IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR

MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION

MAMIE WILSON, DESHAWN GREEN,

JOSEPH WARREN, JR., as Members,
Board Members and on Behalf of the
CHURCH OF GOD TABERNACLE, INC.;
CHURCH OF GOD, TRUE HOLINESS OF
MIAMI, INC.; NATIONWIDE HOLINESS
CHURCH OF BROTHERLY LOVE, INC.;
OPERATION KEEP COOL, INC.; SILVER
STONE SINGING CONVENTION, INC.;
STAR OF DAVE'S TEMPLE, INC.; and
YOUNG LAND USA, INC.,
Plaintiffs,
Vs.

DARRELL WILSON, SR., EMANUEL

WILSON, STEVEN HIGG, AL ALLEN
(A/K/A ELWYN WILSON) AND ROBERT
WATTS,
Defendants.
________________________________/

DEFENDANT DARRELL K WILSON Sr., EMERGENCY MOTION SEEKING COURT SANCTION TO

TRANSFER THE INSTANT, WILSON V. WILSON CASE, TO FEDERAL COURT JURIDICTION FOR
CIVIL RIGHTS VIOLATIONS, PURSUANT TO THIS COURT DEC. 21-2012 AND SEPT, 24th 2015
ORDER[S] UNDER U.S.A 28:1331cv FEDERAL QUESTION HUMAN AND CIVIL
RIGHTS VIOLATIONS AND 18:241 CONSPIRACY AGAINST CITIZEN RIGHTS,

Comes Now Defendant Darrell K Wilson Sr., by and through the under sign and state the
following, The Court sept 24th hearing granting the Receiver omnibus Emergency Motion
against Defendant Darrell Wilson Sr., was based on two principles of due process
1

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
violations, hearsay, no facts supporting the omnibus Emergency Motion just hearsay, , as
the Court appointed Receiver Seth Heller, [ the accuser] didnt show up to be question or
give testimony as to any facts in support of his own Emergency Motion, and racism, the
court granted the Receiver baseless Motion, in its entirety, because Defendant Wilson is
afro American Male, indigent and pro se, while on the other hand the Receiver counsel
is a former colleague of the court,[ EX- Miami-Dade County Judge] and White
American. Defendant Wilson is the Victim of race discrimination and judicial improprieties
including civil rights violations,
1. on Sept. 24th 2015, this court departed from its absolute mandatory requirements
of upholding the rule of both state and federal Law and instead trashed defendant
Wilsons constitutional rights and gave unlawful favor to the courts former
colleague, Retired Miami-Dade County Judge/ Attorney Amy Donner and did
unlawfully struck all of Defendant Wilson pleadings without following the rules of
law, simply because the courts former colleague asked the court to do so.
2. Defendant Darrell K Wilsons Sr., rights to counsel, while facing criminal
proceeding, [ contempt of Court] was denied, in open court from the bench by the
judge, [see transcript], Wilsons right to present evidence, right to speak and be
heard in opposition of the false and unsubstantiated allegation Presented against
him, was also denied, Defendant. Wilson right of equal protection under Florida
Law, right to call upon witnesses, and his fundamental right to due process was,
systematically Denied Sept. 24th 2015, Because Mr. Wilson is a Black Afro
American Male and ex Miami-Dade County Judge / Attorney , Amy Donner is a
White female and being a former colleague of judge cuteo her word, without
producing any facts or evidence, trumps state and federal Law sept 24th .
2

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
3. Judge Jorge cuteo pretty much said in his sept 24th executed order; [after hearing
from both sides ,
[ which is incorrect the court refused to hear from the Defendant, ] The court
only heard from the ex-Judge Amy Donner, her two witnesses and Attorney
Roniel R Rodriguez IV whos client, miraculously purchased all Defendant
Wilson Civil Rights at a sheriff sale.,

