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UNITED STATES DISTRICT COURT
UNITED STATES OF AMERICA EX REL. DR. JORG BUSSE AND JENNIFER
FRANKLIN PRESCOTT, DR. JORG BUSSE, JENNIFER FRANKLIN PRESCOTT,STATE OF FLORIDA EX REL. DR. JORG BUSSE AND JENNIFER FRANKLIN
PRESCOTT, DR. JORG BUSSE AND JENNIFER FRANKLIN PRESCOTT ASPRIVATE ATTORNEY(S) GENERAL,
Plaintiffs,
v. Case No. 1-2010-cv-000_____
UNITED STATES OF AMERICA, UNITED STATES COURTS, UNITED STATES
CUSTOM & IMMIGRATION SERVICE, TONY WEST, BEVERLY B. MARTIN,JOHN EDWIN STEELE, RYAN BARRY, CHARLENE EDWARDS HONEYWELL,
SHERI POLSTER CHAPPELL, KENNETH M. WILKINSON, RICHARD A.
LAZZARA, JACK N. PETERSON, RYAN BARRY, DREW HEATHCOAT, BETTYEG. SAMUEL, STANLEY F. BIRCH, JR, GERALD B. TJOFLAT, SUSAN H. BLACK,JOEL F. DUBINA, SHERRI L. JOHNSON, EUGENE C. TURNER, LEE COUNTY,
FL, COMMISSION AND COMMISSIONERS, ED CARNES, JOHN E. MANNING,
U.S. RACKETEERING AGENTS, HUGH D. HAYES, JOHN LEY, RICHARDJESSUP, DIANE NIPPER, LYNN GERALD, JR., KENNETH L. RYSKAMP,
CHARLIE CRIST, CHARLES BARRY STEVENS, JOHNSON ENGINEERING,
INC., MARK ALLAN PIZZO, ANNE CONWAY, CHARLIE GREEN, REAGANKATHLEEN RUSSELL, RICHARD D. DEBOEST, II, CHENE M. THOMPSON, et al.,
Defendants.
DEMAND FOR JURY TRIAL AND $19,000,000.00__________________________________________________________________________/
COMPLAINT AND DEMAND FOR JURY TRIAL
COMPLAINT OF RACKETEERING, EXTORTION, PUBLIC CORRUPTION
IN THE U.S. DISTRICT COURT, MIDDLE DISTRICT OF FLORIDA,
U.S. COURT OF APPEALS FOR THE ELEVENTH CIRCUIT,
20TH
JUDICIAL CIRCUIT IN AND FOR LEE & COLLIER COUNTIES, FL, AND OF
UNLAWFUL AND CRIMINAL ACTS BY GOVERNMENT AGENTS & OFFICIALS
IN THEIR PRIVATE INDIVIDUAL CAPACITIES OUTSIDE ANY IMMUNITY
COMPLAINT UNDER CIVIL RICO, 18 U.S.C. 1964, 1961-1968
COMPLAINT OF GOVERNMENTS MALICIOUS CIRCULAR ARGUMENT
FOR PURPOSES OF RACKETEERING, EXTORTION, AND RETALIATION:
THE CONCLUSIVELY PROVEN ALLEGATIONS ARE FRIVOLOUS.
THEREFORE THE CASE IS FIXED AS FRIVOLOUS.
REPORT TO THE INTERNATIONAL COURT OF JUSTICE, THE HAGUE
[PAGES TOTAL: 196 + 213 (Exhibits)]
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292. Defendant Martin extorted and concealed, and conspired to extort and conceal, that he
procedure on execution did not accord with the procedure of the State of Florida. See
Fed.R.Civ.P. 69. Defendant knew that Florida procedure required a recorded and certified
judgment, which here had neverexisted. The Court never had any authority to award
$5,048.60, and the judgment issued as mandate on 06/11/2009 in the amount of$24.30 had
been paid. The prima facie fraudulent affidavit by Defendant Racketeer JACK N.
PETERSON fraudulently pretended a 07/29/2009 judgment, Doc. # 432-2, Case No.
2:2007-cv-00228, which all Defendants knew, concealed, and conspired to conceal had
neverexisted. See also Ch. 55, 56, Florida Statutes.
DEFENDANT CHARLENE E. HONEYWELL
RECORD LACK OFIMMUNITY- PERPETRATION OF UNLAWFUL ACTS
293. The Plaintiff public corruption victims are suing Defendant corrupt U.S. District Judge
Charlene Edwards Honeywell (Honeywell), a female Afro-American Judge, in herprivate
individual capacity and official capacity. Defendant Honeywells unlawful and criminal acts
on record were outside any immunity and officialcapacity.
FELONIES OUTSIDE ANY official CAPACITY
294. Defendant Corrupt Honeywell had knowledge of the actual commission offelonies and
concealed them. Here even though Def. Honeywell had knowledge of, e.g., judicial Co-
Defendant Chappells, Steeles, Pizzos, and Lazzaras obstruction of justice and
fraudulent concealment of facially forged land parcels, a falsified writ of execution,
falsified $5,048.60 judgment, Corrupt Honeywell did not make the same known to some
judge or person in authority, but covered up for said Offenders in exchange forbribes, 18
U.S.C. 3, 4.
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ACCESSORY AFTER THE FACT
295. Defendant Crook Honeywell knew that Defendant principal Offenders Steele, Chappell,
Pizzo, and Lazzara had committed record offenses and assisted said Offenders, 18 U.S.C.
3, 4. See, e.g., Case No. 2:2010-cv-00089, Doc. # 50, assistance with facially fraudulent
writ of execution; see Case No. 2:2009-cv-00791, Doc. ## 213, 236, assistance with record
forgeries.
