UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA

FORT MYERS DIVISION
[“TRANSFERRED” FROM: SOUTHERN DISTRICT OF FLORIDA, WEST PALM BEACH DIVISION]

JENNIFER FRANKLIN PRESCOTT, DR. JORG BUSSE,

Plaintiffs,

versus Reassigned Case # 2:09-CV-00791-CEH-SPC

ROGER ALEJO; KENNETH M. WILKINSON; JACK N. PETERSON; ROGER

DESJARLAIS; LEE COUNTY, FLORIDA; LEE COUNTY VALUE
ADJUSTMENT BOARD; LORI L. RUTLAND; STATE OF FLORIDA, BOARD
OF TRUSTEES OF THE INTERNAL IMPROVEMENT TRUST FUND; STATE
OF FLORIDA, DEPARTMENT OF ENVIRONMENTAL PROTECTION; CHAD
LACH; CHARLES “BARRY” STEVENS; REAGAN KATHLEEN RUSSELL;
KAREN B. HAWES; ROGER DESJARLAIS; CHARLIE GREEN; BOB JANES;
BRIAN BIGELOW; RAY JUDAH; TAMMY HALL; FRANK MANN; UNITED
STATES ATTORNEY(S); SEAN P. FLYNN; E. KENNETH STEGEBY; DAVID P.
RHODES; A. BRIAN ALBRITTON; CYNTHIA A. PIVACEK; JOHNSON
ENGINEERING, INC.; STEVEN CARTA; MIKE SCOTT; HUGH D. HAYES;
GERALD D. SIEBENS; STATE OF FLORIDA ATTORNEY GENERAL;
WILLIAM M. MARTIN; PETERSON BERNARD; SKIP QUILLEN; TOM
GILBERTSON, RYAN LENGERICH, NEWS PRESS,
Defendants.

EMERGENCY DEMAND FOR RELIEF

FROM RECORD JUDICIAL CORRUPTION & FRAUD

____________________________________________________________________________/

EMERGENCY DEMAND FOR RELIEF FROM IDIOTIC FRAUDULENT CLAIMS

BY DEFENDANT CROOKED JUDGE CHARLENE E. HONEYWELL

DEMAND FOR RELIEF FROM DEF. CORRUPT JUDGE HONEYWELL’S CRIMES

ON THE PUBLIC RECORD, E.G., DOC. ## 210 - 214, UNDER FED.R.CIV.P. 60

PUBLISHED EMERGENCY DEMAND FOR RELIEF FROM

PUBLIC CORRUPTION & CONCEALMENT OF PUBLIC RECORD TITLE PROOF

 HONEYWELL’S FRAUDULENT PRETENSES ON THE RECORD, DOC. # 213

1. Unintelligently and corruptly, Defendant crooked Judge Honeywell fraudulently pretended

that Plaintiffs’ real property of record, Lot 15A, as legally described in reference to the 1912

“Cayo Costa” Subdivision Plat of Survey in Lee County Plat Book 3, Page 25 “was claimed

as public land”, Doc. # 213, p. 5:

Lot 15A, among other property, was claimed as public land (“Resolution 569/875")
(Dkt 5, Ex. 3, p. 9).”

HONEYWELL’S EMBARRASSINGLY IDIOTIC CASE FIXING RECORD

2. Here, Honeywell’s facially idiotic and fraudulent pretenses of “public land”, Doc. 213, had

no legal and factual basis, but were for the prima facie criminal purposes of obstructing

justice and deliberately depriving the Plaintiff record owners of said Lot 15A, subject Parcel

# 12-44-20-01-00015.015A, PB 3, PG 25 (1912). In particular, Honeywell recklessly

contradicted the public record of Plaintiffs’ unimpeachable ownership of said Lot 15A as

also affirmed by the U.S. Court of Appeals for the 11th Circuit. See Prescott, et al., v. State of

Florida, et al., 343 Fed. Appx. 395, 396-97 (11th Cir. Apr. 21, 2009): Here, Honeywell

fraudulently concealed the dispositive public record evidence that the Plaintiffs were the

unimpeachable “owners of Lot 15A in the Cayo Costa subdivision in Lee County, Florida”:

“I. BACKGROUND
A. Current Action
The Appellants are owners of Lot 15A in the Cayo Costa subdivision in
Lee County, Florida. On May 5, 2008, the Appellants filed the present pro se
complaint against numerous state and county officials n1 alleging that they had
violated the Appellants' constitutional rights with respect to their Cayo Costa
property. Most of the allegations in the complaint concern the 1969 Lee
County Resolution 569/875, which claimed the undesignated areas on the east
and west side of the Cayo Costa subdivision plat and all accretions thereto as
public land to be used for public purposes. The Appellants' Lot 15A is on the
west side of the Cayo Costa subdivision on the Gulf of Mexico and is

2
 adjacent to land that was claimed through Resolution 569/875 to create
the Cayo Costa State Park.”

