLTS FR AUD O N THE C O UR T NO TIC E O F SERVIC E O F MO TIO NS UPO N R EASSIGN
JUDGE/MO TIO N TO STR IKE PLAINTIFFS MO TIO N AS FR AUDULENT & SC ANDALO US
02/16/2010 NO TIC E
O F PLAINTIFF FR AUD O N THE C O UR T MO TIO N TO STR IKE PLAINTIFFS MO TIO N AS
FR AUD & SC ANDALO US AND MO TIO N TO C O MPEL SER VICE
02/17/2010 DEFENDANT
DEC LAR ATO R Y STATEMENTS IN SUP PO R T O F MO TIO N TO DISMISS THIS FR AUDULENT
apps.collierclerk.com/…/Case.aspx?UC… 2/4
9/16/2010 Public Inquiry
AC TIO N/DEFENDANT'S MO TIO N TO Q UIET TITLE BY DR J R BUSSE
02/17/2010 NO TIC E O F SER VIC E
O F PLEADINGS UPO N R EASSIGNED JUDGE EUGENE C TUR NER BY DR JO R G BUSSE
02/17/2010 MO TIO N TO Q UIET TITLE BY DR J R BUSSE
02/17/2010 C O RR ESPO NDENCE FR O M JUDGE TO JR BUSSE
02/18/2010 NO TIC E O F APP EAL O R DER R ENDER ED 2/15/10 CER TIFIED C O PY 10-01-AP
02/18/2010 C O RR ESPO NDENCE FR O M DR JO R GE BUSSE RE NO TIC E O F APPEAL
02/18/2010 AFFIDAVIT
BY JO R G BUSSE MD MBA MM IN SUPPO R T O F MO TIO N TO DISMISS, Q UIET TITLE,
R ELEASE LIEN & O F FR AUD O N THE C O UR T & PERJUR Y BY P LAINTIFF & C O UNSEL
02/18/2010 MO TIO N
(EMER GENC Y) FO R R EVIEW O F C ASE FILE & NO TIC E O F DEMAND FO R JURY TR IAL
02/19/2010 NO TIC E O F SER VIC E
O F NO TIC E O F APP EAL UP O N R EASSIGNED JUDGE EUGENE TUR NER
R EC EIVED BY JUDGE TUR NER FEB 18, 2010
02/22/2010 C O RR ESPO NDENCE FR O M
APP EAL CLER K TO JUDGE TUR NER NO TIC E O F FILING APPEAL O F FINAL O R DER
02/22/2010 UNDELIVER ED MAIL
J R BUSSE & JANE DO E/O R DER O F R EASSIGNMENT S/PIVAC EK 2/10/10
02/22/2010 UNDELIVER ED MAIL
UNKNO W N TENANTS/O R DER O F R EASSIGNMENT S/PIVAC EK 2/10/10
02/23/2010 NO TIC E O F SER VIC E O F EMER GENC Y MO TIO NS UPO N R EASSIGNED JUDGE
02/23/2010 MO TIO N EMER GENC Y FO R PUBLIC R EC O R D AC C ESS
02/25/2010 NO TIC E O F SER VIC E
02/25/2010 MO TIO N
FO R SC HEDULING O F HEAR ING O F MO TIO NS AND NO TICE O F UNAVAILABILITY
2/24/10
02/26/2010 NO TIC E O F SER VIC E
DEMAND FO R JUR Y TR IAL/NO TICE O F SER VIC E O F MO TIO N/MO TIO N FO R
SC HEDULING/NO TIC E O F UNAVAILABITY /BUSSE
03/02/2010 NO TIC E O F PUBLIC ATIO NS/ DEMAND FO R JUR Y TR IAL
03/03/2010 MO TIO N FO R JUDIC IAL NO TIC E
O F PUBLIC LY R EC O R DED ASSO C IATIO N BY LAW S & DEC LAR ATIO N O F C O NDO MINIUM
& IN SUPPO R T O F MO TIO NS TO DEC LAR E TITLE/DEMAND JURY TR IAL BY DR BUSSE
03/03/2010 DEC LAR ATIO N O F TAKING
& PUBLIC R EC O R D EVIDENC E IN SUPPO R T O F NULL & VO ID LIEN & MO TIO N TO
DEC LAR E SUBJECT TITLE AUTO MATIC ALLY Q UIETED/DEMAND JUR Y TR IAL
03/10/2010 NO TIC E O F HEARING 4/5/10 11:00 PENDING MO TIO NS
