Notice Of Removal

 

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

IN RE: MATTER OF: 

MARIO JIMENEZ

Petitioner/Father,

 

and

 

KAREN WIZEL

Respondent/Mother.

FAMILY DIVISIONCase No.: 11-21207-FC-04

 

JUVENILE DIVISION

Case No.: D13-15193A-B (D003)

(closed)

 

DOMESTIC VIOLENCE DIVISION

Case No.: 12-17840-FC-04 (closed)

Case No.: 12-17838-FC-04 (closed)

Case No.: 11-10881-FC-04 (closed)

 

 Notice Of Removal To United States District Court

Comes now the Petitioner, MARIO JIMENEZ, and notifies the parties and the Court that this cause has been removed to the jurisdiction of the United States, by stating the following:

  1. There have been, and continue to be, violations against the civil and constitutional rights of this undersigned Petitioner and his minor children in this cause, which have not been duly protected, and which have unjustly enriched attorneys in detriment of Petitioner and his minor children.
  2. Accordingly, and commensurate with certain issues within these state proceedings also giving independent rise to federal subject-matter jurisdiction, this cause has now been removed to the UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA.
  3. As the Court and all parties can clearly confirm, the attached Notice and Warrant regarding Petition For Removal was filed in said federal court on February 27th, 2015.
  4. The parties and this Court are hereby given formal notice that the combination of filings made under both this cause now herewith, as well as within the aforementioned federal court, automatically divests this Court of any and all further authority and jurisdiction over these proceedings – bar none (see 28 USC § 1446 (d)) – and, therefore, there will be NO more hearings, orders, or any other proceedings held, made, or done within this state cause until, and unless, further notice or order is first made by the judge of said United States District Court.

Respectfully submitted,
________/S/_________________
Mario Jimenez, M.D.
Pro Se Petitioner

 CERTIFICATE OF SERVICE

I hereby certify that, on this 27th day of MONTH, 2015, a true and complete copy of the foregoing petition for removal, by depositing the same in the United States mail, postage prepaid, has been duly served upon all parties of record in the lower state proceedings, to-wit:

Ana C. Morales, Esq.,                                                                                                                                                                                                 Anastasia Garcia
Attorney for Former Wife                                                                          Guardian Ad Litem
Reyes & Arango Moore, P.L.                                                                     agarcia821@aol.com
amorales@reyesmiller.com,
yreyes@reyesmiller.com,
efile@reyesmiller.com
jsegebre@reyesmiller.com

and, that the same is being also filed this same date within the lower state trial court proceedings.

_______/S/__________________

Mario Jimenez, M.D.
Pro Se Petitioner