4. The expression on the judge face and his distinct body language spoke volumes
and his deep concentration to ever word spoken by counsels he give them each
sincere eye contact but when Defendant Wilson expressed the desire to cross
examine the Receiver witnesses, the court sat aloof, no eye contact and began
playing with a rubber band between his fingers.. While over ruling most every
question asked of the witnesses by Defendant Wilson.
5. The courts Mine and decision to grant the Receiver Baseless Emergency Motion
had clearly been made up prior to the sept 24th ex-parte hearing , as it related to
Defendant Wilsons defense, in fact, yet while Ex-Judge Amy Donner was in her
presentation the court interrupted her and stated the court is ready to make its
ruling, without hearing from the defense.
6. , The court wasnt interested in hearing anything the Defendant had to say in Law
or evidence , the courts mine was made up long before the Sept 24th ex-parte
hearing, to grant the Ex- Judge her clients Motion and the sanctions requested.
no CIVIL rights were afforded Mr. Wilson, in Judge cuteo Court, because all Mr.
3

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
Wilson civil Rights as guaranteed by the U S constitution were purchased at a
Miami-Dade County sheriff sale by Miami Attorney Roniel R Rodriguez IV client/
and partner Stuart R Kalb, a/k/a Scorpion Holdings LLC.
7. Therefore according the Receivers counsel and Roniel R Rodriguez IV
arguments Mr. Wilson lacks standings to represent himself or by counsel, His civil
rights in the Wilson V. Wilson case are owned by Money Judgment creditor Stuart
R Kalb, and the court swallowed that hoax hook line and sinker.. Because Mr.
Wilson is a Black Miami-Dade County tax payer/ registered voting citizen living
in Miami 57 years without a criminal record.
8. Retired Miami Police officer and community activist, help promoted Carlos Alverez
campaign for Miami-Dade County Mayor, help religious and social community
organizations calm the community during the Arthur McDuffie 1980 Riots, and
actually saved the life of two white couples unfortunately driving down the wrong
street on N .W 62st from being murdered by street mob when the metro police
verdict was announced During the horrible McDuffie beatings,, where was Amy
Donner then or Stuart R Kalb or Roniel R Rodriguez IV,
9.

Mr. Wilson was appointed by Miami-Dade county commissioner Barbara carey as

the vice chair of C.I.P ,CITIZEN INVESTIGATION PANEL police oversight Board ,
during his service as a Miami Police officer Mr. Wilson arrested several criminals
who violated Florida LAW.

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE
DADE COUNTY, FLORIDA
CASE NO.12-10447
10447 CA (23)
(23
CIVIL ACTION
10. we are a country of Laws in where all must comply, police, Judges, Lawyers,
and citizens must obey the Laws
Law of Florida and U.S . Or we would be no different
than the lawless countries around the world, which are resting grounds for the
terrorist cell called ISIS.
The SEPT, 24TH 2015 Ex-parte
parte Hearing, in Judge Cuteo court that Granted the Receiver its
Entire Omnibus Emergency Motion without the receiver being present was an ABSOLUTE
MISCARIAGE OF JUSTICE in and for the 11 circuit court of Miami
Miami-Dade
Dade County Florida

To all men be known:

This Certificate of ownership of all Keith Wilson Human and civil Rights, including but not limited to
all of his interest in the Wilson V. Wilson case # 12-10447 CA 23 is hereby issued to Miami Attorney
A
Roniel R Rodriguez IV , Client Stuart R Kalb a/k/a Scorpion Holdings LLC , Judgment Creditor, to have
and hold as the owner in law of said rights and interest.

Miami-Dade
Dade County Sheriff Sale 2014 / Defendant Wilson rights /Miami
Miami Attorney Roniel R Rodriguez IV

Sheriff Bill of Sale of Keith Wilson civil rights and interest purchased by Stuart R Ka
Kalb
5

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION

But the moral issue was set in 1819 and 1820 when the United States finally stated,
in unequivocal terms, that enslaving people was a "wrong" and those who engaged
in the African trade were no better than common pirates. And, like common pirates,
they deserved to be disbarred. [The United States used a different word but we replaced it
with disbarred]

11. Stuart R Kalb and Miami Attorney Roniel R Rodriguez IV are part of a criminal
racketeering operation here in Miami-Dade County Florida in where they own a few
county Judges and county officials.
U.S CONSTITUTION SAY MIAMI-DADE COUNTY SHERIFF SALE OF WILSON CIVIL RIGHTS UNLAWFUL

