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RECUSAL MOTION & MEMO (3)

RECUSAL MOTION & MEMO (3)

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Published by GRANADAFRAUD
DEFENDANT TURNER’S IMPROPER CONDUCT ON THE RECORD
1. Here, Def. Judge Eugene C. Turner’s record conduct was improper, because Turner, e.g.:
a. Concealed a fraudulent “lien”, INSTR 4285498; OR 4445 PG 1665;
b. Fraudulently concealed orders;
c. Fraudulently concealed material facts;
d. Fraudulently concealed material misrepresentation by an improper party;
e. Fraudulently concealed the record lack of any valid debt, lis pendens, and action.

“Granada Condominium Homes Association, Inc.” could not have possibly brought any lien.
2. Pursuant to the “DECLARATION OF CONDOMINIUM OF GRANADA CONDOMINIUM HOMES”, O.R. 330, Page 466, ff, Collier County Public Records, “Granada Condominium Homes Association, Inc.” was
a. Not any proper party;

b. Not entitled to enforce a non-existent debt under the record contract and/or Declaration.






RECUSAL MEMORANDUM

3. CANON 2, FLORIDA CODE OF JUDICIAL CONDUCT, states:
”A Judge Shall Avoid Impropriety and the Appearance of Impropriety in all of the Judge's Activities.”

See Florida Supreme Court Original Proceeding - Amendment to Code of Judicial Conduct - American Bar Association's Model Code of Judicial Conduct, Judicial Ethics Advisory Committee; Art. V, § 2(a), Fla. Const.
4. The Florida Supreme Court Panel commented:

”Canon 2A. Irresponsible or improper conduct by judges erodes public confidence in the judiciary. A judge must avoid all impropriety and appearance of impropriety. A judge must expect to be the subject of constant public scrutiny. A judge must therefore accept restrictions on the judge's conduct that might be viewed as burdensome by the ordinary citizen and should do so freely and willingly. Examples are the restrictions on judicial speech imposed by Sections 3B(9) and (10) that are indispensable to the maintenance of the integrity, impartiality, and independence of the judiciary.

The prohibition against behaving with impropriety or the appearance of impropriety applies to both the professional and personal conduct of a judge. Because it is not practicable to list all prohibited acts, the proscription is necessarily cast in general terms that extend to conduct by judges that is harmful although not specifically mentioned in the Code. Actual improprieties under this standard include violations of law, court rules, or other specific provisions of this Code. The test for appearance of impropriety is whether the conduct would create in reasonable minds, with knowledge of all the relevant circumstances that a reasonable inquiry would disclose, a perception that the judge's ability to carry out judicial responsibilities with integrity, impartiality, and competence is impaired.”


ALTERATION OF DOCKET
5. On or around 09/05/2010, i.e., more than one month later, the Case Docket showed:

Here, neither the Clerk of Court nor Dr. Jorg Busse received any original order. Furthermore, subsequently filed Motions for Judge Turner’s Recusal did not appear on the Docket. Attached is the Case Docket as it appeared on 09/02/2010 without the alleged order by Defendant Judge Turner:


FRAUDULENT JUDICIAL CONCEALMENT OF FICTITIOUS debt, O.R. 330/466-500

6. Defendant Judge Eugene Turner knew and fraudulently concealed that there was
a. No debt;
b. No “contract” for the fraudulently pretended obligation to pay “$1,500.00”;
c. No breach of any contract, O.R. 330 / 466 – 500.