DELIBERATE DEPRIVATIONS UNDER COLOR OF FAKE writ AND resolution
296. Defendant Government Whore deliberately deprived the Plaintiffs, e.g., under color of a
fake writ of execution and resolution 569/875, 18 U.S.C. 241, 242.
RECORD RETALIATION UNDER COLOR OF WRIT OF EXECUTION&SANCTIONS
297. With the intent to retaliate, Corrupt Honeywell knowingly took actions harmful to the
Plaintiff public corruption victims, which included interference with Plaintiffs livelihood
and record land ownership, because the Plaintiff landowners had provided truthful
information relating to the commission of Federal offenses to law enforcement, 18 U.S.C.
1513.
298. Knowingly, Honeywell extorted Plaintiffs property and/or threatened to do so, with
corrupt intent to retaliate against the Plaintiffs because the Plaintiffs had blown the whistle
on public corruption; in particular, because the Plaintiffs had produced records and testimony
conclusively evidencing Government corruption and fraud, and information about the
commission of Federal offenses by Government Officials. Here, Plaintiff Government crime
and corruption victims had the right to be reasonably protected from the Government
Offenders and Judges of record, 18 U.S.C. 3771.
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RECORD POLICY, CUSTOM, AND CULTURE OF CORRUPTION
299. Customarily, and over and over again, Honeywell coerced the Plaintiffs to refrain from
prosecuting and producing crime evidence. Idiotic lies and threats of sanctions have played
a central role in Honeywells record crimes and concealment. Just like Jews and
Government opponents in Nazi Germany, the Plaintiff Government crime victims are
running from the anarchy, extortion, and coercion in Honeywells court of perversions
where un-recorded and non-existentjudgments can be perverted into a lien on property.
BLACKMAIL, EXTORTION, UNLAWFUL COMMUNICATIONS & THREATS
300. In retaliation and exchange for bribes, Defendant Crooked Judge Honeywell made
threatening demands without any justification under color of law, authority, and falsified
official records. In particular, Defendant Corrupt Judge threatened, e.g., monetary
sanctions, civil contempt, and/or arrest, merely because the Plaintiff public corruption
victims had exposed and blown the whistle on, e.g., Honeywells crimes, extortion,
coercion, and fraud on the Court.
EXACTION OF MONEY BY THREAT OF, E.G., ARREST AND CIVIL CONTEMPT
301. Honeywell exacted, threatened to exact, and/or conspired with other Officials and
Defendants to exact money from Plaintiffs by threat of monetary sanctions, civil
contempt, and/or arrest under color of, e.g., office and falsified official records. In
particular, Def. Honeywell conspired to extort $5,048.60 in the absence of any recorded
authentic judgment and justification. Honeywell caused other Government Officials to
falsify, alter, and destroy official records forcriminal and illegal purposes ofconcealing
Honeywells extortion, coercion, obstruction of justice and other crimes of record.
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Honeywell made unlawful communications and threatened Plaintiff public corruption
whistleblowers. See, e.g., Case No. 2:2010-cv-00089, Doc. # 50, p. 3:
Shortly thereafter, the writwas issued(2:07-CV-228, Dkt. 425).
Defendant Government Whore Honeywell knew and fraudulentlyconcealed that no writ
had ever been issued and/or could have possibly been issued, because, e.g., no recorded
$5,048.60 judgment had everexisted. For criminal & illegal purposes of, e.g., extorting
and obstructing justice, said Defendant falsely and idiotically pretended lack of
authority over record extortion under color of a falsified official record by U.S.
Defendants, Case No. 2:2010-00089, Doc. # 50, 07/14/10, p. 3:
Because Case No. 2:07-CV-228 was assigned to Judge John Steele, this Court doesnothave the authority togrant relief from the writ of execution.
302. Just like a bunglingGovernment idiot, Def. Honeywell contradicted herself in the next
paragraph, in which she cited Fed. R. Civ. P. 60(b), Doc. # 50, pp. 3-4:
A party may move forrelieffrom afinal judgmentororder. Fed. R. Civ. P. 60(b).
As such, the matter is closed, except for the issue ofsanctions.
Plaintiffs have given the Court more than enough grounds to impose sanctions for
theirmisconduct.
MISCONDUCT AND EXTENSION OF RECORD CRIMES AND FALSIFIED writ
303. Def. Honeywell recklessly extended the record Government crimes and falsified writ,
Doc. # 425:
To the extent that Plaintiffs request injunctive relief, the Motions will be denied.
See Doc. # 50, p. 4.
304. Defendant Honeywell fraudulently concealed that sanctions were not any issue but
Honeywells recordcrimes and unlawfulacts such as, e.g., extortion, concealment, and
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fraud were. In said organized cover-up, Defendant Honeywell concealed that there had
never been any $5,048.60 judgment of record and that no judgment of record had ever
even referenced any frivolous appeal.
305. Honeywell promoted the record culture and policy of corruption, anarchy,
lawlessness and perversion of law and facts. With corrupt intent to obtain illegal benefits,
Honeywell incomprehensibly and disjointedly copied and pasted together illegal
orders and judicial trash without ever addressing the complained about legal issues and
claims for relief.
