! 

Pro Se 15 (~ev. 12116) Complaint for Violation of Civil Rights (Non-Prisoner) 

UNITED STATES DISTRICT'CbtJRT 

for the 

Northern District of FloridaDivision 

Case No. 

) 

Malvin Garnett(Pro se) M 1\'\o< ~ .c.G ) 

) Plaintiffts) 

... (to be filled in by the Clerk's Office) 

(Write the full name of each plaintiff who is filing this romplainl. 

If the names of all the plaintiffs cannot fi1 in the space above, 

) 

) Jury Trial: (check one) t8] Yes ONo 

please write "see arrciched" in the space and auach an additional ) 

page wilhthefull list of names.) ) 

Jud~~~ S"rJ:-~, Pf-r:Sti-1!{ Uwtll~,1' 

'/ASMl-11. f{M5hei{:Ll-~ J \,i-\ ea.,-,~ f"«nA~-ez ) 

Leslie Puzo (FL Bar Number: 2020-70,599) and ) 

Diksba Mehan Sharma (FL Bar Number: 2021- ) 

M«'<ll l,.,~IA.t~ 50,046) · ) 

, Defendant(s) 

(Write the full name of each defendant who is being su·ed, If the 

names of all che defendants cam1ot fit in the space above, please 

write "see attached'' in the space a11d atrach an additional page 

with rite full lisr of names. Do 1101 include addresses here.) 

) 

) 

. -A,t"Ae+'J ~J 

NOV O 2 2022 

ANGELA E. NOBLE 

CLERK U.S. DIST. CT. 

S. D. OF FLA. - MIAMI 

COMPLAINT FOR VIOLATION OF CIVIL RIGHTS 

(Non-Prisoner Complaint) 

NOTICE 

' 

Federal Rules. of Civil Procedure 5.2 addresses the privacy and security concerns resulting from public access to 

electronic court files, Under this rule, papers filed with the court should not contain: an individual's full social 

security number or full birth date; the full name of a person known to be a minor; or a complete financial account 

nu~ber. A filing may include only: the last four digits of a social security number; the year of an individual's 

birth; a minor's initials; and the last four digits of a financial account number. I 

·, 

Except as noted in this form, plaintiff need not send exhibits, affidavits, grievance or witness statements, or any 

other materials to the Clerk's Office with this complaint. 

In order for your \:Omplaint to be filed, it must be accompanied by the filing fee or an application to proceed in 

forma pauperis. 

.J 

Page I of 8 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 1 of 50
. . ' 

Pro Se 15 (Rev, 12/16) Complaint for Violation of Civil Rights (Non-Prisoner) 

I. The Parties to This Complaint 

A. The Plaintiff(s) 

Provide the information below for each plaintiff named in the complaint. Attach additional pages if 

needed, 

Name 

Address 

County 

Telephone Number 

E-Mail Address 

B. The Defendant(s) 

Malvin Garnett, 

437 SW 3rd St,#4 

Miami 

Cin• 

Miami Dade 

786-368-8079 

bkbridge718@aol.com 

Florida 

State 

33130 

Zi11 Code 

Provide the information below for each defendant named in the complaint, whether the defendant is an 

individual, a government agency, an organization, or a corporation. For an individual defendant, 

include the person's job or title (if known) and check whether you are bringing this complaint against 

them in their individual capacity or official capacity, or both. Attach additional pages if needed. 

Defendant No. 1 

Name 

Job or Title (!(known) 

Address 

County 

Telephone Number 

E-Mail Address (if k11own) 

Defendant No. 2 

Name 

Job or Title (!f known) 

Address 

County 

Telephone Number 

Leslie Puzo (Bar Number: 2020-70,599) 

Attorney with the Florida Bar Association 

Puzo 1175 NE 125TH ST #618 

North Miami 

Miami, 

305-428-2220 . ..... 

les)ie~puz .l_aw.com 

IZ! Individual capacity 

Florida 

State 

cg] Official capacity 

Zip Code 

Diksha Mehan Sharma (Bar Number;2021-50,046) 

. Attorney with the Florida Bar Association .. .. ' .. . ..... 

500 E Broward Blvd Ste 1710 .. -. . . . .. .... 

Fort Lauderdale, Florida 

Stale 

Broward 

, ... ' 

954-514-9954 

33394 

Zip Code 

Page 2 of 8 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 2 of 50
Pro Se I (Rev, 12/16) Complaint for a Civil Case 

Defendant No. 1 

Name 

Job or Title (if known) 

Street Address 

City and County 

State and Zip Code 

Telephone Number 

E-mail Address (if known) 

Defendant No. 2 

Name 

Job or Title (if known) 

Street Address 

City and County 

State and Zip Code 

Telephone Number 

E-mail Address (if known) 

Defendant No. 3 

Name 

Job or Title (if known) 

Street Address 

City and County 

State and Zip Code 

Telephone Number 

E-mail Address (if known) 

Defendant No. 4 

Name 

Job or Title (if known) 

Street Address 

City and County 

State and Zip Code 

Telephone Number 

E-mail Address (ifknawn) 

Yasmin Morshedian 

Court Reporter 

1 E Broward Blvd SUITE 700, 

Fort Lauderdale 

FL 33301 

(954) 334-1092 

info(cijymlegalservices.com 

Marie Liautaud 

232 l Laguna Circle #709 

Miami 

FL 33181 

S 16-610-4416 

Judge George Sardy 

Judge 

175 NW 1st Ave #1925, Miami, FL 33128 

Miami Dade 

FL 33128 

(305) 349-5680 

Page 2 of S 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 3 of 50
Pro Se 15 (Rev. 12/16) Complaint for Violation of Civil Rights (Non-Prisoner) 

E-Mail Address (if known) 

Defendant No. 3 

Name 

Job or Title ((f known) 

Address 

County 

Telephone Number 

E-Mail Address (if known) 

Defendant No. 4 

Name 

Job or Title (!{known) 

Address 

County 

Telephone Number 

E-Mail Address (if known) 

II. Basis for Jurisdiction 

diksha@dmsharmalaw.co 

~ Individual capacity ~ Official capacity 

General Magistrate Carlos Fernandez 

General Magistrate 

175 NW 1st Ave #1726, 

Miami, 

Cirv 

Miami Dade 

(305) 349-5557 

FL 

State 

DSomoano@jud11.flcourts.org 

~ Individual capacity ~ Official capacity 

Priscille Duvalsaint 

Licensed Mental Health Counselor 

2321 Laguna Circle #709 

Miami 

Ciry 

Miami Dade 

516-298-6060 

priscillenoelli@gmail.com 

~ Individual capacity 

FL 

Stare 

0 Official capacity 

33128 

Zip Code 

33181 

Zip Code 

Under 42 U.S.C. § 1983, you may sue state or local officials for the "deprivation of any rights, privileges, or 

immunities secured by the Constitution and [federal laws]." Under Bivens v. Six Unknown Named Agents of 

Federal Bureau of Narcotics, 403 U.S. 388 ( 1971 ), you may sue federal officials for the violation of certain 

constitutional rights. 

A. Are you bringing suit against (check all that apply): 

0 Federal officials (a Bivens claim) 

l:?5J State or local officials (a § 1983 claim) 

B. Section 1983 allows claims alleging the "deprivation of any rights, privileges, or immunities secured by 

the Constitution and [federal laws]." 42 U.S.C. § 1983. If you are suing under section I 983, what 

federal constitutional or statutory right(s) do you claim is/are being violated by state or local officials? 

Page 3 of 8 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 4 of 50
Pro Se 15 (Rev. 12/16) Complaint for Violation of Civil Rights (Non-Prisoner) 

Second Amendment, U.S. Constitution 

Fifth Amendment, U.S. Constitution 

Eleventh Amendment, U.S. Constitution 

Sixth Amendment, U.S. Constitution 

Fourteenth Amendment, U.S. Constitution 

STATUTORY PROVISIONS 

18 U.S. Code§ 241, Conspiracy against rights 

18 U.S. Code § 242, Deprivation of rights under color of law 

18 U.S. Code§ 286, Conspiracy to defraud the U.S. Government. 

923.18 USC § Conspiracy to defraud the United States 

18 U.S. ode§ 287, False, fictitious or fraudulent claims 

18 U.S. Code§ 371, Conspiracy to defraud the United States 

18 U.S. Code§ 1031, Major fraud against the United States 

Fed.R.Civ.P.60 Fraud on the court. 

28 U.S. Code § 455, Disqualification of justice, judge or magistrate judge 31 U.S. Code § 

3729(a)(l)(A)(B)(E), False claims. 