HONEYWELL’S OBJECTIVE LACK OF QUALIFICATION ON THE RECORD

3. Defendant judicial Crook Honeywell affirmed, Doc. # 213, p. 5, that the Plaintiff record

owners of “Lot 15A”, riparian Parcel # 12-44-20-01-00015.015A, “appeared for a “quasi-

judicial proceeding”, because the Plaintiffs were the record owners of “Lot 15A”. See public

records on file admittedly affirming Plaintiffs’ unimpeachable ownership of Lot 15A.

4. Here, the Plaintiffs “appeared for” said “proceeding”, because they were the affirmed record

owners of Lot 15A and entitled to appear. Therefore here, crooked Judge Honeywell knew

that the Plaintiffs held unimpeachable marketable record title to said Lot 15A. Here,

Honeywell’s fraudulent pretenses and deprivations were deliberate and premeditated, Doc. #

213, p. 5:

“In a resolution adopted in December 1969 by the Board of Commissioners of Lee

County, Florida, Lot 15A, among other property, was claimed as public land
(“Resolution 569/875") (Dkt 5, Ex. 3, p. 9).”

PUBLIC TAX RECORDS EVIDENCED HONEYWELL’S RECORD FRAUD SCHEME

5. In particular, Honeywell knew that the Plaintiff unimpeachable record property owners had

paid real property taxes for said subject Parcel. See attached public records of Lee County

Tax Collector; Parcel # 12-44-20-01-00015.015A:

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 HONEYWELL’S BRAZEN RECORD FRAUD ON THE COURT & CRIMES

6. Here, crooked Honeywell knew and fraudulently concealed that

a. The Plaintiffs were the unimpeachable record owners of said “Lot 15A”;

b. No “resolution” had ever existed;

c. No “resolution 569/875” had ever existed;

d. No “resolution” had ever been “adopted”;

e. No “resolution” had ever “claimed” Plaintiffs’ “Lot 15A”;

f. No “resolution” could have possibly involuntarily divested the Plaintiff record

property owners and record property tax payers of their riparian Gulf-front Lot

15A.

NOTICE OF APPEAL & EMERGENCY DEMAND FOR RELIEF FROM FRAUD

7. Here, the Plaintiffs appealed from Defendant crooked U.S. District Judge Honeywell’s

“order”, Doc. # 210, “filed 06/22/10”. Here, said judicial Defendant evaded and obstructed

mandatory disqualification in this Case, because Honeywell had “disqualified herself” in

4
 related and/or associated Case 2:2010-cv-00390 on the very same day, 06/22/2010. See

publication:

http://www.scribd.com/doc/33659698/PUBLISHED-NOTICE-OF-APPEAL-FROM-
ORDER-Doc-210

EMERGENCY OF HONEYWELL’S CRIMES ON THE RECORD

8. Here, Honeywell’s fraud, fraud on the Court, and corrupt & criminal acts were an

EMERGENCY. Here, the prima facie criminality, idiocy and irrationality of Honeywell’s

acts were an EMERGENCY.

EMERGENCY OF LIEN & SIMULATANEOUS GOVERNMENT OWNERSHIP CLAIM

9. While Defendant Honeywell fraudulently pretended Lot 15A to be “public land”, Defendant

Polster Chappell affirmed Plaintiffs’ record ownership just like said U.S. Appellate Court.

See Prescott, et al., v. State of Florida, et al., 343 Fed. Appx. 395, 396-97 (11th Cir. Apr.

21, 2009). Here, bungling Judges fatally conflicted with each other on the record at

Plaintiffs’ expense and injury, which created chaos and lawlessness.