RECKLESS DEPRIVATIONS AND OBSTRUCTION OF JUSTICE & COURT ACCESS
306. For criminal and illegal purposes of obstructing justice, extorting, coercing, and
concealing, Defendant Criminal Honeywell obstructed, and caused other Officials and
Defendants to obstruct, the filing of, e.g., Plaintiffs Notice of Appeal from order, Doc. #
213, Notice of Appeal from order, Doc. # 236, Case No. 2-2009-cv-00791:
The Clerk is directed to terminate these motions.3. The Clerk is further directed to no longer accept ANY filings from Plaintiffs
in this case because a judgment has been entered and Plaintiffs have filed a
notice of appeal as to the Courts Order (Dkt. 213), and this case is CLOSED.4. Finally, the Clerk is also directed to strike Published Public Notices from therecord (Dkt. 220, 221, 223, 225, 226, 229, 230, 232, 233, 234, 235).
ILLEGAL DESTRUCTION AND MUTILATION OF OFFICIAL RECORDS
307. With corrupt intent to extort, blackmail, coerce, defraud, deprive, and obtain illegal
benefits, Defendant Corrupt Honeywell destroyed, mutilated, caused others to destroy and
mutilate, and conspired with, e.g., other Officials to destroy and mutilate official records,
Case No. 2:2009-cv-00791, Doc. # 236, 07/02/2010, p. 3:
Plaintiffs have also filed several documents entitled Published Public Notice (Dkt.220, 221, 223, 225, 226, 229, 230, 232, 233, 234, and 235). These documents do notrelate to any pending motion. Further, they are not motions which request affirmativerelief by the Court. They are immaterial to this case, which has been dismissed.
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Moreover, some of the documents contain scandalous materials. These noticesshould, therefore, be stricken. See Case No. 2:2009-cv-00791, Doc. # 236, pp. 2-3.
MISUSE OF PUBLIC OFFICE, CONCEALMENT, AND COVER UP
308. In exchange forbribes, Defendant Government Whore Honeywell obstructed, delayed,
and prevented the communication of judicial and Government corruption information
relating to the commission offelonies by, e.g., U.S. Agents J. E. Steele, S. Polster Chappell,
M. A. Pizzo, R. A. Lazzara, and Def. record Forger of land parcels K. M. Wilkinson, and
Crooked Attorney Jack N. Peterson, 838.022 (1)(c), Fla. Stat.
DELIBERATE DERPRIVATIONS AND PERVERSIONS OF FUNDAMENTAL RIGHTS
309. U.S. Defendant Honeywell recklessly perverted express Florida and Federal
Constitutional guarantees of, e.g., the rights to due process, equal protection of the law, to
own property, exclude Governments from private property, redress Government grievances,
prosecute by jury trial, be free of Government corruption, extortion, coercion, oppression,
falsification of records, unlawful seizure of private property under fraudulent pretenses such
as, e.g.:
a. Idiotically and brazenly, Def. Whore Honeywell manufactured and conspired with
other Government Officials to pervert express Constitutional guarantees and concoct
that property rights are not fundamental rights;
b. Def. Honeywell concocted and conspired to concoct that Plaintiffs could not assert their
perfected state claims against U.S. Agents in U.S. Courts;
c. Def. Honeywell fabricated and conspired to fabricate that Defendant Forger of land
parcels Wilkinson had filed a non-existent Rule 38 motion. Here, Defendant
Honeywell falsified and caused others to falsify dockets, docket entries, and official
records. See 838.022 (1)(a), Fla. Stat.;
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d. Def. Predator Honeywell concealed, covered up, and/or altered official records and
documents, 838.022 (1)(b), Fla. Stat.;
e. With corrupt intent to obtain illegal benefits for Lee County Officials and to harm the
Plaintiff record landowners & corruption victims, Def. Honeywell maliciously fabricated
and conspired to fabricate a regulation by nameless, un-named, and non-existent
legislators. See 838.022 (1), Fla. Stat.
OBSTRUCTION OF COURT ACCESS & FILING OF NOTICE OF APPEAL, DOC. 213
310. On or around07/16/2010, Defendant Whore Honeywell prevented and conspired with
other Officials such as, e.g., Defendant Clerks Drew Heathcoat and Diane Nipper the filing
of Plaintiffs Notice of Appeal from Order, Doc. # 213 , Case No. 2:2009-cv-00791, and
the communication of information relating to the commission of felonies in the U.S. District
Court, Fort Myers, Florida.
311. Recklessly, Honeywells illegal and felonious acts deprived the Plaintiffs of their rights
as stated in Doc. # 214, Case No. 2:2009-cv-00791.
RULE 38/WRIT OF EXECUTION-FRAUD-SCHEME, CONSPIRACY TO EXTORT
312. Pursuant to Fed.R.App.P. 39, costs may be taxed against the appellant, if a judgment is
affirmed. Defendant Whore Honeywell knew and concealed that the costs allowed and/or
taxed were $24.30, Case No. 2:2007-cv-00228, Doc. ## 365, p. 15; 386-3, p. 15. Def.
Honeywell concealed that no costs were everallowedunder purported Rule 38.
FRIVOLOUS APPEAL-FRAUD & EXTORTION-SCHEME
313. FRAP 38, Frivolous Appeal - Damages and Costs provides that
if a court of appeals determines that an appeal is frivolous, it may, after a separatelyfiled motion or notice from the court and reasonable opportunity to respond, awardjust damages and single or double costs to the appellee.
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314. Defendant Government Whore Honeywell knew and fraudulently concealed that pursuant
to 11th Cir. R. 38-1, Time for Filing Motions, Motions for damages and costs pursuant to
FRAP 38 must be filed no later than the filing of appellees brief. Here, Defendant Wilkinson
had tendered and/or filed his prima facie fraudulent brief on or around 08/08/2008. See
Appellate Case No. 2008-13170-BB, certified Docket sheet. Admittedly, Defendant
Wilkinson neverfiledany Rule 38 motion before 08/08/2008.
