ORGANIZED JUDICIAL CRIME – RACKETEERING, EXTORTION, …

1. The publicly recorded extortion and fraud scheme of “Government seizure” and

“forced sale” of Plaintiffs’ Lot 15A, Cayo Costa, would be absolutely impossible, if Lot 15A

had been “claimed as public land” as fraudulently pretended by Def. Honeywell. Here, the

record had conclusively evidenced the lack of any judgment and lack of any involuntary title

transfer to Lee County, FL. See Case 2:2007-cv-00228; Doc. ## 436, 288, 282. Here,

Defendant Honeywell fraudulently pretended and conspired with other Officials to falsely

pretend that the Plaintiff record owners’ Lot 15A had been “claimed as public land”, Case

2:2009-cv-00791; Doc. # 245.

PRIMA FACIE IDIOTIC AND INCOMPREHENSIBLE “claim as public land”

2. Idiotically, Defendant Corrupt C. E. Honeywell perpetrated organized judicial crimes:

“At the heart of each case, Plaintiffs allege that they are the owners of Lot 15A in the
Cayo Costa subdivision of Lee County, Florida (Dkt. 1, ¶1; Dkt. 5, ¶1). Plaintiffs
attempt to challenge a resolution adopted in December 1969 by the Board of
Commissioners of Lee County, Florida, where 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, et al., 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 (11th Cir. Mar 5,
2009). To fully establish the need for a global pre-filing injunction, the Court will
summarize the pertinent facts of each previous case that Plaintiffs filed relating to this
property dispute.” See Doc. # 245, 07/20/2010, p. 3.

PRESCOTT v. STATE OF FLORIDA PROVED ORGANIZED GOVERNMENT CRIME

3. Prescott, et al., v. State of Florida, et al., 343 Fed. Appx. 395, 396-97 (11th Cir. Apr. 21,

2009) had stated:

“I. BACKGROUND
A. Current Action
The Appellants are owners of Lot 15A in the Cayo Costa subdivision in Lee
County, Florida.”
 “The Appellants' Lot 15A is on the west side of the Cayo Costa subdivision on
the Gulf of Mexico and is adjacent to land that was claimed through Resolution
569/875 to create the Cayo Costa State Park.”

CRIMINAL & ILLEGAL “pre-filing injunction”, DOC. # 245

4. Here, the Plaintiff record owners had paid real property taxes, Lot 15A, Cayo Costa,

and were entitled to defend against, e.g., publicly recorded Government racketeering, wire

fraud, extortion, retaliation, obstruction of justice, deliberate deprivations, and bribery.

See Lee County Tax Collector’s public records, riparian Lot 15A, Cayo Costa.

5. Here, Defendant Crooked Judge Honeywell had no authority to fraudulently conceal

Plaintiffs’ unimpeachable record ownership, real property tax payments, rights to own

and exclude Government from Lot 15A, Cayo Costa, under color of facially forged

“resolution 569/875” and by prima facie criminal and illegal means of a “global pre-filing

injunction”, Doc. # 245, Case 2:2009-cv-00791.

BRIBERY & OBSTRUCTION OF JUSTICE

6. Here in exchange for bribes, Defendant Crooked Judge Honeywell obstructed justice,

retaliated, and deliberately deprived the Plaintiff record owners of their fundamental

rights to redress Governmental grievances and defend against unlawful Government

seizures of Plaintiffs’ private property, racketeering, extortion, due process and equal

protection violations, 1st, 14th, 4th, 7th U.S. Constitutional Amendments.

