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UNITED STATES DISTRICT COURTMIDDLE DISTRICT OF FLORIDA

FORT MYERS DIVISION

JENNIFER FRANKLIN PRESCOTT, DR. JORG BUSSE, Plaintiffs,

versus Case # 2:09-cv-

GERALD B. TJOFLAT, UNITED STATES OF AMERICA, JOEL F. DUBINA,STANLEY F. BIRCH, JR, ED CARNES, ROSEMARY BARKETT, J. L.EDMONDSON, SUSAN H. BLACK, STANLEY MARCUS, R. L. ANDERSON,WILLIAM H. PRYOR, RICHARD A. LAZZARA, JOHN E. STEELE, MARK A.

PIZZO, S. POLSTER CHAPPELL, UNITED STATES DEPT. OF JUSTICE, JACK N. PETERSON, S. L. JOHNSON, R. K. RUSSELL, CHAD LACH, C. B.STEVENS, CHARLIE GREEN, STEVEN CARTA, MENELAOS PAPALAS,TOBY PRINCE BRIGHAM, WILLIAM MOORE, BRIGHAM MOORE, STEVENCARTA [HENDERSON & CARTA], RICK JESSUP, J. RUSS DEDRICK, K.ANDERSON, S. FLYNN, BRIAN ALBRITTON, LESLIE KING, S. LOESCH, J. P.GERSTENLAUER, A. TUCK FARRINGTON, T. K. KAHN, KAREN FORSYTH,D. M. COLLINS, D. D. STILWELL, MIKE SCOTT, et al.,

Defendants.

COMPLAINT AND DEMAND FOR JURY TRIAL

NOTICE OF [EXTRA-] JUDICIAL CRIMES UNDER FALSE PRETENSES

OF FICTITIOUSLOT 00A0

OF FRAUDULENTBLOCK 1

OF UN-PLATTED, UNCERTAIN UNIDENTIFIED/UNDESIGNATED AREAS

OFEXCECUTIONOF PRIMA FACIE DEFECTIVE AND UNSIGNED O.R. 569/875

THAT SCAM O.R. 569/875 WAS A LEGISLATIVE ACT

THAT FORGERY O.R. 569/875 WAS ANAUTHORIZED,LEGITIMATECLAIM

THAT PLAINTIFFS WEREFRIVOLOUS

THAT PLAINTIFFS PERFECT TITLE/OWNERSHIP OF RECORD WASENCUMBERED

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THAT PLAINTIFF-APPELLANTS TITLE TO LOT 15A WAS NOT FREE AND CLEAR

THAT PLAINTIFFS DID NOT STATE HIGHLY RECOGNIZABLE/ADMITTED CAUSES

THAT PLAINTIFFS RIPEEMINENT DOMAINISSUES WERENOT RIPE

[E.G.: OBSTRUCTION OF JUSTICE;

EMINENT DOMAINEXTORTION AND FRAUD;

JUDICIAL CORRUPTION, CASE-FIXING, AND BRIBERY;

GOVERNMENTAL ABUSE AND OPPRESSION;

FALSE PRETENSES THAT SCAM O.R. 569/875 WAS A LEGISLATIVE ACT;

DELIBERATE DEPRIVATIONS;

DISPARATE TREATMENT;

CIVIL RIGHTS VIOLATIONS

ADOPTIONS OF SELF-AUTHENTICATING PUBLIC RECORD EVIDENCE

IN SUPPORT OF JUDICIAL CORRUPTION, CASE-FIXING, AND BRIBERY

03/05/2009 AND 04/21/2009 11TH

CIRCUIT SHAM OPINIONS:

PUBLIC RECORD EVIDENCE OF CONSPIRACY TO DELIBERATELY DEPRIVE,

DEFRAUD, AND OBSTRUCT JUSTICE UNDER COLOR OF SCAM O.R. 569/875

[ADOPTION BY REFERENCE IN THIS COMPLAINT]

1. Hereby, the Plaintiffs [-Appellants] adopt by reference any and all Opinions and Orders by

the U.S. Court of Appeals for the 11th

Circuit in Atlanta, GA, in this Complaint. With

particularity, the Plaintiffs adopt the 11th Circuits fraudulent March 5, 2009, and April 21,

2009, Opinions, in which said Circuit conspired to

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a. Pervert Lee County scam O.R. 569/875 into a legislative act absent any evidence

whatsoever [e.g., execution,seal, witnesses, legal description, ascertainable boundaries,

legislator, legislative power,purpose, history];

b. Falsely pretend that Appellant Dr. Busses [unconstitutional temporary

] takings

claim was not ripe;

c. Conceal that said fraudulent claim of uncertain, un-platted, and fictitious

unidentified/undesignated areas could not have possibly effected any permanent

taking;

d. Conceal that Lee County never had any legitimate claim

e. Conceal that said scam O.R. 569/875 could not have possibly ever encumbered

Plaintiffs paramount title to theirprima facie riparian Gulf-front Lot 15A [PID 12-

44-20-01-00015.015A];

f. Conceal that Lee County, Florida, could not havepossibly enforced null and void scam

O.R. 569/875, which was prima facie void for, e.g., uncertainty, lack of execution,

legislative intent, authority, etc.;

g. Falsely pretend that Appellants had not pursued available state remedies;

h. Conceal Plaintiff-Appellants State and State Appellate actions in exchange forbribes;

i. Obstruct justice and Federal adjudication of Appellant(s) multiple independent ripe

Federal claims and eminent domain extortion and fraud issues under color of Lee

County prima facie scam O.R. 569/875;

j. Falsely pretend that Lee County can exercise eminent domain over any land under

false pretenses that said sham claim ofuncertain lands was a legislative act. See

03/05/2009 Opinion, p. 9;

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k. Abuse, oppress, and mis-treat Plaintiff [-Appellants] disparately from, e.g., similarly-

situated owner, Alice M. S. Robinson, ofsimilarriparian Gulf-front lots in the private

undedicated residential Cayo Costa Subdivision. See Lee County Blue Sheet 980206 and

O.R. 2967/1084-1090;

l. Abuse and mis-treat disparately from, e.g., similarly-situated owner ofsimilar and/or

identical riparian Gulf-front lands, A. C. Roesch.

2. The corrupt 11th Circuit concealed that

a. A "bill" is a proposition reduced to writing, submitted to the consideration of the

legislature, which, when it has received the endorsement or support of a majority vote of

the members present of each House and yea and nay vote taken upon the final passage

entered upon the journals of each House it is said to have "passed." The use of the word

"bill" in Section 28 of Article III of the Constitution provided that every "bill" that may

have passed the legislature shall, beforebecoming a law, be presented to the Governor;

and in the proviso to Section 17, Article III providing that all "bills" so passedshall be

signedby the presiding officers of the respective Houses.

b. Eminent domain extortion-scheme O.R. 569/875 was not signed by the two presiding

officers nor the clerk of each House, nor presented to the Governor by the legislature.

Thus, it failed to comply with the mandatory requirements of the Constitution.

Defendants Steele, Lazzara, Polster-Chappell, Pizzo conspired to fabricate a legislative

act, which was factually and legally impossible.

c. Absent any legislative record, there was no legislative purpose and intention. Eminent

domainscam O.R. 569/875 never became any official record and was never approved by

the Governor or passed over his veto;

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d. Under Floridas Constitution, the Secretary of State is the legal custodian of all records of

official acts of the legislative and executive departments.

e. The legislative records in said Office evidenced the fraudperpetrated by, and upon, the

11th Circuit. Contrary to the 11th Circuits concoctions, no legislative actcould be found

to exist. Therefore, all Federal Court Orders in these related/associated actions are

automatically stayed and/or must be vacated.

11TH

CIRCUITS SHAM ORDERS:

AWARD OF COST AND DAMAGESTO DEFRAUD AND EXTORT

PUBLIC RECORD EVIDENCE OF CONSPIRACY TO DELIBERATELY DEPRIVE,

DEFRAUD, AND OBSTRUCT JUSTICE UNDER COLOR OF SCAM O.R. 569/875


3. Fraudulently, the 11th

Circuit awarded cost and damages to Defendant corrupt K. M.

Wilkinson, who fabricated an un-platted lot 00A0, and block 1.

4. Objectively partially, the 11th Circuit suspended the rules in order to obstruct justice.

5. In order to blockAppellants court access and extort, the Appellants fixed Appellants cases

and rejected their pleadings.

6. The Plaintiffs adopt by reference the related sham 11th Circuit orders in this Complaint and

Notice of Judicial Corruption and Bribery.

UNEXECUTED VOID CLAIM OF UNPLATTED, UNCERTAIN AREAS:PUBLIC RECORD EVIDENCE OF PRIMA FACIE LEE COUNTY SCAM O.R. 569/875


7. Hereby, the Plaintiffs adopt by reference the self-authenticating prima facie public record

evidence of Lee Countys null and void scam O.R. 569/875, which fraudulently claimed

uncertainun-platted undesignated/unidentified areas.

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8. The judicial Defendants conspired to conceal that no fictitious undesignated/unidentified

areas, lot 00A0, and block 1 appearedon the 1912 Plat of Survey of the undedicated

Cayo Costa Subdivision referenced in counterfeit O.R. 569/875. See Plat Book 3, p. 25.

9. All platted areas on said referenced 1912 Plat were fully identified as streets, alleys,

lots, and/or blocks]. The sham claim/defense of undesignated/unidentified areas

was prima faciefrivolous and unsupported by the public record evidence on file.