12 . The fundamental question is, on Sept 24th 2015, did Miami Judgment creditor and
Attorney/ Roniel R Rodriguez IV, [who altered Miami-Dade County Judge VICTORIA DEL PINO
COURT ORDER] violated Federal Law and the U. S Constitution slavery Act, when he stood
before Miami-Dade County Judge Jorge Ceuto court and told the court his client Stuart R Kalb
a/k/a Scorpion Holdings LLC purchased all , Afro American, Darrell Keith Wilson Sr., Civil Rights
in the pending Wilson V. Wilson case at a Miami-Dade County Sheriff Sale, and as such
Darrell Keith Wilson Sr., lack standings to speak to the issues against him or participate in
these proceedings in his own defense
13. How then was it even possible that an experienced respected Miami-Dade County Judge
would allow his court room to be transformed into an 1800 century African trade slave
proceedings, And disgrace years of human rights struggles and civil war principles including
the brave soldiers men and woman who lost their life fighting for justice under the banner of

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
equality including federal law, that the court even entertain such an asinine proposition from
an Attorney who openly engaged in Federal slave trading violations in his court.
14. Shockingly, and most disturbingly the Judge was all too happy to accommodate the
counsel[s] pleading and with a smile, and the stroke of his signature on the unconstitutional
sept, 24th order.
15. Keith Wilson civil rights were instantly dissolved, without as much as a trial, or any
resemblance of due process proceedings sept 24th and Defendant Wilson Civil Rights were given
to Miami Attorney Roniel R Rodriguez IV and his partner Judgment creditor Stuart R Kalb, then
the court threaten Mr. Wilson and stated when the court find you Guilty of violating the
courts Dec. 21-2012 order you may be sent to prison.
16. If the court found Defendant Wilson guilty on all counts of the Receivers baseless
Omnibus Emergency Motion, to show cause, based strictly on hearsay, it wouldnt require too
much brightness to conclude Oct 22 Hearing is a staged event the court mine is already made
up, Guilty by color not by deeds. Coming to court Black is the new Crime at the 11 circuit..
MIAMI ATTORNEY RONIEL R RODRIGUEZ IV
17 . This would be the same Roniel R Rodriguez, IV who, in May 2013, falsified the court writ of
possession Order [Judge Victoria Del Pino] and executed a fraudulent affidavit to the MiamiDade County sheriff office instructing the Sheriff to evict Darrell Keith Wilson Sr., off his
7

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
Homestead resident property, pursuant to the Fraudulent shammah Judgment execution, in
where the Shammah Judgment was issued in error , that ,[ according to Florida Department of
Business and professional regulations, ] shammah was an Unlicensed contractor] and as such
the court lack jurisdiction in granting a unlicensed contractor a Money default Judgment
pursuant to state Law 489.127.
18.

Despite the fact Judge Victoria Del Pino in May 2013 court Order removed Darrell Keith

Wilson Sr., from CREDO LLC eviction proceedings.

19. Attorney Roniel R Rodriguez IV and his extremely wealthy and unscrupulous business
partner Stuart R Kalb, are determine in their resolve in acquiring property they want
including violating state and federal Laws, altering any Judge order, lie to any circuit court
Judge, file fraudulent Motions, use unlawful police staff to violate state Law as a means of
taking Darrell Keith Wilson Sr., Homestead mix use real Property, by [e]very and any illegal
trick necessary to accomplish their agenda.
20. Creating a false Judgment debt and using the falsity of the Judgment debt to intervene in
any case where Darrell K Wilson Sr., may have a Money interest in , to intervene Not to
satisfy the alleged Judgment debt, No..no..no.. but to ensure Darrell K Wilson Sr., never acquire
enough cash to hire a real Law firm to go after the Kalb Scam operation and sue for Money
Damages and actually win because the evidence against Stuart R Kalb and Roniel R Rodriguez IV
are so very much pronounced.
8

