Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
11Activity
0 of .
Results for:
No results containing your search query
P. 1
Motion for Judicial Notice of Plaintiff's Fraud

Motion for Judicial Notice of Plaintiff's Fraud

Ratings: (0)|Views: 483|Likes:
Published by GRANADAFRAUD
Motion for Judicial Notice of Plaintiff Home Association's Fraud-
The Public Record Evidence on File
Motion for Judicial Notice of Plaintiff Home Association's Fraud-
The Public Record Evidence on File

More info:

Published by: GRANADAFRAUD on Apr 05, 2010
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

11/05/2011

pdf

text

original

 
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUITIN 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 
.
DEMAND FOR JURY TRIALNOTICE OF PLAINTIFF ASSOCIATION’S FRAUD
 _________________________________________________________________/
MOTION FOR JUDICIAL NOTICE OFPUBLIC RECORD EVIDENCE IN SUPPORT OF FRAUD, FRAUD ON COURT,EMBEZZLEMENT BY PLAINTIFF ASSOCIATION/PLAINTIFF’S ATTORNEYS, ANDCONTINUAL VIOLATIONS OF RECORD DECLARATION OF CONDOMINIUM, ANDBY-LAWS, GRANADA CONDOMINIUM HOME(S) ASSOCIATIONPUBLIC RECORD EVIDENCE ON FILE, COLLIER COUNTY PUBLIC RECORDS,IN SUPPORT OF FRAUD, FRAUD ON THE COURT, AND EMBEZZLEMENT
1. The identified Collier County Public Record(s) on file support record fraud, fraud on the Court,and embezzlement by Plaintiff Association, Directors, and Plaintiff’s Attorneys:
a. Collier County Official Record(s) 330/466 trough 330/493; 194717; DECLARATIONOF CONDOMINIUM (1969);
 
 2
b. Collier County Official Record(s) 330/494 trough 330/500; 194717; BY-LAWS of GRANADA CONDOMINIUM HOMES ASSOCIATION (1969);c. Collier County Official Record(s) 1003/687;d. Collier County Official Record(s) 1332/1750; ande. Collier County Official Record(s) 1517/2165.P. ASSOCIATION’S DELIBERATE NON-DISCLOSURE OF EXPENSES UNDER CH. 718
2. Florida Statutes, Chapter 718, CONDOMINIUMS, required full disclosure of the Plaintiff Association’s expenses. For years, the Plaintiff Association unlawfully refused to disclose itsexpenses as mandated by said Chapter 718. See demands for disclosure on file.3. Here, Plaintiff fabricated
expenses
” for the unlawful purpose of defrauding apartment owners.
 
CONTINUAL VIOLATIONS BY DIRECTORS OF ASSOCIATION BOARD
4. Pursuant to the DECLARATION OF CONDOMINIUM, O.R. BOOK 1517, PAGE 2165,Collier County Public Records:
“[a]ll ownership apartments in Granada shall be by an individual or immediatefamily members only. There shall be only one apartment per owner in the Granada
 
Condominium Home Association. Anyone now owning more than one unit, maykeep the second unit only until sold. Not more than three immediate family
 
members can occupy an apartment. There can be no ownership of an apartment bya corporation or multiple persons not related.”
Here pursuant to the Public Record:
 a. There w
 
ere three (3) apartments per owner [e.g., Director Jackson
 
] in the GranadaCondominium Home Association.b. There were two (2) apartments per owner [e.g., Director van Dongen
 
] in the GranadaCondominium Home Association.c. There was
ownership of an apartment by multiple persons not related 
’ [see, e.g.,
 
Director Jackson; other unrelated owner “
 Brown
”].
 
 3
UNLAWFUL RETALIATION, FRAUD, FRAUD ON THE COURT
5. Here in retaliation, said Directors initiated said fraudulent “
lien
”, which was null and void abinitio.
PROHIBITED LEASE & RETALIATION BY DIRECTORS
6. Pursuant to the DECLARATION OF CONDOMINIUM, 01368522, Collier County PublicRecords:
“[a]nyone purchasing an apartment cannot lease it. It must be for the use of theowners and his immediate family use only.”
Here, e.g., Directors Jackson and van Dongen leased their total of five (5) apartments andretaliated with the fraudulent “
lien
” when Dr. Busse complained.
 
DIRECTORS WERE NOT PRESENT AT MEETINGS7.
Here pursuant to the Public Record,
“Directors and members not present at the meetings … may express their approvalin writing, providing such approval is delivered to the secretary at or prior to the
 
meeting.”
See, e.g., O.R. 330/487.
 
Here, e.g., Director Jackson, who resides in California, was not present at the meetings and the“changes” and/or amendments null and void.
MOTION FOR JUDICIAL NOTICE OF RECORD FRAUD ON COURT & DECEPTION
8. Hereby, Dr. Busse moves this Court to take judicial notice of the record fraud, fraud on theCourt, and violations pursuant to the Collier County Public Records.9. Here, the fraudulent “
lien
” was based on facially fraudulent and un-audited figures and/or expenses, which had never been
disclosed 
under said Ch. 718, F.S. The forged expensesviolated said DECLARATION and/or BY-LAWS.
PUBLICATIONS OF COURT FILINGS & FRAUD EVIDENCE AT:

Activity (11)

You've already reviewed this. Edit your review.
1 hundred reads
1 thousand reads
puretrust liked this
Sonya Davis liked this
Paul Heidemann liked this
Paul Heidemann liked this
Ren liked this
wyzeman liked this
valtec liked this
GRANADAFRAUD liked this

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->