In tue Circurr Courr oF tue Firreenta Joie. Cexcurr WW AND FoR Pata Brac County, FLORIDA Cu. Acrion HSBC Banx USA, Purported Plaintiff Case NO.: 502009C4030403XXMBAW vs, Avny Lorez, et al, Purported Defendant Amicus Brier — Vermiep Motion 10 InreRvENE For tHe Limitep Purrosr oF IN Svupiciar Recorps anp PRocerpies ‘Comes Now, Ronald Gillis, who is appearing by special appearance only as a friend of the court and observer for the limited purpose of Motioning this Court to Intervene Pursuant to Florida Rules of Judicial Administration (hereinafter FRJA) 2.420 and more specifically FRIA 2.420(d)(5) by a non-party to the action, and pursuant to Florida Supreme Court Ruling SCO6- 2136 (see exhibit 1), as well as Judicial Canon 3C(3), and the Florida Constitution Article V Section 2(b), Additionally, in accordance with FRJA 2.420(3) which states @ sealing order issued by @ court must state with specificity the grounds for sealing and the findings of the order that Justify sealing. Tt is the undersigned opinion that insufficient grounds by the purported plaintiff have been stated to justify the sealing of records, nor the closing of the court proceeding. In fact, it appears based upon submissions by the purported plaintiff in this case, that this entire case should be dismissed as a sham pleading and a clear fraud upon the court, and it appears that by attempting to proceed knowing a wrong plaintiff is suing is misprision of a felony by the plaintiff and participating attorneys of the plaintiff. Further, the US Supreme Court has consistently stressed that a plaintiff lacks standing unless he can establish that he has a “personal stake” in the alleged dispute, and that the injury is Lori 502009CA030403KXMBAWparticulatized as to him, see Raines v Byrd, 521 US 811, 819 (1997). Based upon the submissions of the purported plaintiff in this case, it appears quite clear the purported plaintiff has incurred no injury by their own submission, does not have standing, there is no causation and no redressability where: ‘There are three standing requirements: 1) Injury: The plaintiff must have suffered or imminently will suffer injury an invasion of a legally protected interest that is concrete and patticularized. ‘The injury must be actual or imminent, distinct and palpable, not abstract. This injury could be economic as well as non= economic. 2) Causation: There must be a causal connection between the injury and the conduet complained of, so that the injury is fairly traceable to the challenged action of the defendant ‘and not the result of the independent action of some third party who is not before the court. 3) Redressability: It must be likely, as opposed to merely speculative, that a favorable court decision will redress the injury. Further, it appears Purported Plaintiff HSBC Lacks Capacity and Standing, by its own admission, and the Court Lacks Subject Matter Jurisdiction, as it appears this entire complaint is deceptive, fraudulent, and a Sham Pleading [Fla R Civ Pro 50(@)] on its face. Further, Purported Plaintiff knowingly filed and unlawfully served its complaint with no capacity, no legal standing, no proof of its claim, and falsely claimed to be an injured-party and party-of intetest as required by FRCP 1.210(@), and based on its own submission, see exhibit ‘2’ the Purported Plaintiff HSBC and/or their attorney have committed a fraud upon the court in of numerous nules, statutes and laws, Further, in support of the Motion Opposing Closure of Judicial Records and Proceedings, the 2orn '502009CA030403XXMBAWundersigned states the following: 1) Based upon research conducted by the undersigned, the undersigned has been concerned ‘with apparent fraudulent foreclosure filings throughout the state for several years. If an entity atcempting to foreclose, in fact has that right, then the courts should grant such requests to foreclose. But based upon personal research, as well as review of audits of records done by three different recorders offices throughout the country, it appears that at best, 16% of foreclosures might have the initial grounds to foreclose, That leaves 84% that DO NOT have the grounds to foreclose. Based upon the filing of the purported plaintiff in this case, HSBC, it appears that not only does HSBC not have the legal grounds to foreclose, but it appears they knowingly admit this fact in emails, yet make a decision to proceed anyway with this apparent fraudulent foreclosure. 2) See letter and Memorandum of November 17, 2010, exhibit 3" by Florida Chief Supreme Justice Canady, in which he states the courts “belong to the people of Florida.” Further, he states, ry “The chief judges shall promptly exercise their administrative and supe authority to countermand closures or impediments to access that are inconsistent with Florida law.” It would seem quite contrary to my rights as a Floridian to have my rights to observe this court proceeding blocked. 3) The submission of the Affidavit of Indebtedness, exhibit '2" was done on October 13, 2011. The affidavit appears to raise clear and significant questions as to the injured-party-in-fact. ‘This filing have been in the court recerds for some time as well as widely distributed over the internet and remains widely available. 4) It took the purported plaintiff and/or their attorneys six months to request they be removed from the court file and public records. Further, the purported plaintiff attomeys have an obligation once discovered, to alert the court when there is a belief their client may have 3orll 502009C:AO3O403XXMBAW