05/05/2008 FRAUDULENT OPINION AND ORDER [DOC. # 338; FIRST CASE]:

PUBLIC RECORD EVIDENCE OF PRIMA FACIE FRAUDULENT OPINION AND

ORDER BY DEFENDANT CORRUPT JUDGE JOHN E. STEELE


10. Hereby, the Plaintiffs adopt by reference the self-authenticating prima facie public record

evidence of said 05/05/2008 Opinion and Order, in which Defendant John E. Steele falsely

pretended that Lee Countys null and void scam O.R. 569/875, which fraudulently

claimed uncertainun-platted undesignated/unidentified areas, was a legislative act.

See Doc. # 338, p. 12.

11. In their Complaints, Plaintiffs have charged fraud and extortion. Plaintiffs proved that the

Defendant [-Appellee] Governmental Officials, Judges, and Clerks of the legislature

conspired to impose a fraud. The 11th

Circuits concoction of a legislativeact was an act

ofpoliticaldepravity. On its face, sham claim O.R. 569/875 was not any record of an

executive orlegislative act, because the officers of the legislature did not sign it during the

session of the legislature nor was it presented to the Governor by that body. Indisputably,

there was no signing of said fake claim during any session and no presentation to the

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Governor by the legislature. Therefore, there could be no record in the legislative journals

upon said illegal subject. Therefore, forged claim O.R. 569/875 could not have possibly

become a record of either an executive orlegislative act. Indisputably, O.R. 569/875 was a

spurious, illegitimate, voidcounterfeit thing ofno virtuewhatsoever, which the corrupt

11th

Circuit perverted into a legislative act in exchange for Appellees bribes.

12. The 11th Circuit conspired not to review de novo but rubber-stamp Steeles lies of a

legislative act. In his fraudulent and deprivatory May 5, 2008, Opinion and Order

[Document # 338; Case # 2:07-cv-228-FtM-[29]JES-SPC, Defendant corrupt U.S. District

Judge John Edwin Steele falsely pretended that

a. Lee County

i. had adoptedsaid scam O.R. 569/875;

ii. had executedandsignedsaid fraudulent claim O.R. 569/875 ofuncertain, un-

platted, and un-described undesignated/unidentified areas;

b. Disallowed the Plaintiff(s) to assert otherwise [assert, e.g., the invalidity, illegality,

and nullity of said bogus claim O.R. 569/875] and obstructed justice in exchange for

Appellees bribes;

c. Falsely pretended that a suit to quiet title in state court [see Doc. # 338; p. 9] was the

available relief even though Defendant Steele knew that Lee County never had any

authorizedclaim and had removed its sham claim pursuant to Blue Sheet 980206

and O.R. 2967/1084-1090;

d. Concealed that there never was any need to quiet title, because said sham claim O.R.

569/875 was null and void and neverencumberedPlaintiffs prima facie perfect,free

and clear title to said riparianGulf-front Lot 15A.

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13. The Defendant-Appellees conspired to

a. Cover up John Edwin Steeles concoction that said prima faciescam O.R. 569/875 was

a legislative act;

b. Pervert Plaintiff-Appellants actions in the Federal and State Courts into a Cayo Costa

Gate under false pretenses of, e.g., a fictitious legislative act; frivolity,

vexatiousness;

c. Conceal that said prima faciedefective single piece ofsham paper O.R. 569/875 could

not have possibly been a legislative act and/or resolution and/or effected any

permanent taking [with orwithout just compensation], because said scam O.R. 569/875

was prima facie null and void absent, e.g., any legislative execution, history, legislator,

ascertainable boundaries, and any platted legal description;

d. Obstruct justice and Plaintiffs court access to redress their grievances.

PLAINTIFF DR. BUSSES THIRD AMENDED COMPLAINT [DOC. ## 288; 282]:

PUBLIC RECORD EVIDENCE OF PRIMA FACIE FEDERAL JURISDICTION


14. The judicial Defendants conspired to

a. Conceal that in his Third Amended Complaint, Plaintiff Busse had again asserted and

indisputably proven the prima facie invalidity and nullity of said eminent domain

extortion-scheme O.R. 569/875;

b. Conceal that the fictitious resolution was neverpassedby the legislature, and no yea

and nay vote was entered on the legislative journals of each House;

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c. Conceal that the subject-matter of said scam, which was improperly recorded as O.R.

569/875, was unlawful and outside any Lee County legislative power;

d. Conceal that indisputably, said scam was in conflict with the expressprohibitions of

the Constitutions of the United States and State of Florida.

15. For bribes, the 11th

Circuit judicial Defendants conspired to conceal that scam O.R.

569/875 was an invalid instrument and null and void. Said forgery was not executed as

required under the Constitution(s). Lee County never had any legitimate claim, and it never

affirmatively claimed uncertain lands. See Doc. ## 282; 288].

LEE COUNTY BLUE SHEET 980206 AND O.R. 2967/1084-1090:

PUBLIC RECORD EVIDENCE OF REMOVAL OF PRIMA FACIE SCAM O.R. 569/875


16. Said adopted public records indisputably evidenced the removal and elimination of any

cloud and/ornull and void sham claim O.R. 569/875.

17. Said public records before the Federal Courts had indisputably evidenced Defendants

disparate treatment, abuse, and oppression of the Plaintiff-Appellants as compared to, e.g.,

similarly-situated Alice M. S. Robinson and A. C. Roesch.

LEE COUNTY O.R. 1651/2488:

PUBLIC RECORD EVIDENCE OF FRAUD


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18. Adoption of O.R. 1651/2488 by referenc: Cayo Costa landowner Merrill R. Taggart

conveyed his interest in his accreted lands to Lee County, Florida, even though Lee County

had fraudulently claimed an interest in the accretions.

FOUR LEE COUNTY PLATS OF SURVEY OF CAYO COSTA SUBDIVISION:

INDISPUTABLE EVIDENCE OF PLAINTIFFS EQUAL VESTED RIPARIAN RIGHTS


19. The indisputable public record evidence of the four Plats of Survey of the Cayo Costa

Subdivision proved Defendants deliberate deprivations of Plaintiffs equal vested

riparian rights, equal civil, and other well-pleaded and well-established rights under the

14th

, 4th

, 1st, 5

th, and 7

thAmendments. Just like similarly-situated original owner and

Subdivider A. C. Roesch, the Plaintiffs [who are successors-in-perfect title] had the equal

vested riparian rights of A. C. Roesch, who on the public record received and subdivided

accretions onto the undedicated private Cayo Costa Subdivision. Plaintiffs said riparian

Gulf-front Lot 15A was the very product ofaccretions as indicated by the letter A in 15A.

20. The 11th Circuit concealed that

a. Plaintiffs were entitled to the equal riparian rights of A. C. Roesch;

b. Plaintiffs wereentitled to the equal riparian rights of Alice M. S. Robinson;

c. Plaintiffs were entitled to the equal riparian rights of Janet and John Lay. See John Lay

and Janet Lay v. State of Florida, on record.

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TRANSCRIPT OF CORRUPTED NOV. 2007 COURT HEARING [DEF. CHAPPELL]:

INDISPUTABLE EVIDENCE OF CONCEALMENT OF INVALIDITY OF LOT 00A0


21. Hereby, Plaintiffs adopt by reference the Nov. 7, 2007, Transcript of the corrupted and

fraudulent proceedings before Defendant Sheri Polster Chappell, who conspired to conceal

the primafacie invalidity ofun-platted and non-existent lot 00A0 and block 1.

22. In exchange for Appellees bribes, Polster Chappell conspired to sanction the Plaintiff Dr.

Busse in order to obstruct justice and blockPlaintiff(s) court access.

23. Polster Chappell was affiliated with both Defendant-Appellees Lee County and State of

Florida and refused to recuse herselfviolative of 28 U.S.C. 455.

TRANSCRIPT OF PLAINTIFFS FEB.29,2009, DEPOSITION OF JACK N. PETERSON:

INDISPUTABLE EVIDENCE OF PLAINTIFFS PERFECT TITLE, AND

CONCEALMENT OF INVALIDITY OF SHAM O.R. 569/875, LOT 00A0, BLOCK 1


24. During his 02/29/2008 Deposition, Defendant corrupt Jack N. Peterson stated under oath

that Plaintiff-Appellants are the indisputable owners ofriparianGulf-front Lot 15A. No

evidence whatsoever that could have possibly diminished Plaintiffs perfect title and fee

simple ownership of the platted designated street, accretions, and upland had ever existed.

The Federal Courts corrupted and obstructed inquiry and discovery, because they knew

that no such evidence had ever existed. Corruptly, they slandered the Plaintiffs asfrivolous

and vexatious in order to obstruct justice.

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25. While the Federal Courts falsely pretended lack of subject-matter-jurisdiction, they

simultaneously and improperly reached and perverted the merits in order to fix Plaintiffs

Cases forbribes. Said crimes are now under investigation.

26. Forbribes, the 11th Circuit unabashedlyperverted the construction of Plaintiff-Appellants

prima facie perfect conveyance/Warranty Deed and the applicable existing rules of

construction. The lackofintelligence and knowledge exhibited by said 11th Circuit Judges

on the public record has been shocking to the American people. Not only was the 11th

Circuits construction of the public record(s) corrupt and exceptionally unintelligent, but

said Defendant 11

th

Circuit Judges conspired to cover up theircase-fixing and bribery in

this Cayo Costa Gate conspiracy.

PLAINTIFFS APPELLATE BRIEFS:

INDISPUTABLE EVIDENCE OF FRAUD, EXTORTION, AND



27. In Plaintiff(s) 11TH Circuit Briefs, they identified with particularity who, when, where,

how, and whyperpetrated said fraud on said Federal Courts underfalse pretenses of, e.g., a

legislative act, lot 00A0, block 1,frivolity, vexatiousness, ripeness requirements, etc.

28. Like common criminals in robes, said judicial Defendants conspired to deliberately

deprive and defraud the Plaintiff-Appellants even though said Briefs had indisputably

evidenced the eminent domainfraud, extortion, and obstruction of justice.