03/31/2010 SUMMO NS ISSUED
J R BUSSE/ UNKNO W N SPO USE/ HANDED TO PLAINTIFFS ATTO R NEY AT C O UNTER
04/05/2010 NO TIC E O F SER VIC E
MO TIO N TO DISMISS BEC AUSE O F DEFENDANT'S FR AUD O N THE C O UR T/MO TIO N FO R
AC C ESS TO CASE FILE PR IO R TO HEAR ING & SER VIC E O F NO TIC E O F HEAR ING
04/05/2010 MO TIO N TO DISMISS
BEC AUSE O F DEFENDANT'S FR AUD O N THE C O UR T/MO TIO N FO R AC C ESS TO C ASE
FILE PR IO R TO HEARING/SERVIC E O F NO TIC E O F HEAR ING BY PLAINTIFF
04/05/2010 MO TIO N TO DISMISS
BEC AUSE O F DEFENDANT'S FR AUD O N THE C O UR T/MO TIO N FO R AC C ESS TO C ASE
FILE PR IO R TO HEARING & SER VIC E O F NO TIC E O F HEARING BY P LAINTIFF
04/05/2010 NO TIC E
O F PUBLISHED "RIPO FF R EPO R T" R EGAR DING FR AUD O N C O UR T BY P LAINTIFF'S
ATTO R NEYS IN SUPPO R T O F MO TIO N TO DISMISS O N DEFENDANTS FR AUD O N C O UR T
04/05/2010 MO TIO N TO DISMISS
BEC AUSE O F DEFENDANTS FRAUD O N THE C O UR T/MO TIO N TO AC C ESS TO C ASE FILE
PR IO R TO HEAR ING & SER VIC E O F NO TIC E O F HEARING BY PLAINTIFF ASSO C IATI
04/05/2010 MO TIO N
FO R AC C ESS TO C ASE FILE PR IO R TO HEAR ING & SER VIC E O F NO TIC E O F
HEARING UNDER THE R ULES BY JO R GE R BUSSE MD MM MBA
04/05/2010 ATTO R NEY C HENE THO MPSO N PR ESENT FO R P LAINTIFF/ DEFENDANT NO T
PR ESENT/ ATTO R NEY THO MSP O NS MO TIO N TO DENY ALL O F DEFENDANTS
MO TIO NS - GR ANTED/ DEFENDANTS MO TIO N TO STR IKE ALL O F PLAINTIFFS
PLEADINGS - DENIED/ DEFENDANTS MO TIO N O F FR AUD - DENIED/ DEFENDANTS
MO TIO N EXTINGUISHING - DENIED/ DEFENDANTS MO TIO N FO R PLAINTIFF TO
PR O DUCE ALL R EC O R DS - DENIED (NO SP EC IFIC R EC O RDS REQ UESTED)/
DEFENDANTS MO TIO N TO Q UITE TITLE - DENIED/ DEMAND FO R JUR Y TR IAL
FR O M DEFENDANT - BO TH AR E DENIED/ DEFENDANTS MO TIO N TO DELC AR E LEAN
FR AUDULANTE - DENIED/ DEFENDANTS MO TIO N FO R DECLAR EING ASSESSMENT -
DENIED/ DEFENDANTS MO TIO N FO R SANCTIO NS AGAINST ATTO R NEY THO MPSO N -
DENIED/ DEFENDANTS MO TIO N FO R C O UR T TO TAKE JUDIC IAL NO TIC E O F
PLAINTISS ASSO C IATIO N LAW S - DENIED/ DEFENDANTS NO TIC E O F JO INDER O F
apps.collierclerk.com/…/Case.aspx?UC… 3/4
9/16/2010 Public Inquiry
JULIA N JAC KSO N, R O BER T MURR ELL, JO HN PIER R E VAN DO NGEN, KEVIN
GAFFR EY AND R O BER T C SAMO UC E - DENIED/ ALL P ENDING DEFENSE MO TIO NS
AR E DENIED/ ATTO R NEY THO MPSO N TO PR EPARE AND O R DER LISTING ALL THE
MO TIO NS AND SUBMIT THE O R DER TO THE CO UR T
04/05/2010 MINUTES - HEAR ING SEE SC HEDULE MINUTES FO R DETAILS
04/05/2010 MO TIO N FO R JUDIC IAL NO TIC E
04/05/2010 C ER TIFIC ATE O F FILINGS & DELIVERIES UPO N JUDGE TUR NER