FRAUDULENT CONCEALMENT AND CONSPIRACY TO CONCEAL

7. Here, Defendant Honeywell fraudulently concealed and conspired to conceal that, e.g.:

a. The Plaintiffs are the unimpeachable record “owners of Lot 15A in the Cayo

Costa subdivision of Lee County, Florida”, pursuant to, e.g., Ch. 712, Fla. Stat., Florida’s

self-enforcing Marketable Record Title Act;

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b. No “claim” or “resolution”, whatsoever, could have possibly involuntarily

divested the Plaintiffs of their perfected marketable record title to Lot 15A, Cayo

Costa, PB 3 PG 25 (1912);

c. No legislator or lawmaker, whatsoever, had any authority to usurp judicial

authority to make a judicial order transferring title against Plaintiffs’ will;

d. No judge had ever made any order or judgment involuntarily alienating Lot 15A;

e. “The Board of Commissioners of Lee County, Florida,” never adopted any

“resolution 569/875” in December 1969;

f. No name of any commissioner appeared on prima facie scam “O.R. 569/875”;

g. The prima facie sham “land claim” lacked any color and was legally

incomprehensible;

h. Lot 15A was never “claimed as public land”;

i. Prima facie extortion and fraud scheme “O.R. 569/875” was not any “claim”;

j. The law did not recognize facially incomprehensible “resolution 569/875”;

k. The legal description of Lot 15A, Cayo Costa, did not appear in the sham

“resolution”;

l. No valid authentic legal description appeared in the facially forged “resolution”;

m. Falsified “resolution 569/875" had never legally existed;

n. Said facially forged “resolution” was not any writing, instrument, or muniment of

title;

o. The fake “resolution” was not any conveyance, instrument, or eminent domain

document;

p. The prima facie unauthorized “global pre-filing injunction” was an organized

Governmental crime scheme for criminal and illegal purposes of, e.g., extortion and

racketeering;
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 q. Def.Honeywell obstructed justice under color of authority & scam “O.R.

569/875”;

r. Def. Lee County Commissioners had no authority to sign any “claim” of

uncertain and legally un-described lands.

8. For criminal purposes of racketeering, extorting Plaintiffs’ property, fabricating

and/or falsifying the “adoption” of fake “resolution 569/875”, Defendant Crooked U.S.

Judge Honeywell concocted in Doc. # 245, p. 2:

“I. BACKGROUND
Plaintiffs have a persistent history of filing baseless, incomprehensible and repetitive
pleadings which have impacted the resources of this Court, as well as of Defendants.”

Here, Plaintiff unimpeachable record owners of Lot 15A had a history of pleading well-

proven and publicly recorded Government fraud, corruption, deliberate deprivations,

extortion, retaliation, racketeering, et al., which tarnished the reputation of this Court as a

ruthless criminal organization.

RECORD LACK OF ANY instrument & COVER-UP OF SCAM “O.R. 569/875”

9. Neither Defendant Honeywell nor Defendants Lee County were the holder of any

instrument and/or fake “O.R. 569/875”.

RECORD LACK OF grantor AND grant – FAKE “claim”, “O.R. 569/875”

10. § 695.09, Fla. Stat., states:

695.09 Identity of grantor.--No acknowledgment or proof shall be taken, except as

set forth in s. 695.03(3), by any officer within or without the United States unless the
officer knows, or has satisfactory proof, that the person making the acknowledgment
is the individual described in, and who executed, such instrument or that the person
offering to make proof is one of the subscribing witnesses to such instrument.

Facially forged “claim”, fake “resolution 569/875”, was not any genuine legally

comprehensible paper, but a prima facie extortion and racketeering scheme. Here, there

had been no grant and/or conveyance. Here, there was no grantor, and nothing uncertain

and legally un-described could have possibly been granted to anyone and/or Lee County.

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Here, nobody knew who could have possibly executed facially unlawful and unauthorized

scam “O.R. 569/875”. Here, there were no subscribing witnesses.

NO entitlement to enforce FACIAL SCAM “O.R. 569/875”

11. § 673.3011, Florida Statutes, states:

673.3011 Person entitled to enforce instrument.--The term "person entitled to

enforce" an instrument means:
(1) The holder of the instrument;

Here, Defendants Lee County were never the holder of any instrument “O.R. 569/875” and

not entitled to enforce prima facie unauthorized scam “O.R. 569/875”. See Title XXXIX,

Commercial Relations, Ch. 673, Negotiable Instruments.

