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    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 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. EMERGENCY MOTION __________________________________________________________________________/ CONTESTED “lien” NOTICE OFFICIAL RECORD 330 PG 498, 472 COLLIER COUNTY PUBLIC RECORDS, IN SUPPORT OF PLAINTIFF ASSOCIATION’S FRAUD & EXTORTION EMERGENCY MOTION TO DECLARE PROCEEDINGS FRAUDULENT AND UNAUTHORIZED UNDER FLORIDA LAW CONTESTED “lien”, VIOLATIONS OF GOVERNING DOCUMENTS 1. Dr. Jorg Busse had contested the association’s fraudulent lien and/or claim. 2. Dr. Jorg Busse gives notice of contest of the association’s unauthorized and fraudulent lien. NO “authority to file a record of lien” 3. § 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. FALSIFICATION OF “expenses” and “assessments” 4. 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. 5. 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. 6. § 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. 7. Here without authorization, the association purported to have filed “instrument” 4285498, OR 4445 PG 1665. 8. 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. AFFIDAVIT OF PROTECTED HOMESTEADED NAPLES PROPERTY 9. 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 10. Defendant Eugene C. Turner, an investor in bankrupt Orion Bank, knew that Defendant Judicial Officers Chene M. Thompson and Richard DeBoest, II, fraudulently p

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    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 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. EMERGENCY MOTION __________________________________________________________________________/ CONTESTED “lien” NOTICE OFFICIAL RECORD 330 PG 498, 472 COLLIER COUNTY PUBLIC RECORDS, IN SUPPORT OF PLAINTIFF ASSOCIATION’S FRAUD & EXTORTION EMERGENCY MOTION TO DECLARE PROCEEDINGS FRAUDULENT AND UNAUTHORIZED UNDER FLORIDA LAW CONTESTED “lien”, VIOLATIONS OF GOVERNING DOCUMENTS 1. Dr. Jorg Busse had contested the association’s fraudulent lien and/or claim. 2. Dr. Jorg Busse gives notice of contest of the association’s unauthorized and fraudulent lien. NO “authority to file a record of lien” 3. § 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. FALSIFICATION OF “expenses” and “assessments” 4. 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. 5. 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. 6. § 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. 7. Here without authorization, the association purported to have filed “instrument” 4285498, OR 4445 PG 1665. 8. 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. AFFIDAVIT OF PROTECTED HOMESTEADED NAPLES PROPERTY 9. 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 10. Defendant Eugene C. Turner, an investor in bankrupt Orion Bank, knew that Defendant Judicial Officers Chene M. Thompson and Richard DeBoest, II, fraudulently p

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    Condo HOA Law Group - Fraud

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    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 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. EMERGENCY MOTION __________________________________________________________________________/ CONTESTED “lien” NOTICE OFFICIAL RECORD 330 PG 498, 472 COLLIER COUNTY PUBLIC RECORDS, IN SUPPORT OF PLAINTIFF ASSOCIATION’S FRAUD & EXTORTION EMERGENCY MOTION TO DECLARE PROCEEDINGS FRAUDULENT AND UNAUTHORIZED UNDER FLORIDA LAW CONTESTED “lien”, VIOLATIONS OF GOVERNING DOCUMENTS 1. Dr. Jorg Busse had contested the association’s fraudulent lien and/or claim. 2. Dr. Jorg Busse gives notice of contest of the association’s unauthorized and fraudulent lien. NO “authority to file a record of lien” 3. § 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. FALSIFICATION OF “expenses” and “assessments” 4. 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. 5. 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. 6. § 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. 7. Here without authorization, the association purported to have filed “instrument” 4285498, OR 4445 PG 1665. 8. 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. AFFIDAVIT OF PROTECTED HOMESTEADED NAPLES PROPERTY 9. 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 10. Defendant Eugene C. Turner, an investor in bankrupt Orion Bank, knew that Defendant Judicial Officers Chene M. Thompson and Richard DeBoest, II, fraudulently p

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    Richard D. DeBoest
    Mr. DeBoest’s practice is concentrated exclusively in community association law.

    Mr. DeBoest regularly speaks and writes on community association law topics. In the past his presentations
    have covered topics such as assessment collection, conducting board meetings, community association law
    updates, covenant enforcement and financial aspects of association operation. Mr. DeBoest was also co-host of
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    Richard DeBoest Serves Fort Myers, Bonita Springs and Naples

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    Susan M. McLaughlin
    Ms. McLaughlin limits her practice to representing community associations, although in the course of that she
    handles a wide range of legal matters.

    Ms. McLaughlin is a graduate of New York University and has a law degree from Villanova University. Prior to
    moving to Florida, she was a shareholder in the firm of Harvey, Pennington, Ltd., a Philadelphia based firm,
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    Chene Thompson
    Chene’ M. Thompson is an associate in the Condo & HOA Law Group, LLC. Ms. Thompson will focus primarily
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    Ms. Thompson joins the firm and brings to it 8 years of experience as a litigator in Southwest Florida. Prior to
    becoming an associate, Ms. Thompson was employed as an Assistant Statewide Prosecutor with the Attorney
    General’s Office of Statewide Prosecution. She successfully prosecuted cases ranging from traditional “white
    collar” crimes involving fraud and money laundering to large scale narcotics trafficking. Ms. Thompson was
    recently named by the AG as one of the top prosecutors in 2008 for her successful prosecution of organized
    crime and her partnership with local law enforcement. She also worked as an Assistant State Attorney under
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    Diane M. Simons-Burnside, Esquire


    Diane M. Simons-Burnside is an associate in the Condo & HOA Law Group, LLC. Ms. Burnside focuses her
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    She assists her clients in the day-to-day management of their associations including, without limitation,
    preparing governing documents, restrictive covenants, and other agreements. Ms. Burnside also litigates
    assessment, foreclosure, and covenant enforcement matters.

    Ms. Burnside obtained an L.L.M. from Georgetown University Law Center, a J.D. from Richmond University Law
    School, and a B.S. degree from the University of Wisconsin. Prior to joining the Condo and HOA Law Group,
    LLC, Ms. Burnside was employed at the law firm of Roetzel & Andress LLP in Naples, Florida, where she
    practiced for several years serving all aspects of community association law.

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