Case 2:10-cv-00089-CEH-TGW Document 28 Filed 06/30/10 Page 1 of 4

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA
FT. MYERS DIVISION

JORG BUSSE; JENNIFER FRANKLIN

PRESCOTT,

Plaintiffs,

v. Case No. 2:10-CV-89-CEH-TGW

JOHN EDWIN STEELE; SHERI POLSTER

CHAPPELL; ROGER ALEJO; KENNETH M.
WILKINSON; JACK N. PETERSON;
GERALD BARD TJOFLAT; RICHARD
JESSUP; JUDGE BIRCH; JUDGE DUBINA;
RICHARD A. LAZZARA; CHARLIE CRIST;
LEE COUNTY VALUE ADJUSTMENT
BOARD; LORI RUTLAND; EXECUTIVE
TITLE CO.; JOHNSON ENGINEERING, INC.,

Defendants.

MOTION FOR EXTENSION OF TIME

NOW COMES the United States of America, on behalf of its

officers, Chief Judge Joel Dubina and Circuit Judges Gerald

Tjoflat and Stanley Birch of the United States Court of Appeals

for the Eleventh Circuit; District Judges Richard Lazzara, John

Steele and Magistrate Judge Sheri Chappell of the United States

District Court for the Middle District of Florida; and Deputy

United States Marshal Richard Jessup (collectively, “federal

defendants”); and moves for an extension of time in which to

answer or otherwise respond to Plaintiffs’ complaint. In support

of this motion, the United States shows unto the Court as

follows:
 Case 2:10-cv-00089-CEH-TGW Document 28 Filed 06/30/10 Page 2 of 4

1. On February 9, 2010, Plaintiffs filed a complaint

naming the above-referenced federal defendants, and others, as

defendants in their “individual private and official” capacities.

2. The docket sheet indicates that service of process was

effected upon Judge Steele on May 1 [DE-12] and upon Judge

Chappell on May 4 [DE-13], with corresponding answer deadlines of

June 30 and July 3, 2010, respectively. Fed. R. Civ. P.

12(a)(2)&(3). There is no indication that any other federal

defendant has yet been served, and therefore the undersigned is

unable to ascertain their answer deadlines at this time.

3. A suit against a federal officer in his or her official

capacity is in effect a suit against the United States. See

Swank, Inc. v. Carnes, 856 F.2d 1481, 1483 (11th Cir. 1988). It

is the position of the United States that Plaintiffs’ complaint

should be construed as an official capacity suit against the

United States and not the individual federal defendants.

4. The undersigned Special Attorney is entering a general

notice of appearance on behalf of the United States and timely

filing a motion to dismiss the complaint contemporaneous with the

filing of this motion.

5. The United States respectfully suggests to the Court

that the same defenses it asserts in its motion to dismiss the

official capacity suit would apply with equal force if the

federal defendants were sued in their individual capacities;

2
 Case 2:10-cv-00089-CEH-TGW Document 28 Filed 06/30/10 Page 3 of 4

however, if the Court were to construe this as an individual

capacity suit and were to require them to answer, then the

federal defendants require additional time to seek and obtain

authorization for the undersigned to represent them in their

individual capacities. See generally 28 C.F.R. § 50.15.

6. Accordingly, the undersigned makes a limited appearance

on behalf of the individually-named federal defendants solely for

purposes of seeking this extension of time so as to avoid the

possibility of entry of default against them should the Court

construe this as an individual capacity suit and not summarily

dismiss such individual capacity claims as frivolous.

7. Local Rule 3.01(g) requires “that the moving party

shall confer with counsel for the opposing party in a good faith

effort to resolve the issues raised by the motion.” Insomuch as

Plaintiffs are proceeding pro se, Local Rule 3.01(g) is

inapplicable.

WHEREFORE, the individual federal defendants request an

extension of time, up to and including thirty (30) days from such

future date as the Court might require them to answer an

individual capacity suit, in which to answer or otherwise respond

to Plaintiffs’ complaint.