42 U.S.C, § 1983 Malicious prosecution. 

22 U.S. Code § 7102 Abuse of process 

Florida Statue 787.03 Kidnapping and interference with custody. 

Florida Statue 787.02 False imprisonment 

26 U.S. Code § 7434 Civil damages for fraudulent filing of information returns. 

C. Plaintiffs suing under Bivens may only recover for the violation of certain constitutional rights. If you 

are suing under Bivens, what constitutional right(s) do you claim is/are being violated by federal 

officials? 

D. Section 1983 allows defendants to be found liable only when they have acted "under color of any 

statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia." 

42 U.S.C. § 1983. If you are suing under section 1983, explain how each defendant acted under color 

of state or local law. If you are suing under Bivens, explain how each defendant acted under color of 

federal law. Attach additional pages if needed. 

The defendants violated critical court procedures and Florida Bar regulations. Namely, they have: 

a. Abused HIPPA rules in shairing private medical records to make arguments during Florida Bar 

hearings. 

b. Continued racism by the defendants and the court officials in my ongoing case. 

c. Leslie Puzo committed perjury by lying to the court that she had subpoenaed Airline records, which 

she did not. 

d. The defendants continue to with-hold critical evidence that they should share with the plaintiff. This 

violation continues to take place despite being a basic court procedure 

e. Continued suppression of evidence . - . 

Page 4 of 8 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 5 of 50
Pro Se 15 (Rev. 12/16) Complaint for Violation of Civil Rights (Non-Prisoner) 

III. Statement of Claim 

State as briefly as possible the facts of your case. Describe how each defendant was personally involved in the 

alleged wrongful action, along with the dates and locations of all relevant events. You may wish to include 

further details such as the names of other persons involved in the events giving rise to your claims. Do not cite 

any cases or statutes. If more than one claim is asserted, number each claim and write a short and plain 

statement of each claim in a separate paragraph. Attach additional pages if needed. 

A. 

B. 

Where did the events giving rise to your claim(s) occur? 

Miami Dade the mother took the minor child, concealed the minor child and went to Weston. 

What date and approximate time did the events giving rise to your claim(s) occur? 

July 2, 2019 - June 7, 2021 kidnapping 

November 13, 2021 Mother filed a false DV Injunction 

June 7, 2021 got set dates and times time sharing started. 

Divorce September 21, 2021 

Final Judgement March 16, 2022 

Appeal filed by defendants. April 18, 2022 

Appeal is still ongoing the defendnat filed the brief September 2022 

C. What are the facts underlying your claim(s)? ( For example: What happened to you? Who did what? 

Was anyone else involved? Who else saw what happened?) 

Page S of 8 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 6 of 50
Pro Sc 15 (Rev. 12/16) Complaint for Violation of Civil Rights (Non-Prisoner) 

IV. Injuries 

Witnesses, My sister, the marriage counselor, Therapist, police officers that testified during the DV. 

My daughter was kinapped July 2, 2019 I requested a court date for temporary time sharing and 6 days 

before the hearing Leslie Puzo put psychological evaluation. We went to the hearing and they 

defendants were stating it was their court hearing. Judge George Sarduy stated the defendants did not 

show that I was a harm to minor child but he gave me supervisied visitaiton because I am a diabetic. 

Leslie Puzo changed the court order and gave it to Judge George Sarduy ex parte. Judge George Sarduy 

signed it the next day. The plaintiff then got an attorney to try and fix it but George Sarduy was 

discriminating and bias refusing to read the transcript. He would say something happened and when 

asked the transcript will show he did not know. I was ordered to see daughter 3 times a week. Leslie 

Puzo put no more then 3 hours which the Judge never said but he signed it. She put the court finds that I 

am a danger to the minor child court said the opposite. This costs me a lot of money and time to fix. 

Diksha Sharma she gave partial documents, during the court hearing I was given no exhibits before 

hand there was 31 pages from my employer that they illegally obtained. I objected to the subpeoana 

timely. They gave 7 pages out of 31 pages, I told the Judge documents were missing he allowed it to be 

submitted they made it look like I was fired for being violent. My due process of law was broken 

everytime I set a court hearing Judge George Sarduy allowed the defendants to take it over and he 

would only address what they filed, and they would file it days before when my hearing was set months 

before. A false DV injunction was filed and I never seen the defendant body cameras and police reports 

will show I went over the defendants house called the police and did a wellness clieck. Priscille 

Duvalsaint stated I sexually assaulted her and tried to break in. I was unable to work because I had to 

self report for the BCBA. I was not able to see my daughter from July 2, 2019 to June 7, 2021 because 

they would not follow the court order. Visitation was never offered the 3 times that was court ordered 

and Judge George Sarduy refused to put set dates and times. After Leslie Puzo changed the court order 

then Judge George Sarduy stated it wasn't diabetes keeping me away from my daughter it was my 

behavior but the transcript says differently. The plaintiff has filed two appeals to stay out of state court 

and federal court they were denied. The defendnat has filed an appeal that is ongoing currently but 

issues are not addressed in family court. My constiution rights were violated heavenly. 

If you sustained injuries related to the events alleged above, describe your injuries and state what medical 

treatment, if any, you required and did or did not receive. 

The plaintiff has went to a therapist to be able to cope with the loss of the minor child for two years and the way 

that the Judges and attorney has treated the plaintiffs. 

The plaintiff continues to be denied justice because of his ethnicity, gender, and race. Furthermore, despite 

presenting evidence to the Florida Bar against the two defendants, no action has been taken agaisnt their actions. 

Consequnetially, the plaintiff has incurrred the following injuries: 

a. Racial discrimination in accessing justice against the two attorneys 

b. Financial resources have been spent in seeking legal action against these attorneys 

c. The plaintiff continues to be denied justice 

Page 6 of 8 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 7 of 50
Pro Se 15 (Rev. 12/16) Complaint for Violation of Civil Rights (Non-Prisoner) 

V. Relier·-

- State briefly what you want the court to do for you. Make no legal arguments. Do not cite any cases or statutes. 

If requesting money damages, include the amounts of any actual damages and/or punitive damages claimed for 

the acts alleged. Explain the basis foi:_these._claims. 

Immediate investigation and expulsion of the rogue attorneys for breaking Florida Bars rules 

Finacial compensation on all costs incurred in bringing the two defendants to justice 

Investigation of the Florida Bar officials enabling these two rogue attorneys 

Emotional distress from all parties in the kidnapping of minor child and conspiracy. 

Money for minor child of trauma caused of not seeing minor child for two years. 

Money paid for reunification with minor child to therapist, psychologist, supervisors. 

Money paid for attorney fees. 

Future money for therapy for both plaintiffs. 

Investigation of General magistrate Carlos Fernandez and Judge Carlos Sarduy. · 

False Domestic Allegation off of the plaintiff record completely. 

VI. Certification and Closing 

Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge, information, 

and belief that this complaint:-(1) is not being presented for an improper purpose, such as to harass, cause 

unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a 

n~:mfrivolous argument for extending, modifying, or reversing existing law; (3) the factual contentions have 

evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable 

opportunity for further investigation or discovery; and (4) the complaint otherwise complies with the 

requirements of Rule 11. 

A. For Parties Without an Attorney 

I agree to provide the Clerk's Office with any changes to my address where case-related papers may be 

served. I understand that my failure to keep a current address on file with the Clerk's Office may result 

in the dismissal of my case. 

· Date of signing: ~ f_.! 7,,,Dl 2-

Signature of Plaintiff . . ·~. .... .. 

Printed Name of Plaintiff Malvin Garnett 

B. For Attorneys 

.J 

Page 7 of 8 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 8 of 50
I 

Pro Se l 5 (Rev. 12/16) Complaint for Violation of Civil Rights (Non-Prisoner) 

Date of signing: 

Signature of Attorney 

Printed Name of Attorney 

Bar Number 

Name of Law Firm 

Address 

Telephone Number 

E-mail Address 

c;,,,, Stace Zip Code 

Page 8 of 8 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 9 of 50
Malvin Garnett 

Plaintiff, and N.C.G., plaintiff 

Vs. 

I 

United States Southern District Court 

District of Florida 

Civil Docket No. __ _ 

VERIFIED COMPLAINT- DEMAND FOR JURY TRIAL 

Priscille Duvalsaint, Marie Liautaud, Leslie Puzo Esq "individually and in her official capacity", 

Diksha Sharma Esq "individually and in her official capacity,", Yasmin Morshedian, 

"individually and in her official capacity." Judge George Sarduy, "individually and in his official 

capacity and General Magistrate Carlos Fernandez, "individually and in his official capacity." 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 10 of 50
PLAINTIFF CLAIMS 

1. Federal jurisdiction pursuant to Article III_§ 2 which extends the jurisdiction to cases arising 

under the U.S. Constitution. Plaintiff brings this suit pursuant to Title 42 U.S. Code§ 1983 for 

violations of certain protections guaranteed to him by the First, Fifth, Eighth, Ninth, and Fourteenth 

~mendments of the federal constitution, by the defendant under color of law in his capacity as a 

judge and general magistrate in the Superior Court of Miami Dade County. 

