ROGER DESJARLAIS PUBLIC CORRUPTION

ROGER DESJARLAIS FEDERAL CORRUPTION COMPLAINT

DEFENDANT ROGER DESJARLAIS

1. The Plaintiff declared unimpeachable record owners of said platted riparian subject Parcel # 12-44-20-01-00015.015A “on the Gulf of Mexico” sue Defendant Roger Desjarlais in his private individual and official capacity [“Deputy Chief”; Lee County Property Appraiser’s Office].

2. This legal action is also based on Defendant Roger Desjarlais’ criminal acts of record such as, e.g., deliberate deprivations, fraud, and conspiracy under 18 U.S.C. §§ 241, 242.

FRAUDULENT CONCEALMENT

3. Maliciously, Defendant Roger Desjarlais misconstrued the 1912 record Plat of Survey of the undedicated private residential Cayo Costa Subdivision. Said Defendant knew and concealed that pursuant to said 1912 record Plat, all lands between the natural boundaries of the “Gulf of Mexico” on the West side and “Charlotte Harbor” on the East side of said Lee County residential private undedicated Subdivision have been the “property of A.C. Roesch” and/or his successors-in-title, who paid any and all property taxes since 1912. Because Lee County, FL, had never paid any property taxes, and/or asserted any claim, adverse possession was factually and legally impossible. No eminent domain judicial proceedings ever took place. Desjarlais fraudulently concealed and conspired to conceal that only a judgment in a court of law pursuant to Florida’s strict eminent domain and/or adverse possession Statutes could have possibly transferred record title to Lee County, FL.

4. Here, Defendant Desjarlais knew and concealed that the Plaintiff unimpeachable record owners hold exclusive unencumbered and automatically quieted record title to the Lee County riparian subject Parcel # 12-44-20-01-00015.015A, which touches the “Gulf of Mexico”, Plat Book 3, page 25 (1912). In particular, Desjarlais knew that any and all “Lee County” involuntary alienation “claims” were factually and legally impossible and fraudulent. No judicial due process and/or proceedings had ever taken place. No title ever transferred to Lee County, FL.

5. Defendant Roger Desjarlais fraudulently concealed

a. Plaintiffs’ true marketable and automatically quieted record title to;

b. Plaintiffs’ true and unimpeachable riparian record ownership of;

c. The true record legal boundary of the “Gulf of Mexico” on the West side of;

d. The true record Parcel area of more than 2.6 Acres of; and

e. The true record Parcel depth of more than 2,300 ft of

Plaintiffs’ riparian 2.6 plus Acres Parcel # 12-44-20-01-00015.015A “on the Gulf of Mexico”, PB 3, PG 25 (1912).

6. Defendant Roger Desjarlais fraudulently concealed, e.g., the

a. Fraud of facially forged and unplatted “Lee County” “parcel 12-44-20-01-00000.00A0”;

b. Fraud of facially forged and unplatted “Lee County” “parcel 07-44-21-01-00001.0000”;

c. Fraud of forged “Lee County” “claim” “O.R. 569/875”, which never legally existed;

d. Facial fraud of a forged and unplatted “park”, which never legally existed, PB 3, PG 25;

e. Fraud of falsely pretended involuntary alienation by facial scam “O.R. 569/875”.

7. Defendant Roger Desjarlais knew and fraudulently concealed that

a. Lee County never held any record title to Plaintiffs’ riparian 2.6 plus Acres Parcel # 12-44-20-01-00015.015A, which admittedly adjoins and/or touches “the Gulf of Mexico”.

b. No property interest and/or estate in Plaintiffs’ said 2.6 plus Acres riparian Parcel “on the Gulf of Mexico” ever transferred to Lee County;

c. The Plaintiffs hold exclusive unimpeachable marketable record title to riparian Parcel # 12-44-20-01-00015.015A, which admittedly abuts and touches “the Gulf of Mexico”;

d. Florida’s Marketable Record Title Act [M.R.T.A.] had automatically quieted and perfected Plaintiffs’ free and clear record title, which was derived from the Federal Land Patent recorded in the Lee County, Florida, public records and Grantor/Grantee Index.

e. Lee County never owned Plaintiffs’ riparian 2.6 plus Acres Gulf-front Parcel # 12-44-20-01-00015.015A.

f. Lee County, Florida, never asserted any “claim” to Plaintiffs’ riparian 2.6 plus Acres Parcel # 12-44-20-01-00015.015A, which abuts “the Gulf of Mexico”.

