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9/16/2010 Public Inquiry

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Case Information Printer Friendly Version

Style: GR ANADA C O NDO HO MES INC vs BUSSE, J R


Uniform Case Number: 112009C C 0026170001XX Filed: 08/14/2009
Clerks Case Number: 0902617C C
Court Type: C O UNTY C IVIL Disposition Judge:
Case Type: LIEN FO R ECLO SURES Disposed:
Judge: TUR NER , EUGENE C Reopen Reason:
Case Status: O PEN Reopened:
Next Court Date: Reopen Close:
Last Docket Date: 09/07/2010 A ppealed:

Parties Dockets Events Financials

1 of 2 page s. Entrie s pe r page : 100

Date Text All Entries


08/13/2009 NO TIC E O F LIS PENDENS
08/13/2009 C O RR ESPO NDENCE FR O M C O UNSEL TO C LERK
08/13/2009 C IVIL C O VER SHEET
08/13/2009 C O MPLAINT
08/13/2009 PAID $10.00 PER ISSUANC E O F SUMMO NS $30.00
08/13/2009 MO TIO N TO APPO INT A R EC EIVER
TO C O LLEC T R ENTS O R IN THE ALTER NATIVE PLAC E R ENTS IN THE R EGISTRY O F
THE C O UR T
08/21/2009 SUMMO NS ISSUED
J R BUSSE/JANE DO E AS UNKNO W N SPO USE/UNKNO W N TENANTS MAILED TO
ATTO R NEY
08/25/2009 NO TIC E O F JO INDER O F JULIA N JAC KSO N & MO TIO N TO STRIKE
08/25/2009 MO TIO N EMER GENC Y / BY DR JO R G BUSSE
08/25/2009 NO TIC E O F JO INDER/ DR JO R G BUSSE
08/25/2009 NO TIC E
(EMER GENC Y) O F FR AUD O N C O UR T & FRAUDULENT C LAIM BY DEFENDANT
J R BUSSE
08/25/2009 MO TIO N (EMER GENCY) TO STR IKE ASSO C IATIO N'S PLEADINGS BY PLAINTIFF
08/26/2009 NO TIC E O F JO INDER O F R O BER T C SAMO UC E TO THIS AC TIO N
08/26/2009 NO TIC E O F JO INDER O F KEVIN P GAFFNEY
08/26/2009 NO TIC E O F JO INDER O F R O BER T E MUR ELL TO THIS AC TIO N
08/26/2009 R EQ UEST FO R ADMISSIO NS DIREC TED TO R O BER T E MUR R ELL
08/26/2009 NO TIC E
O F C O NC LUSIVE EVIDENC E O F FR AUD O N THE C O URT AND FR AUDULENT C LAIM/
AC TIO N BY GR ANADA C O NDO HO MES ASSN INC BY DR JO R G BUSSE
08/26/2009 R EQ UEST FO R ADMISSIO NS DIREC TED TO JULIA N JAC KSO N
08/26/2009 MO TIO N TO C O MPEL PR O DUC TIO N O F ALL ASSO C IATIO N R EC O R DS
08/27/2009 MO TIO N
EMERGENC Y PLAINTIFFS NO TIC E O F JO INDER O F JO HN PIER RE VAN DO NGEN TO

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.

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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

Ne w Se a rch R e turn to C ase List

Case Information Printer Friendly Version

Style: GR ANADA C O NDO HO MES INC vs BUSSE, J R


Uniform Case Number: 112009C C 0026170001XX Filed: 08/14/2009
Clerks Case Number: 0902617C C
Court Type: C O UNTY C IVIL Disposition Judge:
Case Type: LIEN FO R ECLO SURES Disposed:
Judge: TUR NER , EUGENE C Reopen Reason:
Case Status: O PEN Reopened:
Next Court Date: Reopen Close:
Last Docket Date: 09/07/2010 A ppealed:

Parties Dockets Events Financials

2 of 2 page s. Entrie s pe r page : 100

Date Text All Entries


06/09/2010 O R DER DENYING DEFENDANTS MO TIO N TO DISQ UALITY JUDGE S/TUR NER
06/11/2010 O BJEC TIO N TO
FR AUDULENT 5/10/10 O R DER JUDICIAL INPAIR MENT AND O BSTR UC TIO N O F
JUSTIC E
06/11/2010 MO TIO N TO C O MPEL EMER GENC Y MO TIO NS TO SHO W GO O D C AUSE
06/11/2010 NO TIC E
PUBLIC NO TIC E O F JUDIC IAL IMPAIR MENT O BSTR UC TIO N O F JUSTIC E AND
UNLAW FUL 6/09/10 O R DER
06/11/2010 O BJEC TIO N TO
6/9/10 O R DER JUDIC IAL IMPAIRMENT AND O BSTR UC TIO N O F JUSTIC E
06/11/2010 NO TIC E O F APP EAL O R DER R ENDER ED 6/9/10 10-06-AP C ER TIFIED C O PY
06/25/2010 MO TIO N TO C O MPEL & SHO W C AUSE BY J R BUSSE
06/25/2010 MO TIO N TO C O MPEL & SHO W C AUSE BY J R BUSSE
06/29/2010 O R DER BY AP BANC C ER TIFIED C O PY O R DER O F DISMISSAL 10-01-AP
07/23/2010 AFFIDAVIT O F NO N-SER VIC E O F SUMMO NS J.R . BUSSE
07/23/2010 AFFIDAVIT O F NO N-SER VIC E O F SUMMO NS
JANE DO E AS UNKNO W N SPO USE O F J.R . BUSSE
07/27/2010 MO TIO N TO ENJO IN FR AUD O N CO UR T
07/27/2010 MO TIO N TO ENJO IN FR AUD O N CO UR T (EMER GENC Y)
07/27/2010 MO TIO N TO STR IKE FR AUDULENT AFFIDAVIT
07/27/2010 MO TIO N TO DISMISS
07/27/2010 MO TIO N FO R R EC USAL O F AND DISC LO UR E BY JUDGE
07/29/2010 NO TIC E
(PUBLISHED) O F FR AUDULENT AFFIDAVIT AND PER JUR Y EMER GENC Y MO TIO N TO
ENJO IN FR AUD O N C O UR T BY J R BUSSE
07/29/2010 MO TIO N TO DISMISS
BEC AUSE O F PUBLICLY R EC O R DED FO R EC LSO URE FR AUM BY J R BUSSE
07/29/2010 MO TIO N FO R R EC USAL O F AND DISC LO SUR E BY EUGENE C TUR NER BY J R BUSSE
07/29/2010 MO TIO N TO DISMISS

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.

Home | Site Map | Search | Disclaimer | Privacy Statement | FA Qs | Contact Us


This we bsite is m aintaine d by The C ollie r C ounty C le rk of the C ircuit C ourt. Unde r Flo rida law, e m ail
addre sse s are public re co rds. If you do not want your e m a il addre ss re le ase d in re sponse to a public
re cords re que st, do not se nd e m ail to this e ntity. Inste ad, co ntact this office by phone or in writing.

apps.collierclerk.com/…/Case.aspx?UC… 2/2
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA

GRANADA CONDOMINIUM HOMES,

Purported “plaintiff”

vs. Clerk’s Case Number: 09 02617CC

BUSSE, J. R.,

__________________________________________________________________________/

RECORDING OF RELEASE OF lis pendens NOTICE


IN SUPPORT OF RECUSAL MOTION, DEF. JUDGE E. C. TURNER,
UNDER § 38.10, FLA. STAT., CANON 3E(1), AND FLA. R. JUD. ADMIN. 2.330

DEFENDANT TURNER’S IMPROPER CONDUCT ON THE RECORD

1. Here, Def. Judge Eugene C. Turner’s record conduct was improper, because Turner,

e.g.:

a. Concealed a fraudulent “lien”, INSTR 4285498; OR 4445 PG 1665;


b. Fraudulently concealed orders;
c. Fraudulently concealed material facts;
d. Fraudulently concealed material misrepresentation by an improper party;
e. Fraudulently concealed the record lack of any valid debt, lis pendens, and
action.