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29. Said corrupt 11th Circuit Judges conspired to obstruct any de novoreview but to rubber-

stamp and cover-up the prima facie crimes and extra-judicialmisconduct by their fellow

Judges John Edwin Steele and Sheri Polster Chappell.

BINDING PRECEDENT IN PLAINTIFFS PETITIONS FOR RE-HEARINGEN BANC:

INDISPUTABLE EVIDENCE OF FRAUD, EXTORTION, AND



30. West Peninsular Title Co. v. Palm Beach County, 41 F.3d 1490(11

th

Cir. 1995);

Caples v. Taliaferro, 197 So 861(Fla. 1940);

31.

Murrell v. United States, 269 F.2d 458(5th Cir.1959);

See also 16.33 Acres;

32. Anthony v. Franklin County, 799 F.2d 681, 684(11th Cir.1986);

33.

Corn v. City of Lauderdale Lakes, 816 F.2d 1514,1517(11th Cir.1987);

[Dade County v. Nat. Bulk Carriers,Inc., 450 So. 2d 213,216(Fla. 1984)];

34. First English Evang. Lutheran Church v. Los Angeles County, 482 U.S. 304, 107 S.Ct.

2378, 96 L.Ed.2d 250(1987);

35.

Mineral Range R. Co. v. Detroit & L. S. Copper Co. Miss. & R. River Boom Co. v.

Patterson, 98 U. S. 403, 25 L.ed. 206;

36. Kaiser Aetna v. U.S., 444 U.S. 164(1979).

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U.S.411,414, 46S.Ct.144-45,70L.Ed.339; Cobbledick v. U.S., 309 U.S. 323-28, 60S.Ct. 540-

42, 84L.Ed. 783.

DOC. # 89-2:

INDISPUTABLE EVIDENCE OF DONNA M. COLLINS FRAUD, EXTORTION, AND



40. Hereby, Plaintiffs adopt by reference Doc. ## 89; 89-2; 89-1 in this Complaint. In her Feb.

22, 1999 Letter of Extortion, Defendant Donna Marie Collins extorted, exacted, and/or

compelled Cayo Costa landowners to relinquish their private property and to refrain from

pursuing the exclusive Federal and State remedy of invalidation and damages for the

unconstitutional temporary takings underscam O.R. 569/875.

JURISDICTION

41. The Plaintiffs are suing the Defendant Governmental Officials, Clerks, Judges, and other

Defendants in their private individual and official capacities. The Federal Courts have

jurisdiction over the well-proven allegations against said Federal agents, which are

supported by the public record evidence.

42. The eminent domain extortion and fraud issues and deliberate deprivations by State of

Florida Officials invoked Federal subject matter jurisdiction. Pursuant to the concessions of

the Defendant U.S. Attorney(s), who have been representing judicial Defendants, e.g., in the

Third Case, Federal jurisdiction has been patently clear.

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43. This Court hasjurisdiction under, e.g., 28 U.S.C. 1343; and 28 U.S.C. 1331; 42 U.S.C.

1983, 1985, 1988 [18 U.S.C. 241, 242] over Defendants well-proven deliberate

deprivations of Plaintiffs well-established Federal Statutory and Constitutionally-

guaranteed rights directly under, e.g., the 1st, 14th, 4th, 7th, and 5th Amendments. No ripeness

requirements ever existed. The Federal Courts concealed that any condemnation, inverse,

direct, or any other were factually and legally impossible. Prima facie unauthorized and

expressly unconstitutional scam O.R. 569/875 could not have possibly effected any

permanenttaking. The Defendants conspired to obstructjustice and the exclusive available

remedy of invalidation and damages for the expressly unconstitutional temporary

takings undereminent domainscam O.R. 569/875.

44. The Florida and Federal Constitutions expressly prohibited any permanent taking, except

for public use, and/or any resolution, legislative act claiming uncertain,

unidentified, and un-platted areas.

45. Under28 U.S.C. 455, the Plaintiffs were entitled to the absolutely mandatoryrecusal of

the judicial Defendants, who objectively partially presided over theirownprosecution.

46. The Defendants conspired to obstruct justice under 28 U.S.C 1503 and have no immunity

for theirextra-judicialcriminal acts underfalse pretenses that eminent domainscam O.R.

569/875 was a purported legislative act/passed/adopted resolution.

47. The 11th

Circuit conspired to fix and dismiss Appellants Cases and played God with the

indisputable self-authenticating facts on the record. The 11th Circuit conspired to

fabricate lack of ripeness/jurisdiction even though no ripeness requirements could have

possibly attached/existed. The 11th

Circuit concealed patently clearjurisdiction under, e.g.,

28 U.S.C. 1343; and 28 U.S.C. 1331; 42 U.S.C. 1983, 1985, 1988. Plaintiffs

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demandedre-hearings en banc by anotherimpartialcircuit, which does not accept bribes

in exchange forfixing Plaintiff-Appellants cases and fabricatingripeness requirements.

48. E.g., Defendant Federal agents crimes, and Plaintiffs eminent domain issues,

unconstitutional temporary takings and other independentripe claims directly under

the 1st

[obstruction of right to redress governmental grievances], 14th

[arbitrary,

capricious, pretextual due process and equal protection violations], 4th [seizure,

confiscation, and/or destruction of Plaintiffs property], 7th [right tojurytrial] Amendments

had patently clearlyinvokedFederaljurisdiction.

49. The 11

th

Circuit concealed that all of its fraudulent orders are automatically stayed and

vacated, because the Defendant 11th

Circuit Judges conspired to perpetrate a fraud on the

Court underfalse pretenses that counterfeit claim O.R. 569/875 was a legislative act.

CONCEALMENT OF PLAINTIFFS PERFECT PUBLIC RECORD OWNERSHIP:

INDISPUTABLY, PLAINTIFFS OWN PLATTED RIPARIAN GULF-FRONT LOT 15A

50. Indisputably and admittedly, the Plaintiffs are the exclusive record owners of riparian

Gulf-front Lot 15A [Lee County PID 12-44-20-01-00015.015A; A=ACCRETED] in the

undedicated private Cayo Costa Subdivision on Cayo Costa Island in Lee County, Florida.

51. Pursuant to the self-authenticating public record evidence on file, the Federal and State

Courts knew that Plaintiff-Appellants hold perfect exclusive legal title to said platted

upland, the platted designated 60 wide street adjoining their upland, and the accretions

onto said upland and/or adjoining street.

52. Lee County, Florida, never had any interestin Plaintiff-Appellants said riparian Gulf-front

Lot 15A. Lee County never held title to any and/orallof Plaintiffs said riparianGulf-front

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Lot 15A. Concededly, Lee County never held title to the uncertain undesignated areas

fraudulently claimed in Lee County extortion and fraud-scheme O.R. 569/875, which

Lee County had neverexecutedand/orsigned.

53. Since there was no such description [undesignated/unidentified areas], Lee Countys

claim was null and void for uncertainty and unlawful. No conveyance of any interestin

the fictitious, uncertain, and un-platted unidentified/undesignated areas was legally or

factually possible.

54. Lee County never had any interest in fictitious lot 00A0 [fraudulent PID 12-44-20-01-

00000.00A0], which did not appear on the Cayo Costa Subdivision Plat. Lee County never

had any interest in fake block 1 [fraudulent PID 07-44-21-01-00001.0000], which did

not appear on said Subdivision Plat.

55. Lee County never had any eminent domain authority or purpose to fraudulently claim un-

platted undesignated areas, which did not appear on the Cayo Costa Subdivision Plat.

56. Lee County extorted Plaintiff-Appellants private property underfalse pretenses that fake

claim ofuncertain and un-platted unidentified/undesignated areas was a resolution.

57. Lee County never had any validclaim and/or power to claim uncertain, un-platted, and

non-existent undesignated and/or unidentified areas.

58. Lee County never had any legitimate claim to any and/orallof said riparian Gulf-front

Lot 15A.

59. Lee County never identified any legitimate claim to either said riparian Gulf-front Lot

15A or the fraudulently claimed un-platted and uncertain undesignated areas.

60. Pursuant to the public record, the Plaintiffs are successors-in-title and interest to Alexander

C. Roesch, the Subdivider and original owner of said private Cayo Costa Subdivision.

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61. Pursuant to the Federal Land Patent root title in Lee County Deed Book C, p. 110, the

Defendant United States of America conveyed certain legally described lands to said A. C.

Roesch and his successors-in-title.

62. The Plaintiffs had the equalrights, and in particular, equal riparian rights, equal private

easement rights, and equal civil rights of said Alexander C. Roesch.

63. The 1912 Plat of Survey of the Cayo Costa Subdivision evidenced the absence of any Lee

County acceptance of any dedication and/or any reversionary interest.

64. Said 1912 Plat in Plat Book 3, p. 25 was the fourth offour Plats of Survey between 1910

and 1912 of said private residential Subdivision, which has been subject to accretions and

erosion. Indisputably and admittedly, said four publicly recorded Subdivision Plats

evidenced the vested riparian rights of A. C. Roesch and his successors-in-title, which

include the Plaintiffs.

65. The platted natural monuments and boundaries of said Cayo Costa Subdivision were the

Gulf of Mexico and Charlotte Harbor. Said A. C. Roesch and his successors-in-title

owned fee simple any and all areas and/or lands between said platted natural

boundaries of the Gulf of Mexico and Charlotte Harbor. Said platted natural

monuments superseded any distances, and/oracreage.

66. Indisputably and admittedly, all Cayo Costa easements have been private easements since

1912. The public had no access to said undedicated Subdivision.

67. Indisputably, said publicly recorded privateeasements are Appellants Constitutionally-

protected property. Indisputably, Appellants publicly recorded vested riparian rights are

their Constitutionally-protected property. Indisputably, Appellants publicly recorded

causes of action are theirConstitutionally-protected property.