JURISDICTIONAL BASIS 

2. There has been a violation of the due process of the law for the plaintiff with the conspiracy 

of the defendants. The totality of the facts will show a denial of fundamental fairness, shocking to 

the universal sense of justice. All defendant parties listed have conspired together and violated the 

plaintiffs constitutional rights therefore following under federal jurisdiction. Statutory Authority 

Plaintiff is asking the Federal courts to resurrect justice, fairness, accountability, and responsibility 

of all parties involved and correction and investigation to their torts and like torts while their duties 

of color of the law. I ask that the federal courts follow the law and prosecute civilly by the laws 

stated. 

3. Federal Courts can rule on federal claims involved in state divorce cases and award money 

damages for federal torts cases involving intentional infliction of emotional distress by denial of 

parental rights visitation, as long as the Federal Court is not asked to modify custodial Status. Lloyd 

v. Loeffler 518 F. Suppo 720; Fenslage V. Dawkins, 629 F. 2d 1107, Kjtaziv. Kajtaz, 489 F> Supp 

15 ( 1976), Spindel V. Spindel, 283 F. Supp. 797 ( 1969). 

LIST OF PARTIES 

PLAINTIFF 

MAL VIN GARNETT natural person residing at 437 SW 3rd St #4 Miami, FL 33130 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 11 of 50
N.C.y. MINOR CHILD natural person residing at 437 SW 3rd St #4 Miami, FL 33130 

DEFENDANTS 

Judge George Sarduy Defendant is a Judge presiding at Miami Dade County, "individually and in 

his official capacity" 

General Magistrate Carlos Fernandez is a General Magistrate presiding at Miami Dade County 

"individually and in his official capacity" 

Priscille Duvalsaint natural person residing at 2321 Laguna Circle #709 North Miami, FL 33181 

Marie Liautaud natural person residing at 2321 Laguna Circle #709 North Miami, FL 33181 

Leslie Puzo Esq "individually and in his official capacity" 

Diksha Sharma, Esq "individually and in his official capacity" 

Yasmin Morshedi~n "individually and in his official capacity" 

CONSTITUTIONAL PROVISIONS 

Second Amendment, U.S. Constitution 

Fifth Amendment, U.S. Constitution 

Eleventh Amendment, U.S. Constitution 

Sixth Amendment, U.S. Constitution 

Fourteenth Amendment, U.S. Constitution 

STATUTORY PROVISIONS 

18 U.S. Code § 241, Conspiracy against rights 

18 U.S. Code § 242, Deprivation of rights under color of law 

18 U.S. Code§ 286, Conspiracy to defraud the U.S. Government. 

923:18 USC § Conspiracy to defraud the United States 

18 U.S. ode§ 287, False, fictitious or fraudulent claims 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 12 of 50
18 U.S. Code§ 371, Conspiracy to defraud the United States 

18 U.S. Code§ 1031, Major fraud against the United States 

Fed.R.Civ.P.60 Fraud on the court. 

28 U.S. Code§ 455, Disqualification of justice, judge or magistrate judge 31 U.S. Code§ 

3729(a)( 1 )(A)(B)(E), False claims. 

42 U.S.C. § 1983 Malicious prosecution. 

22 U.S. Code § 7102 Abuse of process 

Florida Statue 787.03 Kidnapping and interference with custody. 

Florida Statue 787.02 False imprisonment 

26 U.S. Code § 7434 Civil damages for fraudulent filing of information returns. 

COUNTS 

1. US Code§ 241 Conspiracy against rights all defendants came together to violate the plaintiffs 

constitutional rights. 

2. 18 U.S. Code § 242, Deprivation of rights under color of law Leslie Puzo, Diksha Sharma, GM 

General Magistrate, Carlos Fernandez, Judge George Sarduy, and Yasmin Morshedian were 

acting under the color of any law to willfully deprive a person of a right or privilege protected by 

the constitution and laws of the United States. 

3. 18 U.S. Code§ 286, Conspiracy to defraud the U.S. Government Leslie Puzo Esq, Diksha 

Sharma frauded the Judge as officers of the court gave partial documents and falsified a court 

order to defraud the Judge. Leslie Puzo, Priscille Duvalsaint gave fraudulent tax documents to 

defraud the US Government. 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 13 of 50
4. 923.18 USC § Conspiracy to defraud the United States Leslie Puzo, Diksha Sharma, and 

P~iscille Duvalsaint falsified a court order and turned in partial documents to defraud United 

States Judge. 

5. 18 U.S. Code§ 371, Conspiracy to defraud the United States, Leslie Puzo, Diksha Sharma, 

Priscille Duvalsaint, Marie Liautaud, GM Carlos Fernandez, Judge George Sarduy, and Yasmin 

Morshedian conspired to violate the plaintiffs constitutional rights from being a father to having 

the right to file an appeal. 

18 U.S. Code§ 1031, Major fraud against the United States Leslie Puzo, Priscille Duvalsaint 

committed fraud against Judge William Haury to attempt to get the marital residence dropping 

the case from the divorce and creating a new case in civil court. Defendant has Filed Second 

Action Against the Same Parties Related to the Same Allegations for summary judgment. 

6. Fed.R.Civ.P.60 Fraud on the court. Yasmin Morshedian, Leslie Puzo, Priscille Duvalsaint, 

Diksha Sharma, 

7. 28 U.S. Code§ 455, Disqualification of justice, judge or magistrate Judge George Sarduy, GM 

Carlos Fernandez 

8. 42 U.S.C. § 1983 Malicious prosecution Leslie Puzo, Priscille Duvalsaint 

9. 22 U.S. Code § 7102 Abuse of process Leslie Puzo, Priscille Duvalsint, and Diksha Sharma 

10. Florida Statue 787.03 Kidnapping and interference with custody. Marie Liautaud, Priscille 

Duvalsaint, Leslie Puzo, Diksha Sharma, Judge George Sarduy, and GM Carlos Fernandez 

11. Florida Statue 787.02 False imprisonment Priscille Duvalsaint, Marie Liautaud, Leslie Puzo, 

Judge George Sarduy, and GM Carlos Fernandez 

12. 26 U.S. Code § 7434 Civil damages for fraudulent filing of information returns. Leslie Puzo, 

Priscille Duvalsaint, Carlos Fernandez 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 14 of 50
STATEMENT OF THE CASE 

3. Everything stated the plaintiff has proof in support of, the mother had a conspiracy plan with 

Dr. Malissa Tigges who the attorney and specifically chose as a psychologist after the plaintiff 

objected, Judge George Sarduy, Leslie Puzo, Diksha Sharma, Marie Liautaud, Priscille Duvalsaint, 

Yasmin Morshedian, and GM Carlos Fernandez. They conspired to take and keep the child away 

from the father unlawfully and unconstitutionally. In the process of keeping the children outside 

Miami Dade County each defendant actively concealed the children's where abouts and interfered 

with the father's efforts to locate the child. All parties involved aided the mother's efforts to keep the 

child from their father unlawfully. These acts were committed intentionally and it was reasonably 

foreseeable that the acts would result in the mental anguish that the plaintiffs has suffered. 