12. Here, Defendant Corrupt Judge Honeywell fraudulently concealed that prima facie

sham “claim” “O.R. 569/875” was not any negotiable instrument and on its face null and

void. On its face, publicly recorded scam “O.R. 569/875” lacked any authentic legal

description, legislative names, signatures, history, acknowledgment, and witnesses. Here as a

matter of law, nobody was entitled to enforce unauthorized extortion and fraud scheme

“O.R. 569/875”.

LEE COUNTY, FL, WAS NOT ANY real party in interest

13. Pursuant to Florida’s real party in interest Rule, Fla. R. Civ. P. 1.210(a), Lee County

was not any real party in interest. Here, Lee County had no interest, was not any record

owner, and Lee County’s presence was neither necessary nor proper to a complete

determination of the cause. Id.

CONSPIRACY TO FRAUDULENTLY CONCEAL AND EXTORT

14. Here, Defendant Honeywell fraudulently concealed and conspired to conceal that Lee

County, FL, had never been any real party in interest.

RECORD LACK OF ANY GENUINE INSTRUMENT

15. § 697.10, Fla. Stat., states:

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 697.10 Liability for error in mortgage deed or note.--In any action relating to real
property, if the court shall find that any person has prepared an instrument which due
to an inaccurate or improper legal description impairs another person's title to real
property, the court may award to the prevailing party all costs incurred by her or him
in such action, including reasonable attorney's fees, and in addition thereto may
award to the prevailing party all actual damages that she or he may have sustained as
a result of such impairment of title.

Here, facially forged “O.R. 569/875” was not any genuine instrument. Here, there was no

authentic accurate legal description in said prima facie sham and legally

incomprehensible “claim”.

16. Here, Defendant Crooked Honeywell recklessly slandered and conspired with other

Officials to slander Plaintiffs’ perfected marketable title to said Lot 15A under color of

falsified “resolution 569/875”, which impaired Plaintiffs’ title to their record riparian real

property on the Gulf of Mexico, Parcel 12-44-20-01-00015.015A.

17. Here, Plaintiffs were entitled to all costs incurred by them while defending their record

Lot 15A ownership against, e.g., publicly recorded Government racketeering, retaliation,

extortion, obstruction of justice, fraud on the Court, deliberate deprivations, and

bribery.

ORGANIZED GOVERNMENT CRIME SCHEMES

18. Defendant Corrupt Judge C. E. Honeywell evidenced, e.g., organized Government

crime, racketeering, extortion, obstruction of justice, bribery, retaliation, Doc. # 245,

pp. 3 through 12:

“To fully establish the need for a global pre-filing injunction, the Court will
summarize the pertinent facts …”

Here Defendant Honeywell summarized facts pertinent to the conclusively proven

fraudulent Governmental concealment and cover-up of the prima facie criminality,

illegality, and nullity of extortion and fraud scheme “O.R. 569/875”.

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19. In each fixed “case”, Judges and/or Government Officials conspired to, e.g., defraud,

deliberately deprive, racketeer and extort Cayo Costa land and money from the Plaintiffs

under fraudulent and false pretenses of, e.g., facially forged “resolution 569/875” and

“frivolity”. Here, obstruction of justice, retaliation, bribery, and silencing the Plaintiffs

were unlawful acts. See Doc. # 245, pp. 3 through 12.

CONSPIRACY TO FALSIFY ATTORNEY’S FEES AND EXTORT

20. Defendant Charlene Edwards Honeywell conspired with other Government Officials and

Defendants to falsify attorney’s fees.

21. Defendant Crooked Judge Honeywell knew and fraudulently concealed that Defendant

Appellee Kenneth M. Wilkinson, Lee County Property Appraiser’s Office had never

incurred and could not have possibly incurred actual and necessary attorney’s fees in the

amount of $5,000.00 …