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68. Indisputably, the Plaintiffs own fee simple the platted designated 60 wide street adjoining

Plaintiffs upland. See Caples v. Taliaferro, supra, and West Peninsular Title Co., supra.

69. Indisputably, the Plaintiff-Appellants have a Constitutionally-protected right to own their

property and exclude the government.

70. Indisputably, the Plaintiffs had a Constitutionally-protected right to be free from

governmental abuse, oppression, and crimes such as here, e.g., obstruction of justice,

deliberate deprivations, false pretenses, violations of due process and equal protection of

the law directly under the 14th

, 4th

, 5th

, 1st, and 7

thAmendments to the U.S. Constitution.

71. Indisputably, the Plaintiffs own fee simple the accretions onto the platted designated

adjoining street, which belongs to the Plain

tiffs pursuant to West Peninsular Title Co., supra,

and Caples v. Taliaferro, supra.

72. Defendant corrupt U.S. Circuit Judge J. L. Edmondson

had presided over West Peninsular

Title Co., supra.

73. The Appellants had proven and alerted the Courts to the prima facie invalidity and nullity

of Lee County eminent domainextortion-scheme O.R. 569/875.

74. In said prima facieunexecutedforgery O.R. 569/875, Lee County fraudulently claimed

undesignated areas, which did not appear on the 1912 Subdivision Plat. No

undesignated/unidentified areas appeared on the Subdivision Plat. Therefore, the corrupt

11th

Circuits concoction of a legislative act was unintelligible and unlawful.

CONCEALMENT OF PRIMA FACIE LACK OF ANY LEE COUNTY CLAIM

75. The Defendant corrupt Officials and Judges conspired to conceal the prima facie absence

of any legitimatecertain Lee County claim.

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76. The Defendants conspired to conceal that

a. No legal description of any undesignated/unidentified areas existed;

b. Absence of anysignatures and execution evidenced the prima facieabsence of any Lee

County intentto claim uncertain and un-platted lands;

c. Lee Countys sham claim was null and void for uncertainty and unlawful;

d. No conveyance of any interest in unidentified/undesignated areas was legally or

factually possible;

e. Lee County could have neverpossibly held any title to said un-described and non-

existent unidentified/undesignated areas by virtue of said unexecuted and forged

claim O.R. 569/875.

77. The judicial Defendants conspired to conceal that the fictitious description was such an

uncertainty appearing on the face of said scam O.R. 569/875 that no court, reading the

language of said prima facie unexecuted and unsealedforgery in the light of all facts and

circumstances referred to therein, could have possibly been able to derive therefrom any

legitimate claim. Absent any legislator, ascertainable boundaries, legal description,

legislative history, Lee County never had any intentto claim any certain lands. Had there

been any intent, Lee County would have been absolutely required to, e.g., execute,sign, and

sealits intendedclaim in the presence ofwitnesses. Only an unfit and corrupt judge could

have determined any intentby Lee County to claim any and/or all of Appellants riparian

Gulf-front Lot 15A. All of said riparian Gulf-front Lot 15A was unencumbered by said

forged and null and void claim O.R. 569/875. The Defendants conspired to conceal that

Appellants perfect title was free and clear of any cloud and/orfraudulent claim O.R.

569/875.

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78. Said case-fixing judges conspired to conceal that no legislatorhad everexecutedsaid un-

sealed, un-signed, and un-witnessedscam O.R. 569/875. Multiple errors and type-fonts of

varying sizes appeared on said prima facie forgery O.R. 569/875.

79. No intelligent and fit person and/or judge could possibly identify any undesignated or

unidentified areas.

80. By definition, and indisputably, unidentified/undesignated areas could not possibly be

identified for lack of any identity.

81. No particularpublic use was indicated in said sham claim O.R. 569/875. Therefore, any

evidence of any necessity was factually and legally impossible.

82. Lee Countys sham claim O.R. 569/875 of uncertain, un-platted, and non-existent

unidentified/undesignated areas was null and void ab initio. The purported fictitious

description was prima facie null and void for uncertainty. Nothing in said unexecuted

and unsealed forged claim indicated which area could possibly be claimed. Any

criminal could have drafted said prima facie forgery O.R. 569/875. No intelligent and

impartialcourt and/or person could havepossibly concluded that fake claim O.R. 569/875

was a legislative act. No legislatororlegislative history couldpossibly be identified.

83. The Defendant corrupt Officials conspired to conceal the patent ambiguity of sham

claim O.R. 569/875.

84. In 1998, Lee County itself had again eliminated and removed any claim and/or cloud

under said scam O.R. 569/875 pursuant to Lee County Blue Sheet 980206 and O.R.

2967/1084-1090.

85. Lee Countys said scam of a RESOLUTION PERTAINING TO PUBLIC LANDS IN

CAYO COSTA SUBDIVISION was a fraudulent subject matter, because all private lands

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in said Subdivision exclusively belonged fee simple to said A. C. Roesch and/or his

successors-in-title. Lee County had nopossessoryinterestunder said scam O.R. 569/875.

86. Said 11th

Circuit fabrications of a legislative act purportedly claiming unidentified

areas were extraordinarily unintelligent criminal acts by said Defendant corrupt

Officials.

DEFENDANT CORRUPT 11TH

CIRCUIT JUDGE GERALD BARD TJOFLAT

87. In exchange for Defendant-Appellees bribes, Defendant corrupt U.S. 11th

Circuit Judge

Gerald Bard Tjoflat falsely pretended that Plaintiff(s) unconstitutional temporary

takings and other several independent ripe claims were not ripe because he [Plaintiff-

Appellant Busse] had not pursued available state remedies See 11th

Circuit 03/05/2009

Opinion; Appeal # 08-13170; III. Conclusion. In his sham Opinion, Tjoflat perverted

the truth about Appellants State [Case # 2006-CA-003185] and State Appellate [Appeal #

2D08-5797] actions and pursuit of invalidation of said prima facie scam O.R. 569/875.

Tjoflat betrayed the publics and Appellants trust.

88. Defendant Tjoflat conspired to conceal Appellants pursuit of the exclusive remedy of

invalidation of said eminent domainextortion-scheme O.R. 569/875.

89. Defendant Tjoflat conspired to conceal that Lee County fraud-scheme O.R. 569/875 could

not havepossibly effected anypermanenttaking orcondemnation, direct, orinverse.

90. Defendant Tjoflat conspired to [unintelligently] invoke inverse condemnation, which was

factually and legally impossible. Government cannot claim uncertain and un-platted

unidentified areas, whether with or without just compensation.

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91. Defendant Tjoflat concealed that Lee County could not illegally bypass that which both the

Florida and Federal Constitutions expressly prohibited.

92. Defendant Tjoflats criminal acts on the record deprived him of any immunity.

93. Defendant Tjoflat had conceded that Lee County scam O.R. 569/875 effected an

unconstitutional temporary taking underfalse pretenses that said scam was adopted.

94. In particular, Defendant corrupt Gerald Bard Tjoflat conspired to

a. Extend Lee County scam O.R. 569/875 for Appellees bribes;

b. Concoct that Lee County adopted eminent domainscam O.R. 569/875, absent, e.g.,

any boundaries, legal description, execution, seal, witnesses, legislator, legislative

history in said prima facie fake claim;

c. Concoct resolution 569/875, no evidence of which could be found to exist in the public

record;

d. Conceal the invalidity of Official Record [O.R. 569/875], which fraudulently claimed

un-platted undesignated areas, which did not appear on the 1912 Plat of Survey of the

undedicated Cayo Costa Subdivision. See Lee County Plat Book 3, p. 25;

e. Fix Appellants Cases;

f. Accept bribes for the illegal purpose offixing Appellants cases and falsely pretending

that Lee County eminent domain scam O.R. 569/875 was a legislative act and/or

resolution;

g. Falsely pretend thateminent domainextortion-scheme O.R. 569/875 was a legislative

act and/or resolution;

h. Conceal that Lee County never had any intent to claim un-platted and uncertain

undesignated areas absent anysignatures,seal, and/orexecution.

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95. Defendant Tjoflat extorted the Appellants in multiple different ways, by, e.g.,

a. Falsely pretending that Lee Countys fake claim O.R. 569/875 was a legislative act;

b. Obstructing justice and Federal adjudication under false pretenses that Plaintiffs

patently clearly ripeeminent domainextortion and fraud issues were not ripe;

c. Obstructing justice under false pretenses that Plaintiffs indisputable proof of the

prima facie invalidity of scam O.R. 569/875 wasnon-meritorious;

d. Objectively partially awarding cost and damages to Appellee K. M. Wilkinson, who

conspired to defraud and deliberatelydeprive the Appellants underfalse pretenses of,

e.g., said forgery O.R. 569/875, lot 00A0 and block 1, and a forged plat;

e. Fixing Appellants Cases in exchange for Appellees bribes;

f. Suspending 11th

Circuit Rules to benefit the Appellees in exchange for theirbribes.

DEFENDANT CORRUPT 11th

CIRCUIT JUDGE STANLEY F. BIRCH

96. Defendant 11th

Circuit Judge Birch conspired with the Defendant-Appellees to conceal that

Lee Countys fake claim O.R. 569/875 was invalid and void because of

insufficiency/uncertainty of the purported description of unidentified/undesignated areas.

In exchange for Appellees bribes, Defendant Birch conspired to conceal that all areas of

said Subdivision as platted on said 1912 Plat were identified as [60 wide designated]

streets, [20 wide designated] alleys, lots [and/or blocks].