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
21. This would be the same Roniel R Rodriguez IV , Attorney , who secretly hold
undisclosed managing Member interest in, CREDO LLC , who unlawfully instructed MiamiDade North side , Police Sergeant to assist his staff , [CREDO LLC ] in an absolute improper self
help eviction of Darrell Keith Wilson Sr., and his family from his 20 year, Homestead resident
property, in July 19th 2012, in execution of a defective Shammah Default Judgment, without a
writ of possession, or court order.
22 . Rodriguez IV committed what most American citizens term as an ISIS terrorist act in
direct violation of Florida Chapter 83, simply because he says hes a lawyer, Well, fact
check , so was Scott Rothstein but hes in prison.
23. Mr. Rodriguez IV so desperate so obsessed in stealing and prostituting his position as
officer of the court to take from low income citizens of Miami-Dade County Florida, like a Bully
taking a Childs Lunch money in school, while wearing Rolex watch in court to show a since of
prosperity, when in reality his watch actually represent deceit, fraud and prostitution of his
oath of office..Mr. Rodriguez IV , unlawful behavior in this instant case seemingly reflect that
of ISIS terrorist wearing a suit. He defecates on the rule of Law and do so with a Jeffery
Dahmer like Smile.
24. [as part of the Kalb scam Racketeering scheme] Miami Attorney Roniel R Rodriguez IV
prepared, what he knew to be a fraudulent Ex-parte Emergency Motion before Miami-Dade
County Judge Lester Langer Court and told the court his partner, in CREDO LLC, just purchased
9

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
Darrell Keith Wilson Sr., Homestead mix use Property at a Sheriff sale July 18th 2012 and the
place is under unsafe structure violations and there exist emergency condition of public safety
threat, where vagrants are entering the property and the new owners need police assistance
to secure the building.
He didnt tell the court it was Darrell K Wilson Sr, and his Family living in the property, which
the court would have immediately denied the writ of police assistance and instructed counsel
to follow Florida Chapter 83 landlord tenant eviction proceedings in removing the so called
vagrants off his clients alleged property..

25. Mr. Rodriguez IV is calling the 20 year property owner Darrell Keith Wilson Sr., former city
of Miami Police officer and his family, vagrants, Rodriguez IV is the most embarrassing
spectacle in the Miami Legal community to be allowed a law license, he bring nothing but
contempt of court behavior in this instant case.
26. Miami Attorney Roniel R Rodriguez IV is a habitual liar, he lied to judge Darrin P Gayle
Judge Langer, he lied to Judge Lisa Walsh, he lied to Judge Gill Freeman, he Lied to Judge
Barbara Aceres, judge Stand Blake, judge dresnick and Judge Jorge cuteo dont have a abysmal
clue of the level of deceit Rodriguez IV and Stuart R Kalb will go to defraud the court in the
execution of their agenda. Rodriguez IV has repeatedly lied to the Florida Bar, on several
complaints filed against him by other victims and are currently pending resolution.

10

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
27. Rodriguez IV falsified the court records and filed an Emergency EX Parte Motion when in
reality, his plan was to trick the court into issuing him a improper writ of police assistance to
evict Darrell Keith Wilson Sr., on an ex-parte basis, without following Florida chapter 83.,
Landlord tenant procedures, and the court trusting in Rodriguez IV fraudulent affidavit, did
issued the requested writ.
RACISM IN MIAMI-DADE COUNTY FLORIDA CIRCUIT COURT
No matter how wrong or improper Attorney Rodriguez IV behavior as an officer of the court
is or the plethora of evidence that reflect same, , it doesnt matter, to some of Miami-Dade
County officials because Mr. Wilson at the end of the day regardless of his service as a
Miami Police Officer, and upstanding citizen, he is still a Black Man in a terribly racist
southern legal system , that still uses 1800 century calculations in determining the guilt or
innocence of people of color in America , that actually encourage and favor Mr. Rodriguez
IV racist attacks on Miami Minority community like ISIS terrorist unlawful attacks on
American interest, terrorism starts in our legal system at home and spread abroad., . Until
we as red blood , American citizens demand accountability of our judiciary and clean up our
own corrupt legal community including demanding Florida Bar reform, we cant began to
check mate other folks backyards domestic or foreign. Darrell Keith Wilson Sr., 2015
28. When Miami-Dade Police responded to the resident, after being called by Mr. Wilson, they
looked at Rodriguez IV Ex-parte court order Writ of police assistance, look at the Address on
Darrell Keith Wilson Sr., Drivers License, saw that the Address match the subject resident and
told Mr. Rodriguez IV, CREDO LLC staff, that the court writ of police assistance was not proper
procedure in removing occupants from a dwelling, that they will have to follow Florida chapter
83 to properly have Mr. Wilson and his family removed from these premises.