04/12/2010 O BJEC TIO N TO FR AUDULENT & ER R O NEO US O R DER BY JO R G BUSSE
04/12/2010 MO TIO N FO R PR O DUC TIO N O F ALL C O MMO N EXPENSE REC O R DS BY JO R G BUSSE
04/12/2010 MO TIO N FO R PR O DUC TIO N O F ALL AC C O UNTING R EC O RDS BY JO R G BUSSE
04/13/2010 MO TIO N FO R R EC USAL O F JUDGE TUR NER
04/13/2010 MO TIO N FO R JUDIC IAL NO TIC E O F JUDGE PIVAC EKS MO TIO N TO DISMISS
04/13/2010 NO TIC E O F SER VIC E
O F MO TIO N FO R R EC USAL O F JUDGE TUR NER AND MO TIO N FO R PR O DUC TIO N O F
ALL AC C O UNTING
04/29/2010 NO TIC E O F APP EAL
JUDIC IAL IMPAIR MENT AND O BSTR UC TIO N O F JUSTIC E 10-03-AP
04/29/2010 NO TIC E O F SER VIC E O F 4/29/10 NO TIC E O F APPEAL
04/29/2010 NO TIC E PUBLIC NO TIC E
04/29/2010 NO TIC E O F EMERGENC Y AND UNAVAILABILITY UNTIL FUR THER NO TIC E
05/05/2010 C O RR ESPO NDENCE FR O M C O UNSEL TO JUDGE
05/10/2010 O R DER DENYING ALL DEF PENDING MO TIO NS
05/12/2010 O R DER O F R EC USAL DENIED
05/28/2010 NO TIC E O F APP EAL O R DER R ENDER ED 5/10/10 CASE 10-04-AP CER TIFIED C O PY
05/28/2010 MO TIO N EMER GENC Y MO TIO N FO R R EC USAL O F JUDGE TUR NER
05/28/2010 NO TIC E O F INTENT TO TO SUE JUDGE TUR NER
W e dne sday night is re gular m a inte nance tim e on our se rve rs; as a re sult brie f o utage s m ay o ccur.
W e apologize in advance for any inconve nie nce.
apps.collierclerk.com/…/Case.aspx?UC… 4/4
9/16/2010 Public Inquiry
Find it here...
Site Search
Home / Records Search / Court Records / Public Inquiry / Search Results - A LL / C ase - 112009C C 0026170001XX
apps.collierclerk.com/…/Case.aspx?UC… 1/2
9/16/2010 Public Inquiry
BASED O N C O LLIER C O UNTY PUBLIC R ECO R DS AND PAYMENT R EC O R DS BY
J R BUSSE
07/29/2010 MO TIO N
TO DEC LAR E TITLE TO DR BUSSE'S PR O PER TY UNENC UMBER ED BY J R BUSSE
07/29/2010 MO TIO N
(EMER GENC Y) TO ENJO IN FR AUD O N C O UR T P UBLISHED NO TIC E O F FR AUDULENT
AFFIDAVIT AND PER JUR Y BY J R BUSSE
07/29/2010 MO TIO N
(EMER GENC Y) TO STIKE FR AUDULENT AFFIDAVIT BECAUSE O F PUBLIC LY R EC O R DED
PER JUR Y & FO R EC LO SUR E FRAUD P UBLISHED NO TIC E BY J R BUSSE
07/30/2010 O PINIO N BY AP BANC APP EAL DISMISSED C ER TIFIED C O P Y 10-04-AP
07/30/2010 O PINIO N BY AP BANC APP EAL DISMISSED C ER TIFIED C O P Y 10-03-AP
08/04/2010 O R DER DENYING MO TIO N
TO DISQ UALIFY JUDGE/CO PY P RO VIDED BY ATTO R NEY C LER K DID NO T R EC EIVE
THE O R IGINAL
08/05/2010 NO TIC E
O F LAW SUIT AGAINST EUGENE C TUR NER DEF C HENE M THO MPSO N ESQ SUMMO NS
08/05/2010 NO TIC E O F LAW SUIT AGAINST EUGENE C TUR NER DEF EUGENE C TURNER SUMMO NS