3
 Case 2:10-cv-00089-CEH-TGW Document 28 Filed 06/30/10 Page 4 of 4

Date: June 30, 2010 Respectfully submitted,

TONY WEST
ASSISTANT ATTORNEY GENERAL

By: /s/ Matthew L. Fesak

MATTHEW L. FESAK
Special Attorney and
Assistant United States Attorney
Civil Division
310 New Bern Avenue, Suite 800
Raleigh, NC 27601-1461
Telephone: (919) 856-4530
Facsimile: (919) 856-4821
E-Mail: matthew.fesak@usdoj.gov
N.C. Bar No. 35276

CERTIFICATE OF SERVICE

I do hereby certify that I have this 30th day of June, 2010,

served a copy of the foregoing upon the below-listed party

electronically or by placing a copy in the U.S. Mail, addressed

as follows:

Jorge Busse
c/o Legal and Consular Department
100 N. Biscayne Blvd.
Suite 2200
Miami, FL 33132

Jennifer Franklin Prescott

P.O. Box 845
Palm Beach, FL 33480

/s/ Matthew L. Fesak

Assistant United States Attorney

4
 UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
FORT MYERS DIVISION
[“TRANSFERRED” FROM: SOUTHERN DISTRICT OF FLORIDA, WEST PALM BEACH DIVISION]

JENNIFER FRANKLIN PRESCOTT, DR. JORG BUSSE,

Plaintiffs,

versus Reassigned Case # 2:09-CV-00791-CEH-SPC

ROGER ALEJO; KENNETH M. WILKINSON; JACK N. PETERSON; ROGER
DESJARLAIS; LEE COUNTY, FLORIDA; LEE COUNTY VALUE
ADJUSTMENT BOARD; LORI L. RUTLAND; STATE OF FLORIDA, BOARD
OF TRUSTEES OF THE INTERNAL IMPROVEMENT TRUST FUND; STATE
OF FLORIDA, DEPARTMENT OF ENVIRONMENTAL PROTECTION; CHAD
LACH; CHARLES “BARRY” STEVENS; REAGAN KATHLEEN RUSSELL;
KAREN B. HAWES; ROGER DESJARLAIS; CHARLIE GREEN; BOB JANES;
BRIAN BIGELOW; RAY JUDAH; TAMMY HALL; FRANK MANN; UNITED
STATES ATTORNEY(S); SEAN P. FLYNN; E. KENNETH STEGEBY; DAVID P.
RHODES; A. BRIAN ALBRITTON; CYNTHIA A. PIVACEK; JOHNSON
ENGINEERING, INC.; STEVEN CARTA; MIKE SCOTT; HUGH D. HAYES;
GERALD D. SIEBENS; STATE OF FLORIDA ATTORNEY GENERAL;
WILLIAM M. MARTIN; PETERSON BERNARD; SKIP QUILLEN; TOM
GILBERTSON, RYAN LENGERICH, NEWS PRESS,
Defendants.
PUBLISHED PUBLIC NOTICE OF
JUDICIAL CORRUPTION & FRAUD
____________________________________________________________________________/
PUBLISHED PUBLIC NOTICE OF CORRUPTION, CASE FIXING, AND CRIMES
BY DEF. CROOKED JUDGE CHARLENE E. HONEYWELL, AND IN PARTICULAR,
OF HER IDIOTIC INCOMPREHENSIBLE ‘PUBLIC LAND CLAIM’ [DOC. # 213, P. 5]
OF PLAINTIFFS’ LOT 15A, AS CONVEYED IN REFERENCE TO PB 3, PG 25 (1912)
Lot 15A, among other property, was claimed as public land (“Resolution 569/875")
(Dkt 5, Ex. 3, p. 9).”
PUBLISHED RECORD AS TO PUBLIC CORRUPTION: DOC. # 93-1; 2:2007-cv-00228
___________________________________
/S/JENNIFER FRANKLIN PRESCOTT
Governmental Corruption & Fraud Victim, Plaintiff, pro se
P.O. BOX 845, Palm Beach, FL 33480; T: 561-400-3295
______________________________________
/S/JORG BUSSE, M.D., M.M., M.B.A., C.P.M.
Judicial Corruption & Crime Victim; Plaintiff, pro se, JRBU@aol.com
State Cert. Res. Appraiser, Licensed Real Estate Broker, Mortgage Broker, Appraisal Instructor;
ATTACHED EXHIBITS & EVIDENCE OF PUBLIC CORRUPTION: DOC. # 93-1
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 ;' J,:'
TROY PARNELL 'F'"
REGISTERED REAL ESTATE BROKER