315. Admittedly, Defendant Wilkinson had never filed any Rule 38 motion. Rule 38 only
provided for damages and costs. Here, Defendant Wilkinson had neverfiledany such motion
and perpetrated fraud on the Court. See certified Docket. Defendant Government Whore
Honeywell concealed said Rule 38 motion-fraud-scheme and conspiracy to extort.
CONSPIRACY TO CONCEAL ILLEGALITY & CRIMINALITY OF FAKE WRIT
316. On or around 07/14/10, Defendant corrupt U.S. Judge Honeywell conspired with, e.g.,
U.S. Defendants Chappell and Steele to fraudulently conceal the prima facie nullity and
illegality of a facially forged writ of execution and July judgment, Case No. 2:2010-cv-
00089, Doc. # 48, p. 1:
On February 1, 2010, Magistrate Judge Chappell issued an order granting DefendantKenneth M. Wilkinson's Motion for Issuance of a Writ of Execution (2:07-CV-228,Dkt. 424). Shortly thereafter, the writ was issued (2:07-CV-228, Dkt. 425).
317. Defendant crooked Honeywell fraudulently concealed and conspired to conceal that
Defendant Wilkinson had never filed any Rule 38 motion, Fed.R.App.P.
318. Defendant corrupt U.S. Judge Honeywell fraudulently concealed and conspired to
conceal that Defendant Co-conspirator Chappell had fabricated a mandate and/orjudgment,
Case No. 2:2007-cv-00228, Doc. # 424:
On July 28, 2009, the Eleventh Circuit issued a Judgment awarding Wilkinson$5,000.00 in attorneys fees and double costs in the amount of $48.60, as sanctionsfor Busses pursuit of a frivolous appeal.
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319. Defendant Honeywell fraudulently concealed and conspired to conceal that admittedly
Defendant Wilkinson had never alleged a frivolous appeal and that no mandate or
judgment awarding Wilkinson $5,000.00 in attorneys fees had ever existed, Case No.
2:2007-cv-00228.
320. In the certified record absence of any Rule 38 motion by Def. Wilkinson, a fraudulent
judgment in the amount of $24.30 issued as mandate on June 11 2009, Case No.
2:2007-cv-00228.
321. Defendant Honeywell fraudulently concealed and conspired to conceal that the mandated
amount of $24.30 had been paid and was not outstanding:
TheJudgmentto date remains outstanding.
322. Defendant Honeywell fraudulently concealed and conspired with other U.S. Agents to
conceal that
a. No such mandated judgment existed, Case No. 2:2007-cv-00228;
b. No mandated judgment was ever recorded in the Public Records of Lee County;
c. The fraudulently alleged certification was facially forged;
d. Instrument No. 2009000309384 could not have possibly become any lien on any
property pursuant to Ch. 55, 56; and 55.10 Florida Statutes; and
e. No writ of execution legally existed.
323. Defendant Honeywell fraudulently concealed and conspired with U.S. Defendants
Chappell, Steele, and other U.S. Agents to conceal that nothing in that or any other Case
could havepossibly served as a lien against any property under Florida and Federal law:
A certified copy of the Judgment was recorded in the Public Records of Lee County,
Florida at Instrument No. 2009000309384 andserves as a lien against the property.
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324. Defendant Honeywell fraudulently concealed and conspired to conceal that
a. Defendant Wilkinson had neverfiledany Rule 38 motion;
b. Kenneth M. Wilkinson had never been awardedany mandatedjudgment;
c. Def. Wilkinson was not entitled to tax.;
d. The prima facie fraudulent Writ was due to be denied as unlawful and unauthorized.
FRAUDULENT CONCEALMENT OF JURISDICTION & FRAUD ON THIS COURT
325. On or around 06/23/10, Defendant Honeywell fraudulently concealed the jurisdiction of
this Court over the unlawful acts of the Defendant U.S. Agents and recklessly deprived the
Plaintiffs of any chance of justice and adjudication of their perfected claims, Doc. # 213:
B. Supplemental Jurisdiction
The decision to exercise supplemental jurisdiction over pendent state claims restswithin the discretion of the district court.Raney v. Allstate Ins. Co., 370 F.3d 1086,1088-89 (11th Cir. 2004). Once a district court dismisses all claims over which it hadoriginal jurisdiction, it may decline to exercise supplemental jurisdiction over theremaining state claims. 28 U.S.C. 1367(c)(3). This Court, therefore, declines toexercise supplemental jurisdiction over Plaintiffs remaining state claims.
326. Defendant Honeywell knew and fraudulently concealed that this Court had jurisdiction of
any and all claims involving the Defendant U.S. Government Officials and including state
claims. Defendant Honeywell had no discretion but was absolutely obligated to adjudicate
Plaintiffs claims, because United States Agents had perpetrated unlawful and criminal acts
of record.
327. Defendant Honeywell knew and concealed that Co-Defendant U.S. Judges Steele and
Chappell themselves had removed Plaintiffs State action, 2006-CA-003185, BUSSE v.
STATE OF FLORIDA, to Federal Court. See 2:2008-cv-00899.
328. Declining jurisdiction over unlawful and criminal U.S. Governmental acts proved
Defendant Honeywells fraud on the Courts and required her disqualification.
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RECKLESS OBSTRUCTION OF COURT ACCESS
DISPARATE DENIAL OF COURT ACCESS RIGHTS
329. Recklessly, Defendant Honeywell again obstructed Plaintiffs court access on 06/23/10,
Doc. # 213, p. 21:
With its discretionary authority, the Court declines to exercise supplementaljurisdiction over Plaintiffs state claims.