08/06/2010 MO TIO N FO R INDEPENDENT AC CO UNTNG AND AUDIT (EMER GENC Y)
08/06/2010 MO TIO N TO R ESTR AIN NIC HO LAS KRANC HER (EMER GENCY)
08/09/2010 NO TIC E O F VIO LATIO NS O F R EC O R D
08/09/2010 MO TIO N TO DEC LARE PR O C EEDINGS FR AUDULENT AND UNAUTHO R IZED (EMER GENC Y)
08/09/2010 AFFIDAVIT O F NO SER VIC E
08/09/2010 NO TIC E C O NTESTED LIEN
08/11/2010 AFFIDAVIT DR JO R G BUSSE
08/19/2010 AFFIDAVIT FR O M JO R G BUSSEE
08/27/2010 NO TIC E O F APP EAL NO FEE PAID NO O R DER ATTAC HED C ER TIFIED C O PY
08/30/2010 NO TIC E
O F R ELEASE AND DISC HAR GE O F FR AUDULENT LIS PENDENS - FILED BY
JO R G BUSSE
08/31/2010 NO TIC E
O F R ELEASE & DISC HAR GE O F FRAUDULENT LIS PENDENS BY DEFENDANT DR JO R G
BUSSE
08/31/2010 MO TIO N
FO R JUDIC IAL NO TIC E & NO TIC E O F LAC K O F PR O SEC UTIO N BY DEFENDANT
09/01/2010 R EQ UEST FO R JUDIC IAL NO TIC E
09/01/2010 NO TIC E O F R ELEASE AND DISC HAR GE O F FR AUDULENT LIS PENDENS
09/01/2010 MO TIO N FO R SUMMAR Y FINAL JUDGMENT & ATTY FEES BY GRANADA C O NDO HO MES
09/01/2010 AFFIDAVIT AS TO AMO UNTS DUE AND O W ING
09/01/2010 AFFIDAVIT AS TO C O STS
09/01/2010 AFFIDAVIT AS TO ATTO R NEYS FEES
09/01/2010 AFFIDAVIT O F FR ANK ALO IA JR
09/02/2010 MEMO R ANDUM AS TO R EC USAL
09/03/2010 MEMO R ANDUM AS TO R EC USAL
09/07/2010 DEFENDANT R EC O R DING O F R ELEASE O F LIS P ENDENS
09/07/2010 MO TIO N FO R R EC USAL O F JUDGE
W e dne sday night is re gular m a inte nance tim e on our se rve rs; as a re sult brie f o utage s m ay o ccur.
W e apologize in advance for any inconve nie nce.
apps.collierclerk.com/…/Case.aspx?UC… 2/2
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
Purported “plaintiff”
BUSSE, J. R.,
__________________________________________________________________________/
1. Here, Def. Judge Eugene C. Turner’s record conduct was improper, because Turner,
e.g.:
“Granada Condominium Homes Association, Inc.” could not have possibly brought any lien.
CONDOMINIUM HOMES”, O.R. 330, Page 466, ff, Collier County Public Records,
b. Not entitled to enforce a non-existent debt under the record contract and/or
Declaration.
2
3
RECUSAL MEMORANDUM
”A Judge Shall Avoid Impropriety and the Appearance of Impropriety in all of the
Judge's Activities.”
See Florida Supreme Court Original Proceeding - Amendment to Code of Judicial Conduct -
American Bar Association's Model Code of Judicial Conduct, Judicial Ethics Advisory
ALTERATION OF DOCKET
5. On or around 09/05/2010, i.e., more than one month later, the Case Docket showed:
Here, neither the Clerk of Court nor Dr. Jorg Busse received any original order.
