Professional Documents
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Thompson
Florida Bar 541540
Richard D. DeBoest, II
Richard D. DeBoest, II
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CERTIFIED DELIVERIES TO THE ABOVE DEFENDANTS
Chene M. Thompson:
2. You fraudulently concealed the public record evidence in support of the fraud and
fraudulent “lien” by Granada Condominium Homes Association, Inc.
3. You fraudulently concealed the undersigned’s satisfactory and full payment of 1/12
share of the record expenses under the Association By-Laws, Declaration of
Condominium, and Ch. 718, F.S.
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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
Plaintiffs,
_________________________________________________________________/
1. Defendant Dr. Busse hereby moves this Court to take judicial notice of the following Collier
County public records in support of the fraud and fraud on the Court by Counsel and Plaintiff
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“The lien is in effect until all sums secured by it have been fully paid or until barred by law.”
Here, the “lien” was “barred by law” and procured through fraud; and all sums and/or expenses
DEF. DR. BUSSE FULLY SATISFIED HIS “LIABILITY” UNDER THE BY-LAWS
“the making and collection of assessments against apartment owners for common
expenses shall be pursuant to the By-Laws and subject to the following provisions …
each apartment owner shall be liable for a one-twelfth [1/12] share of the common
expenses, and shall share in the common surplus, such share being the same as his
undivided share in the common elements.”
4. Pursuant to Collier County Official Records, Book 330, Page 499 [6.7]:
“An audit of the accounts of the Association shall be made annually by a certified public
accountant, not a member of the Association, and a copy of the report shall be furnished
to each member not later than April 1st of the year following the year for which the
report is made.”
5. Pursuant to Collier County Official Records, Book 330, Page 498 [6.2]:
“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.”
6. Here since 2003, the purported record “assessments for recurring common expense” were
7. In support of Plaintiff’s and Counsel’s fraud and fraud on the Court, attached are the
Uniform Title Standards by the Florida Bar. See Exhibits. Here, Plaintiff’s “lis pendens” was
unsupported and for the unlawful purpose of extorting unauthorized and/or fraudulent
assessments.
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ESSENTIAL RECORDS OF PLAINTIFF’S DEFUNCT AND/OR BANKRUPT AGENTS
8. The Plaintiff and/or Association’s agents have repeatedly refused to disclose the accounting
and expense records of the previous defunct and bankrupt agents for Plaintiff Granada
b. “Orion Bank”;
9. Said records are essential in these and other judicial proceedings, and in particular, because
the Plaintiff and Counsel fraudulently initiated a purported “lis pendens” in the absence of
1. An Order taking judicial notice of the Plaintiff Association’s said By-Laws, Public
2. An Order declaring the fraudulent lien null and void and/or not in effect and Defendant’s
3. An Order declaring any and all unapproved assessments null and void under said By-Laws
4. 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
5. 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
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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.
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 34102, on this 2nd
day of March, 2010. The pleading is also being published worldwide. See, e.g., www.scribd.com.
CC: Donna Woodruff, Facsimile: 239-252-8020, Clerk of Courts; Angela Turner, J.A.
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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
Plaintiffs,
_____________________________________________________/
(March 1, 2010)
NOTICE OF PUBLICATIONS
10. Hereby, Defendant Dr. Busse gives this Court notice of the publications in support of
http://www.scribd.com/people/documents/23136066-granadafraud?popular=1
11. In particular, the publication of Defendant’s Affidavit on file can be found at:
http://www.scribd.com/doc/27086132/AFFIDAVIT
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NOTICE OF DEFENDANT’S MEETING WITH PLAINTIFF’S AGENT, AND
12. On Monday, March 1, 2010, at approximately 10:00 AM, on the premises of the subject
property, Defendant Dr. Busse spoke to Charles “Chuck” Schumacher with Platinum Property
Management, LLC, and again requested disclosure of Plaintiff’s accounting, expense, and other
records since 2003 as previously and repeatedly requested. See previous and present legal
13. Said agent of the Plaintiff again refused to disclose Plaintiff’s accounting and expense
records pursuant to Defendant Dr. Busse’s multiple requests on record under Ch. 718,
14. In particular, said agent stated in the presence of a witnessing agent that “he was not privy
to” the accounting and expense records of the previous defunct and bankrupt agents for Plaintiff
b. “Orion Bank”;
15. Said records are essential in these and other judicial proceedings, and in particular, because
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6. An Order compelling the Association to disclose any and all accounting records since 2003
pursuant to Ch. 718, Florida Statutes, and in particular the records of failed Orion Bank;
7. An Order sanctioning Chene M. Thompson, esq., FL 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;
8. An Order releasing the fraudulent lien based on said record evidence before this Court,
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., FL 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 34102, on this 1 st day of
March, 2010. The pleading is also being published worldwide. See, e.g., www.scribd.com.
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