10. Here, Honeywell knew that her co-conspirator and fellow judicial Defendant Sheri Polster

Chappell had fraudulently made an order for the illegal Governmental seizure of said “Lot

15A”. See fraudulent “writ of execution”; fraudulent “lien”; fraudulent Doc. ## 432, 432-3:

DEMAND FOR RELIEF FROM DEF. CORRUPT JUDGE HONEYWELL’S CRIMES

ON THE PUBLIC RECORD, E.G., DOC. ## 210, 213, UNDER FED. R. CIV. P. 60

5
6
 EMERGENCY DEMAND TO ENJOIN PERVERSION OF PUBLIC RECORD

11. The Plaintiff record owners of said riparian Gulf-front Lot 15A, PB 3, PG 25 (1912), who

paid real property taxes, demand EMERGENCY relief from Honeywell’s material

misrepresentation and fraudulent concealment of the truth and public record evidence of

Plaintiffs’ record title and ownership of said Lot 15A, STRAP # 12-44-20-01-00015.015A;

see also Appeal # 08-13170, BUSSE, et al., v. LEE COUNTY, et al., Appellate Brief by

Defendants Lee County, 11th Circuit:

PUBLIC RECORD EVIDENCE OF HONEYWELL’S FRAUD & CORRUPTION

12. Here, ‘public records confirmed’ that the Plaintiffs paid property taxes and unimpeachably

owned said riparian Lot 15A as platted and subdivided in 1912, PB 3, PG 25. Here, public

records confirmed that Honeywell was a crooked U.S. Official and liar of record.

13. Here, on Plaintiffs’ Motion and just terms of record, the Court shall relieve the

Plaintiffs from the fraudulent judgment, orders, and proceedings of record such as, e.g.,

Doc. ## 210, 212, 213, 214. for the following reasons:

7
 HONEYWELL CONSPIRED TO FALSELY PRETEND RIPENESS REQUIREMENTS

14. Idiotically and corruptly, Honeywell fraudulently pretended “ripeness requirements” for,

e.g., claims of record 4th, 1st, 14th, and 7th U.S. Const. Amendment violations, fraud, and

CORRUPTION. See Doc. # 213. Here, Plaintiffs could directly assert, and rightfully

asserted, their claims for relief from, e.g., Government CORRUPTION and fraud in

Federal Court. Honeywell knew that no ripeness requirements had ever existed.

15. Here, the Plaintiffs rightfully defended against Honeywell’s NAZI-style terror and

CORRUPTION and demanded EMERGENCY relief from Honeywell’s well-proven fraud

upon the Court and legally “incomprehensible” bogus contentions of “frivolity” and “public

land”. Here, Honeywell concealed that no condemnation had ever occurred nor could have

possibly occurred. Had there [hypothetically] been any condemnation, title would have

involuntarily transferred to Lee County, which Honeywell knew never happened. Only then

could there have possibly been any “compensation”, because here Plaintiffs rightfully

defended their record title against fraud and Government CORRUPTION:

8
16. Here, the Plaintiffs had rightfully pleaded, e.g., fraud and fraudulent concealment in both

State and Federal Courts. See State Case # 2006-CA-003185; www.LeeClerk.org:

17. Here, Honeywell fraudulently concealed that Plaintiffs paid property taxes and held perfected

marketable title to said “Lot 15A”. Here, Honeywell’s “order”, Doc. # 213, constituted prima

facie premeditated & deliberate deprivations under color of office and authority. Here,

Honeywell had no authority to pervert the public record & obstruct justice. Prescott v. State

of Florida, supra. Here, Honeywell knew that the Lee County Attorney had categorically

ruled out any possibility of Lee County ownership of Lot 15A, 12/29/2000 Memorandum:

9
10
 HONEYWELL’S COVER-UP FOR FELLOW JUDICIAL GANG MEMBERS

18. Here like a brainless parrot, Honeywell merely repeated the null and void orders by the

named judicial Defendants. Because the Plaintiffs had demanded relief from said null and

void orders by judicial Defendants such as, e.g., Steele, Polster Chappell, Pizzo, Lazzara,

which were based on facially fraudulent and legally impossible “Government ownership”

“claims”, Honeywell was obligated to review de novo and use a brain. However here, she

never reviewed anything, but repeated the same old judicial record trash and continued to

pervert the public record just like said fellow judicial Defendants had. Here more than one

hundred (100) pages of Plaintiffs’ Complaint had never even been filed, Doc. # 1:

WHEREFORE, Plaintiffs demand

1. An EMERGENCY order relieving the Plaintiffs from the fraudulent judgment, orders, and

proceedings of record such as, e.g., Doc. ## 210, 212, 213, 214. for said well-proven reasons;

2. An EMERGENCY order relieving the Plaintiffs from the fraudulent concealment of their

State action, 2006-CA-003185, Lee County Circuit Court, BUSSE v. STATE OF FLORIDA;