lA~~~~ Street TELEPHONE

18131 275-858(
~~
x~~x~:x~x
FORT ~IYERS. I<'LORIDA ~ 33901

January 29, 1999

Mr. James G. Yaeger

County Attorney'
P. O. Box 398
Ft. Myers, Florida 33902

Re: Second Revised Plat of Cayo Costa Subdivision!

Accretion

Dear Mr. Yaeger:

In your letter of December 15, 1998 you informed me that

you were requesting input from department heads. I would
appreciate any information you have received. I also would
like your opinion of the validity of the enclosed instrument.

If this instrument is legal, then it would appear that the

County Commission could file such an instrument pertaining
to any waterfront subdivision in Lee County, thereby robbing
the waterfront owners of any waterfront properties.

~ would appreciate hearing from you at your earliest

convenience. For ready reference I have enclosed copies of
our previous correspondence.
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Sinze-:r,':"y? / ,- .

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STE\NART & KEYES \:::::::",,/
ATTORNEYS AT LAW

1534 HENDRY STREET

P.O. DRAWER 790
FORT MYERS. FL 33902-0790
WILLIAM L. STEWART (841) 334-7477
WILLIAM A. KEYES. JR. FAX (841) 334-7941

May 14, 1997

Mr. Troy Parnell

1429 Colonial Boulevard
Suite 203
Fort Myers, FL 33907 "

Dear Troy:

You have asked me about the ownership of the accretion to the

area between Lots 2 and 3, Block 14, Second Revised Plat of Cayo
Costa Subdivision and the Gulf of Mexico.

The Plat of this subdivision does not have any dedication of

easements for any purpose. It divides the property into numbered
blocks with spaces between, which are obviously intended" to be
roads. It does, however, have the following wording:
II NOTE
All streets 60' wide
All alleys 20' wide
All lots shown in uniformly square
Blocks 50' x 130' other lots scale measure.1I
The area between
the Blocks and the Gulf of Mexico has no
designation, but it is part of the street since all streets lead
to it and there is no line indicating the end of the streets.

Our Supreme Court has repeatedly held that when a lot on a

subdivision pl'at borders on a street each lot owner owns to the
center of the street, and, when the street is on the border of the
subdivider's property title of the,lot owner extends to the out~r
limits of the street. .

In the case of Caples v. Taliaferro, 197 So. 861 the Supreme

Court said:

IIThere are also authorities holding that

when a
street or highway is laid out wholly on the
margin
of a grantor' s land, a conveyance of the lands
abutting such street or highway carried the fee to
the entire u -widt h of
- - --- - ..:J" such street or highway unless
 ~
'(

r
, .Mr. Troy par'nell
I May 14, 1997

I Pa ge Two

"The more specific question here involved is this:

Where a street, way or walk way is laid out wholly
on the margin of the grantor's lands, said street,
way or walk way being bordered by navigable water,
does a conveyance of land abutting on such street,
way or walk way, as designated on the plat, carry
the fee to the"width of such street, way or
walkway, together with all riparian rights incident
thereto, unless expressly reserved?
While there is some conflict in the decisions on
this quest, we have reached the conclusion that the
answer should be in the affirmative."