OBSTRUCTION OF COURT ACCESS UNDER FALSE PRETENSES OF misconduct
330. On 07/07/10, Defendant Honeywell again fabricated misconduct and/or loss of
electronic filing privileges in response to Plaintiffs specific demand for equal court
access and privileges for filing purposes. See Case No. 2:2010-cv-00089, Doc. # 38, p. 1;
see Def. Honeywells previous fabrications, Case No. 2:09-CV-791, Doc. ## 133, 151.
RECORD CONSPIRACY TO OBSTRUCT JUSTICE & ADJUDICATION
331. Defendant Honeywell conspired with other Defendant U.S. Judges and Officials not to
justly and speedily adjudicate Plaintiffs conclusively proven state claims against Federal
Defendants.
DENIAL & FRAUDULENT CONCEALMENT OF EQUAL PROTECTION RIGHTS
332. On or around 06/23/2010, Defendant Honeywell recklessly and disparately denied the
Plaintiffs the equal protection of the laws under fraudulent pretenses, Doc. # 213, p. 19:
In this case, Plaintiffs claim that they were denied equal protection of the laws byDefendants in relation to Lot 15A. As a general matter, Florida counties may exerciseeminent domain over property not owned by the state or federal government. Fla.Stat. 127.01(1)(a); id. Since a state landowner would not be subject to eminentdomain power but [Plaintiffs], as . . . [alleged] private landowner[s], would be,Plaintiffs cannot be similarly situated to a state landowner. Busse, 317 Fed. Appx. at973. Plaintiffs, therefore cannot rely on [their] disparate eminent domain treatmentvis-a-vis state landowners as the basis for an equal protection claim. Id.Consequently, the Court finds that Plaintiffs failed to state a claim upon which reliefcan be granted and dismisses their Equal Protection claim.
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333. In exchange for Defendants bribes, Defendant Honeywell fixed and fraudulently
concealed Plaintiffs perfected equal protection claim and the record absence of any
eminent domain exercise. On 06/23/2010, Defendant Honeywell fraudulently concealed
that none of the Government Defendants ever had any eminent domain power and
perpetrated fraud on the Court.
CONSPIRACY TO CONCEAL U.S. JURISDICTION & OBSTRUCT COURT ACCESS
334. Defendant Honeywell conspired with other Federal Defendants to conceal Federal
jurisdiction and obstruct Plaintiffs meaningful court access.
335. In particular, Defendant Honeywell conspired to conceal that of course, the Plaintiffs
rightfully prosecuted 1st, 14
th, 4
th, 7
thand 5
thAmendment violations by Federal Defendants in
Federal Court.
336. On or around 06/23/10, Defendant U.S. Judge Honeywell fabricated necessary state
procedures, Doc. # 213, p. 18:
They have not exhausted the necessary state procedures to address their disputeprior to filing in federal court. Therefore, the Court finds that Plaintiffs failed to statea claim upon which relief can be granted and dismisses their Seventh Amendmentclaim.
337. Defendant Honeywell knew and fraudulently concealed that Plaintiffs prosecution of
Federal Defendants forSeventh AmendmentViolations did of course not require necessary
state procedures. Brazenly and idiotically, Defendant Honeywell concocted necessary
state procedures on the record. Said reckless fabrications were outside Honeywells scope
ofimmunity and officialcapacity.
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DELIBERATE DEPRIVATIONS OF COURT ACCESS UNDER FALSE PRETENSES
338. Without any meritorious defense or claim, and under facially idiotic pretenses of
frivolity and vexatiousness, Defendant Honeywell deliberately deprived the Plaintiffs of
court access.
CONCEALMENT OF FUNDAMENTAL RIGHT TO OWN PROPERTY AND
CONSPIRACY TO CONCEAL THAT PROPERTY RIGHTS ARE FUNDAMENTAL
339. Defendant Honeywell conspired to fraudulently conceal that property rights are most
fundamental rights. On or around 06/23/2010, Defendant Honeywell conspired to brazenly
and irrationally concoct, Doc. # 213, p. 20:
Property rights would not be fundamental rights since they are based on state law.Id. Here, Plaintiffs claim that they have been denied their alleged property rights inLot 15A. These property rights are defined by state law. Therefore, the Court findsthat Plaintiffs failed to state a claim upon which relief can be granted and dismissestheir Substantive Due Process Claim.
340. No halfway intelligent and non-corrupt judge in Defendant Honeywells shoes could
havepossibly denied that property rights and the right to own property are most fundamental
rights. Honeywells above assertion was recklessly false and for unlawful and criminal
purposes of extorting property and fees and illegally bypassing due process and equal
protection of the law.
FRAUDULENT CONCEALMENT OF PLAINTIFFS PREVIOUS STATE ACTION
341. Defendant Honeywell fraudulently concealed Plaintiffs State action, Case No. 2006-CA-
003185 (Lee County Circuit Court), BUSSE v. STATE OF FLORIDA, Doc. # 213, p. 15:
Although they have been previously told by the Eleventh Circuit that they mustproceed in state court prior to bringing suit in federal court for several of their claims,Plaintiffs refuse to do so and continue to re-file their complaints with additionalDefendants and claims all surrounding the same property dispute.
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342. Defendant Honeywell conspired with other Officials such as, e.g., Defendants Steele and
Polster Chappell to conceal Plaintiffs 2006 State action of record, 2006-CA-003185.
Defendant Honeywell knew and concealed that Defendants Steele and Chappell had removed
Plaintiffs record 2006 State action to Federal Court. See 2:2008-cv-00899.
343. Defendant Honeywell knew and concealed Plaintiffs fundamental entitlement to sue
Defendant U.S. Agents in Federal Court for any and all claims.