4. In the cause of action for civil conspiracy every person involved as defendants had a place in 

the organization. Priscille Duvalsaint was the kidnapper, Leslie Puzo created a 9 page court order 

that kept the father away from the minor child. Dr. Malissa Tigges did not complete the 

psychological evaluation that the father agreed for as long as Priscille Duvalsaint paid for it. The 

evaluation was not done for 9 months. Priscille Duvalsaint refused to pay for the evaluation, the 

transcript will show Dr. Malissa Tigges stated the report took so long because she was not paid the 

full amount the father was not notified because Priscille Duvalsaint was court ordered to pay. Leslie 

Puzo false court order came in effect again. Originally the Judge stated the plaintiff did nothing 

wrong but after reading the fraudulent court order and him stating on the court record on March 9, 

2020 he doesn't remember what happened, He then stated that he never kept me away because 

diabetes but the transcript says differently. Judge George Sarduy stated from the way that I asked 

questions but it is my constitutional right to question the accuser but he yelled at while doing it. 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 15 of 50
----------------

Diks~a Sharma gave partial documents which is illegal as a Florida Bar attorney in which the 

plaintiff objected stating items were missing. Judge George Sarduy made a decision off of partial 

documents there was no exhibits that had anything to do with daughter and there was no exhibits 

given before this hearing. No Judge wanted to deal with Judge George Sarduy falsified court order 

that was signed. I was legally harmed severally walking into the psychological evaluation, in court, 

with new judges. On March 9, 2020 it was brought to the Judges attention the defendant did not go 

to FCS delaying visitation. It was stated that visitation was not given, do to the falsified court order 

the Judge signed he stated I was not seeing my daughter due to behavioral issues. When asked by the 

attorney Jennifer Ford Judge George Sarduy did not remember. So Judge George Sarduy kept a 

father away from his child and he did not even bother to make a note of the reason. The plaintiff 

hired an attorney to fix what Leslie Puzo by fraud on the court. On February 28, 2020 Jennifer Ford 

filed another emergency order that was ignored by Judge George Sarduy because she falsified an 

agreed order between Jennifer Ford and Leslie Puzo stating that I would only see my daughter in an 

indoor day care. Marie Liautaud kept the daughter away from the father along with the mother. The 

mother wanted anybody to have visitation with the minor child except for the father. 

5. The mother moved away from the father in this day and age of absent fathers why would the 

mother want to intentionally severe the ties of a child and father. Everyone is calling out for fathers 

to be involved in their child lives but all defendants involved have played a part in destroying and 

undermine the father child relationship. Priscille Duvalsaint has inflected trauma on the child, my 

daughter has stated traumatic things to the father on several occasions caused by Priscille 

Duv<l,lsaint. Children feel trauma when they feel rejected from a parent and Priscille Duvalsaint has 

intentionally done that. Priscille Duvalsaint personally hates me more then she loves the child and 

she is willing to inflict harm on the child for her personal vendetta against me. What normal rational 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 16 of 50
..------------------------------------------ ---

n~rmal human being does that, what parent does that to a child? Only someone who has severe 

m_ental issues her personal psychologist friend stated that she needs to be further evaluated. The 

mother lived with the father for 10 years, now the mother has attempted to make the everyone else 

around the child to have a greater relationship but me. When I was not seeing my daughter, the 

daycare, the preschool but when the father was to see the child she stated for supervised visitation 

but none of these other people needed such. 

6. The child has suffered when the plaintiffs were separated, the mother has defied the law she 

has defied the court order. She will defy the law, she lied to the police when I did a wellness check 

she lied and say that she called the police on plaintiff stating nothing but lies. The body cameras will 

show she did not even know I was there. The false domestic injunction costs plaintiff attorney fees, 

job opportunities, emotional distress, and not seeing my daughter from November 2020 to June 

2021. 

7. During the Domestic Violence injunction until the disposition was given the plaintiff 

constitutional rights to bear arms was violated due to the malicious prosecution of Priscille 

Duvalsaint and Leslie Puzo. The DV injunction :-Vas expired on numerous occasions and reinstated 

illegally. January 25, 2021 was the first time it was expired. 

8. The mother's plan was to kidnap the child abusing the child NCG mentally and keeping her 

from companionship of a loving father. Violaiing the former husband rights before the divorce was 

served. The mother ascertained an emotional act of violence and abuse against the minor child 

'N,C.G. and violated the father's constitutional rights. The defendants with the abuse of the process, 

violations of rule 11 with pleadings with no evidence in support has committed malicious 

p~osecution, and fraud on the court. 

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9. Leslie Puzo had Judge George Sarduy sign an ex parte court order that was signed the next day 

of things that were not stated in court. The things that were falsely signed the defendant had to walk 

into the psychologist evaluation with negative things that were not stated in court due to Leslie Puzo 

falsified court order she had the Judge signed. For example Leslie Puzo put in the court order that 

the court finds the defendant to be a danger to the minor child but the Judge said the exact opposite. 

The court order was 9 pages long and was fraud on the court filled . 

I 0. The plaintiff paid for a transcript of the Judge George Sarduy ruling. The Judge then stated for 

the plaintiff to pay for the entire transcript. When the plaintiff paid for the entire transcript the Judge 

then recused himself two days after uploading it to the court docket. Judge George Sarduy was 

refusing to set the case for hearing if the entire transcript was not paid available. 

11. The plaintiff is asking for the ability to recover for the loss of society of minor child NCG and 

for her emotional distress resulting fo~m its abduction or enticement. NCG was 21 months old at the 

time of abduction. 

12. The plaintiff is asking for reasonable expenses incurred for reunification and regaining custody 

that have been paid by the plaintiff. Attorney fees, private investigation fees to find the minor child. 

The plaintiff is also requesting therapy fees for future allocation of the minor child and plaintiff that 

have been spent and may be spent. 

13. The plaintiff has failure to obtain substantial justice in state courts lead to suit being filed in 

Federal Court under Title 42 United States Code Standard 1983. This suit asks for relief of all orders 

mad~ in violation of the law, that due process of law be allowed, and further issue relief as the court 

deems appropriate. 

14. The court in this manner the court being Judge George Sarduy failed to stress, "the parent-child 

relationship is an important interest that undeniably warrants deference and, absent a powerful 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 18 of 50
countervailing interest, protection." A parent's interest in the companionship, care, custody and 

management of his or her children rises to a constitutionally secured right, given the centrality of 

family life as the focus for personal meaning and responsibility. 

15. Leslie Puzo ex parte court order denying parental rights, personal liberties can be the basis of 

suits for money damage sand it was unconstitutional. Rankin V. Howard, 633 F. 2d 844(1980); 

Geisinger V. Vose, 352. Supp. 104 (I 972). Ex parte communications are inherently unfair and 

violative of the due process. 

16. Recent decisions have made it clear that when state law regulating divorce comes into 

conflict with the Fourteenth Amendment, then it is the duty of the federal courts to resolve that· 

conflict in favor of the constitution. Boddie V. Connecticut, 401 U.S. 371, 91 s. Ct. 780, 28 L. Ed. 2d 

113 (1971). In this instance Judge George Sarduy discriminated against the plaintiff Malvin Garnett, 

Troxel v. Granville Malvin Garnett was to be presumed a fit parent instead Judge George Sarduy 

violated his constitutional rights restricting his parenting. Malvin Garnett has never been arrested, 

has an MBA, was a basketball coach for Booker T. Washington, worked with Autistic kids, and was 

a volunteer for big brothers big sisters but Judge George Sarduy stated for him to have supervised 

visitation and signed a fictious court order stating no more then 3 hours to spend with daughter 

totaling 6 hours per week. 

17. Leslie Puzo and Priscille Duvalsaint committed conspiracy to deprive plaintiff of the society 

and companionship of his child, in violation of a custody decree of the State of Florida. 

18. The plaintiff as a result of defendants willful and deliberate violation of the custody decree, 

the plaintiff has incurred substantial expenses in attempting to locate and recover the custody of his 

minor child as well as suffered severe emotional and mental strain and anguish. 

19. Testimony of the mother will show the minor child suffered mental anguish as well. 

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20. Judge George Sarduy and GM Carlos Fernandez was administered with an·evil eye and a heavy 

hand was discriminatory and violated the Equal protection clause of the Fourteenth Amendment 

depriving the plaintiff of his constitutional protection. 

21. On October 31, 2019 the plaintiff and Leslie Puzo went to court for T-mobile records, Judge 

George Sarduy at the time told Leslie Puzo 5 year attorney it would not be easy to keep the father 

away, that was changed when another attorney was added Diksha Sharma 15 year attorney. 

22. The plaint claims asserts an conspiracy to deprive the plaintiffs of civil rights by defendants 

Priscille Duvalsaint, Marie Liautaud, Leslie Puzo Esq, Diksha Sharma Esq, Judge George Sarduy, 

General Magistrate Carlos Fernandez defendant under color of law in his capacity as General 

Magistrate in the Superior Court of Miami Dade County, Yasmin Morshedian. 

23. Judge George Sarduy and General Magistrate Carlos Fernandez are 

trespassers of the law. Fathers' Rights Case Law Title 42 USC 1983 is for (federal) civil rights 

violations. "Judges may be punished criminally for willful deprivation of rights on the strength of 

Title 18 U.S.A. 241 and 242." IMBLER V. PACHTMAN, 424 U.S. 409; 96 S.Ct. 984 (1976). 

24. The Plaintiffs rights were violated by all defendants the right of the plaintiff to the care, custody 

and to nurture the child is of such character that it cannot be denied without violating those 

fundamental principals of liberty and justice which lie at the base of all our civil and political 

institutions, and such right is a fundamental right protected by this amendment and amendment 5, 9, 

and 14 DOE V. IRWIN, 441 f. SUPP. 1247. 