“Granada Condominium Homes Association, Inc.” could not have possibly brought any lien.

2. Pursuant to the “DECLARATION OF CONDOMINIUM OF GRANADA

CONDOMINIUM HOMES”, O.R. 330, Page 466, ff, Collier County Public Records,

“Granada Condominium Homes Association, Inc.” was


a. Not any proper party;

b. Not entitled to enforce a non-existent debt under the record contract and/or
Declaration.

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3
RECUSAL MEMORANDUM

3. CANON 2, FLORIDA CODE OF JUDICIAL CONDUCT, states:

”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

Committee; Art. V, § 2(a), Fla. Const.

4. The Florida Supreme Court Panel commented:

”Canon 2A. Irresponsible or improper conduct by judges erodes public confidence


in the judiciary. A judge must avoid all impropriety and appearance of
impropriety. A judge must expect to be the subject of constant public scrutiny. A
judge must therefore accept restrictions on the judge's conduct that might be viewed
as burdensome by the ordinary citizen and should do so freely and willingly.
Examples are the restrictions on judicial speech imposed by Sections 3B(9) and (10)
that are indispensable to the maintenance of the integrity, impartiality, and
independence of the judiciary.

The prohibition against behaving with impropriety or the appearance of impropriety


applies to both the professional and personal conduct of a judge. Because it is not
practicable to list all prohibited acts, the proscription is necessarily cast in general
terms that extend to conduct by judges that is harmful although not specifically
mentioned in the Code. Actual improprieties under this standard include violations
of law, court rules, or other specific provisions of this Code. The test for appearance
of impropriety is whether the conduct would create in reasonable minds, with
knowledge of all the relevant circumstances that a reasonable inquiry would disclose,
a perception that the judge's ability to carry out judicial responsibilities with
integrity, impartiality, and competence is impaired.”

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

by Defendant Judge Turner:

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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

the agreement and/or contract of record, O.R. 330 / 466, ff.

OBJECTIONS, NON-CONSENT, AND DIRECT ATTACK OF FRAUD SCHEME

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

8. Said Rule stated:

(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.

(c) Motion. A motion to disqualify shall:


(1) be in writing;
(2) allege specifically the facts and reasons upon which the movant relies as the
grounds for disqualification;
(3) be sworn to by the party by signing the motion under oath or by a separate
affidavit;”

SECTION 38.10, FLA. STAT.

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

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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

prejudice or bias of the judge.” Fla. R. Jud. Admin. 2.330.

10. S. 38.10, Fla. Stat., stated:

38.10 Disqualification of judge for prejudice; application; affidavits; etc.--


Whenever a party to any action or proceeding makes and files an affidavit stating fear
that he or she 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 against the applicant or in favor of
the adverse party, the judge 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 presiding judge is disqualified.

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

presiding judge is disqualified.”

DR. BUSSE’S RIGHT TO APPEAL

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

disqualify is governed substantively by section 38.10, Florida Statutes, and procedurally by

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).

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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

Supreme Court says it is.

CANON(S) 3E(1), 3E(1)(f), FLORIDA CODE OF JUDICIAL CONDUCT

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

“impartiality might reasonably be questioned,” including when he has “made a public

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)

(f) [“commits clause” at Canon 3E(1)(f)].

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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

area in which a judge’s “impartiality might reasonably be questioned.” See In re Amendment

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

authority to bring disciplinary charges against a judge.

SPECIFIC ALLEGATIONS – WELL-GROUNDED FEARS

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.