11

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
29. As much as Rodriguez IV didnt want to have Mr. Wilson in court to speak before any Judge
and unravel the Kalb Scam criminal operation of Florida constitutional violations, he was
nonetheless, forced to file eviction proceedings against Mr. Wilson, but as part of the criminal
scam to alter Judge Victoria Del Pino order.
30. Mr. Rodriguez IV filed a Motion with the court, the day of the hearing to determine rent,
to dismiss Darrell K Wilson Sr., from his partner CREDO LLC eviction complaint.
31. the court Hearing no objections granted the motion, in open court, and refused to allow
Mr. Wilson to speak, because the court stated to Mr. Wilson youre no longer a party to the
eviction action and therefore you lack any standings to speak , you are dismissed as a
Defendant Mr. Wilson the Court said But, before the ink dried on the order, Mr. Rodriguez IV
altered the courts order and executed a writ of possession to the Miami-Dade County Sheriff
office, in where he placed Mr. Wilson Sr,., name on the courts writ of possession affidavit,
instructing the sheriff to specifically evict Darrell K Wilson Sr., in absolute contrast to the
courts direct order which removed and dismissed Mr. Wilson Sr., from the law suit, this
matter currently is pending Florida Bar investigation.
32. Mr. Rodriguez IV is a carbon copy of the disgraceful disbarred and currently jailed Attorney
Scott Rothstein [ a dishonest individual ] , waiting to be discovered and looking to taking down
as any Miami-Dade county 11 circuit court judge[s] with him as possible when the feds finish
building their case.
12

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
33. On sept 24th 2015, Miami Attorney Roniel R Rodriguez IV, millionaire business partner ,
Stuart R Kalb appeared in court , in support of his interest in the slave trade purchase of all
Darrell Keith Wilson Sr., Human and civil rights, and look on, as his partner Miami Attorney
Roniel R Rodriguez IV stood before Miami Dade County Judge Jorge Cuteo and stated;
Your Honor, We own all Mr. Wilson civil Rights in this case, Darrell Keith Wilson Sr., lack
standing to represent himself or by counsel we purchased his interest and civil rights, via
Miami-Dade County sheriff sale under the Cartronics Default Money Judgment assignment
to Scorpion Holdings LLC
Sounds like an 1800s African slave trade movie script straight out of Hollywood California

In conclusion:
34. Whats the difference between ISIS terrorist in the Middle East and the illegal actions in
the 11th Circuit Court in and for the southern District of Florida by officers of that court, at the
end of the day, both resolutions, takes something from its victims that the Law says.. they are
not legally entitled to have ISIS terrorist or Attorneys committing fraud on the court there is
no difference.

35. as a former Miami Police officer, and tax payer, I completely respect our Judicial process
and the court Authority , and will always demonstrate said respect in chambers , make no
mistake, Judge cuteo took an oath of office to up hold Florida Constitution and U.S
constitution and the statutes and Laws that shape our society , just like I, as a Former Police
13

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
officer, and thousands of other public servants, both sworn and non sworn personnel in
Government positions have a duty to the Law and the protection of its citizens against the
doers of injustice.
36. if however, judge cuteo, sept 24th ruling was just emotionally inspired and off beat or
misguided, ok, not too much of a problem, we all are subject to a few crazy mistakes, in our
public service careers but for the court to knowingly violate Mr. Wilson constitutional Civil
Rights, in defiance to federal Law, as a favor to Ex-Miami-Dade County Judge, / Attorney, Amy
Donner, this is a problem that needs federal court review, that cant be easily swept under the
judicial state court rug of misgivings.
37. The entire sept. 24th ex-parte proceedings were influenced by Stuart R Kalb, Roniel R
Rodriguez IV and Ex-Judge/ Attorney Amy Donner, in that Florida Law, and the rules of civil
procedure was barred from participating in the proceedings.
38.