Furthermore, subsequently filed Motions for Judge Turner’s Recusal did not appear on the
4
Docket. Attached is the Case Docket as it appeared on 09/02/2010 without the alleged order
5
6
FRAUDULENT JUDICIAL CONCEALMENT OF FICTITIOUS debt, O.R. 330/466-500
6. Defendant Judge Eugene Turner knew and fraudulently concealed that there was
a. No debt;
b. No “contract” for the fraudulently pretended obligation to pay “$1,500.00”;
c. No breach of any contract, O.R. 330 / 466 – 500.
Here, there was an unfounded and facially fraudulent foreclosure action as supported by
7. Here, Defendant Turner knew and concealed that Dr. Jorg Busse was
a. Never served;
b. Had attacked the record fraud scheme;
c. Had demanded judicial notice of the applicable Florida Statutes, and file, Ch.
92, F.S.;
d. Objected to any hearing, because this Court has no jurisdiction;
e. Objected to any and all magistrates;
f. Objected to any and all magistrate hearings.
RULE 2.330. DISQUALIFICATION OF TRIAL JUDGES
(a) Application. This rule applies only to county and circuit judges in all matters in
all divisions of court.
(b) Parties. Any party, including the state, may move to disqualify the trial judge
assigned to the case on grounds provided by rule, by statute, or by the Code of
Judicial Conduct.
9. Section 38.10 gives parties the right to move to disqualify a judge when the party fears
that “he or she will not receive a fair trial . . . on account of the prejudice of the judge of that
7
court against the applicant or in favor of the adverse party.” Fla. Stat. § 38.10. Rule of
Judicial Administration 2.330 specifies that a motion to disqualify must show that “the party
fears that he or she will not receive a fair trial or hearing because of specifically described
11. Here, Dr. Jorg Busse has been “stating fear that he will not receive a fair trial in the court
where the suit is pending on account of the prejudice of the judge of that court [Eugene C.
Turner] against the applicant. Here, objectively biased and bribed Judge Eugene C. Turner
“shall proceed no further, but another judge shall be designated in the manner prescribed by
the laws of this state for the substitution of judges for the trial of causes in which the
12. If the judge denies a motion to disqualify brought under § 38.10 the movant has the right
to appeal. Lynch v. State, ___ So. 2d ___, Nos. SC06-2233, SC07-1246, 2008 WL 4809783,
at *26 (Fla. Nov. 6, 2008). As the Florida Supreme Court recently held: “A motion to
Florida Rule of Judicial Administration 2.330. Here, Dr. Busse’s motion to disqualify
Defendant objectively partial Judge Turner is citing § 38.10 and Rule 2.330, as well as
Canon 3E(1).
8
13. The Florida Supreme Court has also held, in effect, that § 38.10 and the Canons require
the same thing. See Livingston v. State, 441 So. 2d 1083, 1086 (Fla. 1983). In Livingston the
court cited the Canon’s requirement that a judge disqualify himself when his “impartiality
might reasonably be questioned” and concluded that it was “totally consistent” with Florida
case law applying § 38.10. Id. Both require disqualification when a party can show “a well
grounded fear that he will not receive a fair trial at the hands of the judge.” Id. (quoting State
ex rel. Brown v. Dewell, 179 So. 695, 697-98 (Fla. 1938)); see also Berry v. Berry, 765 So.
2d 855, 857 (Fla. 5th DCA 2000) (quoting Canon 3E(1) when describing the standard for
granting a motion under § 38.10). Here of course, this Court was bound to follow Florida
appellate court decisions interpreting that state’s law. The final arbiter of state law is the
state Supreme Court, which is another way of saying that Florida law is what the Florida
14. The Florida Supreme Court has adopted a Code of Judicial Conduct to govern the
actions of state court judges and candidates for judicial office. Canon 3E(1) states, e.g.:
(1) A judge shall disqualify himself or herself in a proceeding in which the judge’s
impartiality might reasonably be questioned, including but not limited to instances
where …
15. Those provisions address situations in which a judge must disqualify himself because his
statement that commits, or appears to commit, the judge with respect to” a particular party,
issue, or controversy. Canon 3E(1) [general disqualification provision in Canon 3E(1)], 3E(1)
9
16. Canon 3E(1), backed by the threat of a disciplinary proceeding, requires a judge to
disqualify himself if his “impartiality might reasonably be questioned.” Fla. Stat. § 38.10,
supplemented by Rule 2.330, allows a party to have a judge disqualified for the same reason.