06/23/2010 SLANDER OF RECORD REAL PROPERTY TITLE, DOC. # 213
344. On or around 06/23/2010, Defendant Honeywell unintelligently slandered Plaintiffs
record marketable title to riparian Lot 15A, Cayo Costa, Doc. # 213, 2:2009-cv-00791:
In a resolution adopted in December 1969 by the Board of Commissioners of LeeCounty, Florida, Lot 15A, among other property, was claimed as public land(Resolution 569/875") (Dkt 5, Ex. 3, p. 9). See Prescott, et al., v. State of Florida, etal., 343 Fed. Appx. 395, 396-97 (11th Cir. Apr. 21, 2009);Busse, et al. v. Lee County,Florida, et al., 317 Fed. Appx. 968, 970 (11
th Cir. Mar 5, 2009).
07/14/2010 FABRICATION OF WRIT OF EXECUTION
345. On or around 07/14/2010, Defendant Honeywell irrationally fabricated a writ of
execution, Doc. # 48, p. 1, 2:2010-cv-00089:
In the motion, Plaintiffs appear to seek a release of the writ of execution andattachment of a lien to property issued inBusse v. Lee County, Florida, et al., Case No. 2:07-CV-228-FtM-29SPC. That case was before Judge John Steele andMagistrate Judge Sheri Chappell.
346. Defendant Honeywell knew and concealed the record lack of any writ of execution
mandated July 2009 judgment, and of any Rule 38 motion by Def. land parcel Forger
Wilkinson. See Case No. 2:2007-cv-00228; see Case Docket as certified on 07/16/2010 by
Def. Clerk D. Nipper.
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347. Defendant Honeywell knew and concealed that the record 03/05/2009 judgment and
paid amount of $24.30 issued as mandate on 06/11/2009, Case No. 2:2007-cv-00228,
had ruled out any possibility of a writ of execution.
348. Because of her irrational contradictions on record, Defendant Honeywells orders were
facially arbitrary, capricious, incomprehensible, and idiotic:
349. In particular, no rational, competent, and honest judge in Defendant Honeywells shoes
could havepossibly reconciled a fake writ of execution with a fake claim.
350. Defendant Honeywell knew and concealed that in the hypothetical event of any
involuntary title transferto Government, no writ of execution could havepossibly existed.
351. Defendant Honeywell knew and concealed that in the hypothetical event of a writ of
execution, there could not havepossibly been any involuntary title transferto Lee County,
Florida. For bribes, Def. Whore Honeywell conspired to extort Plaintiffs property under
fraudulent pretenses of a non-existent Rule 38 motion, fake judgment, and fake writ.
TRESPASS ONTO PRIMA FACIE PRIVATE CAYO COSTA SUBDIVISION
352. Defendant Honeywells unlawful and criminal acts of record, reckless orders, Case ##
2:2009-cv-00791; and 2:2010-cv-00089, slander of title, fraudulent pretenses and/or
fabrications of a non-existent mandatedjudgment, writ of execution, lien proximately
caused unlawful and criminal trespass onto Plaintiffs private street and up lands on the Gulf
of Mexico in the private undedicated residential Cayo Costa Subdivision.
353. Defendant Honeywell knew and fraudulently concealed that the public had no
Subdivision access, because as a matter of law, the public had no right to use any of the
prima facie private street and alley easements as legally conveyed in reference to the 1912
Plat of Survey in PB 3 PG 25.
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ILLEGAL FIRES AND ARSON
354. Defendant Honeywells reckless orders, Case ## 2:2009-cv-00791, and 2:2010-cv-00089,
slander of title, fraudulent pretenses and/or fabrications of a non-existent mandated
judgment, writ of execution, lien have been inducing the public to start unlawful fires
and perpetrate arson on private Cayo Costa Subdivision property, PB 3 PG 25 (1912).
CONSPIRACY TO COVER UP FOR GOVERNMENT CROOKS
355. Defendant Honeywell fraudulently concealed and conspired to conceal the record crimes
and illegal acts of, e.g., U.S. Defendants John E. Steele, Sheri Polster Chappell, Richard A.
Lazzara, Mark Allan Pizzo, and to cover up for said Government Crooks.
RECORD THREATS AND FABRICATIONS OF VIOLATION OF ORDER
356. On or around 07/14/20, Defendant Honeywell again threatened, intimidated, and
coerced the Plaintiffs to refrain from prosecuting Defendant Honeywell, 2:10-cv-00089, Doc.
# 49, p. 2:
Plaintiff Busse has directly violated an orderof this Court.
357. Defendant Government Whore Honeywell has been a named party Defendant, because
she, e.g., accepted Defendants bribes, fixed Plaintiffs Cases under false pretenses of a
regulation, fabricated a writ of execution, perverted the Florida and Federal
Constitutional guarantees of the most fundamental rights to own property and exclude
Governments, redress Government grievances, be free of Government corruption,
oppression, unlawful seizure of property, et al. The Plaintiff corruption victims sued Def.
Honeywell in her individual private capacity outside any immunity, because Def.
Honeywell maliciously extended, e.g., record Government extortion, corruption, and crimes
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and unlawful acts. See, e.g., Case No. 2:2009-cv-00791, Doc. # 213, 236; Case No. 2:2010-
cv-00089, Doc. ## 48, 49, 50.
358. Under color of office, Defendant Honeywell falsified and/or caused other persons to
falsify official record and documents. See 838.022, Fla. Stat.
RECORD EXTORTION OF FEES AND PROPERTY
359. For unlawful and criminal purposes of extorting fees and Plaintiffs record property,
Defendant Honeywell fabricated a writ of execution.