On Sept 24th 2015, at 10:00 Am , in Judge Cuteo Court, Darrell Keith Wilson Sr., civil

rights of equal protection under Law as guaranteed by both state and U S Constitution, was
instead used by counsels for the Receiver and Judgment Creditor, who purchased Wilson civil
Rights as a doormat..
Amy Donners spoken word seemingly trumps Florida rules of evidence ; without
producing any facts or conclusive evidence, all Ex-Judge Amy Donner needs to say in a court
of Law, is that she Believe, an unknown Attorney wrote Mr. Wilson Pleadings and with
that mere Belief, the court accepted the hoax, hook line and sinker..and did stripped
14

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION
Defendant Wilson of his Constitutional rights of equal protection under Law and struck all of
his pending Pleadings including prohibiting his further participation as a defendant in the
Wilson v. Wilson case..

39. Perhaps Amy Donner may Now say to this same court, that some unknown attorney
wrote this Complaint Motion to transfer the Wilson v. Wilson case to federal court for civil
rights violations as she told the court [a]ll of Darrell Keith Wilson Pleadings and Motions [
which demanded her clients accountability of several thousand of missing Dollars from his
court appointed estate ] should be stricken from the record because she Believe Mr. Wilson
pleadings were written by an unknown attorney in this instant case, and therefore the court
must strike all Darrell Keith Wilson Sr., pending pleadings, and the court without asking
Defendant Wilson a single word , or without fact checking the former Judge hypothesis, or
even allowing Defendant Wilson to Defend the ridiculous allegation of an unknown Attorney
assistance theory, moments after the sept 24th 2015Ex-parte hearing executed an order, ,
striking [ a]ll Darrell Keith Wilson Sr., pleadings without due process of law, which was
precisely what occurred in the 1800s era where all negro people/ slaves had no rights and so
this court, Sept, 24TH 2015 Ex-parte proceedings were at best consistent with that era.
Whereas Civil Rights victim Darrell K Wilson Sr,. Move this court to grant a transfer of the
Wilson V. Wilson case to Federal Court Jurisdiction for the limited purposes and review of
Darrell K Wilsons Sr., civil rights violations which was witnessed by civil right Attorney court
Keeley and other[s] in attendance Sept, 24th who shall be subpoenaed as federal witnesses and
provide any other relief the court deem appropriate
Darrell K Wilson Sr., civil rights victim
Pro se litigant
786-424-1364
Keithkeith618@aol.com
CERTIFICATE OF SERVICE
I DARRELL K WILSON Sr, HEREBY CERTIFY THAT ON THIS, 13 DAY OF OCT 2015, A TRUE COPY OF THIS
EMERGENCY MOTION TO TRANSFER THE WILSON V. WILSON CASE TO FEDERAL COURT WAS E-MAIL, FAXED, OR
FAXED TO THE PARTIES OF RECORD HEREIN.
: Seth Heller
Heller & Company, Inc.
P.O. Box 331928
Miami, FL 33233
sheller@hellerandcompany.com

Mark S. Steinberg, P.A. Roniel Rodriguez IV,

Esq.
20533 Biscayne Blvd., Ste. 1243
Aventura, FL 33180
ron@rjrfirm.com

15

IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.12-10447 CA (23)
CIVIL ACTION

Jonathan M. Drucker, P.A.

2605 Ponce de Leon Blvd.
Coral Gables, FL 33134
jdruc@tdslawyers.com
Alan Marcus, Esq.
Marcus Law Center, LLC

2600 S. Douglas Rd., Suite 1111

Coral Gables, FL 33134
amarcus@marcuslawcenter.com
Darrell K Wilson
Pro se
786-424-1364Keithkeith618@aol.co

9400 S. Dadeland Blvd.

Penthouse Five
Miami, FL 33156
mss@steinberglawoffices.com
Frank Wolland, Esq.
12865 West Dixie Highway
North Miami, FL 33161
fwolland@wolland.com
Rhett Traband, Esq.
Broad & Coassel
2 South Biscayne Blvd., 21st Floor
Miami, FL 33131
Rttraband@broadandcassel.com
Court Keeley, Esq.
P.O. Box 310522
Miami, FL 33231-0522
CourtKeeley@gmail.com

16