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Plaintiffs,
“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.”
3. 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.”
4. 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.”
5. Here since 2003, the purported record “assessments for recurring common expense” were “more
6. 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.
7. 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”;
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c. “Palm Property Services, LLC”;
8. 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 expense
1. An Order declaring the fraudulent lien null and void and/or not in effect and Defendant’s record
2. An Order declaring any and all unapproved assessments null and void under said By-Laws and
Public Records;
3. 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
4. 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.
5. An Order taking judicial notice of the Plaintiff Association’s said By-Laws, Public Records,
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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 34102, on this 1st
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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12/19/2009 The Real Property, Probate and Trust …
Chapter 2 - Bankruptcy
Executive Council Meeting
Chapter 3 - Conveyances - Part 1
January 14 – January 17,
2010 Chapter 3 - Conveyances - Part 2
Chapter 7 - Leases
Com m ittee Schedule
Chapter 8 - Construction Liens
Future Meetings
Chapter 9 - Judgments and Mortgages
Chapter 10 - Names
The Real Property Probate
and Trust Law Section of Chapter 11 - Plats
The Florida Bar
Chapter 12 - Tax Liens
651 East Jefferson Street
Tallahassee, Florida Chapter 13 - Trusts
32399-2300
Chapter 15 - Tax Titles
Chapter 18 - Homestead
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