3. An Order compelling Defendant crooked Judge Honeywell to SHOW CAUSE why she did

not fraudulently conceal Plaintiffs’ record ownership of said Lot 15A, Parcel # 12-44-20-01-

00015.015A as evidenced in Plaintiffs’ Complaint and pleadings;

4. An Order compelling Defendant crooked Judge Honeywell to SHOW CAUSE why she did

not fraudulently conceal Plaintiffs’ unimpeachable record ownership of said Lot 15A, Parcel

# 12-44-20-01-00015.015A as affirmed by the public record;

11
5. An Order compelling Defendant crooked Judge Honeywell to SHOW CAUSE why she did

not maliciously pervert the dispositive affirmation of Plaintiffs’ record ownership by the U.S.

Court of Appeals for the 11th Circuit, Prescott, et al., v. State of Florida, et al., 343 Fed.

Appx. 395, 396-97 (11th Cir. Apr. 21, 2009);

6. An Order compelling Defendant crooked Judge Honeywell to SHOW CAUSE why she did

not capriciously conceal Plaintiffs’ unimpeachable record ownership of said Lot 15A, Parcel

# 12-44-20-01-00015.015A, which the Defendants Lee County had asserted before the 11th

Circuit U.S. Appellate Court, Appeal # 08-13170, BUSSE v. LEE COUNTY;

7. An Order compelling Honeywell to SHOW CAUSE why the grounds for ‘her

disqualification’, Doc. 3, 2:10-cv-00390, did not absolutely demand recusal in this Case;

8. An Order compelling Defendant Honeywell to SHOW CAUSE why her “rulings” were not

NULL AND VOID and procured through the criminal scheme of false “frivolity” and

“vexatiousness” pretenses and the concealment of said fake “legal descriptions”, fake “land”

“parcels”, and fake “Government ownership” “claims” and contentions;

9. An EMERGENCY Order recusing Defendant crooked Judge Honeywell, because she

disrespected the law, disrupted the proceedings in favor of the Defendants, perverted the

facts of record, and could not possibly be trusted to be impartial and fair, 28 U.S.C. § 455;

10. An EMERGENCY Order enjoining objectively partial/crooked Judge Honeywell from

perverting the record & concealing Plaintiffs’ record ownership of Lot 15A, PB 3, PG 25.

/S/JENNIFER FRANKLIN PRESCOTT

Governmental Corruption & Fraud Victim, Plaintiff, pro se
P.O. BOX 845, Palm Beach, FL 33480; T: 561-400-3295
____________________________________
/S/JORG BUSSE, M.D., M.M., M.B.A., C.P.M.
Judicial Corruption & Crime Victim; Plaintiff, pro se
State Cert. Res. Appraiser, Licensed Real Estate Broker, Mortgage Broker, Appraisal Instructor;
JRBU@aol.com

12
 Honeywell’s Real Estate Fraud:

• Fake “lot” and “block” numbers such

as, e.g.:
o “12-44-20-01-00000.00A0”;
o “07-44-21-01-00001.0000”;
Neither fake “lot” “00A0” nor
“block” “00001”ever existed.
• Fake “Government ownership” claims;
• Fake “transaction(s)” such as, e.g.,
“O.R. 569/875”;
• Fake “resolution” and “law” “claims”;
• Fake “land” “parcels”;
• Fake “frivolity” “defenses”;
• Fake “vexatiousness” contentions;
• Fake “legal descriptions”:

13
14
15
Crooked Judge Charlene Edwards Honeywell

http://www.scribd.com/Judicial%20Fraud
 Crooked Judge Charlene Edwards Honeywell

JUDICIAL TRASH
DOC. # 213
2:09-cv-00791-CEH-SPC
Prescott, et al., v. State of Florida, et al., 343 Fed. Appx. 395, 396-97 (11th Cir. Apr. 21, 2009):