25. Judge George Sarduy has violated my Fourteenth Amendment he has deprived plaintiff liberty in 

terms of my rights to be a father restricting me because of what someone said with no evidence in 

supp~rt of and stating it on the record. Judge George Sarduy has violated due to race, gender, and 

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v,iolating ADA the father being a diabetic. The father has not been judged on his actions but on 

things that he was born with and unable to control. 

26. Diksha Sharma, General Magistrate, Judge George Sarduy, and 

Leslie Puzo used their official position to exert influence and physical control over the plaintiff. 

Dilq;ha Sharma has placed fraud on the court knowingly and Judge George Sarduy has welcomed it 

as well as GM Carlos Fernandez . 

27. Judge George Sarduy intentionally caused emotional distress there is a part of the transcript 

where he states the mental harms of the court can cause and he unjustly put the plaintiff through it 

knowingly there was not a case plan or reunification plan ever put in place for the father nor was 

Judges actions ever justified by case law or statue. 

28. Priscille Duvalsaint with her mother and the help of her attorneys 

has abused the legal process and has not taking responsibility of her actions exercising toxic 

parenting, refuses to coparenting, not letting the father know what is going on with the minor child, 

continued litigation, knowingly false allegations, denied parenting time, concealment of the minor 

child, violating numerous court orders that were put in place for the best interest of the minor child. 

29. Yasmin Morshedian on two occasions refused to type a transcript under conspiracy and being 

friends to Leslie Puzo. On September 29, 2021 and September 30, 2022 Yasmin Morshedian gave a 

partial transcript of the contempt of court of Leslie Puzo when everything was asked for by the 

plaintiff except of the opening statement. 

30. On or about September 2021, The plaintiff was appealing Judge William Haury on the terms 

of fraud on the court and not vacating the fraudulent court order. Judge William Haury also made an 

· decision without hearing all of the evidence. Judge William Haury also allowed an expert witness 

that was irrelevant to testify defendants contempt of court filed less then 12 hours prior. 

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31. Leslie Puzo stated that she did not have a transcript when she drafted the 9 page court order but 

the Florida Bar states when she found out her job as an Florida Bar attorney is to correct the court 

order. During the contempt of court hearing Leslie Puzo testimony did not contradict anything that 

the plaintiff alleged with regards to the contempt. Yasmin stopped typing the transcript for no reason 

to protect Leslie Puzo. 

32. Judge George Sarduy and Gm Carlos Fernandez pledged to a Judges Oath of office and canons 

of Judicial Code of Conduct. 

33. I am asking for relief from Judge George Sarduy and GM Carlos Fernandez attorney fees and 

declaratory relief and injunctive relief and these two parties all of their cases be reviewed of people's 

constitutional rights violated. These Judges tend to believe that this is their communist country and 

they can do whatever they want and they are above the law. 

34. Judge George Sarduy and GM Carlos Fernandez have violated my rights refusing to follow 

61.13 best interest of the child. The most important constitutional right that was violated was equal 

protection of the laws. 

35. From August 2018 to October 2018 the parties went to marriage counseling by request of the 

plaintiff for issues in the marriage pertaining' to maternal mother, the defendant constantly 

disappearing and concealing with the minor child, the defendant driving around with the minor child 

with no seat belt, irresponsible spending, and being inconsiderable in the marriage. Both parties has 

the chance to speak to the marriage counselor by themselves before then having counseling together. 

The parties issues in the marriage have been documented but the defendant came up with issues 

adding a psychological evaluation in order to keep the father away from the minor child. There has 

been no findings that was justified in the mother's actions the entire case to be able to restrict the 

father from the minor child. 

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36. The defendants acts or omissions were intentional. 

37. On June 17, 2019 the defendant, Priscille Duvalsaint filed for divorce with the help of her 

attorney Leslie Puzo. The legal document was of allegations of the plaintiff mistreating the minor 

child when he was upset, erratic, screaming, and yelling at the wife and minor child traumatizing the 

minor child, leaving diabetic needles out never taking medication for diabetes, playing with pens, 

taking the minor child out of jurisdiction without informing the wife Stating she did not know the 

whereabouts of the minor child. Stating that during the trip she did not know if the minor child is 

safe and unharmed. The wife is extremely concerned about the safety and well-being of the minor 

child when the minor child is left with the husband unsupervised. The plaintiff is extremely violent 

and has shown aggressive behavior towards the wife and minor child, numerous times. The 

respondent is an aggressive and violent person. 

38. Text messages of five years shows that the mother was lying about all incidents in the 

previous paragraph. The plaintiff has never had his day in court. The mother and attorney lie and the 

plaintiff then has to spend time showing proof it is a lie. 

39. The mother, attorney, and Judge this entire case has ignored the best interest of the child 

under the constitution Troxel v. Granville. Judge George Sarduy violated the plaintiff rights as to be 

presumed a fit parent. Judge George Sarduy violated plaintiffs constitutional rights to be a parent. I 

have been discriminated against by George Sarduy and was treated differently in terms of people 

going through divorce in the same situation. 

40. The US Supreme Court implied that a (once) married father who is separated or divorced 

from a mother and is no longer living with his child' could not constitutionally be treated differently 

from a currently married father living with his child. Judge George Sarduy ignored this there were 

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pictures shown before the divorce and the relationship of child and parent and he did nothing to 

restore no case plan or anything. The parties in this case were married until September 24, 2021. 

41. Plaintiff rights were violated due to being a black, a man, and a diabetic in violation of the ADA 

and was retaliated against for fighting for his daughters rights and his rights under the following 

listed amendments. 

42. The mother and attorney talked bad about the plaintiff with no evidence none what so ever and 

Judge George Sarduy stated so. Everything was hypothetical, hearsay potential and sometime in the 

future. The mother crystal ball has not worked because everything that she has stated will happen 

hasn't happened. The only evidence the mother has showed this entire case it the father likes to 

travel. The mother lied to the tribunal and did not state she was traveling with the father. 

43. Florida is a not at fault state for divorce and the only purpose of stating these lies knowingly was 

due to legally harm the plaintiff, harass, embarrass, and cause emotional distress. 

44. The father took the minor child NCG California for a family reunion for three days and text 

messages show that the defendant always knew where the minor child was. The mother also face 

time the minor child numerous times a day and the plaintiff has screen shots of the record the 

plaintiff knowingly stating the lies she did not know if the minor child was unsafe. 

45. The plaintiff has documentation from insurance company of insulin taken through the years. The 

plaintiff has documentation that the police have never been called to the residence and from the 

marriage counseling no claims of abuse. There was ADT cameras in the home but during discovery 

the defendant refused to give dates of any type of screaming or any of the claims with no evidence of 

support. The plaintiff has 5 years of text messages that have been turned in to court showing the 

plaintiff has never put hands on the defendant. 

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46. Defendant, Priscille Di.lvalsaint from November 12, 2019 to June 7, 2021 refused court 

ordered visitation to the plaintiff and had the minor child concealed .. 

47. Priscille Duvalsaint and her mother Marie Liautaud ran away with the minor child NCG. 

48. On June 17, 2019 on the UCCJEA the mother and attorney put down the marital address 437 

SW Yd St. #4 Miami, FL 33130 instead of the actual address she took the minor child to. The proper 

address was not filled out until February 2022 when the plaintiff took them to court twice to have 

filled out. 

49. During the child support hearing you will see that GM Carlos Fernandez lead the defendant 

while questioning her. His report is false and the transcript will show he follows the conspiracy the 

parties have come together for the father to pay 30k for child support and 366 a month even though 

the mother makes 5 times more then the father and the father was rewarded 50/50. 

50. On July 2, 2019 the defendant, Priscille Duvalsaint took the minor child N.C.G. outside of 

the county violating the Status Quo from Miami Dade to Weston, FL. The father did not have access, 

the child was concealed from July 2, 2019 when the father was served with divorce paperwork to 

June 7, 2021 when the case at the plaintiffs request moved to Broward. 

51. The fat~er filed an emergency motion to get the child back but Judge George Sarduy ignored 

th~ hearing among other hearings. The plaintiff attorney filed a emergency motion more then one 

that was also ignored by Judge George Sarduy showing other motives. 

52. In May 2019 the defendant Priscille Duvalsaint got a 2nd apartment in Weston and did not tell 

the husband and did not put the apartment on the UCCJEA. 

53. When the mother filled out the UCCJEA she put the marital home only. There is text 

messages she stayed at the new home with the minor child and her mother and did not put on the 

UCCJEA to conceal the minor child. 