FRAUDULENT CONCEALMENT OF RECORD 06/11/2009 MANDATE
360. Defendant Honeywell knew and concealed that a facially fraudulent 03/05/2009
judgment issued as mandate on June 11, 2009 and was received by the U.S. District
Court on 06/15/2009. See Doc. # 365; Case No. 2:2007-cv-00228.
FRAUDULENT CONCEALMENT OF CLOSURE OF CASE 08-17130-BB ON 06/11/2009
361. Defendant Honeywell knew and concealed that the U.S. Court of Appeals for the 11th
Circuit had closed Case No. 2008-13170-BB on 06/11/2009.
FRAUDULENT CONCEALMENT OF $24.30 MANDATE
362. Defendant Honeywell knew and concealed that the U.S. Court of Appeals for the 11th
Circuit had allowed the amount of $24.30 issued as mandate on June 11, 2009
363. Defendant Honeywell knew and concealed that the amount of $24.30 was not
outstanding.
364. Defendant Honeywell knew and concealed that no writ of execution could have
possibly existed on the record.
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FRAUDULENT CONCEALMENT OF NON-EXISTENCE OF RULE 38 MOTION
365. Defendant Honeywell knew and concealed that Defendant crooked Official Kenneth M.
Wilkinson had never filed any Rule 38 motion.
FRAUDULENT CONCEALMENT OF RECORD COERCION
366. Defendant Honeywell fraudulently concealed that Defendant K. M. Wilkinson expressly
coerced the Plaintiff corruption victims to refrain from prosecution on the record. See
Wilkinsons Rule 27-4 motion.
COERCION
367. On the record, Defendant Honeywell coerced the Plaintiffs to refrain from prosecution
under color ofauthority and office.
368. Without any authority orjustification, Defendant Honeywell threatened, intimidated,
harassed, and punished the Plaintiffs on the record, including the obstruction of court
access.
FRAUDULENT CONCEALMENT OF NON-EXISTENT LAND PARCELS
369. Defendant Honeywell knew and concealed that Defendant ForgerK. M. Wilkinson had
unlawfully and criminally forged land parcels 12-44-20-01-00000.00A0 and 07-44-21-
01-00001.0000. Defendant Honeywell knew and fraudulently concealed that said forged
parcels did not appear on the 1912 Cayo Costa Subdivision Plat of Survey in Lee
County Plat Book 3 Page 25.
370. Defendant Honeywell knew and concealed that said non-existent and forged land
parcels had never been legally described,platted, and/orconveyedin reference to said Plat
of Survey, PB 3 PG 25 (1912) and had neverexisted.
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BRIBERY AND CORRUPTION
371. In exchange for Defendants bribes, Defendant Honeywell concealed said evident record
forgeries and covered up for Defendant K. M. Wilkinson.
372. Defendant Honeywell accepted Defendants bribes and enforced the culture and policy of
corruption in her office even though Honeywell knew that the prima facie fake writ of
execution, lien, judgment, and land parcels had never existed and could not have
possibly existed.
DELIBERATE DEPRIVATIONS & FRAUD ON THE COURT
373. With wanton disregard for Plaintiffs fundamental rights to, e.g.
a. Be free of Government racketeering, corruption, extortion, coercion, and threats;
b. Be free of unlawful seizure, bribery, and retaliation;
c. Redress Government grievances without retaliation, coercion, extortion, and threats;
d. Have meaningful and free court access;
e. Have due process and equal protection of the law;
f. Own property;
g. Exclude Defendant Governments from Plaintiffs record property.
Defendant Honeywell perpetrated fraud on the Court and deliberately deprived the
Plaintiffs of theirexpress fundamental rights under the Federal and Florida Constitutions.
DEF. HONEYWELLS PROSECUTION UNDER CIVIL RICO
374. The Civil RICO statute, 18 U.S.C. 1964, 18 U.S.C. 1961-1968, expressly
authorized civil remedies. Defendant Racketeer Honeywell perpetrated record RICO
predicate acts such as, e.g., extortion, obstruction of justice, and retaliation.
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375. Defendant Honeywell knew that Defendant K. M. Wilkinsons motion, Rule 27-4,
Fed.R.App.Proc., Doc. # 386-2, was for prima facie illegal and criminal purposes of
extortingmoney and property, obstructing justice, retaliating, and racketeering:
In order to discourage the Appellant [Dr. Jorg Busse] from engaging in the same practices [of having conclusively proven and exposed Government extortion,racketeering, and corruption] in this Court, the Appellee [Def. Racketeer KennethM. Wilkinson, Lee County Property Appraisers Office] would respectfully requestthat this Court require the Appellant to pay a monetary penalty into the Court forfiling his frivolous motion to strike. Id., p. 2.
Plaintiff Appellant, Dr. Jorg Busse, was entitled to defend against recorded extortion,
racketeering, corruption, and fraud.
INJURY TO PLAINTIFFS CAYO COSTA PROPERTY AND BUSINESS
376. Defendant Crooked Honeywell injured the Plaintiff record property and business owners
by reasons of publicly recorded violations of Section 1962. See Section 1964(C). Plaintiffs
are holding legal and beneficial interests in their Cayo Costa business and property, riparian
Lot 15A on the Gulf of Mexico, Parcel # 12-44-20-01-00015.015A. See Section 1961(3).
Plaintiffs demand recovery for both tangible and intangible property losses, business
interruptions, and other losses as a direct and proximate result of Defendant Honeywells
extortion, racketeering, and obstruction of justice.