97. Birch conspired to obstructjustice and mandatory [under writ of mandamus] judicial

determination of the primafacieinvalidity of said scam O.R. 569/875. Birch conspired to

a. Concoct a legislative act, which Birch knew could not have possibly existed absent,

e.g., any legislator, legal description, ascertainable boundaries, Lee County

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condemnationauthority, execution, seal, witnesses, etc. See 03/05/2009 fraudulent 11th

Circuit Opinion;

b. Conceal that Lee County never had any intent to claim un-platted and uncertain

undesignated areas absent any signatures, seal, and/or execution by Lee Countys

legislative body;

c. Conceal that Lee County never had any authority to diminish Plaintiff-Appellants

prima facieperfect title to their riparian Gulf-front Lot 15A under false pretenses of

scam O.R. 569/875, which was a prima facienull and void sham claim.

98. Nofitand intelligentjudge and/or person in Birchs shoes could havepossiblyperverted the

platteddesignated 60 wide streets into unidentified areas. Birch knew that in America,

lot owners and/or subdivision residents customarily use platted designated streets to

access their residential lots and not unidentified/undesignated areas. In exchange for

Appellees bribes, Birch unusually unintelligently perverted said 1912 public record

evidence of a 60 wide designated street in order to obstruct justice, deliberately

deprive, and defraud the Appellants underfalse pretenses that said scam O.R. 569/875 was

a legislative act.

99. Defendant Birch conspired to conceal that said prima facie defective and unexecutedfake

claim O.R. 569/875 ofuncertain lands could not havepossibly been adopted absent,

e.g., any witnesses, legal description, ascertainable boundaries, legislator, legislative

authority,purpose, history, Lee Countyseal, execution, etc.


CIRCUIT JUDGE JOEL F. DUBINA

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100. Defendant corrupt U.S. 11th Circuit Judge Joel F. Dubina [Dubina] conspired with the

Defendant-Appellees to conceal that said eminent domain scam O.R.569/875 falsely

claimed that undesignated areas appeared on the 1912 Subdivision Plat of Survey.

See said extortion-scheme O.R. 569/875; 2.

101. In exchange for Defendant-Appellees bribes, Defendant Dubina conspired to fix and

dismiss Appellants Cases and/or Appeals and to falsely pretend that Lee County, Florida,

eminent domainscam O.R. 569/875 was a legislative act. See www.leeclerk.org.

102. Defendant Dubina conspired to conceal the prima facie invalidity of said fraudulent

claim of uncertain undesignated areas, which Dubina knew did not appear on said

Plat. See 1912 Plat in Lee County Plat Book 3, p. 25.

103. Dubina conspired to conceal that Lee County had never executed said claim of

fictitiousun-platted undesignated areas. See said scam O.R. 569/875.

104. Defendant corrupt Judge Dubina conspired to

a. Conceal the platted designated 60 wide street. See said 1912 Plat;

b. Extend Lee County fraud-scheme O.R. 569/875;

c. Obstruct justice, deliberately deprive, and defraud the Appellants by falsely

pretending the said scam O.R.569/875 was a legislative act;

d. Conceal that the platted Cayo Costa Subdivision had never been dedicated and that Lee

County had never accepted any dedication;

e. Conceal that no witnesses and/orseal appeared on said sham claim of uncertain

lands;

f. Conceal that nolegislatorand/orlegislative history could be identified in said scam O.R.

569/875;

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g. Conceal that Lee County never had any legislative authority orpurpose to fraudulently

claim all of raid lands and accretions thereto, which admittedly could not be

identified. See eminent domainfraud-scheme O.R. 569/875;

h. Conceal that admittedly unexecuted scam O.R. 569/875 contained multiple different

type fonts and errors such as, e.g., raid lands; tho County; there;

i. Conceal that admittedly and indisputablyunexecutedand unsignedLee County fraud-

scheme O.R. 569/875 was neveradopted;

j. Conceal that Defendant-Appellees, State of Florida, sham claim/defense ofadverse

possession of the uncertain undesignated areas was a scam in order to deliberately

deprive and defraud the Appellants;

k. Concoct apermanenttaking of 200 Acres in all even though Dubina knew that scam

O.R. 569/875 could not havepossibly effected anypermanenttaking.

105. Judicial Defendant Dubina conspired to usurp legislative authority and to concoct a

legislative act, which he knew was factually and legally impossible.


CIRCUIT JUDGE SUSAN H. BLACK

106. Defendant corrupt 11th

Cicuit Judge Susan H. Black, who is being sued in herprivate

individual and official capacities, conceded in her 04/21/2009 Opinion [p. 3] that

[Plaintiff-] Appellantss Lot 15A is on the west side of the Cayo Costa subdivision on the

Gulf of Mexico Here, Blackaffirmed the riparianess of Plaintiffs Gulf-front Lot 15A.

107. In her Opinion, Black refers to resolution 569/875, which indisputably never existed.

In exchange for Appellees bribes, Blackconcocted a resolution 569/875 even though she

knew that there was no resolution numberon Lee Countys scam O.R. 569/875.

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108. Defendant corrupt 11th Circuit Judge Susan H. Blackconspired to

a. Falsely pretend that [t]he Appellants complaint alleged that the Appellees

i. passed and/or enacted resolution 569/875.

b. Conceal that no resolution 569/875 had ever existed and/or was ever passed or

adopted by Lee County or any Lee County legislatororlegislative body;

c. Conceal that Lee County never had any intent to claim un-platted and uncertain

undesignated areas absent any signatures, seal, and/or execution by Lee Countys

legislative body;

d. Conceal Lee Countys prima facie lack of any legislative intent as indisputably

evidencedby the absence of anysignatures,seal, and witnesses on said sham claim;

e. Conceal that Lee County never had any authority to diminish Plaintiff-Appellants

prima facieperfect title to their riparian Gulf-front Lot 15A under false pretenses of

scam O.R. 569/875, which was a prima facienull and void sham claim;

f. Falsely pretend that Lee County had eminent domain authority to claim uncertain and

un-platted lot 00A0, block 1, and/or undesignated areas;

g. Falsely pretend that Plaintiffs failed to state a claim even though Blackknew the 11th

Circuit had admitted to Plaintiff-Appellants unconstitutional temporary takings

and other claims, which were ripe;

h. Concoct that Plaintiff-Appellants eminent domain extortion and fraud issues

purportedly did not invoke Federal subject matter jurisdiction;

i. Concocted ripeness requirements that no reasonable and intelligent judge in Blacks

shoes could havepossibly determined to exist;

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j. Conceal that the Defendant-Appellees treated the Plaintiff-Appellants disparately from

similarly-situated owners of Cayo Costa riparian lands such as, e.g., Alice M. S.

Robinson and A. C. roesch as indisputably evidenced by the

109. Blackknew that

a. Lee County never had any validclaim;

b. Plaintiff-Appellants title was free and clear of any fictitious encumbrance by sham

O.R. 569/875;

c. Sham claim O.R. 569/875 had never created any cloud, because it was null and void

foruncertainty and lackofexecution and legislative intent.


CIRCUIT JUDGE WILLIAM H. PRYOR

110. Defendant corrupt 11th Circuit Judge William H. Pryor conceded in his 4/21/2009

Opinion, on p. 2: The Appellants are owners of Lot 15A in the Cayo Costa subdivision in

Lee County, Florida.

111. Absent, e.g., any legislative intent, execution,signatures, legal description, ascertainable

boundaries, Pryor concealed that no evidence had ever existed to diminish Plaintiff-

Appellants perfect title to said prima facie Cayo Costa riparian Gulf-front Lot 15A.

112. Pryorknew that indisputably said Lot 15A was a prima facie riparian Gulf-front lot,

which abuts the natural boundary of the Gulf of Mexico as platted.

113. Defendant Pryorconcealed that

a. Lee County never had any validclaim;

b. No resolution 569/875 had ever existed;

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c. Plaintiff-Appellants title was free and clear of any fictitious encumbrance by sham

O.R. 569/875;

d. Sham claim O.R. 569/875 had never created any cloud, because it was null and void

foruncertainty and lackof, e.g., any execution and legislative intent;

e. Lee County had no authority to condemn un-platted and uncertain

undesignated/unidentified areas

f. Lee County had removed and eliminated its sham claim in 1998 pursuant to Blue

Sheet 980206 and O.R. 2967/1084-1090;

g. Lee County had abused and mis-treated Plaintiff-Appellants disparately from

similarly-situated owners ofsimilar and/or identical riparian Cayo Costa lands such as,

e.g., Alice M. S. Robinson and A. C. Roesch.

114. Unintelligently, Pryorconcealed that Plaintiff-Appellants had the equal rights, and in

particular, equal vested riparian rights of, e.g., A. C. Roesch, who had received and

subdivided the accretions onto said Subdivision as indisputablyevidenced by the four Cayo

Costa Plats of Survey publicly recorded between 1910 and 1912. See www.leeclerk.org.

115. Pryor was objectively partial and unfit and must be recused pursuant to 455. Plaintiff-

Appellants are entitled to be free from Pryors arbitrary, capricious, and exceptionally

unintelligentdeliberate deprivations under 18 U.S.C. 241, 242.


CIRCUIT JUDGE FRANK M. HULL

116. In his 04/21/2009 Opinion, Defendant corrupt 11th Circuit Judge Frank M. Hull

conceded that [T]he Appellants are [exclusive] ownersof[riparian Gulf-front] Lot 15A

in the Cayo Costa subdivision in Lee County, Florida. With particularity, Defendant Hull

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affirmed and conceded the riparianess of said Gulf-front Lot 15A: The Appellants Lot

15A is on the west side of the Cayo Costa subdivision on the Gulf or Mexico.

117. The Plaintiffs are suing said Defendant in his private individual and official capacities.

Hulls criminal acts were extrajudicial, and Hull has no immunity. Objectively partially

and unintelligently, said Defendant conspired to fix Plaintiff-Appellants Case(s): The

district court dismissed Busses procedural due process claims regarding [non-existent] Lee

County resolution 569/875 because the [fictitious] resolution was a legislative act that was

not subject to a procedural process claim and, even if it was not, Busse had not alleged that

post-deprivation remedy was inadequate.