Here, there was an unfounded and facially fraudulent foreclosure action as supported by the agreement and/or contract of record, O.R. 330 / 466, ff.
OBJECTIONS, NON-CONSENT, AND DIRECT ATTACK OF FRAUD SCHEME
7. Here, Defendant Turner knew and concealed that Dr. Jorg Busse was
a. Never served;
b. Had attacked the record fraud scheme;
c. Had demanded judicial notice of the applicable Florida Statutes, and file, Ch. 92, F.S.;
d. Objected to any hearing, because this Court has no jurisdiction;
e. Objected to any and all magistrates;
f. Objected to any and all magistrate hearings.
RULE 2.330. DISQUALIFICATION OF TRIAL JUDGES
DEFENDANT TURNER’S IMPROPER CONDUCT ON THE RECORD
1. Here, Def. Judge Eugene C. Turner’s record conduct was improper, because Turner, e.g.:
a. Concealed a fraudulent “lien”, INSTR 4285498; OR 4445 PG 1665;
b. Fraudulently concealed orders;
c. Fraudulently concealed material facts;
d. Fraudulently concealed material misrepresentation by an improper party;
e. Fraudulently concealed the record lack of any valid debt, lis pendens, and action.

“Granada Condominium Homes Association, Inc.” could not have possibly brought any lien.
2. Pursuant to the “DECLARATION OF CONDOMINIUM OF GRANADA CONDOMINIUM HOMES”, O.R. 330, Page 466, ff, Collier County Public Records, “Granada Condominium Homes Association, Inc.” was
a. Not any proper party;

b. Not entitled to enforce a non-existent debt under the record contract and/or Declaration.






RECUSAL MEMORANDUM

3. CANON 2, FLORIDA CODE OF JUDICIAL CONDUCT, states:
”A Judge Shall Avoid Impropriety and the Appearance of Impropriety in all of the Judge's Activities.”

See Florida Supreme Court Original Proceeding - Amendment to Code of Judicial Conduct - American Bar Association's Model Code of Judicial Conduct, Judicial Ethics Advisory Committee; Art. V, § 2(a), Fla. Const.
4. The Florida Supreme Court Panel commented:

”Canon 2A. Irresponsible or improper conduct by judges erodes public confidence in the judiciary. A judge must avoid all impropriety and appearance of impropriety. A judge must expect to be the subject of constant public scrutiny. A judge must therefore accept restrictions on the judge's conduct that might be viewed as burdensome by the ordinary citizen and should do so freely and willingly. Examples are the restrictions on judicial speech imposed by Sections 3B(9) and (10) that are indispensable to the maintenance of the integrity, impartiality, and independence of the judiciary.

The prohibition against behaving with impropriety or the appearance of impropriety applies to both the professional and personal conduct of a judge. Because it is not practicable to list all prohibited acts, the proscription is necessarily cast in general terms that extend to conduct by judges that is harmful although not specifically mentioned in the Code. Actual improprieties under this standard include violations of law, court rules, or other specific provisions of this Code. The test for appearance of impropriety is whether the conduct would create in reasonable minds, with knowledge of all the relevant circumstances that a reasonable inquiry would disclose, a perception that the judge's ability to carry out judicial responsibilities with integrity, impartiality, and competence is impaired.”


ALTERATION OF DOCKET
5. On or around 09/05/2010, i.e., more than one month later, the Case Docket showed:

Here, neither the Clerk of Court nor Dr. Jorg Busse received any original order. Furthermore, subsequently filed Motions for Judge Turner’s Recusal did not appear on the Docket. Attached is the Case Docket as it appeared on 09/02/2010 without the alleged order by Defendant Judge Turner:


FRAUDULENT JUDICIAL CONCEALMENT OF FICTITIOUS debt, O.R. 330/466-500

6. Defendant Judge Eugene Turner knew and fraudulently concealed that there was
a. No debt;
b. No “contract” for the fraudulently pretended obligation to pay “$1,500.00”;
c. No breach of any contract, O.R. 330 / 466 – 500.

