IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT

IN AND FOR COLLIER COUNTY, FLORIDA, U.S.A.

“GRANADA CONDO HOMES, INC.”,

purported “plaintiff” [no right to sue under O.R. 330/466-500],

vs. Clerk’s Case Number: 09-02617-CC

BUSSE, JORG, DR. (not obligated to pay more than 105% in assessments; paid 1/12 of expense)
__________________________________________________________________/

NOTICE OF “PLAINTIFF’S” FRAUDULENT CONCEALMENT

Dr. Jorg Busse

P.O. Box 1140
Naples, FL 34106-1140
CERTIFIED DELIVERY
Hon. Eugene C. Turner
County Court Judge
Judicial Assistant Angela Turner
Twentieth Judicial Circuit
Collier County Courthouse
Naples, FL 34112, U.S.A.

RE: FRAUDULENT CONCEALMENT EVIDENCE

Hon. Judge Eugene C. Turner:

DISCOVERED PROOF OF FRAUD

1. Pursuant to the 10/18/2010 “status conference” instructions, Dr. Jorg Busse respectfully
submits the following proof of “plaintiff’s” fraud to the Hon. Court’s attention:
2004 FINANCIAL INFORMATION: $260.00 ASSESSMENT
2. The attached “Granada Condominium Homes Association Financial Information for 2004,
Operating Expenses” evidenced monthly maintenance of $260.00.
“PLAINTIFF” FRAUDULENTLY CLAIMED UNJUSTIFIED “ASSESSMENTS”
3. Expressly, the governing documents, O.R. Book 330 Page 498 stated:
“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 entitled to cast 9 votes in the Association.”
See attached “By-Laws of Granada Condominium Homes Association”, O.R. 330/494,
“6. Fiscal Management; 6.2. Assessments for recurring common expenses”.
PURPORTED PLAINTIFF’S FRAUDULENT CLAIM EXCEEDED 105%
4. Here, the purported “plaintiff” fraudulently claimed “assessments”, which exceeded said
105% under the governing documents and were patently clearly unlawful.
 ATTACHED 2004 GRANADA FINANCIAL STATEMENTS
5. “Granada Condominium Homes, Inc. Financial Statement(s) Dec. 31, 2004” are attached.
6. The attached “Detail of Monthly Expenditures” evidenced Dr. J. Busse’s 2004 purchase,
payments, and association expenditures. Furthermore, AMSouth Bank and Wachovia Bank
documents are attached.
ATTACHED O.R. 330 / 472
7. Attached Off. Record 330/472 evidenced “6. Assessments” and “Share of common
expense”, 1/12 share. Here, Dr. Jorg Busse had fully and satisfactorily paid his 1/12 share
under said By-Laws.
ATTACHED ASSOCIATION CASH FLOW ANALYSIS
8. A past cash flow analysis by a financial consultant is attached.
ASSOCIATION’S FAILURE TO PROVIDE AUDITS
9. In violation of the governing association documents, the purported plaintiff failed to provide
the required audits after 2004.
FRAUDULENT CONCEALMENT
10. Here, the purported plaintiff and/or opposing counsel fraudulently concealed the maximum
allowed assessments under the governing association documents:
MAXIMUM ASSESSMENTS ALLOWED
UNDER O.R. 330/498
2004 $260.00 1.05
2005 $ 273.00
2006 $ 286.65
2007 $ 300.98
2008 $ 316.03
2009 $ 331.83
2010 $ 348.42

WHEREFORE, Dr. Jorg Busse demands

1. An Order summarily dismissing this facially fraudulent action, because the claims are
indisputably controverted by said public governing association documents, O.R. 330 / 466-
500;
2. An Order summarily dismissing this action, because the facially non-meritorious “claims”
by the purported “plaintiff” exceed said 105% under the governing instrument;
3. An Order summarily dismissing this action, because Dr. Jorg Busse fully and satisfactorily
paid said 105% pursuant to the payment proof on file;
4. An Order summarily dismissing this action, because Dr. Jorg Busse was never obligated to
pay more than said 105% and affirmatively defends against this fraudulent action under
Florida law;
5. An Order summarily dismissing this action, because Florida law prohibits harassment under
false pretenses and in contradiction to the governing association documents;
6. An Order summarily dismissing this action, because said association By-Laws are in the
name of “Granada Condominium Homes Association”;
7. An Order compelling Chene M. Thompson to be available as Counsel and to furnish Dr.
Jorg Busse with any and all pleadings and communications under the Rules.

/s/Jorg Busse, M.D., M.B.A., M.M.; JRBU@aol.com; P.O. Box 1140, Naples, FL 34106-1140

2
ATTACHMENTS: 15 Pages

CERTIFICATES OF SERVICE AND PUBLICATION

I HEREBY CERTIFY that pursuant to the 10/18/2010 AM “status conference” and judicial
instructions, a true and correct copy of the above has been furnished to the purported and
improper “plaintiff”, “Granada Condo Homes, Inc.”, and opposing Counsel, Chene Thompson,
Esq., Condo & HOA Law Group, LLC, 2030 McGregor Boulevard, Fort Myers, FL 33901,
U.S.A., Fax: 001-239-333-2999; T: 239-333-2992, County Court Judge E. C. Turner at 001-239-
774-3618, and the Hon. Clerk of Court at Fax: 001-239-252-8020 on 10/18/2010 from abroad to
the U.S.A. See Facsimile Certificates; see also e-mails and postal certificates.

/s/Jorg Busse, M.D., M.B.A., M.M.; JRBU@aol.com; P.O. Box 1140, Naples, FL 34106-1140
www.scribd.com; www.myfax.com; www.gotfreefax.com

Chene Thompson, Esq. – ON LEAVE & UNAVAILABLE pursuant to Counsel’s e-mails

Condo & HOA Law Group, LLC
Counsel for purported “plaintiff” without standing & cause of action
2030 McGregor Boulevard
Fort Myers, FL 33901
Fax: 001-239-333-2999; T: 239-333-2992

Clerk of Court, Dwight E. Brock

Collier County Courthouse
3301 Tamiami Trail East
Naples, FL 34112, U.S.A.
CollierClerk@CollierClerk.com
Fax: 001-239-252-8020; T: 239-252-2646
Angela Turner, Judicial Assistant to the Hon. Eugene C. Turner, County Court Judge
Collier County Courthouse
3301 Tamiami Trail East
Naples, FL 34112, U.S.A.
Fax: 001-239-774-3618; T: 001-239-252-8125
Administrative Office of the Courts
20th Judicial Circuit of Florida
1700 Monroe Street
Fort Myers, FL 33901
T: 239-335-2299