IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT

IN AND FOR COLLIER COUNTY, FLORIDA

GRANADA CONDOMINIUM HOMES ASSOCIATION, INC., et al.,

“Plaintiffs”,

vs. Clerk’s Case Number: 09 02617CC

DR. JORG BUSSE [“BUSSE, J. R.”], et al.

FORECLOSURE FRAUD NOTICE
__________________________________________________________________________/

MOTION TO DISMISS

BECAUSE OF PUBLICLY RECORDED FORECLOSURE FRAUD

PUBLISHED NOTICE OF FORECLOSURE FRAUD

FORECLOSURE FRAUD OF RECORD

1. In this Case, no debt in the name of “J. R. BRUSSE” existed.

2. “J. R. BRUSSE” was not any named party to this facially fraudulent action.

3. Here, no authentic and lawful debt attached to Dr. Busse’s homesteaded property of record.

FRAUDULENT “J R BUSSE” “affidavit of non-service” OF RECORD

4. On or around “07/23/2010”, the Clerk entered a facially fraudulent “affidavit of non-service of

summons J.R. BUSSE” on the Docket:

Here, no summons for “J. R. BUSSE” had been “issued” pursuant to the public record, Docket.

Here on its face, said “Affidavit” was fraudulent, because no “summons” for “J. R. BUSSE”

had existed or could have possibly been “served”.

 “J R BRUSSE” SUMMONS OF RECORD

5. On or around “03/31/2010”, the Clerk of this Court reportedly “issued a summons” regarding

“J R BRUSSE”:

“J R BRUSSE” WAS NOT ANY PARTY TO THIS FRAUDULENT ACTION

6. “J R BRUSSE” has not been any named party to this facially fraudulent action. See Docket.

FORECLOSURE FRAUD OF RECORD

7. Here, no debt in the name of “J. R. BRUSSE” existed.

8. Here, no debt attached to Dr. Busse’s homesteaded property of record.

EMERGENCY: PREVENTION OF FORECLOSURE FRAUD

9. Prevention of foreclosure fraud is a top-ranking public agenda. Under public policy, the

recorded fraud and perjury created an EMERGENCY.

RECORD PATTERN OF PERJURY

10. Purported “Plaintiff” and "Plaintiff’s” Attorney demonstrated a publicly recorded pattern of

perjury. Dr. Busse objected to “Plaintiff’s” and Plaintiff Attorney’s perjury and demanded the

Court to intervene.

11. Previously, Dr. Busse had filed:

“MOTION TO COMPEL EUGENE C. TURNER TO SHOW CAUSE WHY

THE AFFIDAVITS AND PUBLIC RECORDS ON FILE DID NOT ESTABLISH THE

PRIMA FACIE FRIVOLITY & ILLEGALITY OF DEFENDANTS’ CLAIMS

AND WHY THEY SHOULD NOT BE SUMMARILY DISMISSED”

12. Dr. Jorg Busse had moved this Court to compel objectively partial Judge Eugene C. Turner to

SHOW CAUSE why the Affidavits and Public Records on file did not conclusively evidence the

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 prima facie frivolity and illegality of Defendants’ claims and why said facially fake cause(s)

should not be summarily dismissed.

ARBITRARY, CAPRICIOUS & VOID SO-CALLED “ORDERS” & “RULINGS”

13. Under separate cover, Dr. Jorg Busse had moved this Court to compel objectively partial Judge

Eugene C. Turner to SHOW CAUSE why his so-called “rulings” and “orders” 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.

FEDERAL LAW SUIT AGAINST DEFENDANT EUGENE C. TURNER

14. Dr. Busse filed a lawsuit against Defendant Eugene C. Turner in U.S. District Court. See

publications at www.scribd.com.

WHEREFORE, Dr. Busse demands

1. An Order dismissing this Case because of the publicly recorded foreclosure fraud;

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

procured through perjury and fraud an on its face fraudulent;

3. An EMERGENCY Order striking said fraudulent “affidavit of non-service”, because “J.R.

BRUSSE” was not any named party to this action;

4. An EMERGENCY Order striking said fraudulent “affidavit of non-service”, because no

recorded debt in the name of “J.R. BRUSSE” attached to Dr. Busse’s property pursuant to the

public record;

5. An Order dismissing this Case because of the recorded foreclosure fraud;

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

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

violated Florida’s Rules of Civil Procedure;

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8. 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;

9. 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.

10. 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;

11. 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];

12. 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;

13. 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;

14. 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 Plaintiff Association on file in this and the related

Case;

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15. 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;

16. An Order compelling the Plaintiff to disclose and produce the Association’s “common expense”

records as required by law;

17. An Order compelling the Plaintiff to disclose and produce the Association’s “accounting”

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

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

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

19. An Order providing Dr. Busse with mandatory access to the case file prior to any hearing;

20. An Order for service of a notice of hearing upon Dr. Busse under said Rules;

21. An Order declaring the fraudulent lien null and void and/or not in effect and Defendant’s record

title free and clear;

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

Public Records;

23. 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;

24. 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.

25. An Order taking judicial notice of the Plaintiff Association’s said By-Laws, Public Records,

and Declaration of Condominium.

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 CERTIFICATE OF SERVICE AND PUBLICATION

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. 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 27th
day of July, 2010. The pleading is also being published worldwide. See, e.g., www.scribd.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.