g. Even if [merely arguendo and/or hypothetically] Lee County would have asserted a colorable “claim” [which Lee County never did], Florida’s Marketable Record Title Act would have automatically extinguished and/or barred such a fictitious “claim”;

h. The Lee County Property Appraiser’s Office fraudulently pretended “Lee County” “ownership” of Plaintiffs’ riparian street land and private street easement, which abuts the “Gulf of Mexico” [Parcel # 12-44-20-01-00015.015A] as subdivided and platted by the original Cayo Costa Subdivision Owner and Developer Alexander C. Roesch, PB 3, PG 25 (1912);

i. Defendants Roger Desjarlais and Kenneth M. Wilkinson fraudulently pretended “Lee County” “ownership” of Plaintiffs’ riparian 2.6 plus Acres Parcel # 12-44-20-01-00015.015A, which abuts the “Gulf of Mexico” as admitted by Roger Alejo under oath on 11/17/2009, PM, and conclusively evidenced by said Plat Book 3, p. 25.

FRAUDULENT CONCEALMENT OF PRIVATE STREET & ALLEY EASEMENTS,

LEE COUNTY PLAT BOOK 3, PAGE 25 (1912); WWW.LEECLERK.ORG

8. Defendant Roger Desjarlais knew and/or fraudulently concealed that

“The plat for Cayo Costa Subdivision [Lee County Plat Book 3, p. 25 (1912)] indicates a 60-foot wide roadway easement.”

“The plat to Cayo Costa Subdivision is recorded at Plat Book 3, Page 25. The recorded plat designates roadways throughout the subdivision; however, there is no dedication of the roads to the public indicated on the plat.”

See 12/29/2000 “Memorandum from the Office of [Lee] County Attorney, Joan C. Henry”;

see www.LeeClerk.org; PB 3, PG 25 (1912).

9. Here, in the known and publicly recorded prima facie absence of any dedication of the private platted “paper” street and alley easements, PB 3, PG 25 (1912), to the public, said Defendant Desjarlais and the other Officials knew that Lee County, Florida, could not have possibly been the owner of Plaintiffs’

a. Record private Subdivision street and alley easements as conveyed by implied covenant;

b. Record private adjoining riparian street lands and street easement along the natural boundary of the “Gulf of Mexico”, which were conveyed as an integral part of Plaintiffs’ riparian subject Parcel # 12-44-20-01-00015.015A, PB 3, PG 25.

MATERIAL AND MALICIOUS MISREPRESENTATION

10. Defendant Roger Desjarlais materially and maliciously misrepresented

a. Plaintiffs’ true, unimpeachable, and free and clear record ownership of;

b. Plaintiffs’ true marketable, automatically quieted, and perfected record title to;

c. The true platted “Gulf of Mexico” record legal subject Parcel boundaries of;

d. The true record subject Parcel depth of more than 2,300 ft of; and

e. The true record subject Parcel area of more than 2.6 Acres of

Plaintiffs’ riparian Parcel # 12-44-20-01-00015.015A “on the Gulf of Mexico”.

VIOLATION OF HOUSE BILL 521

WILLFUL USE OF FRAUDULENT & DECEPTIVE APPRAISAL METHODOLOGY

11. With wanton disregard for the truth and conclusive public record evidence, Defendant Desjarlais violated House Bill 521 (H.B. 521). Here, Desjarlais knew that in the 2009 legislative session, an important change to Florida Statutes was passed and then approved by Governor Crist on June 4, 2009. See 194.301, F.S., as amended by Ch. 2009-121, Laws of Florida (H.B. 521). In this case, Defendant Desjarlais, the “Deputy Chief”, had the burden of proof, and perverted the truth. Here, Desjarlais knew, concealed, and conspired to conceal that the forged depth of “135 feet” could not have possibly been the true record subject Parcel depth of more than 2,300 feet. In particular, Desjarlais knew that more than 2,300 feet separated the Eastern subject Parcel boundary from the admitted Western “Gulf of Mexico” natural legal boundary on the record. See Defendant Desjarlais’s Geographical Information System (G.I.S.) data on record.