There now appears to be considerable accretion to this street

bordering these lots. Since ti tIe to the land under the street
belongs to you the accretion belongs to you. In the case of
Mexi co Bea ch Cor pora tion v. st. Joe pa per Cor pora tion, 97 So .2d
708, the Court said:
"The common-law rule which vests title to soil
formed along navigable waters by accretion or
reliction in owners of abutting land is in force in
Florida."

I have assumed that you did not install groins or other

devices that caused this accretion. In the case of Board of
Trustees of the Internal Improvement Trust Fund v. Sand Key
Associates, Ltd., 512 So.2d 934, our Supreme Court said:

"Waterfront owner who did not participate in

construction of improvement which, together wi th
natural causes, caused accretion, had vested right
to new lands formed as a result of accretion,
notwithstanding fact that accretions or relictiohs
occurred in part because of artificial
improvements.

Very truly yours,

STEWART & KEYES

~ 1~
Will i am L. Stewar';-\
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 '
TROY PARNELL '" '
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REGISTERED REAL ESTATE BROKER 1£..
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TELEPHO:
xx'Xx<;.C:£x]tx3{IX3(x
~ID'{~~~ 9 41 ~~275-85
MAIL'~X'MX3922 Rogers Street
~'ORT~rYERS.
FLORIDA3~3 3 9 01

December 11, 1998

Lee County Attorney's Office

P. O. Box 398
Ft. Myers, Florida 33902 ..

Attention: Judy

Pursuant to your request in our phone conversation of December la,

1998 I enclose the following:
(1) Copy of the Resolution recorded in OR 569 page 875.

(2) Copy of a letter from Attorney William L. Stewart.

(3 ) Copy of the plat with our property indicated - same

being Lots 2 & 3 of Block 14.

The Board of Trustees of the Internal Improvement Trust Fund of

the State of Florida has made an offer to purchase the property
but has said because of the recorded Resolution we do not own Gulf
front property.

It would seem that this instrument does not appear to be a valid

instrument because it is not executed by any Authority, as a matter
of fact it is not signed by anyone. Neither was the instrument
notorized since there wasn't anything to acknowledge. A Title
Insurance Policy did not reveal the existence of the Resolution:
A title search would not know where to look for such an instrument.

There are no recordings related to the Resolution on the preceding

ten pages of OR 569 page 875. The enclosed one page instrument 'is
the Resolution in its entirety.

We are of the opinion that the Resolution does not affect our
ownership of Gulffront property since the public lands referred to
in the Resolution, specifically the Gulffront, are in fact not public
lands and are part of the plat.

The representative of the State (Buyer) advised me to present this

matter to the County Attorney's Office or to seek an opinion from

the County Attorney. Z;'~ '

TPIk /<-~ '-7

SOUTHWEST FLORIDA
BOARD OF COUNTY COMMISSIONERS Writer's Direct Dial Number: (941) 335-2236

John E. Manning
District One

Douglas R. SI. Cerny

District Two December 15, 1998
Ray Judah
District Three Mr. Troy Parnell
Andrew W. Coy 3922 Rogers Street
District Four
Fort Myers, Fl 33901
John E. Albion
District Five
Re: Second Revised Plat of Cayo Costa Subdivision/Accretion
Donald D. Stilwell
County Manager
Dear Mr. Parnell:
James G. Yaeger
County Attorney

Diana M. Parker
I am in receipt of your December 11, 1998 letter on the above. We will attempt
County Hearing to review the history of the County Resolution and let you know our position as soon
Examiner
as possible. In order to expedite review, I have taken the liberty of forwarding your
inquiry to the attention of the County lands Department.

