Professional Documents
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Emergency Motion For Independent Audit & Accounting
Emergency Motion For Independent Audit & Accounting
Plaintiffs,
EMERGENCY MOTION
__________________________________________________________________________/
2. The Twentieth Judicial Circuit Certified Civil Process Server Review Board, 2072 Victoria
Ave., Ft. Myers, FL 33901, has been monitoring Defendant process server Nicholas Krancher.
3. Dr. Jorg Busse complained about troubled process server Nicholas Krancher with the
4. Troubled process server Nicholas Krancher never served Dr. Jorg Busse with any summons
and/or complaint.
5. Defendant Nicholas Krancher had perjured himself and falsified official documents.
6. Defendant Krancher knew that Dr. Jorg Busse had not been served.
FRAUDULENT PRETENSES
8. Defendant Krancher could not have possibly attempted any service at said Courthouse.
9. Dr. Jorg Busse has not been any served party Defendant.
11. Based on the public record evidence, troubled Nicholas Krancher was arrested and has a
12. Defendant Krancher perjured himself for criminal and illegal purposes on the public record.
13. Dr. Jorg Busse lives in reasonable fear of further unlawful acts by Defendant Nicholas
14. Defendant N. Krancher poses a threat. Dr. Jorg Busse has a Constitutional right to be free of
15. Dr. Jorg Busse is suing Defendant Chene M. Thompson, a judicial officer, in Federal Court.
NO service – NO jurisdiction
16. Pursuant to the record, Dr. Jorg Busse was not served and did not submit to any jurisdiction.
NO debt – NO lien
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17. Defendant Thompson knew that no debt had existed in this facially fraudulent action. Here,
nothing could have possibly become any lien on Dr. Jorg Busse’s record property.
18. Orion Bank, the purported “Plaintiff’s” failed agent went bankrupt, and Defendant E. C.
2. An EMERGENCY Order restraining Defendant Nicholas Krancher from any service upon Dr.
Jorg Busse;
3. An EMERGENCY Order restraining Defendant Nicholas Krancher from any further perjury;
7. An Order compelling Eugene C. Turner to SHOW CAUSE why Defendants’ facially frivolous
and illegal claims should not be summarily dismissed as supported by the Affidavits and Public
8. An Order compelling Eugene C. Turner to SHOW CAUSE why his “orders” and “rulings” were
not on their faces irrational, arbitrary, capricious, and null & void as evidenced by the public
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9. An EMERGENCY Order disqualifying and recusing objectively impaired Judge Eugene C.
Turner, because he was so impaired that he could not perform the essential duties of a judge in
10. An EMERGENCY Order disqualifying and recusing objectively impaired Judge Eugene C.
Turner, because no reasonable, intelligent, and fit judge, juror, and/or person in Turner’s shoes
could have possibly determined Dr. Busse’s “liability” without first obtaining the absolutely
11. An EMERGENCY Order disqualifying and recusing objectively impaired Judge Eugene C.
Turner, because no reasonable, intelligent, and fit judge, juror, and/or person in Turner’s shoes
could have possibly refused to give full credit to the record evidence of payments by Dr. Busse
12. An Order compelling said Judicial Officer Turner and the Court to show good cause why said
13. An Order compelling said Judicial Officer Turner and the Court to show good cause why said
judicial Officer must not be disqualified under the Rules and based upon the conclusive
evidence of Dr. Busse’s payments to the Plaintiff Association on file in this and the related
Case;
14. An Order compelling said Judicial Officer Turner and the Court to show good cause why said
judicial Officer did not conceal that Dr. Busse was NEVER served;
15. An Order compelling the Plaintiff to disclose and produce the Association’s “common expense”
16. An Order compelling the Plaintiff to disclose and produce the Association’s “accounting”
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17. An Order dismissing Plaintiff’s fraudulent Complaint with prejudice pursuant to said Official
18. An Order providing Dr. Busse with mandatory access to the case file prior to any hearing;
19. An Order for service of a notice of hearing upon Dr. Busse under said Rules;
20. An Order declaring the fraudulent lien null and void and/or not in effect and Defendant’s record
21. An Order declaring any and all unapproved assessments null and void under said By-Laws and
Public Records;
22. 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
23. 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.
24. An Order taking judicial notice of the Plaintiff Association’s said By-Laws, Public Records,
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 34112, on this 6th
day of August, 2010. The pleading is also being published worldwide. See, e.g., www.scribd.com.
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/s/Jorg R. Busse, M.D., M.M., M.B.A.
SIGNATURE
State Certified Residential Appraiser, Licensed Real Estate and Mortgage Broker
P.O. Box 11124, Naples, FL 34101-11124, jrbu@aol.com, 239-595-7074
CC: Donna Woodruff, Facsimile: 239-252-8020, Clerk of Courts; Angela Turner, J.A.
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Case 1:10-cv-00321-JL Document 3 Filed 08/03/10 Page 27 of 28
Plaintiff
Defendant
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,
whose name and address are: UNITED STATES OF AMERICA Ex Rel. Dr. Jorg Busse & J. Franklin Prescott
Mail to: 10 Benning ST # 135
West Lebanon, NH 03784-3402
If you fail to respond, judgment by default will be entered against you for in the complaint.
You also must file your answer or motion with the court.