17. Canon 3E(1)(f), which the Florida Supreme Court adopted in January 2006, covers one
to Code of Judicial Conduct, 918 So. 2d 949 (Fla. 2006). In addition to the Florida Supreme
Court, the Judicial Ethics Advisory Committee (Ethics Committee) and the Judicial
Qualifications Commission (JQC) have roles in administering the Code. The Florida
Supreme Court established the Ethics Committee “to render written advisory opinions to
inquiring judges concerning the propriety of contemplated judicial and non-judicial conduct.”
Petition of Comm. on Standards of Conduct for Judges, 327 So. 2d 5, 5 (Fla. 1976).
18. Canon 3E is enforced by the Judicial Qualifications Commission, which has the
19. Here, Dr. Jorg Busse has been specifically alleging the following facts and reasons upon
which the movant relies as the grounds for Defendant County Judge Eugene Turner’s
disqualification. Here, Dr. Busse had well grounded fears that he will not receive a fair
trial at the hands of Defendant objectively partial and bribed County Judge Eugene C.
Turner.
20. Defendant Turner is a named party Defendant. See summons, service on file.
21. Defendant Turner had a conflict of interest, because Turner had invested in bankrupt
Orion Bank, which collected money for the purported Plaintiff Association.
10
22. In violation of the governing documents, no audits were conducted. Here, Defendant
Turner knew and concealed that the fictitious expenses and/or assessments had been
falsified.
23. The governing documents did not authorize the Plaintiff Association to “assess” more
than 105% …:
“The total of the assessments for recurring common expense shall be not more than
105% of the assessments for this purpose for the prior year unless approved in
writing by apartment owners …”
Here, there had been no “approval in writing” and the association falsified “assessments”.
24. Here, Defendant Turner knew and concealed that pursuant to the Governing Association
Documents Dr. Busse had satisfactorily paid his 1/12 share of the actual and necessary
25. In violation of the governing documents, the Association President, Julia N. Jackson,
owned more than the allowed one (1) unit. Here, Jackson owned three (3) association
26. In violation of the governing documents, the Association President, Julia N. Jackson, was
28. Here, Defendant Judge Turner knew and fraudulently concealed that no audit had been
furnished to each member and Dr. Jorg Busse pursuant to the Governing Association
“6.7 An audit of the accounts of the Association shall be made annually by a certified
public accountant…”
11
RETALIATION AND EXTORTION WERE ILLEGAL
29. Retaliation and extortion were illegal. For years, Dr. Busse had proven record
30. Attached are said Collier County Public Records in support of the publicly record
Association, Inc. See, e.g., O.R. 1517, Page 2165, and O.R. 330, Pages 498, 472.
31. Dr. Jorg Busse had contested the association’s fraudulent lien and/or claim.
32. Again, Dr. Jorg Busse gives notice of contest of the association’s unauthorized and
fraudulent lien.
“(4) A homeowners' association may not file a record of lien against a parcel for
unpaid assessments unless a written notice or demand for past due assessments as
well as any other amounts owed to the association pursuant to its governing
documents has been made by the association. The written notice or demand must …”
Here, “pursuant to its governing documents”, Dr. Jorg Busse had owed absolutely nothing to
the association. No “written notice or demand for” any “amounts owed to the association
pursuant to its governing documents” has been made by the association. Here, the association
12
FALSIFICATION OF “expenses” and “assessments”
34. The purported Plaintiff and Plaintiff’s Attorneys falsified expenses and/or assessments.
See, e.g., attached O.R. 330, Pages 498, 472, Collier County Public Records.
35. The governing documents did not authorize the Plaintiff association to “assess” more
than 105% …:
“The total of the assessments for recurring common expense shall be not more than
105% of the assessments for this purpose for the prior year unless approved in
writing by apartment owners …”
Here, there had been no “approval in writing” and the association falsified “assessments”.