12. Pursuant to § 194.301, the Plaintiff exclusive property taxpayers and unimpeachable record title holders have been entitled to a determination by the Courts of the appropriateness of the appraisal methodology used in making the assessment and/or agricultural use classification of Plaintiffs’ 2.6 plus Acres riparian Gulf-front Parcel. The value and use classification of Plaintiff Petitioners’ Constitutionally protected property [Lee County riparian Parcel # 12-44-20-01-00015.015A “on the Gulf of Mexico”] had to be determined by an appraisal methodology that complies with the criteria of § 193.011 and professionally accepted appraisal practices. Defendant Desjarlais knew that Defendant Alejo’s perjury and forged “fixed boundary” and their fabrications of an un-platted and fictitious “135 ft x 50 ft” “lot” violated Ch. 193, and § 193.011. Here, Defendant Desjarlais knew and concealed that Defendant Alejo perjured himself and recklessly perverted of, e.g.:

a. The true riparian Gulf-front subject Parcel area and/or size of more than 2.6 Acres;

b. The true riparian Gulf-front subject Parcel depth of more than 2,300 feet to the “Gulf of Mexico”;

c. Plaintiffs’ true unimpeachable record ownership of said 2.6 plus Acres riparian subject Parcel, which admittedly abuts and/or touches the “Gulf of Mexico”.

Here, Defendant Roger Desjarlais knowingly used and conspired to use fraudulent appraisal methodology for the unlawful purpose of defrauding and deliberately depriving the Plaintiff unimpeachable record title holders of said automatically quieted, unencumbered and paramount title to said 2.6 plus Acres riparian subject Parcel.

FORGERY

13. Defendant Roger Desjarlais forged, and conspired to forge, e.g., the

a. Ownership data pertaining to;

b. Title information to;

c. Legal boundary data of;

d. Depth of; and

e. Area, size, and/or Acres of;

Plaintiffs’ riparian Parcel # 12-44-20-01-00015.015A, which admittedly is bounded by and touches the “Gulf of Mexico”, PB 3, PG 25 (1912).

BREACH OF PUBLIC TRUST

14. Defendant Roger Desjarlais breached the public trust and wrongfully concealed

a. Plaintiffs’ true, unimpeachable, and perfected record ownership of;

b. Plaintiffs’ true marketable and automatically quieted record title to;

c. The true record “Gulf of Mexico” natural legal boundary of;

d. The true record subject Parcel depth of more than 2,300 ft of; and

e. The true record area of more than 2.6 Acres of

Plaintiffs’ riparian Parcel # 12-44-20-01-00015.015A “on the Gulf of Mexico” for the unlawful purpose of defrauding and deliberately depriving the Plaintiffs and unimpeachable record owners of platted real property in the private undedicated residential Cayo Costa Subdivision, Lee County Plat Book 3, page 25 (1912).

CIVIL AND CRIMINAL FRAUD

15. Defendant Roger Desjarlais fraudulently pretended that

a. The Plaintiffs allegedly did not own their riparian “paper” street lands and private street easements “on the Gulf of Mexico”, which was a reckless perversion and misconstruction of Plaintiffs’ grant in reference to said 1912 record Plat;

b. The Plaintiffs purportedly did not apply for agricultural classification of their riparian Gulf-front lands and private accreted riparian Gulf-front street easement;

c. Plaintiffs’ riparian 2.6 plus Acres Parcel # 12-44-20-01-00015.015A “on the Gulf of Mexico” had

i. A depth of only “135 feet” [rather than the true more than 2,300 feet to the natural “Gulf of Mexico” monument and boundary];

ii. An area of only 6,750 square feet or approx. 0.15 Acres [rather than the true more than 2.6 plus Acres];

iii. Plaintiffs’ adjoining riparian street lands and private street easement were purportedly “owned” by “Lee County” in the prima facie absence of any “Lee County” title to Plaintiffs’ platted record “paper” street and accretions thereto, which abut and/or touch the “Gulf of Mexico”.

16. Here, Defendant Roger Desjarlais’ fraudulent concealment of the true platted record natural Parcel and Subdivision boundary of the “Gulf of Mexico” defrauded the Plaintiff unimpeachable record owners of, e.g.:

a. More than 94 [ninety four] % of their Constitutionally protected riparian lands and Parcel # 12-44-20-01-00015.015A “on the Gulf of Mexico”;

b. Plaintiffs’ private and unencumbered street and alley easements across said admittedly private undedicated residential Subdivision, PB 3, PG 25 (1912).

DEFAMATION AND LIBEL

17. When the Plaintiffs blew the whistle on said egregious fraud and public corruption, Defendants Roger Desjarlais and Kenneth M. Wilkinson defamed and conspired with other State and County Officials to defame the Plaintiffs as “vexatious” and “litigious”. Rather than answer to Plaintiffs’ conclusively proven allegations, said Defendants fraudulently pretended that Plaintiffs’ claims for relief were “frivolous” and that Plaintiffs’ owned a forged “0.15 Acres” “fixed boundary” lot rather than the record 2.6 plus Acres Parcel of public record, which forever is bounded by the ever-changing “Gulf of Mexico”.