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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 …”

See O.R. 330, Page 498, 6. Fiscal Management, 6.2. Assessments …

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

common expenses in full as publicly recorded.

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

“apartments”. See deeds on file.

26. In violation of the governing documents, the Association President, Julia N. Jackson, was

in California and did not attend association meetings.

BRIBERY WAS ILLEGAL

27. Here, it was unlawful for any Judge to accept bribes.

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

Documents, Exhibit: OR 330 Page 499, Collier County Public Records.

“6.7 An audit of the accounts of the Association shall be made annually by a certified
public accountant…”

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RETALIATION AND EXTORTION WERE ILLEGAL

29. Retaliation and extortion were illegal. For years, Dr. Busse had proven record

violations by the purported Plaintiff Association.

ASSOCIATION VIOLATIONS OF RECORD

OFFICIAL RECORDS 330 PG 498, 499, 500, 472; 1517 PG 2165;

2922 PG 1364; 3950 PG 3899; 3950 PG 3900,

COLLIER COUNTY PUBLIC RECORDS,

30. Attached are said Collier County Public Records in support of the publicly record

violations of the governing documents of purported Plaintiff, Granada Condominium Homes

Association, Inc. See, e.g., O.R. 1517, Page 2165, and O.R. 330, Pages 498, 472.

CONTESTED “lien”, VIOLATIONS OF GOVERNING DOCUMENTS

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.

NO “authority to file a record of lien”

33. § 720.3085, Fla. Stat. expressly states:

“(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

had no “authority to file a record of lien” under Florida law.

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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 …”

See O.R. 330, Page 498, 6. Fiscal Management, 6.2. Assessments …

Here, there had been no “approval in writing” and the association falsified “assessments”.

LACK OF AUTHORITY UNDER THE GOVERNING DOCUMENTS, § 720.3085, F.S.

36. § 720.3085, Fla. Stat. (Payment for assessments; lien claims), states:

(1) When authorized by the governing documents, the association …

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,

Dr. Jorg Busse; Bank of America, et. al.

PRIMA FACIE UNAUTHORIZED AND FRAUDULENT “lien”, § 720.3085, F.S.

37. Here without authorization, the association purported to have filed “instrument”

4285498, OR 4445 PG 1665.

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

payment in full. See Google Blog Sites.

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MOTION TO DECLARE PROCEEDINGS FRAUDULENT & UNAUTHORIZED

39. Dr. Busse had moved this Court to declare the proceedings fraudulent and

unauthorized.

AFFIDAVIT OF PROTECTED HOMESTEADED NAPLES PROPERTY

40. This Court knew that

a. Dr. Jorg Busse’s record homesteaded property was protected;

b. The purported “Plaintiff” did not hold any legitimate and genuine lien on Dr.

Busse’s homesteaded Naples real property of record;

c. There was no “debt” pursuant to Dr. Busse’s publicly recorded payment records

and the “governing documents”.

EMERGENCY MOTION FOR INDEPENDENT ACCOUNTING AND AUDIT

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

recorded payment records on file.

DEMAND FOR INDEPENDENT AUDIT AND ACCOUNTING

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

the purported Plaintiff’s money receipts prior to its bankruptcy.

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.

ONGOING THREATS & INTIMIDATION

44. Process server Nicholas Krancher, ID # 157188, was arrested on February 9, 2008.

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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.

COMPLAINT AGAINST NICHOLAS KRANCHER

46. Dr. Jorg Busse complained about troubled process server Nicholas Krancher with the

Twentieth Judicial Circuit Certified Civil Process Server Review Board.

DEFENDANT KRANCHER PERJURED HIMSELF

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

48. Defendant Krancher fraudulently pretended attempted service at the Naples

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.

51. Defendant Krancher pretends to work for:

Sherman & Associates, LLC


62575 Cleveland Ave., 2nd Floor
Fort Myers, FL 33901
(239) 437-9600
shermanpi@juno.com

DEFENDANT KRANCHER’S HISTORY OF DRUG/ALCOHOL ABUSE

52. Based on the public record evidence, troubled Nicholas Krancher was arrested and has a

history of drug and/or alcohol abuse.