Very truly yours,

2~~
County Attorney

JGY/jm
xc: J. W. French, Director, Public Works
Karen Forsyth, County lands
Timntn\l Innce .6.eeiet~nt ('nllnt\l .6.ttnrnc\l
 ,,'-'

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3922 Rogers Street

Ft. Myers, Florida 33901

February 12,1999

Mr. James G. Yaeger

County Attorney
P.O. Box 398
Ft. Myers, Florida 33902
Re: Second Revised Plat of Cayo Costa
Subdivision/Accretion

Dear Mr. Yaeger:

I enclose a copy of my letter of January 29, 1999 and

also a copy of your letter of December 15, 1998.

Since it has been two months I would think that your

County Lands Department has had time to respond.
At any rate I would appreciate your advising me as to
when I can expect an answer.

Sin;_.~;%lY /.
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LEECO~TY
SOUTHWEST , .
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FLORIDA
,./9:~~
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BOARD OF COUNTY COMMISSIONERS Writer's Direct DialNumber: (941) 335-2236

John E. Manning
District One

Douglas R. SI. Cerny February 22, 1999

District Two

Ray Judah
District Three
Mr. Troy Parnell
Andrew W. Coy
District Four
3922 Roger Street ,
Fort Myers, FL 33901
John E. Albion
District Five
Re: Second Revised Plat of Cayo Costa Subdivision
Donald D. Stilwell
County Manager
Dear Mr. Parnell:
James G. Yaeger
County Attorney
In response to your correspondence to Mr. Yaeger, the Lee County Attorney's
Diana M. Parker
County Hearing
Office researched the history of the second revised plat of the Cayo Costa Subdivision
Examiner and governing case law on accretion and reliction. Based on this research, we conclude
that the public may have a valid claim to the accreted lands on the Gulf side of the Cayo
Costa Subdivision. Moreover, it is the Board's policy to retain public lands for public
purposes rather than relinquishthose intereststo private entities. It would be acceptable
for the County to relinquish its interests in this property if the intent is to transfer the
property in question to the State as part of the CARL Program. Your letter indicates that
the'Board of Trustees of the Internal ImprovementTrust Fund of the State of Florida has
offered to purchase the property, but claims that the resolution recorded in the public
records and reflected in the County Commission Minute Books calls into question your
client's ability to convey fee simple title to the accreted lands. This office would
recommend that the Board of County Commissioners release the public's interest in the
accreted land on the condition that the County deed is held in escrow until the closing
with the State. At that time, the deed would be released and available for recordation in
the public records.

If your client is interested in pursuing this course of action, please contact me at

your earliest convenience so that we may discuss the details of this transaction.

f2 i egards

1~;uJr~tif a{f~;v1.
Donna Mafie Collins
Assistant County Attorney

DMC/amp
cc: James G. Yaeger, County Attorney
Timot~y Jones, Assistant County Attorney

S:\LU\DMC\DMCL TR\PARNELL.WPD

P.O. Box 398, Fort Myers, Florida 33902-0398 (941) 335-2111

Lee On Line Access (LOLA) Internet address http://lola.co.lee.fI.us
~"",~"~~,~""""""""",,,",.,r::..nlrw"c
 Dep~rtment of
Environmental Protection
Marjory Stoneman Douglas Building
Jeb Bush 3900 Commonwealth Boulevard Colleen M. Cast
Governor Tallahassee, Florida 32399-3000 Secretary

February 2, 2006

Troy Parnell
3922 Roters Street
Ft. Myers, FL 33901

RE: Cayo Costa Project, Lee County

0.30 Acres

Dear Property Owners:

As agent for the Department of Environmental Protection of the State of Florida, I ,«ould like to extend a
cash offer in the amount of $222,000.00, to purchase the above referenced property located in Lee
County, Florida. The State of Florida is offering to purchase this property due to its location within an
area that qualifies for State acquisition as part of the State's Florida Forever Program. The Division of
State lands will be the agent for this transaction.

Over the past several years, the State has diligently worked on acquiring property within the Cayo Costa
Project. The state has had the properties appraised numerous times and has made several offers to
property owners. Recent purchases within the last year have caused the Division of State Lands to
reevaluate its priorities. I was recently informed that the funds and time allocated for this project are
now limited.