DELIBERATE DEPRIVATIONS

18. Defendant Roger Desjarlais knew and concealed that the Plaintiffs have a Constitutionally guaranteed right to own the entire width [50 ft] of their riparian street land and private implied street easement along the “Gulf of Mexico” [2.6 plus Acres riparian Parcel # 12-44-20-01-00015.015A] as platted and subdivided, Lee County PB 3, PG 25 (1912).

19. Plaintiffs bought their riparian Gulf-front Parcel # 12-44-20-01-00015.015A in reference to said 1912 Plat of Survey of the undedicated private residential Cayo Costa Subdivision, Lee County Plat Book 3, p. 25 (1912).

20. Defendant Roger Desjarlais deliberately deprived the Plaintiffs of their fundamental Constitutional right to own and exclude the Government and public from their

a. Private 2.6 plus Acres riparian Gulf-front Parcel # 12-44-20-01-00015.015A;

b. The platted private implied street and alley easements all over said undedicated private Subdivision, PB 3, PG 25.

CONSPIRACY

21. Defendant Roger Desjarlais agreed and/or conspired with Defendant Kenneth M. Wilkinson and other Lee County Officials to fraudulently pretend, e.g., that

a. The Plaintiffs only own the paltry fraction of “135’ x 50’” of their riparian Gulf-front Parcel # 12-44-20-01-00015.015A with a surveyed area (2008) of approximately more than 2.6 Acres in size. See Exhibit: 2008 Survey of Plaintiffs’ 2.6 plus Acres riparian Gulf-front Parcel. See also Geographical Information System data for and Aerial Photography of Plaintiffs’ 2.6 plus Acres riparian subject parcel at Defendants’ website: www.LeePA.org.

b. The Plaintiff unimpeachable riparian record owners purportedly only own the paltry and un-platted area of 6,750 square feet [135’ x 50’] of their 2.6 plus Acres riparian subject Parcel # 12-44-20-01-00015.015A rather than the true record area of approximately more than 2.6 Acres as surveyed [2,300 plus feet x 50 feet];

c. Lee County owns Plaintiffs’ riparian street lands and private street easement “on the Gulf of Mexico” in the prima facie absence of any Lee County title, adverse possession, eminent domain, and/or involuntary alienation proceedings.

TRESPASS

22. Defendant Desjarlais and his material misrepresentation encouraged the public to trespass onto, e.g.

a. Private Cayo Costa Subdivision lands, PG 3, PG 25;

b. Private implied Cayo Costa Subdivision street and alley easements, PB 3, PG 25 (1912);

c. Plaintiffs’ 2.6 plus Acres riparian Parcel 12-44-20-01-00015.015A “on the Gulf of Mexico”;

d. Plaintiffs’ adjoining riparian “paper” street lands and private street easement along the “Gulf of Mexico” with a depth of more than 2,170ft [more than 2,300ft-130ft]

23. Defendant Desjarlais and his fraudulent data encouraged the public to start open fires, camp, and erect tents on Plaintiffs’ private implied street and/or alley easements within the facially undedicated Cayo Costa Subdivision, PB 3, PG 25 (1912), which endangered the Plaintiffs’ lives and destroyed their property. See, e.g., April 2008 Cayo Costa Fires Reports and Records.

WIRE AND/OR INTERNET FRAUD

24. Defendant Desjarlais used the wires and/or Internet [see, e.g., www.LeePA.org] to materially misrepresent the true record riparian ownership of, e.g., Plaintiffs’

a. Record private Cayo Costa Subdivision street and alley easements, PB 3, PG 25 as conveyed by implied covenant;

b. Record adjoining riparian “paper” street lands and private street easement along the “Gulf of Mexico” with a depth of more than 2,170ft [more than 2,300ft-130ft].

OBSTRUCTION OF JUSTICE AND REAL PROPERTY & CONSTITUTIONAL LAW

25. Defendant Roger Desjarlais perverted the truth and conclusive and reliable public record evidence of Plaintiffs’ unimpeachable and unencumbered record ownership of and automatically quieted title to Plaintiffs’

a. Record private platted Cayo Costa Subdivision street and alley easements, PB 3, PG 25 as granted by implied covenant;

b. Record adjoining riparian “paper” street lands and private street easement along the “Gulf of Mexico” with a depth of more than 2,170ft [more than 2,300ft-130ft].