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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

Krancher and Krancher’s intent to further injure Dr. Jorg Busse.

EMERGENCY OF FURTHER INJURY

55. Defendant N. Krancher poses a threat. Dr. Jorg Busse has a Constitutional right to be

free of said intimidation, threats, perjury, and harassment.

SUMMONS, SERVICE, CHENE M. THOMPSON

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.

BANKRUPT ORION BANK – DEF. INVESTOR EUGENE C. TURNER

59. Orion Bank, the purported “Plaintiff’s” failed agent went bankrupt, and Defendant E.

C. Turner had invested in failed Orion Bank.

60. Prevention of publicly recorded foreclosure fraud is a top-ranking public agenda and an

EMERGENCY.

WHEREFORE, Dr. Busse demands

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1. An EMERGENCY Order recusing and/or disqualifying objectively partial Defendant

Judge Turner under said Rules and Memorandum;

2. An Order declaring the falsified proceedings fraudulent and unauthorized under said

Chapter 720, F.S., and the Governing Documents of said association;

3. An Order for said independent audit and accounting pursuant to Florida law;

4. An EMERGENCY Order restraining Defendant Nicholas Krancher from any further

intimidation of and threats against Dr. Jorg Busse;

5. An EMERGENCY Order restraining Defendant Nicholas Krancher from any service

upon Dr. Jorg Busse;

6. An EMERGENCY Order restraining Defendant Nicholas Krancher from any further

perjury;

7. An EMERGENCY Order enjoining said perjury and fraud on the Court;

8. An EMERGENCY Order striking said fraudulent “affidavit of non-service”, because it

was procured through perjury and fraud an on its face fraudulent;

9. An EMERGENCY Order striking said fraudulent “affidavit of non-service”, because it

violated Florida’s Rules of Civil Procedure;

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

Affidavits and Public Record evidence on file;

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

of a judge in his shoes in this Case;

13. An EMERGENCY Order disqualifying and recusing objectively impaired Judge

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

the absolutely required “common expenses” [denominator in said fraction];

14. An EMERGENCY Order disqualifying and recusing objectively impaired Judge

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

payments by Dr. Busse to the Plaintiff Association;

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

expense” records as required by law;

19. An Order compelling the Plaintiff to disclose and produce the Association’s

“accounting” records as required by law [see, e.g., Ch. 718];

18
20. An Order dismissing Plaintiff’s fraudulent Complaint with prejudice pursuant to said

Official Records, By-Laws, and conclusive evidence on file;

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

record title free and clear;

24. An Order declaring any and all unapproved assessments null and void under said By-

Laws and Public Records;

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

Records, and Declaration of Condominium.

CERTIFICATE OF SERVICE AND PUBLICATIONS

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.

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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.

/s/Jorg R. Busse, M.D., M.M., M.B.A.


SIGNATURE, State Certified Residential Appraiser, Licensed Real Estate and Mortgage Broker
P.O. Box 11124, Naples, FL 34101-11124, jrbu@aol.com, 239-595-7074

CC: Donna Woodruff, Facsimile: 239-252-8020, Clerk of Courts; Angela Turner, J.A.

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AFFIDAVIT OF DR. JORG BUSSE

STATE CERTIFIED RESIDENTIAL APPRAISER, REAL ESTATE BROKER

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

STATES OF AMERICA, Ex Rel. et al. v. UNITED STATES OF AMERICA et al., against

Defendant bribed Collier County Judge Eugene C. Turner.

FURTHER AFFIANT SAYETH NAUGHT.

__________________________

/s/JORG BUSSE, M.D., M.M., M.B.A.

Sworn to and subscribed before me on the ___ day of August, 2010.

Name of Notary Public:

Expiration of Commission:

__________________

/s/Notary Public

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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

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