36. § 720.3085, Fla. Stat. (Payment for assessments; lien claims), states:
Here, the “governing documents” did not “authorize” “the association” to defraud Dr. Jorg
Busse. Id. Here in particular, the governing documents did not authorize the association to
extort, and violate said Section 6, OR 330 Page 498. As a matter of law, the fraudulent lien
was null and void. See pleadings on file; see publicly recorded assessment payment records,
37. Here without authorization, the association purported to have filed “instrument”
38. Here, Dr. Jorg Busse had made satisfactory payment in full. In particular, the
association knew and fraudulently concealed that Dr. Jorg Busse had made satisfactory
13
MOTION TO DECLARE PROCEEDINGS FRAUDULENT & UNAUTHORIZED
39. Dr. Busse had moved this Court to declare the proceedings fraudulent and
unauthorized.
b. The purported “Plaintiff” did not hold any legitimate and genuine lien on Dr.
c. There was no “debt” pursuant to Dr. Busse’s publicly recorded payment records
41. Defendant Eugene C. Turner, an investor in bankrupt Orion Bank, knew that
Defendant Judicial Officers Chene M. Thompson and Richard DeBoest, II, fraudulently
pretended a falsified lien, which had been conclusively controverted by the publicly
42. Here, Federal Defendant Eugene C. Turner had conflicts of interest and refused to
recuse himself even though Turner had invested in failed Orion Bank, which had managed
43. Therefore, Dr. Jorg Busse demands an independent audit and accounting of any and all
of purported Plaintiff’s transactions under Florida law, and Ch. 718, Fla. Stat.
44. Process server Nicholas Krancher, ID # 157188, was arrested on February 9, 2008.
14
45. The Twentieth Judicial Circuit Certified Civil Process Server Review Board, 2072
Victoria Ave., Ft. Myers, FL 33901, has been monitoring Defendant process server
Nicholas Krancher.
46. Dr. Jorg Busse complained about troubled process server Nicholas Krancher with the
47. Troubled process server Nicholas Krancher never served Dr. Jorg Busse with any
summons and/or complaint. Defendant Nicholas Krancher had perjured himself and
falsified official documents. Here, Defendant Krancher knew that Dr. Jorg Busse had not
been served.
FRAUDULENT PRETENSES
Courthouse.
49. Defendant Krancher could not have possibly attempted any service at said Courthouse.
50. Dr. Jorg Busse has not been any served party Defendant.
52. Based on the public record evidence, troubled Nicholas Krancher was arrested and has a
15
53. Defendant Krancher perjured himself for criminal and illegal purposes on the public
record.
54. Dr. Jorg Busse lives in reasonable fear of further unlawful acts by Defendant Nicholas
55. Defendant N. Krancher poses a threat. Dr. Jorg Busse has a Constitutional right to be
56. Dr. Jorg Busse is suing Defendant Chene M. Thompson, a judicial officer, in Federal
Court.
NO service – NO jurisdiction
57. Pursuant to the record, Dr. Jorg Busse was not served and did not submit to any
jurisdiction.
NO debt – NO lien
58. Defendant Thompson knew that no debt had existed in this facially fraudulent action.
Here, nothing could have possibly become any lien on Dr. Jorg Busse’s record property.
59. Orion Bank, the purported “Plaintiff’s” failed agent went bankrupt, and Defendant E.
60. Prevention of publicly recorded foreclosure fraud is a top-ranking public agenda and an
EMERGENCY.
16
1. An EMERGENCY Order recusing and/or disqualifying objectively partial Defendant
2. An Order declaring the falsified proceedings fraudulent and unauthorized under said
3. An Order for said independent audit and accounting pursuant to Florida law;
perjury;
10. An Order compelling Eugene C. Turner to SHOW CAUSE why Defendants’ facially
frivolous and illegal claims should not be summarily dismissed as supported by the
11. An Order compelling Eugene C. Turner to SHOW CAUSE why his “orders” and
“rulings” were not on their faces irrational, arbitrary, capricious, and null & void as
evidenced by the public record evidence, Affidavits, and Dr. Busse’s payment records on
file.