26. Roger Desjarlais knew, fraudulently concealed, and conspired to conceal that the Plaintiffs have fundamental Constitutional rights to own and exclude Government(s) and the public from their

a. Private platted implied Cayo Costa Subdivision street and alley easements, PB 3, PG 25;

b. Plaintiffs’ adjoining riparian “paper” street lands and private street easement along the “Gulf of Mexico” with a depth of more than 2,170ft [more than 2,300ft-130ft].

27. Here, Defendant Desjarlais knew and fraudulently concealed that Lee County, Florida, never held title to Plaintiffs’ said Constitutionally protected property. Said Defendant Desjarlais deliberately obstructed the just and timely adjudication of the pro se Plaintiff riparian street and subject Parcel owners’ claims for relief by fraudulently pretending, e.g., “frivolity” of Plaintiffs’ causes of action and allegations, which had been conclusively proven by the public record evidence such as, e.g., PB 3, PG 25 (1912). Said Defendants deliberately deprived and defrauded the Plaintiff riparian street land owners under fraudulent pretenses of “frivolity” and a “Lee County” “resolution” [“O.R. 569/875”], which they concealed, and conspired to conceal, could not have possibly created and/or transferred any interest and/or estate to Lee County, Florida. Here, said Defendant interfered with the orderly administration of justice and real property law by giving false information and withholding evidence. In particular, said Defendant Desjarlais gave false and fraudulent information about

a. “Lee County” facially forged “parcel 12-44-20-01-00000.00A0”, which A. C. Roesch had never platted, subdivided, or legally described in reference to said 1912 record Subdivision Plat.

b. “Lee County” facial forgery “O.R. 569/875”, which on its face, was not any instrument, muniment of title, or conveyance, but a prima facie fraud scheme and scam, which could not have possibly created and/or transferred any title, interest, and/or estate to Lee County, Florida;

c. “Lee County” facially forged “parcel 07-44-21-01-00001.0000”, which A. C. Roesch had never platted, subdivided, or legally described in reference to said 1912 record Subdivision Plat, PB 3, PG 25;

d. “Lee County” facially forged “park”, which A. C. Roesch had never platted, subdivided, or legally described in reference to said 1912 record Subdivision Plat, PB 3, PG 25;

e. “Lee County” forged and un-asserted sham “claim”, which the law does not recognize;

f. Plaintiffs’ unimpeachable and unencumbered record title to their adjoining platted riparian “paper” street lands and private street easement, which admittedly and indisputably touch and abut the “Gulf of Mexico” [see PB 3, PG 25, www.LeeClerk.org; public recordings of 11/17/2009 Lee County Value Adjustment Board Hearing: testimony and perjury of Defendant Roger Alejo];

g. Plaintiffs’ unimpeachable and unencumbered marketable record title to their adjoining riparian subject Parcel # 12-44-20-01-00015.015A, which extends to the ordinary high water mark of the “Gulf of Mexico” as platted and surveyed by, e.g., Measurement Science Corporation in 2008;

h. Plaintiffs’ unimpeachable and perfected marketable record title to their adjoining riparian “paper” street [unimpeachable title to which runs with Plaintiffs’ marketable title to subject Parcel # 12-44-20-01-00015.015A], which Florida’s self-enforcing Marketable Record Title Act had automatically quieted in the early part of the last century.

28. On 04/21/2009, the 11^th Federal Appellate Circuit had dispositively declared the Plaintiffs the unimpeachable record owners of their riparian Gulf-front subject Parcel # 12-44-20-01-00015.015A, marketable unencumbered title to which had been automatically quieted by Florida’s self-enforcing Marketable Record Title Act:

“The [Plaintiffs’-]Appellants’ Lot 15A [riparian Gulf-front Parcel 12-44-20-01-00015.015A, Lee County Plat Book 3, p. 25 (1912)] 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.”

See PRESCOTT, No. 08-14846, 2009 U.S. App. LEXIS 8678, 2009 WL 1059631.

Here, said Defendant Desjarlais fraudulently concealed that the “Cayo Costa State Park” is “adjacent to” and entirely North of the riparian private undedicated residential Cayo Costa Subdivision, PB 3, PG 25 (1912). No “park” exists in the riparian and facially undedicated private Cayo Costa Subdivision pursuant to said 1912 Subdivision Plat of Survey. Here, Lee County never asserted any “claim”. No title ever transferred to Lee County by virtue of the fraudulently pretended “claim”.