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54. Everyday the plaintiff would contact the attorney because the mother blocked the father from 

access to the minor child. N.C.G. when showed a recording of the mother hanging up the lmin and 

38 seconds. The mother would hang up the phone when the plaintiff made NCG laugh. The father 

would start to record the conversations as protection the mother then refused to allow the father to 

speak to the minor child. 

55. The mother tried to make it seem like the face time calls was to replace visitation which goes 

against best interest of the child and it was unlawful and against the court order. 

56. Leslie Puzo would sabotage visitation the parties only offered visitation twice from July 2, 2019 

to June 7, 2021 it was supervised visitations one of the times February 2020 Leslie Puzo stated for 

visitation less then 5 hours notice with sister Keisha Garnett, the email will show when everything 

was set Leslie Puzo cancelled it for no reason. The next day knowing Keisha Garnett had to work the 

mother showed up to the sister house to make it look like the father did not show up for visitation. 

57. Another time Leslie Puzo stated the father could not see the minor child unless they were to meet 

at an indoor day care. When the father agreed Leslie Puzo cancelled the meeting. Leslie Puzo wanted 

the father to sign his rights to all meetings to be at a indoor play ground. 

58. Another time in July 2020 Leslie Puzo would not allow visitation unless the mother could come 

sit on the couch. The father state he was afraid of false DV allegations, due to in the original marital 

documents the defendants stated the plaintiff was extremely violent. False DV allegations was filed 

in November 13, 2020 and the plaintiff did not see the defendant. 

59. The plaintiff had the option of two supervisors his sister Keisha Garnett or Nigel Degraff in July 

2020. Leslie Puzo sent an email stating that if my attorney did not see me with my daughter at his 

law office I could not see my daughter. After the visitation Leslie Puzo filed a motion to disqualify 

the attorney being that he was representing the plaintiff. The entire visit was recorded there was no 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 26 of 50
issues. Leslie Puzo then stated we needed a parent coordinator in which the defendants asked Judge 

Sarduy for and stated on the record they would pay half. They refused to pay and there was not a 

reason for a parent coordinator because there was email stating any date any time by the plaintiff. 

This was only attempt to violate and sabotage the minor child and the father visitations. 

60. When the child was kidnapped the father went to the City of Miami Police station located at 

400 NW 2nd Avenue, Miami, FL 33128. They stated that they do not get involved in custody cases 

there has to be a court order from the Judge for arrest. Judge George Sarduy refused to put set dates 

and times and the transcript will show on March 9, 2020 the plaintiff requested set dates and times. 

Judge George Sarduy would say during court hearings this was a tragedy for the minor child but not 

enforce anything. Judge George Sarduy blamed Jennifer Ford and the plaintiff for no visitation, there 

was to be visitation twice a week at no point and time was any attempts showed by the defendants in 

the means the plaintiff believes this clarifies as conspiracy between the defendants, Leslie Puzo, 

Diksha Sharma, Diksha Sharma, and Judge George Sarduy. 

61. The plaintiff contacted Weston police department they stated the court order had to have set 

dates and times to get involved. The parties went to court twice Judge George Sarduy knew the 

father was not seeing the minor child but refused to set dates and times. 

62. The plaintiff contacted North Miami police department and they stated they must have a 

court order to be able to take the child. 

63. For the false domestic violence case the plaintiff went to the police department they stated 

they can't do anything because the defendant did not file a police report. 

64. The plaintiff went to the State attorneys office at 1350 NW 12th Avenue, they stated they 

cannot do anything because the plaintiff was not arrested. 

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65, The plaintiff filed motions to handle false domestic violence case in family court and Judge 

William Haury would not allow the father to bring it up stating that he dismissed it. 

66. The court orders and the transcript from August 26, 2021 with the kidnapping Judge William 

Haury stated he was not dealing with any prior judges court orders. He stated I might be right for the 

domestic violence allegations and the kidnapping but he is trying to move the case along and add 

more time sharing with supervised visitations. In which the court order was done ex parte and under 

terms of fraud. The two lawyers gave partial documents to make it look like the plaintiff was fired 

due to violence knowing that was not true. Florida statue and case law only way to restrict visitation 

was if the father was a harm to the child. The original Judge George Sarduy stated he was not a harm 

to the child. 

67. The father emailed the mother and attorney to see the minor child they either ignored or denied. 

At one time Leslie Puzo asked what the plaintiff wants and he stated what Status Quo says, the 

conversation was through email. 

68. The father started recording the plaintiffs.on the phone to protect himself and the defendant 

Priscille Duvalsaint no longer allowed communication because she was stating the father was being 

inappropriate. The father did not want to answer the phone because the mother would hang up the 

phone when he made NCG laugh text messages will show he was on the phone for 1.38 seconds 

before the mother would hang up the phone. 

69. Priscille Duvalsaint unlawfully took away the minor child without the plaintiff consent. Priscille 

Duvalsaint is guilty of custodial interference, child concealment, and parental abduction. The 

defendant Priscille Duvalsaint refused to allow the father to see the minor child N.C.G. until set 

dates and times was set by Judge Fabienne Fahnestock. 

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70. When Judge Fabienne Fahnestock set dates and times there was a DV Injunction, she went 

off of the falsified court order that Leslie Puzo stated that Judge George Sarduy stated no more then 

J hours. It was never stated in court. Judge Fabienne Fahnestock stated to set a motion to modify the 

court order when done so immediately a court date was never set. 

71. On July 2, 2019 The defendant and her mother, Marie Liautaud the co abductor violated 

Florida Statue 787.03 in which is a felony of the third degree by kidnapping NCG maternal mother 

harbored and abetted. The defendant Marie Liautaud showed up to court on March 9, 2020 so she 

was aware of the court proceedings and the wrong doings of the co-defendant. 

72. Defendant Priscille Duvalsaint removed the child from the county of Miami Dade purposeful 

and unlawfully abducted the child or even removing the child without the plaintiff consent. 

73. The transcript will show the defendant testified that her mother gave her money, abetting. 

74. The plaintiff asked the defendant, Priscille Duvalsaint by text message and email where the 

child was, the defendant refused to state location as well as her attorney. 

75. The plaintiff asked the defendant Leslie Puzo and the defendant Priscille Duvalsaint 

everyday where the minor child was and to see the minor child the parties refused. They chose to 

emotionally abuse the minor child by affecting her developmental by her not seeing her father who 

was active in her life and the primary care giver before the divorce was filed. 

76. On or about August 2019 the plaintiff called Judge George Sarduy judicial assistant to set 

hearing for temporary time sharing. The assistant called the attorney Leslie Puzo on three way and 

set on November 12, 2019. Before setting the hearing Leslie Puzo stated that we had to simply wait 

for a court hearing. She lied to the plaintiff so things would stay the way they were. When the 

Plaintiff set a court hearing Leslie Puzo violated the plaintiff due process by taking over the court 

date and misleading the tribunal. 

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77. On November 6, 2019 Leslie Puzo filed a motion for psychological evaluation in which violated 

the plaintiffs due proves of law. Leslie Puzo during her opening statement states that she set the 

hearing for psychological evaluation. The plaintiff only brought pictures to the temporary time 

sharing to show the relationship between father and daughter before the kidnapping The plaintiff had 

two witnesses that contradicted what the defendant testified to. The full transcript for November 12, 

2019 is available. 

78. On November 12, 2019 the defendant Priscille Duvalsaint testified that the father was not in the 

daughters life the first year she was born. Ms. Duvalsaint placed fraud on the court. 

79. The defendant Malvin Garnett was the primary care giver from two months after NCG was born 

October 21, 2017 until kidnapped July 2, 2019. Text messages will show. 

80. The defendant kidnapped and interfered with the plaintiffs custodial rights. The defendant 

Priscille Duvalsaint did not have lawful authority, who took the minor NCG who was 1 year and 9 

months when the defendant kidnapped the minor child and her Marie Liautaud abetted*** 

81. From July 2, 2019 to November 12, ,2019 the minor child and father were protected by 

Status Quo. The defendant committed a 3rd degree felony of interference with custody. The 

defendant filed numerous emergency orders to be reunited with the minor child by different judges it 

was never heard the judges violating the fathers constitutional rights to be a father the first Judge 

being Judge George Sarduy there was other judges after Judge George Sarduy who the Judge swore 

in Like Marcia Del Rey and the discrimination and violation of constitutional rights continued .. 

82. On November 13, 2020 the defendant Priscille Duvalsaint committed another felony. The 

plaintiff hired a private investigator to find out where she was living. When the plaintiff found out 

where the minor child was he did a wellness check, on October 31, 2020 and November 8, 2020. The 

body cameras and police report show the father is the one that called the police. 