18 U.S.C. 1962 VIOLATIONS
377. Pursuant to Section 1964(C), Plaintiffs suffered damages by reason of Defendant
Honeywells Section 1962 violations, which proximately and directly resulted from the
publicly recorded commissions of the predicate acts such as, e.g., extortion, retaliation,
fraud, fraud on the State and Federal Courts, fraudulent concealment of facially forged land
parcels 12-44-20-01-00000.00A0 and 07-44-21-01-00001.0000 under color of a fake
writ of execution, fake judgment, fake debt, fake $5,048.60 debt, fake ripeness
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requirements, et al. See Case No. 2:2007-cv-00228, Doc. ## 434, 432, 424, 422, 386, 338,
288, 282, 360, 87, 25, 5.
CONSPIRACY TO CORRUPTLY GAIN CONTROL OF PLAINTIFFS PROPERTY
378. Defendant Honeywell acquired control and conspired with other Officials to acquire
control of Plaintiffs Lee County property and business through, e.g., organized crime such
as, e.g.:
a. Exercising various forms ofextortion;
b. Acquiring interest in Plaintiffs property in satisfaction of illegally procured debt such
as, e.g., $5,048.60;
c. Charging & collecting Government fees and forfictitious frivolity with usurious rates;
d. Profiteering from extra-judicialcrimes and bribes.
FOR BRIBES DEFENDANT FRAUDULENTLY CONCEALED BINDING PRECEDENT
379. In exchange forbribes, Defendant Racketeer Honeywell concealed and conspired with
other Officials and U.S. Circuit & District Judges to conceal binding precedent:
WEST PENINSULAR TITLE CO. v. PALM BEACH COUNTY, 41 F.3d 1490
(11th Cir.1995); Murrell v. United States, 269 F.2d 458 (5th Cir.1959)
DEFENDANT HONEYWELLS SECTION 1962(B) LIABILITY
380. Under color of prima facie falsified writ of execution, falsified judgment, fake
$5,048.60 debt, falsified law, legislative act, regulation, resolution 569/875,
O.R. 569/875, falsified land parcels, Defendant Honeywell has been collecting an
unlawful debt to acquire and maintain an illegal interest in and control of the prima facie
illicit park enterprise in the private, undedicated, residential Cayo Costa Subdivision
as platted in 1912, PB 3 PG 25. Plaintiffs injuries flowed directly from Defendant
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Honeywells and other Officials maintenance and acquisition of control of the park,
entertainment, and recreation enterprise, and acquisition and/or maintenance of control of
falsified land parcels 12-44-20-01-00000.00A0 and 07-44-21-01-00001.0000 with an
area of Hundreds of Acres along the Gulf of Mexico and Charlotte Harbor, PB 3 PG 25.
381. Section 1962(B) provides that:
It shall be unlawful for any person through a pattern of racketeering activity orthroughcollection of an unlawful debt to acquire or maintain, directly or indirectly,any interest in or control of any enterprise which is engaged in, or the activities ofwhich affect, interstate or foreign commerce.
DEFENDANT HONEYWELLS SECTION 1962(C) LIABILITY & ASSOCIATION
382. Under color of prima facie falsified writ of execution, falsified judgment, fake
$5,048.60 debt, falsified law, legislative act, regulation, resolution 569/875,
O.R. 569/875, falsified land parcels, Defendant Honeywell has been collecting an
unlawful debt and participated in the conduct and affairs of said Government enterprise.
Plaintiffs injuries flowed directly from Defendant Honeywells and other Officials
participation in said recordGovernment land parcel extortion and fraud scheme, ##
12-44-20-01-00000.00A0 and 07-44-21-01-00001.0000, and the participation in
Government fraud and extortion schemes of frivolity and vexatiousness.
383. Section 1962(c) provides that:
It shall be unlawful for any person employed by orassociated with any enterpriseengaged in, or the activities of which affect, interstate or foreign commerce, toconduct or participate, directly or indirectly, in the conduct of such enterprise's affairsthrough a pattern of racketeering activity orcollection of unlawful debt.
384. The Plaintiffs proved
1. The existence of Defendant(s) entertainment and recreational enterprise affectinginterstate commerce;2. That the Defendants were associated with the State Park and Recreationenterprise;
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3. That Defendant participated, either directly or indirectly, in the conduct or theaffairs of said entertainment enterprise; and4. That Defendants participated through a pattern of racketeering activity, whichincluded the allegation of at least two racketeering acts such as, e.g., extortion,bribery, obstruction of justice, and retaliation.
385. As a Judge presiding over Defendants prima facie fraudulent defenses, claims,
falsifications, and forgeries, Defendant Honeywell had a very meaningful connection
between the illegal enterprise and the racketeering and extortion of land, money, and fees
for the enterprise under color of, e.g., office and authority.
Defendant Honeywell extorted and concealed, and conspired to extort and conceal, that he
procedure on execution did not accord with the procedure of the State of Florida. See
Fed.R.Civ.P. 69. Defendant knew that Florida procedure required a recorded and certified
judgment, which here had neverexisted. The Court never had any authority to award
$5,048.60, and the judgment issued as mandate on 06/11/2009 in the amount of$24.30 had
been paid. The prima facie fraudulent affidavit by Defendant Racketeer JACK N.
PETERSON fraudulently pretended a 07/29/2009 judgment, Doc. # 432-2, Case No.
2:2007-cv-00228, which all Defendants knew, concealed, and conspired to conceal had
neverexisted. See also Ch. 55, 56, Florida Statutes.
DEFENDANT GERALD BARD TJOFLAT
RECORD LACK OF IMMUNITY
386. The Plaintiff public corruption victims are suing Defendant corrupt Gerald Bard Tjoflat
(Tjoflat) in his private individual capacity and official capacity as very old U.S. Circuit
Judge. Defendant Tjoflats unlawful and criminal acts on record were outside any immunity
and officialcapacity.