17
12. An EMERGENCY Order disqualifying and recusing objectively impaired Judge
Eugene C. Turner, because he was so impaired that he could not perform the essential duties
Eugene C. Turner, because no reasonable, intelligent, and fit judge, juror, and/or person in
Turner’s shoes could have possibly determined Dr. Busse’s “liability” without first obtaining
Eugene C. Turner, because no reasonable, intelligent, and fit judge, juror, and/or person in
Turner’s shoes could have possibly refused to give full credit to the record evidence of
15. An Order compelling said Judicial Officer Turner and the Court to show good cause why
said judicial Officer was not impaired and not objectively partial;
16. An Order compelling said Judicial Officer Turner and the Court to show good cause why
said judicial Officer must not be disqualified under the Rules and based upon the conclusive
evidence of Dr. Busse’s payments to the Association on file in this and the related Case;
17. An Order compelling said Judicial Officer Turner and the Court to show good cause why
said judicial Officer did not conceal that Dr. Busse was NEVER served;
18. An Order compelling the Plaintiff to disclose and produce the Association’s “common
19. An Order compelling the Plaintiff to disclose and produce the Association’s
18
20. An Order dismissing Plaintiff’s fraudulent Complaint with prejudice pursuant to said
21. An Order providing Dr. Busse with mandatory access to the case file prior to any
hearing;
22. An Order for service of a notice of hearing upon Dr. Busse under said Rules;
23. An Order declaring the fraudulent lien null and void and/or not in effect and Defendant’s
24. An Order declaring any and all unapproved assessments null and void under said By-
25. An Order compelling the Association to disclose any and all accounting and other
records since 2003 pursuant to said By-Laws, and Ch. 718, Condominiums, Florida Statutes,
and in particular the records of said failed and/or defunct Association agents;
26. An Order sanctioning Chene M. Thompson, Esq., Florida Bar 541540, for the prima
facie perjury and fraud on the Court she and her firm, Richard D. DeBoest, II, Condo &
HOA Law Group, LLC, 2030 McGregor Blvd., Fort Myers, FL 33901, perpetrated on the
record when Thompson swore to and filed the fraudulent Affidavit (01/28/2010) to mislead
this Court.
27. An Order taking judicial notice of the Plaintiff Association’s said By-Laws, Public
I HEREBY CERTIFY that a true and correct copy of the above pleading has been furnished to
the Plaintiff, Granada Condominium Homes Association, Inc., and/or its agent of record,
Platinum Property Management, LLC, North Collier Corporate Center II, 1016 Collier Center
Way, Suite 102, Naples, FL 34110, Chene M. Thompson, Esq., Florida Bar 541540, Richard D.
19
DeBoest, II, Condo & HOA Law Group, LLC, 2030 McGregor Blvd., Fort Myers, FL 33901,
and to reassigned Judge Eugene C. Turner, Naples Courthouse, 3301 E. Tamiami Trail, Naples,
FL 34112, on this 3rd day of September, 2010. The pleading is also being published worldwide.
See, e.g., www.scribd.com, www.google.com.
CC: Donna Woodruff, Facsimile: 239-252-8020, Clerk of Courts; Angela Turner, J.A.
20
21
22
23
24
AFFIDAVIT OF DR. JORG BUSSE
STATE OF FLORIDA
BEFORE ME, the undersigned authority authorized to administer oaths and take
acknowledgments, personally appeared Dr. Jorg Busse, and who, after first being duly sworn,
deposes and says upon oath the foregoing and Complaint in U.S. District Court, UNITED
__________________________
Expiration of Commission:
__________________
/s/Notary Public
25
PUBLICATIONS:
http://www.scribd.com/eugene_C_turner
http://www.scribd.com/doc/35732834/Granada-Condo-Homes-Association-
Inc-Fraud
http://www.scribd/Foreclosure_Fraud
http://www.scribd.com/doc/35611989/Eugene-C-Turner-Florida-Bar-
Complaint
http://www.scribd.com/doc/35563611/GRANADA-CONDO-HOMES-
ASSOCIATION-FRAUD-GOV-DOCUMENTS
http://www.scribd.com/doc/35727913/38-10-DISQUALIFICATION-OF-
JUDGE-Florida-Statutes
http://www.scribd.com/doc/35727611/Eugene-C-Turner-Disqualification
http://www.scribd.com/doc/35692445/Motion-for-Recusal-of-Def-Eugene-C-Turner
http://www.scribd/Foreclosure_Fraud
http://www.scribd.com/doc/35611989/Eugene-C-Turner-Florida-Bar-
Complaint
http://www.scribd.com/doc/35563611/GRANADA-CONDO-HOMES-
ASSOCIATION-FRAUD-GOV-DOCUMENTS
26