“I. BACKGROUND
A. Current Action
The Appellants are owners of Lot 15A in the Cayo Costa subdivision
in Lee County, Florida. On May 5, 2008, the Appellants filed the present
pro se complaint against numerous state and county officials n1 alleging
that they had violated the Appellants' constitutional rights with respect to
their Cayo Costa property. Most of the allegations in the complaint
concern the 1969 Lee County Resolution 569/875, which claimed the
undesignated areas on the east and west side of the Cayo Costa
subdivision plat and all accretions thereto as public land to be used for
public purposes. The Appellants' Lot 15A is on the west side of the
Cayo Costa subdivision on the Gulf of Mexico and is adjacent to
land that was claimed through Resolution 569/875 to create the
Cayo Costa State Park.”
- - - - - - - - - - - - - - Footnotes - - - - - - - - - - - - - - - 1
The complaint named the following defendants (herein collectively "the Appellees"): (1) the State of
Florida Board of Trustees of the Internal Improvement Trust Fund; (2) the Florida Department of
Environmental Protection, Division of Recreation and Parks; (3) Lee County, Florida; (4) the Board of
Lee County Commissioners; (5) Jack N. Peterson, Lee County Attorneys [*3] Jack Peterson, Donna
Marie Collins, and David Owen; (6) Lee County property appraisers Kenneth M. Wilkinson and Sherri L.
Johnson; and (7) Cayo Costa State Park employees Reginald Norman, Harold Vielhauerin, Linda
Funchess, Reagan Russell, and Tom Beason.

http://www.scribd.com/Judicial%20Fraud
Crooked Judge Charlene Edwards Honeywell

http://www.scribd.com/Judicial%20Fraud
Crooked Judge Charlene Edwards Honeywell

http://www.scribd.com/Judicial%20Fraud
Crooked Judge Charlene Edwards Honeywell

http://www.scribd.com/Judicial%20Fraud
Crooked Judge Charlene Edwards Honeywell

http://www.scribd.com/Judicial%20Fraud
Crooked Judge Charlene Edwards Honeywell

http://www.scribd.com/Judicial%20Fraud
Crooked Judge Charlene Edwards Honeywell

http://www.scribd.com/Judicial%20Fraud
merely because state mandated procedures were not followed. First

Assembly of God of Naples, Florida, Inc. v. Collier County, Fla.,

20 F.3d 419, 422 (11th Cir. 1994). In this regard, some of the

allegations in the Third Amended Complaint are contradicted by the

Resolution which is attached to it. The copy of the Resolution

attached to the Third Amended Complaint establishes that it was

signed, executed, and duly recorded in the public records, and

plaintiff will not be allowed to assert otherwise. The remaining

claimed defects are arguments concerning state law which do not

arise to a constitutional level. Finally, plaintiff fails to state

a procedural due process claim because he has failed to allege that

Florida law provided him with an inadequate post-deprivation

remedy, Tinney v. Shores, 77 F.3d 378, 382 (11th Cir. 1996), and as

discussed above it is clear that Florida does provide adequate

post-deprivation remedies. Therefore, any claim founded on

procedural due process will be dismissed.

D. Equal Protection Claim:

Plaintiff also alleges that the Resolution violated his equal

protection rights. “To properly plead an equal protection claim,

a plaintiff need only allege that through state action, similarly

situated persons have been treated disparately.” Boyd v. Peet, 249

Fed. Appx. 155, 158 (11th Cir. 2007)(citation omitted). See also

Executive 100, Inc. v. Martin County, 922 F.2d 1536, 1552 (11th

Cir. 1991). The Third Amended Complaint does not identify any

similarly situated person with whom plaintiff can be compared. The

-12-
 UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
FORT MYERS DIVISION

JORG BUSSE

Plaintiff,

vs. Case No. 2:07-cv-228-FtM-29SPC

LEE COUNTY, FLORIDA; BOARD OF LEE

COUNTY COMMISSIONERS; KENNETH M.
WILKINSON; LEE COUNTY PROPERTY
APPRAISER’S OFFICE; STATE OF
FLORIDA, BOARD OF [PAST & PRESENT]
TRUSTEES OF THE INTERNAL IMPROVEMENT
TRUST FUND, STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL
PROTECTION, AND DIVISION OF
RECREATION AND PARKS; LEE COUNTY
ATTORNEY; JACK N. PETERSON,

Defendants.
___________________________________

OPINION AND ORDER

This matter comes before the Court on the following motions:

(1) defendant Property Appraiser’s Motion to Dismiss and Close File

(Doc. #285), to which plaintiff filed a Response (Doc. #302); (2)

defendants State of Florida Board of Trustees of the Internal

Improvement Trust Fund (Trustees) and Florida Department of

Environmental Protection’s (DEP) Joint Motion to Dismiss for Lack

of Jurisdiction and for Failure to State a Cause of Action (Doc.

#291), to which plaintiff filed a Response (Doc. #316); (3)

defendant The Lee County Appraiser’s Motion to Dismiss for Lack of