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83. The defendant filed knowingly a false DV injunction stating the police were summoned, the 

plaintiff tried to break in, the plaintiff punched her, the plaintiff sexual assaulted her. The plaintiff 

does drugs, the plaintiff is an alcoholic, the plaintiff has a history of mental health issues and takes 

medication. 

84. The defendant did this purposely she lied to get adv injunction and she also did it to stop the 

plaintiff from working. Both parties are licensed by the BCBA which you must self report and you 

cannot have mental issues. When the plaintiff self reported he was unable to work and was unable to 

finish his school classes due to not being allowed to have a client. The defendant has ruined his 

reputation and defamed his character knowingly and the evidence will show. 

85. The Plaintiff is suing for defamation of character, slander, libel as an civil tort to knowingly 

stated things about the plaintiff Priscille Duvalsaint knew not to be true regarding domestic violence, 

drugs, mental health, and accusations of being an alcoholic. This caused 8 months of not being able 

to work and missing out on job opportunities the parties are both licensed by the same licensure so 

she was aware of her actions before doing so. 

86. The mother also staged a fake break in showing someone went through her car stating it was 

the father but just like everything else in this case no police report was filed and the mother refused 

to state the date when the car was broken into allegedly. 

87. The civil case of defamation will help in restoring the injured spouses' tarnished reputation 

and a part to his mental health. 

88. The defendant Priscille Duvalsaint provided false information, false testimony to obtain a 

DV injunction and the plaintiff has a basis for relief. The plaintiff lied about sexual assault, mental 

health issues, drugs, and being an alcoholic in order to gain an advantage in a custody dispute. The 

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plain.tiff is still trying to clear his name of the malicious conduct designed to harm the reputation of 

the p~aintiff. 

89. Leslie Puzo represented this violating Rule 11, she requested for a continuance to be able to 

subpoena the officers and never did. She saw the body cameras from both days and still tried to 

suppress the truth during thre trial and she still brought the false claims forward violating malicious 

prosecution and abuse of the process. 

90. The plaintiff has reported both attorneys to the Florida Bar and they are stating this is a civil case 

they do not have the investigatory powers according to them. The plaintiff feels the disciplinary 

committee should have handled the attorney but since they didn't Federal Court is the proper realm. 

During a contempt of court hearing against Leslie Puzo the transcript will show on August 26, 2021 

told Judge William Haury he does not have the power to suspend her bar license. The plaintiff is 

asking for accountability on all parties on their conspiracy. 

91. The Fraudulent scheme that was dependent upon an Leslie Puzo and Diksha Sharma is common 

law fraud liability. Leslie Puzo and Diksha Sharma are guilty of malicious prosecution and abuse of 

process by their stated actions of psychological evaluation as well as domestic violence injunction, 

and the civil case regarding the house. 

92. Leslie Puzo dropped the case to try and obtain the house out of the divorce, out of family court 

and filed the case in civil court to try and place fraud on the court to steal the house. The plaintiff 

paid for attorney fees for help with briefing the response. 

93. Leslie Puzo and Diksha Sharma have a pattern of deceitful activity the instance of deceit is 

enou,gh to sustain liability. 

94. Leslie Puzo has committed and suborns perjury. 

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95. The attorney and Priscille Duvalsaint have lied about anything and everything for just 

senseless reasons, the judicial process can not survive with such liars. For example Leslie Puzo has 

stated in open court that she has asked me about a violin. All communication is a paper trail and no 

such things have been asked for but they have stated it to portray me as a thief. 

96. The defendant, Priscille Duvalsaint then testified that the father was only left alone with the 

child no more then 4 hours a day and she had cameras installed in the house which was a lie. There 

was a baby monitor in the house and that was it. The defendant place fraud on the court so the 

plaintiff was legally harmed and it affected time with the minor child NCG. The defendant lies 

depending on action she stated this but then in child support stated she made less money because she 

had to care for the minor child. Depending on the Judge depending on what the defendant wants she 

will tell new lies contradicting her old lies. 

97. Leslie Puzo sent a subpoena for family members who lived out of state threatening contempt 

of court if they did not show up. The subpoenas was to harass family members. 

98. On November 12, 2019 the plaintiff constitutional rights were violated by Judge George 

Sarduy. Judge George Sarduy started yelling at the plaintiff when he was questioning the defendant 

Priscille Duvalsaint about being extremely violent. The defendant stated that the plaintiff squeezed 

her thighs, squeezed her ear lobe. While the plaintiff was questioning the defendant on cross 

examination trying to get the specifics as to when, where, how, and why the Judge interrupted the 

line of questioning. While the Judge was interrupting the testimony the defendant added to her 

testimony that wasn't stated during direct and the Judge replied with bias that is extremely violent. 

99. Leslie Puzo did not give interrogatories or notice of production so the plaintiff can be 

prepared for the motions, hearings, and have a defense for the psychological evaluation and the DV 

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injunction. The defendant Leslie Puzo gave no.exhibits prior to the date of hearing to restrict his 

right~ as a father on November 12, 2019 

100. On October 16, 2019 Leslie Puzo requested to subpoena a 3rd party Malvin Garnett 

family members Leslie Puzo called argued, harassed Sharon Greene while she was at work who lives 

in Conyers, GA, Junior Greene who also lives in George, Phillip Harris who lives in Brooklyn, New 

York, and Carol Harris who also lives in New York threatening for contempt of court. Regina the 

plaintiffs mother. The plaintiff objected in a timely manner. Leslie Puzo violated Federal Rules of 

Civil Procedure Rule 45 knowingly. 

101. On October 16, 2019 Leslie Puzo subpoena records from the former plaintiff job, the 

plaintiff objected in a timely manner. Leslie Puzo still subpoena the records illegally violating 

Federal Rules of Civil Procedure Rule 45 knowingly. 

102. On November 12, 2019 Diksha Sharma gave partial documents 7 pages out of 31 pages. 

During the hearing she did not give the letter of authentication to the defendant during the line of 

questioning. The plaintiff objected to the documents stating documents were missing. Diksha 

Sharma placed fraud on the court and mislead the tribunal to make it look like the plaintiff was fired 

for being violent. When the plaintiff stated he received his job back with back pay she objected and 

stated facts not into evidence. It was not into evidence because she withheld the truth from the 

tribunal against rules of the Florida Bar, which is illegal as a Florida Bar attorney. This drastically 

legally hurt plaintiff, during the psychological evaluation case in terms was set for temporary time 

sharing. There was no evidence shown to support their claims except this false information. 

103. Leslie Puzo on every occasion with numerous judges has filed motions intentionally after 

the plaintiff was awarded a court date and piggy backed off of the court date and took over the court 

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hearing violating the plaintiffs due process of the law. It was not a cross hearing the attorney Leslie 

Puzo would lie and state she set the hearing or the days before file a notice of hearing. 

104. On November 12, 2019 the plaintiff was awarded time sharing 3 times a week, one day with 

FCS other two with his sister. 

105. On November 20, 2019 the defendant Priscille Duvalsaint was non complaint of Family 

Court Services in which she requested it. She had two attorneys and still violated FCS delaying the 

father seeing his child. 

106. Leslie Puzo did not respond to the plaintiff proposed court order until the day the day before 

she went on vacation. From November 12, 2019 to December 11, 2019 Leslie Puzo did not turn in 

the court order. Leslie Puzo purposely delayed turning in the proposed court order and respondent to 

the plaintiff. Taking time away from the father missing his child for holidays. When the court order 

signed the plaintiff was not notified until 27 days later. 

107. On December 11, 2019 Leslie Puzo turned in a ex-parte court order to Judge George 

Sarduy restricting the father access to the child. Leslie Puzo violated the plaintiffs fifth Amendment 

an 14th amendment right to due process. 

108. On December 12, 2019 Judge George Sarduy signed the ex parte court order on the 

next day not giving the plaintiff a chance to object to it. 

I 09. On December 17, 2019 the plaintiff found out that the defendant, Leslie Puzo turned in the 

court order ex- parte. He notified the Judge and received no response. 

110. At no point of time did Judge George Sarduy ever give a case plan to be reunited with NCG. 

111. On January 8, 2020, the plaintiff set a court hearing for the court order to be signed. On the 

day of the hearing, Leslie Puzo cancelled plaintiff court hearing and sent me a signed court order 

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from George Sarduy that was dated December 12, 2019. Judge did not give me a copy nor did the 

attorney after her ex parte court order was signed. 

112. Leslie Puzo frauded the court she put things in a court order that the Judge never said, 

made findings that the Judge never stated. Leslie Puzo made a 9 page court order to take place of a 

transcript and turned it in ex parte to make fraud on the court. 