118. Here unfit Hull concealed the exclusive remedy of invalidation and damages for the

unconstitutional temporary takings underscam O.R. 569/875, which was null and void.

119. Hull falsely pretended a [counterfeit] legislative act and post-deprivation remedy

even though he knew that prima facie void claim O.R. 569/875 could not have possibly

effected any permanent taking. Therefore, Hull fabricated a post-deprivation remedy in

order to deliberately deprive and defraud the Plaintiffs. Hull concealed that the Plaintiffs

were entitled to Federal adjudication and invalidation of said unauthorized scam O.R.

569/875.

120. Said Defendant concealed that the Constitution requires all bills to be signed by the

presiding officers of the two houses and the Secretary of the State and the Clerk of the House

of Representatives during the legislative session. Such bills when so signed must be

presented to the Governor by the legislature before adjournment. Like all other provisions of

the Constitution, this was mandatory. Therefore, prima facie forged O.R. 569/875 was

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never, and could not have possibly been, enacted in accordance with the essential

requirements of the Constitution, and thus invalid, inoperative, and void.


CIRCUIT JUDGE JAMES LARRY EDMONDSON

121. The Plaintiffs are suing Defendant corrupt 11th

Circuit Chief Judge J. L. Edmondson

who conspired with the Appellees to conceal that Defendant John E. Steele had falsely

pretended that prima facie defective and unconstitutionalfake claim was a legislative

act.

122. Edmondson concealed that

a. Prima facie sham claim O.R. 569/875 was void for uncertainty, because no

reasonable surveyor could have possibly ascertained and located the fictitious un-

platted undesignated/unidentified areas;

b. Lee Countysprima facie intentwas not tosign, execute, seal, and acknowledge said

sham claim.

c. Edmondsons and the 11th Circuits perversion of the truth and obstruction of justice

were brazen and unlawful;

d. The official legislative records were devoid of any [fictitious] legislative act and/or

resolution 569/875;

e. The 11th

Circuit fixed Plaintiff-Appellants cases in exchange for Appellees bribes;

f. while Plaintiffs Warranty Deed was signed, sealed, and witnessed, purported Lee

County sham claim O.R. 569/875 was neversigned, executed,sealedorwitnessed;

g. No evidence of any legislative intent existed, and Lee County never affirmatively

claimed the fictitiousun-platted and uncertain unidentified/undesignated areas.

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JUDICIAL DEFENDANTS R. L. ANDERSON, ED CARNES, AND R. BARKETT

123. The Plaintiff-Appellants are again suing 11th

Circuit judicial Defendant-Appellees R.

Lanier Anderson, Ed Carnes, Rosemary Barkett in their private individual and official

capacities. Said 11th

Circuit judicial Defendants conspired to conceal the prima facie

invalidity of said sham Lee County claim of uncertain unidentified land(s) [prima

facie scam O.R. 569/875], which lacked, e.g., any legal description, boundaries, seal,

legislator, legislative history, vote count, notarial acknowledgment,signatures and execution

by Lee County.

124. Said Defendant-Appellees conspired to conceal that in 1998 Lee County had removed

and eliminated any cloud from said fake claim ofuncertainnon-platted undesignated

areas pursuant to Lee County Blue Sheet 980206 and O.R. 2967/1084-1090. Said

Defendant-Appellees conspired to conceal that Defendants Lee County, Florida, could not

havepossibly laid claim to un-platted unidentified areas. See fraudulent Opinion, p. 2.

125. Said Defendants conspired to refuse to enjoin Defendant-Appellees from enforcing said

eminent domain scam O.R. 569/875 and defrauding the Appellants under false pretenses

that the Plaintiff-Appellants were purportedly frivolous and vexatious even though their

concoctions were controverted.

126. Said Appellees obstructed justice and perverted the truth, because they knew that all

areas platted on the publicly recorded 1912 Cayo Costa Subdivision Plat within the 4

corners of Appellants Appeals and/or Complaints were identified as either lots, alleys,

streets [and/or blocks].

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DEFENDANT CORRUPT REAGAN KATHLEEN RUSSELL

127. The Plaintiffs are suing Defendant-Appellee corrupt Reagan Kathleen Russell in her

private individual and official capacities. Defendant-Appellee Reagan Kathleen Russell

conspired to conceal the prima facie illegality and nullity of Lee County eminent domain

extortion and fraud-scheme O.R. 569/875, which fraudulently claimed uncertain

undesignated lands. Russell conspired to conceal that no undesignated and/or

unidentified areas were ever platted on the 1912 Plat of Survey of the undedicated private

residential Cayo Costa Subdivision on Cayo Costa Island in Lee County, Florida.

DEFENDANT CORRUPT U.S. DISTRICT JUDGE RICHARD A. LAZZARA

128. The Plaintiffs are suing Defendant-Appellee corrupt U.S. District Judge Richard A.

Lazzara in his private individual and official capacities. Said Defendant Lazzara conspired

to falsely pretend that the Plaintiff-Appellants were frivolous and vexatious even though

the Appellees knew that Appellants legal claims and causes of action had been highly

cognizable and meritorious and supported by the self-authenticating public record

evidence.

129. Defendant corrupt Judge Lazzara concealed that concededly, Lee County eminent

domain extortion and fraud-scheme O.R. 569/875 effected unconstitutional temporary

takings. Lazzara knew that said forgery O.R. 569/875 could not havepossibly effected any

permanenttaking, because claim O.R. 569/875 was prima facienull and void ab initio.

130. Absent any legislativeauthority and intent, Lee County had neverexecuted said scam

and cleared the title ofsimilarly-situated Cayo Costa landowner Alice M. S. Robinson,

who owned riparian lots similar to Appellants riparian Gulf-front Lot 15A [PID 12-44-

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20-01-00015.015A]. Plaintiffs said admittedly riparian Lot 15A was only approx. 560 feet

north of Robinsons riparian lots. Underfalse pretenses of frivolity, vexatiousness, and

a fictitious passed resolution/legislative act, Defendant-Appellee Lazzara conspired to

conceal that the Appellants had the equal rights of, e.g., Cayo Costa landowners Alice M. S.

Robinson, original Subdivider A. C. Roesch, Janet Lay, and John Lay. In exchange for

Appellees bribes, Lazzara conspired to treat the Plaintiff-Appellants disparately from said

similarly-situated Cayo Costa landowners.

131. Lazzara has no immunity for his brazenlycorruptextra-judicialcriminal activities.

DEFENDANT CORRUPT U.S. MAGISTRATE S. POLSTER CHAPPELL

132. Defendant-Appellee corrupt U.S. Magistrate Judge S. Polster Chappell concealed

a. The invalidity and nullity of said eminent domainfraud-scheme O.R. 569/875;

b. Theinvalidity and scam offraudulent lot 00A0;

c. The invalidity and scam offictitious block 1;

d. Heraffiliations with Defendant-Appellees Lee County and State of Florida and objective

partiality.

e. The illegality of herobjectively partial sanctions, Recommendations, and Report(s)

against Plaintiff-Appellant Dr. Busse

133. The Plaintiffs are suing said Defendant Chappell in herprivate individual and official

capacities.

134. Polster Chappell concealed that the Constitution(s) require all bills to be signedby the



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the Constitution, this was mandatory. Therefore, forged O.R. 569/875 was neverenactedin

accordance with the essential requirements of the Constitution, and thus invalid,

inoperative, and void.

135. The Plaintiffs were entitled to the absolutely mandatory recusal of said corrupt

Defendant Magistrate, who concealed the prima facie absence of any platted lot 00A0,

block 1, and unidentified/undesignated areas on the public record in exchange for

Appellees bribes.

136. Even though Lee County had never [and could have neverpossibly] laid any affirmative

claim on un-platted, legally un-described, and uncertain [non-existent]

unidentified/undesignated areas, Polster Chappell conspired to fabricate a legislative

act. In exchange for Appellees bribes, Polster Chappell conspired to extend said fraud

and extortion of Plaintiffs property underfalse pretenses of, e.g., fraudulent lot 00A0,

block 1, frivolity, and scam O.R. 569/875, which Chappell knew were all null and void.

137. Polster Chappell concealed that no area determinations, such as, e.g., 107 Acres by co-

conspirator K. M. Wilkinson, and 200 Acres by co-conspirators Tjoflat, Birch, and Dubina

could have been factually or legallypossible.

DEFENDANT CORRUPT U.S. MAGISTRATE MARK ALLAN PIZZO

138. Defendant-Appellee corrupt U.S. Magistrate Judge Mark Allan Pizzo concealed

a. The invalidity and nullity of said eminent domainfraud-scheme O.R. 569/875;

b. Theinvalidity and scam offraudulent lot 00A0;

c. The invalidity and scam offictitious block 1;

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d. The illegality of his objectively partial sanctions, Recommendations and Reports

against the Plaintiff-Appellants. In particular, the illegality of F.R.C.P. 11 sanctions for

pleadings filed in State Court.

139. The Plaintiffs are suing said Defendant Pizzo in his private individual and official

capacities.

140. Pizzo concealed that the Constitution(s) require all bills to be signed by the presiding

officers of the two houses and the Secretary of the State and the Clerk of the House of

Representatives during the legislative session. Such bills when sosignedmustbe presented

to the Governor by the legislature before adjournment. Like all other provisions of the

Constitution, this was mandatory. Therefore, forged O.R. 569/875 was never enacted in



141. In his perverted Report and Recommendation [Case # 2:08-cv-899-FtM-99MAP; Doc.

# 121], Pizzo perpetrated a fraud on the Court and falsely pretended that Plaintiffs had not

stated a cause of action and slandered Plaintiffs as vexations andfrivolous.