Here, there was an unfounded and facially fraudulent foreclosure action as supported by the agreement and/or contract of record, O.R. 330 / 466, ff.
OBJECTIONS, NON-CONSENT, AND DIRECT ATTACK OF FRAUD SCHEME
7. Here, Defendant Turner knew and concealed that Dr. Jorg Busse was
a. Never served;
b. Had attacked the record fraud scheme;
c. Had demanded judicial notice of the applicable Florida Statutes, and file, Ch. 92, F.S.;
d. Objected to any hearing, because this Court has no jurisdiction;
e. Objected to any and all magistrates;
f. Objected to any and all magistrate hearings.
RULE 2.330. DISQUALIFICATION OF TRIAL JUDGES

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Published by: GRANADAFRAUD on Sep 06, 2010
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06/17/2013

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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUITIN AND FOR COLLIER COUNTY, FLORIDAGRANADA CONDOMINIUM HOMES,Purported “
 plaintiff 
vs.
Clerk’s Case Number: 09 02617CC
 BUSSE, J. R., __________________________________________________________________________/
MOTION FOR DEF. E. C. TURNER’S RECUSAL/DISQUALIFICATION
 
UNDER § 38.10, FLA. STAT., CANON 3E(1), AND FLA. R. JUD. ADMIN. 2.330RECUSAL MEMORANDUM
1.
CANON 2
, FLORIDA CODE OF JUDICIAL CONDUCT, states:”A Judge
Shall Avoid Impropriety
and the Appearance of Impropriety in all of theJudge's Activities.”See Florida Supreme Court Original Proceeding - Amendment to Code of Judicial Conduct -American Bar Association's Model Code of Judicial Conduct, Judicial Ethics AdvisoryCommittee; Art. V, § 2(a), Fla. Const.2. The Florida Supreme Court Panel commented:”Canon 2A. Irresponsible or 
improper conduct by judges erodes public confidence
 in the judiciary.
A judge must avoid all impropriety and appearance of impropriety
. A judge must expect to be the subject of constant public scrutiny. A judge must therefore accept restrictions on the judge's conduct that might be viewedas burdensome by the ordinary citizen and should do so freely and willingly.Examples are the restrictions on judicial speech imposed by Sections 3B(9) and (10)that are indispensable to the maintenance of the integrity, impartiality, andindependence of the judiciary.The
prohibition
against behaving with impropriety or the appearance of impropriety
 
 2applies to both the professional and personal conduct of a judge. Because it is not practicable to list all prohibited acts, the proscription is necessarily cast in generalterms that extend to conduct by judges that is harmful although not specificallymentioned in the Code.
Actual improprieties
under this standard include
violationsof law
,
court rules
, or other specific provisions of this Code. The test for appearanceof impropriety is whether the conduct would
create in reasonable minds
, withknowledge of all the relevant circumstances that a reasonable inquiry would disclose,a perception that the
 judge's ability to carry out judicial responsibilities withintegrity, impartiality, and competence is impaired.”
 
 
DEFENDANT TURNER’S IMPROPER CONDUCT ON THE RECORD
3. Here, Judge Eugene C. Turner’s record conduct was
improper
, because Turner, e.g.:a.
Concealed
a
fraudulent
lien
”, INSTR 4285498; OR 4445 PG 1665; b.
Fraudulently concealed
orders;c.
Fraudulently concealed
material facts;d.
Fraudulently concealed
material misrepresentation by an
improper
 
 party
;e.
Fraudulently concealed
the record
lack 
of any
valid debt 
,
lis pendens
, and
action
.“Granada Condominium Homes Association, Inc.” could not have
 possibly brought 
any
lien
.4. Pursuant to the “DECLARATION OF CONDOMINIUM OF GRANADA CONDOMINIUMHOMES”, O.R.
330
, Page
466
, ff, Collier County Public Records, “
Granada Condominium Homes Association, Inc.
” wasa.
Not
any
 proper party
; b.
Not
 
entitled 
to
enforce
a
non-existent
 
debt 
under the record contract and/or Declaration.
ALTERATION OF DOCKET
5. On or around 09/05/2010, i.e., more than
one month later
, the Case Docket showed:Here,
neither
the Clerk of Court
nor
Dr. Jorg Busse
received 
any
original order 
.Furthermore, subsequently filed Motions for Judge Turner’s Recusal did not
appear 
on theDocket. Attached is the Case Docket as it appeared on
09/02/2010 without
the alleged
order 
  by Defendant Judge Turner:
 
 3 

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