Prior to extending an offer to purchase property, Florida law requires an appraisal to be completed by an
independent real estate appraiser. The appraiser is asked to give the market value of the property. The
appraisal is confidential, by law, until a contract is signed by the Seller and approved by the Division of
State lands. Your offer was formulated based on such an appraisal.

Please notify me within 60 days of receipt of this offer and I will prepare, for your review, an
Agreement to purchase your property. It is important for you to know that this is a voluntary
program, and you are under no obligation to sell your property or participate in this program.

Many times owners prefer to donate their property and, in some cases, tax benefits may be realized from
a donation. . An accountant, tax professional, or the Internal Revenue Service can provide you with
additional information. Please let us know if you are interested in donating the property for environmental
purposes.

If I may provide additional information or assistance, please do not hesitate to call me at the number
below. I hope to hear from you soon.

~
Si.~cereIY' .

-
.- ~"-.;
abrina Carter '-.,
-"

land Acquisition Agent

(.~ c c~~k
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Bureau of Land Acquisition

(850) 245-2669 ext. 4702
 JEFF PARNELL
REAL ESTATE INVESTMENTS, INC.
LICENSED REAL ESTATE BROKER
0)5 KELLYROAD TEll
SUITE 112 (239) ~
cRS. FLORIDA 33908 FA.'{ (239

K.M. Roesch, Jr. & Anita Roesch May 15,2007

15411 NW 46th Ln.
Chi efland, FL 32626

Re: Gulf front lot on Cayo Casta ,

Dear Mr. & Mrs. Roesch:

My father, Troy Parnell and the estate of William Reynolds own the northern most gulf
front lots (lots 1A & 2A). On December 10, 1969 the Lee County Commission voted to
deed itself an area of accretion to the west of certain gulf front lots. The effect of this
makes what was once gulf front lots no longer gulf front. They had no right to do this.
We have done much research on this matter. There have been recent rulings by the courts
to support our position that the area of accretion belongs to the gulf front owners. I have
had discussions with attorneys in Miami and Sarasota that specialize in this matter and
they have suggested our case is so strong that we hire a local attorney here in town.

My father is prepared to move ahead with a law suit. Through our correspondence with
the county and discussions with attorneys we believe the county, state or DEP will not or
can not do anything until they are sued. However, we will not go ahead without the
support of all the effected lot owners who will benefit from this. I have identified seven
lot owners who will benefit from this and included the lots on the enclosed plat.

The estimated cost to file the suit is $15,000. Each owner will most likely have to survey
their lots including the accretion area at a cost of $7,500.each. Even though our case is
extremely strong and supported by recent precedence we should be prepared to go to trial
at an estimated cost of an additional $25,000. This would be a total of approximately
$13,215.00 for each lot owner.

The average depth ofthe accretion is about 1,400 feet. Most of the single lots are 50 feet
wide. That would be about 70,000 square feet more property for each 50 foot lot.
Considering the state has offered as much as $18.00 per square foot for gulf front lots, the
reward for filing the law suit is impressive and the risk appears to be very low.

I am asking that each owner please contact me by telephone and let me know how you
feel about this issue so I can see what kind of consensus we have.

JJ/Tr;ld
7?eff ~arnell
Gulf Front Lot Owners Effected:

Troy Parnell & Reynolds Real Estate, LLP - Lots 2 & 3

Busse, Jorg, PO Box 1126, Naples, Fl34106 - Lot 15A

Lewis, Allen E., Kensington Investments, 347 Congress St., #3A, Boston, MA, 0221
Lots 23A & 24A
,
Elrubaie, Salman B 11810 Isle of Palms Dr., Ft. Myers Beach, FL 33931 - Lot 27A

Baucomm, Ruth K, Tr., 28232 Tung Oil Rd., Kinston, AL 36453 - Lot 28A

Garvey, William R, 519 Clubside Dr., Naples, FL 34110 - Lot 67A

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