DEFENDANT JACK N. PETERSON

142. In his 02/29/2008 Deposition, Defendant Jack N. Peterson had stated under oath that

Appellant(s) are the exclusive record owners of said riparian Gulf-front Lot 15A.

143. Peterson concealed that

a. No judicial determination had ever challenged or diminished Plaintiffs prima facie

perfect title to said riparian Gulf-front Lot 15A;

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b. Lee County never had any legitimate claim to any orallof Plaintiffs riparian Gulf-

front lot;

c. Lee County and Peterson conspired to threaten, harass, and intimidate the Plaintiffs in

order to compel them to refrain from asserting theirConstitutionally-guaranteed rights

under, e.g., the 14th

, 1st, 4

th. 7

th, and 5

thAmendments and 42 U.S.C. 1983, 1985, 1988.

144. Defendant Peterson had conceded that Lee County had removed and/oreliminated any

claim and/or cloud under color of said prima facie scam O.R. 569/875. In particular,

Defendant Peterson had asserted the platted designated 60 wide street adjoining Plaintiffs

riparian Gulf-front Lot 15A, which they ownfee simple. See, e.g., Defendant Petersons

Brief in the 11th

Circuit.

145. Said Defendant Peterson had conceded that Lee County did not necessarily own the

uncertain undesignated areas fraudulently claimed in eminent domain extortion-

scheme O.R. 569/875. See, e.g., business correspondence between the eminent domain

attorneys at Brigham & Moore and said Defendant.

146. Peterson had directlycontroverted the 11th Circuits brazen criminalfabrications of a

legislative act. In his Briefs Peterson had proven the platted designated street

adjoining Plaintiffs upland.

147. All of the lands which the Plaintiffs indisputably and admittedly own, i.e., their

riparian upland, said designated adjoining street, and the accretions thereto were

perfectly identified on said 1912 Plat of Survey referenced in scam O.R. 569/875 and

Plaintiffs Warranty Deed. Said 11th Circuit Judges conspired to conceal that the sham

claim of undesignated areas could not have possibly diminished or encumbered

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Plaintiffs perfecttitle and fee simple ownership of said platteddesignatedstreet, upland,

and accretions.

148. Peterson further evidenced how and why the 11th

Circuit perverted the public record in

exchange for Appellees bribes.

DEFENDANT(S) UNITED STATES OF AMERICA AND U.S. ATTORNEY

149. The Plaintiffs are suing the U.S. Attorneys James Russ Dedrick, Sean Flynn, Kent

Anderson, and Brian Albritton in theirprivate individual and official capacities.

150. Said Defendant U.S. Attorneys concealed that the Constitution(s) require all bills to be

signed by the presiding officers of the two houses and the Secretary of the State and the

Clerk of the House of Representatives during the legislative session. Such bills when so

signed must be presented to the Governor by the legislature before adjournment. Like all

other provisions of the Constitution, this was mandatory. Therefore, forged O.R. 569/875

was neverenacted in accordance with the essential requirements of the Constitution, and

thus invalid, inoperative, and void.

151. Said Defendants conspired to falsely pretend that the Federal Courts did not have

jurisdiction over said eminent domain [extortion and fraud] issues and Plaintiff-Appellants

ripe Federal claims. Said Defendants conspired with the Appellees to manufactureripeness

requirements and to conceal patently clear Federal subject-matter jurisdiction over said

State eminent domain [extortion and fraud] issues and the States deliberate deprivations

as evidenced by the public records.

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DEFENDANT U.S. MARSHAL RICK JESSUP

152. The Plaintiffs are suing Defendant U.S. Marshal Rick Jessup in his private individual

and official capacities. Pursuant to the investigation by the Naples Police Department, said

Defendant harassed, intimidated, and threatened the Plaintiffs with arrest in Naples,

Florida, for suing and prosecuting Defendant John E. Steele and judicial Defendants for,

e.g., deliberate deprivations under the 1st, 14th, 4th, 5th, and 7th Amendments, obstruction of

justice, fraud, and extortion under false pretenses that said scam O.R. 569/875 was a

legislative act. Jessup knew that said prima facieeminent domainextortion-scheme was

null and void ab initio and that Plaintiffs were entitled to own their said Constitutionally-

protected property and exclude the government without threats of, e.g., retaliation, arson,

trespass, seizure, and destruction of private property, and arrest without any probable

cause.

DEFENDANT(S) U.S. DEPARTMENT OF JUSTICE

153. Defendant U.S. Department of Justice conspired to deliberately deprive Plaintiff Dr.

Busse of his Constitutionally-protected immigration privileges inretaliation for his actions

against the various Government Officials and while blowing the whistle on Lee County

eminentdomainextortion and fraud-scheme O.R. 569/875.

154. Without any due process and equal protection, Defendant U.S. Department of Justice

deliberately, arbitrarily, and capriciously deprived Plaintiff-Appellant Dr. Busse of

mandatory and non-discretionary immigration benefits.

155. Said Defendant(s) concealed that said Plaintiff(s) had a

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a. Constitutionally-protected right to redress his/their grievances under the 1st

Amendment withoutretaliation and governmental abuse and oppression;

b. Constitutionally-protected right to own his/their property and exclude said

Governments.

156. Defendants U.S. Department of Justice concealed that the Constitution(s) require all bills

to besignedby the presiding officers of the two houses and the Secretary of the State and the






DEFENDANT KENNETH M. WILKINSON AND ROGER J. DESJARLAIS

157. Defendants Kenneth M. Wilkinson and Roger J. Desjarlais, in theirprivate individual

and official capacities as Lee County Property Appraiser, and Chief Deputy, respectively,

conspired to

a. Conceal the prima facie nullity and invalidity of said scam;

b. Falsely pretend that said Lee County scam O.R. 569/875 was a legitimate instrument

even though they knew that Lee County had removed and eliminated any cloud and/or

claim

c. Falsely pretend that said Lee County fraudulent claim encumbered Appellants

perfect title to prima facie riparian Gulf-front Lot 15A;

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d. Concoct fictitious lot 00A0 [fraudulent PID 12-44-20-01-00000.00A0] and block

1 [fake PID 07-12-44-21-00001.0000], which could not be found to appearon said

1912 Cayo Costa Plat;

e. Abuse and mis-treat the Appellants disparately from similarly-situated Lee County

riparian landowners such as, e.g. Alice M. S. Robinson, and A. C. Roesch under

f. Seize, confiscate, and/or destroy the substantial fencing of Appellants riparian Gulf-

front Lot 15A;

g. Forge boundaries and a plat of said undedicated Cayo Costa Subdivision;

h. Tamper with the public record evidence in order to deliberately deprive and defraud

the Appellants and obstruct justice;

i. Perpetrate a fraud on the Court(s) underfalse pretenses that said forged claim O.R.

569/875 was a resolution and fictitious lot 00A0 and block 1 were platted and

legally describedland parcels even though said lot and block had never appeared on said

1912 Cayo Costa Plat.

158. Said Defendants concealed that the Constitution(s) require all bills to be signedby the







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DEFENDANTS AMY TUCK FARRINGTON AND SHERRI L. JOHNSON

159. Defendants Amy Tuck Farrington and Sherri L. Johnson conspired with the other

Defendant-Appellees to conceal the prima facieinvalidity and illegality of said scam O.R.

569/875 and diminish Plaintiffs perfect title and ownership of said riparian Gulf-front Lot

15A absent even a shred of evidence in support of theirfrivolous and fraudulent claims.

160. Said Defendants fraudulently claimed that Plaintiff-Appellants did not own their

platted designated street and accretions thereto. They conspired to forge and tamper with

the 1912 plat and perpetrate a fraud on the Court. They conspired to obstruct justice and

extend the fraud, trespass, and arson under, e.g., false pretenses of said concoctions of a

legislative act, un-platted lot 00A0, and fictitious block 1.

161. Said Defendants conspired to perpetrate a fraud on the Courts and extort cost,

damages, and their Constitutionally-protected property from the Plaintiffs by falsely

pretending that Appellants werefrivolous, which was factually and legally impossible.

162. Johnson perpetrated a fraud on the Florida Bar when she concocted criminal

allegations against Plaintiff Dr. Busse, who had blown the whistle on scam O.R. 569/875.

163. Said Defendants concealed that he Constitution requires all bills to be signed by the

presiding officers of the two houses and the Secretary of the State and the Clerk of the

House of Representatives during the legislative session. Such bills when so signedmust be




inoperative, and void. Johnson and Tuck Farrington were absolutely obligated to disclose

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said perpetrated fraud of a legislative act, which they knew could not have possibly

existed.

DEFENDANT CHARLIE GREEN

164. Defendant Charlie Green in his private individual and official capacity as Clerk of Lee

County Courts conspired to

a. Conceal the prima facie invalidity and nullity of said Lee County scam O.R. 569/875;

b. Conceal that theprima facie defective and unexecutedsham claim O.R. 569/875 of

unidentified/undesignated areas was null and voidforuncertainty in the description

of said un-platted areas and/or lands;

c. Usurp judicial authority in order to falsely pretend that Lee County was the grantor of

said fictitious unidentified/undesignated areas and to deliberately deprive and

defraud the Plaintiffs of their lands.

165. Because the fictitiousdescription of unidentified areas was by definition and prima

facienull and void, any Lee County claim was invalid.

166. Defendant Green conspired to conceal that Plaintiffs perfectunencumbered Warranty

Deed conferred upon them valuable rights, of which they may not be involuntarily and

deliberatelydeprived without due process of law and judicial determination.

167. It was for the Federal Courts to determine, as a matter of law, whether or not the

fictitiousdescription ofun-platted undesignated areas, which was so vague, indefinite,

and uncertain as to amount to a prima facienullity, could have possibly constituted any

claim.

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168. Furthermore, Defendant Green concealed that any eminent domain or condemnation

claim was legally and factually impossible, because the public could not possibly access

any land parcels in private undedicated Cayo Costa. Green concealed the absolute absence

of any Lee County eminent domain authority, except forpublic use. Private use was

expresslyprohibited by the Florida and Federal Constitutions.

169. Despite the prima facie deficiency and invalidity of said scam, Green conspired to

falsely pretend that Lee County was the grantor of undesignated areas. See

www.leeclerk.org.

170. Defendant Green concealed that legislature cannot exercise judicial function and is

precluded from delegating the exercise of judicial functions to ministerial officers. Here, Lee

County had no power whatsoever to invalidate any or all of Appellants conveyance of said

riparian Gulf-front Lot 15A.

171. Defendant Green concealed that judiciary, legislative, and executive government

branches were to remain forever separate and distinct. Judicial determination of any

[fictitious] Lee County interest in Appellants riparian Gulf-front Lot 15A was entirely

outside the scope of any authority of Lee Countys legislative body and/or the Clerk of

Court. Illegally, Lee County and Defendant Green conspired to usurp judicial authority to

deliberately, arbitrarily, and capriciously deprive the Plaintiff-Appellants of their

Constitutionally-protected property.

172. Defendant Charlie Green conspired with Defendant-Appellees State to suspend Plaintiff

Dr. Busses drivers license without any probable cause in order to harass, intimidate, and

threaten said Appellant and to compel him to refrain from any further litigation and

invalidation of said scam O.R. 569/875.

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DEFENDANT STEVEN CARTA

173. Defendant-Appellee Steven Cart conspired to conceal that Lee County nevergranted,

and could not have possibly ever granted that which Carta knew Lee County never had

any interest in. Carta conspired to falsely pretended that Lee County had an interest in

Plaintiffs riparian Gulf-front Lot 15A even though Carta knew that O.R. 569/875 was a

prima facie extortion and fraud-scheme. Carta violated his obligation to disclose

Defendant-Appellees prima facie crimes ofdeliberate deprivations under 18 U.S.C.

241, 242, and obstruction of justice under 18 U.S.C. 1503.

174. Defendant Steven Carta conspired to conceal that the Constitution(s) require all bills to

besignedby the presiding officers of the two houses and the Secretary of the State and the






DEFENDANTS CHAD LACH AND CHARLES B. STEVENS

175. Defendants Chad Lack in theirprivate individual and official capacities as Cayo Costa

State Park, and Assistant Park Managers, respectively, conspired to

a. Assault the Plaintiffs on theirprima facie riparian Gulf-front Lot 15A;

b. Conceal the invalidity and nullity of Lee Countys scam O.R. 569/875;

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c. Threaten, harass, and intimidate the Plaintiffs within said undedicated private

residential Cayo Costa Subdivision;

d. Trespass and encourage trespass by the public onto said private Cayo Costa

Subdivision, which they knew was neverdedicatedto the public;

e. Set and/or encourage open fires and arson in said residential Cayo Costa Subdivision,

which is absolutely prohibited under Florida law;

f. Endanger Plaintiffs and/or other Cayo Costa residents lives by arson and/or open fires

in said private residential Subdivision;

g. Confiscate, seize, and/or destruct Plaintiffs substantial fencing of said prima facie

riparian Gulf-front Lot 15A;

h. Seize, confiscate, and/or destroy Plaintiffs private property on said prima facie

riparian Gulf-front Lot 15A, which said Defendants knew abuts the platted natural

boundary of the Gulf of Mexico;

i. Extort Plaintiffs property under false pretenses that Lee County had a purported

interest in Plaintiffs prima facie riparian Gulf-front Lot 15, to which Plaintiffs hold

exclusiveperfect title.

j. Conceal that any public use of Appellants private easements within said private

undedicated Cayo Costa is unlawful and disturbs the peace.

DEFENDANT DONALD D. STILWELL

176. Defendant Donald D. Stilwell in his private individual and official capacity [disgraced

Lee County Manager] conspired to

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a. Conceal the prima facie invalidity and nullity ofprima facie defectivefake claim

O.R. 569/875 ofuncertain, un-platted, and un-described unidentifiedareas;

b. Extort Plaintiffs

c. Falsely pretend that said scam O.R. 569/875 was an adopted/passed resolution;

d. Confiscate, seize, and destroy Plaintiff [-Appellants] property, fence, building

materials, fence materials, tent, building and gardening tools, carts, etc.,

DEENDANT KAREN FORSYTH

177. Defendant-Appellee Karen Forsyth, in her private individual and official capacities

conspired to conceal that Lee County never had any interestin Appellants said admittedly

Gulf-front Lot 15A and theirdesignated adjoining street and the accretions thereto.

178. Forsyth falsely and fraudulently pretended that Lee County had an interest in

unplatted and uncertain undesignated areas in order to extort and defraud the Plaintiff-

Appellants.

DEFENDANT DONNA MARIE COLLINS

179. The Plaintiffs are suing Defendant Donna Marie Collins in herprivate individual and

official capacities for the publicly recorded fraud and extortion outside the scope of her Lee

County employment. See First Case; Doc. # 89; 89-2.

180. After said 1998 removal of any cloud and fraudulent claim under Blue Sheet

980206, Defendant Collins concealed that absent any legitimate claim, legal description,

signatures and execution of said eminent domain extortion-scheme, no inverse, direct, or

any other type ofcondemnation could havepossibly occurred and that Lee County never had

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any interest in said riparian Lot 15A and the fictitious, un-platted, and non-existent

undesignated areas in scam O.R. 569/875.

181. Collins knew that Lee Countys removed sham claim ofuncertain and fabricated

undesignated/unidentified areas invoked Federal subject-matter-jurisdiction over said

eminent domain [fraud and extortion] issues.

182. Collins conspired to conceal that the law did not recognize said fake claim of

uncertain lands, and it was as if said forgery had never been drafted.

DEFENDANTS JAMES P. GERSTENLAUER, AND CLERKS OF FEDERAL COURTS,

LESLIE KING, SHERYL L. LOESCH, THOMAS K. KAHN

183. The 11th

Circuit conspired to conceal who, when, where, how, why, and with what

authority could havepossibly claimed non-existent undesignated/unidentified areas.

184. Nopublic use, necessity, was apparent from the face ofprima facie scam O.R. 569/875.

185. The Clerk of the U.S. District Court in Fort Myers conspired with, e.g., Defendant

Richard A. Lazzara, and John E. Steele to reject and/orrefuse to file multiple pleadings by

the Plaintiffs, who blew the whistle on said fraud, extortion, andjudicial corruption.

186. Pursuant to an order by Defendant corrupt Judge Richard Lazzara, the Plaintiffs were

given time until February 13, 2009, to file their responses. Prior to said deadline however,

Defendant Clerk of the U.S. District Court, Leslie King, conspired to reject and refuse to

file Plaintiffs filings. Said Defendants conspired to extendprima facie fraud-scheme O.R.

569/875 absent any justification. Said Clerk then demanded that Plaintiff(s) be escorted by

security.

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187. In return for Appellants payment(s) of, e.g., multiple $455.00, and other fees, and absent

any evidence of any legitimate claim by Lee County, the 11th Circuit deliberately

deprived and defrauded the Appellants of their right(s) to, e.g., own theirConstitutionally-

protected property, exclude Government(s), be free from governmental abuse, fraud,

corruption, and extortion, redress their governmental grievances, be free from disparate

treatment, have reasonable court access, and blow the whistle on said judicial corruption,

case-fixing, and bribery.

188. Even though the 11th Circuit admitted and conceded Plaintiffs perfect title and

ownership, Defendant Clerk Thomas K. Kahn and his staff conspired with the judicial

Defendants to arbitrarily, capriciously, and falsely pretend that multiple of Plaintiff-

Appellants pleadings could not be filed.

189. Said unlawful rejections of Plaintiff-Appellants pleadings, such as, e.g., Appellants

Motions to enjoin any enforcement ofscam O.R. 569/875, Motions forinvalidation of said

fraud-scheme were improperly rejected, because the 11th

Circuit has been conspiring to

extend said forgery and eminent domainextortion-scheme and extort the Plaintiffs.

190. In effect, the Plaintiffs have been paying fees to be told said brazen lies about a non-

existent legislative act and apermanenttaking of 200 Acres in all.

191. No intelligentperson or juror could have possibly determined that Appellants multiple

Appeals should be dismissed [fixed]. See any and all 11th

Circuit Dockets relating to said

extra-judicialcorruption, case-fixing, and bribery underfalse pretenses that the Federal

Courts lacked jurisdiction, that Plaintiffs and/or their well-evidenced assertions were

frivolous [non-meritorious] and/or vexatious, and that their patently clearly ripe eminent

domain claims were not ripe. None of the fictitious ripeness requirements could have

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possibly attached to, e.g., the 4th, 14th independent claims. See West Peninsular Title Co.,

supra; in said case Defendant J. L. Edmondson had presided and set bindingprecedent of

ripeness.

192. Admittedly, said eminent domainextortion-scheme stated on its face that it was a scam.

The Federal Courts extorted $455.00 and other fees from the Appellants to fabricate and

falsely pretend that said scam was a legislative act. Said 11th Circuit Defendant Judges

abused, oppressed, and extorted the Appellants under color of said forged claim of

undesignated lands.

193. The Appellants were entitled to redress their grievances and to injunctive relief from

said scam and any enforcementofremovedsham claim O.R. 569/875.

194. While Plaintiffs Warranty Deed was signed, sealed, and witnessed, purpor

Documents

09 cv 341 001 Complaint