113. Leslie Puzo wrote things that she stated where to testified to but the transcript shows 

otherwise. 

114. Leslie Puzo as an attorney of law- a lawyer must not knowingly misstate, misrepresent, or 

distort any fact or legal authority to the court or to opposing counsel and must not mislead by 

inaction or silence. Further, the discovery of additional evidence or unintentional misrepresentation 

must immediately be disclosed or otherwise corrected. Leslie Puzo lies and fraud on the court has 

affected the plaintiffs time sharing, cost thousands of dollars of litigation to correct it and was never 

corrected. 

115. On January 9, 2020 the plaintiff hired Jennifer Ford to correct the fraud on the court, 

abuse of the process and malicious prosecution Leslie Puzo did. 

116. Leslie Puzo had over 90 paragraphs in her court order. 

117. Leslie Puzo wrote pursuant to Fla. Fam. L.R.P. 12.360, this request for a psychological 

examination meets the standard. Judge George Sarduy did not make these findings. 

118. Leslie Puzo falsely wrote The court finds petitioner has met her burden, Husband's 

psychological examination is sin controversy as the petitioner has raised her concerns about the 

minor child's safety and welfare while in the care of the husband. Judge George Sarduy stated that 

they have not shown that the father is a danger to the minor child. 

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119. Leslie Puzo wrote the court finds, based on the testimony, that the husband is aggressive, 

defiant, and there are concerns regarding the minor child being in danger while in his care. The 

transcript will show that Leslie Puzo falsified the court order on this paragraph as well as many 

others. 

120. Leslie Puzo fraudulently wrote husband shall be psychologically evaluated by Dr. Malissa 

Tigges. The petitioner volunteered for a psychological evaluation as long as the petitioner paid for 

both of them. 

121. Leslie Puzo wrote wife has voluntarily agreed to also be psychologically evaluated by Dr. 

Malissa Tigges, PsyD. The transcript shows that if she did not agree to it he would court order her to 

a psychological evaluation. 

122. Leslie Puzo wrote to harm the minor child and the father relationship, the 

Respondent/husband shall have supervised visitation two times a week, no long than three hours. 

There was never a restriction placed. 

123. When Leslie Puzo did her opening statement she came in there asking for one psychologist 

and one only. Judge George Sarduy gave them the psychologist they asked for and Leslie Puzo has 

worked with this psychologist before. Normal instances there are 3 options and the Judge chooses 

one. The parties had the option and the transcript will show to go to FCS where the payment of the 

psychologist would be on a sliding schedule pertaining to salary. The attorneys chose to pick this 

one psychologist and pay for both or agree to pay for both. 

124. On November 12, 2019 the Judge stated for plaintiff to bring medical records and hurry with 

the psychological evaluation. The only way to restrict to a parent from their child is if they are a 

danger to the child. Judge George Sarduy kept me away from my child due to the bitterness of a ex 

wife. It is normal for couples going into divorce to say things but for a Judge to take action of 

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restriction with the minor child NCG without any evidence in support of is discrimination and 

against the plaintiffs constitutional rights. 

125. My constitutional rights as diabetic were violated in terms of HIPPA. I am to walk into 

the court innocent until proven otherwise. Due to discrimination I had to prove what they'rn saying 

is a lie versus them bringing evidence in support of. 

126. Diksha Sharma stated my confidential records to the Florida Bar over a argument of the 

charges that were stated of her wrong doings, My medical records were given by Leslie Puzo they 

were not given to her by the Dr. This is a violation of HIPP A and my constitutional rights. 

127. I was punished by Judge George Sarduy called toxic, belittled talked down to and the 

transcript will show just for exercising a protected statutory constitutional right. 

128. Judge George Sarduy the state chose means which unnecessarily burden and restricted 

constitutional protected activity. After Judge George Sarduy told plaintiff to bring my medical 

records, he then stated for me to have the doctor come in after I brought the medical records. He then 

stated I was not seeing my daughter due to behavior versus having diabetes and he didn't remember 

what happened that restricted me access from child. 

129. Judge George Sarduy made me feel as if it was 4 against one in the court room, he did not 

proceed in respect of the child as parents patriae he treated me as an adversary. 

130. For Judge George Sarduy to make the plaintiff bring in his medical records is 

discrimination against the disabled. Diabetes is a disability classified by the ADA. He stated nobody 

has shown me nothing he did this to discriminate against a black person, a man as well as a diabetic. 

If nobody has shown him anything it is not to be considered, it is not the plaintiffs job to prove or 

unproven what the petitioner is claiming. The plaintiff stating something in court for Rule 11 

attorney and defendant is supposed to bring evidence in support of. 

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131. From June 17, 2019 to July 7, 2020 the parties had two hearings and both hearings Judge 

George Sarduy violated due process he allowed Leslie Puzo to take over both hearings what was set 

before the court by the plaintiff was not heard instead. What the hearings were set for was not heard 

violating procedural due process of law. 

132. On November 12, 2019 the hearing was set for temporary time sharing instead 6 days before 

the only thing heard was psychological evaluation. 

133. On March 9, 2020 the hearing was set for GAL, set dates and times, and temporary spousal 

support. What was heard was the defendants hearing that was set 6 days before for parent 

coordinator violating my due process by Judge George Sarduy and Leslie Puzo. 

134. On March 9, 2020 the plaintiff attorney told the Judge he signed a falsified court order. The 

Judges ruling of the transcript was printed out during the hearing. The attorney stated that the JA 

would not give a court date for motion for reconsideration. Judge George Sarduy stating he did not 

know what happen during the hearing because the hearing was long, he stated something happened. 

Judge George Sarduy stating he was not setting a motion to reconsider unless the entire transcript 

was printed out. 

135. During the hearing Judge George Sarduy left during 30 minutes taldng up time for the 

hearing to commence that was set 2 months prior to handle time sharing and the defendant violating 

the court order, 

136. On March 9, 2020 at the beginning of the hearing Diksha Sharma was having an ex parte 

conversation with the Judge George Sarduy while everyone was outside including her co counsel 

Leslie Puzo. To the Florida Bar this was not denied by Diksha Sharma. Ex parte communications are 

inherently unfair and violative of the due process. 5 U.S.C. §§ 554,556,557 (1976). The original 

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Administrative Procedure Act prohibited ex parte contacts during any adjudication proceeding. Ex 

parte communication violates the plaintiff 51

h amendment rights. 

137. On March 9, 2020 Plaintiff attorney Jennifer Ford notified the Judge that the plaintiff did 

not know where the minor child was. Judge George Sarduy stated to get the address from a 

deposition insisting in the conspiracy to conceal the child. 

138. On March 10, 2020 when asked for the address the defendant Priscille Duvalsaint got up 

and walked out of the deposition at the direction of her attorney when asked for the address. This is 

against rules of the Florida Bar there was no protection for the defendant and the Judge has heard all 

allegations on November 12, 2019 with no evidence in support of. 

139. On or about April 6, 2020 the plaintiff filed an appeal, due to it not being a final 

judgement the appeal was denied. 

140. On or about July 5, 2020 the entire transcript was printed out. On July 7, 2020 Judge 

George Sarduy recused hims~lf. The way that he did it was to purposely cost the plaintiff money. 

The plaintiff had Jennifer Ford as his attorney and she was withdrawing, Judge George Sarduy 

would not allow her to withdraw without a motion. The new attorney Jon May was present the 

hearing was set for case management conference. 5 minutes into the hearing with two attorneys 

present the George Sarduy started calling the plaintiff toxic for fighting for his constitutional rights 

to be a father The plaintiff believes this to be retaliation. Judge George Sarduy could have recused 

himself the same way the other 7 judges did without a hearing. 

141. Judge George Sarduy is a racist, the plaintiff believes so because he said, "I can look at 

you and tell your psychological evaluation." Judge George Sarduy made this comment in front of 

Leslie Puzo, his bailiff Cesar, Jennifer Ford, Priscille Duvalsaint, and Jon May. The transcript will 

show during the two hearings the plaintiff didn't say close to anything to the judge so for him to talk 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 40 of 50
to him like this there is a problem with him and black people or him and men fighting for their kids. 

The plaintiff finds the comment bias, discriminatory, and racist by a judge that is bonded to be fair 

and impartial. 

142. Judge George Sarduy works in family court there are divorces all the time, in the plaintiffs 

case Judge George Sarduy decided to do things based of only what the mother stated. The transcript 

will show there was no evidence in support of and he stated it. The law states that I am not to be 

restricted from being a parent unless I am a detriment. Judge George Sarduy stated on the record 

they have not shown that I'm a danger to the minor child but he gave me supervised visits based off 

of what a bitter wife going through divorce stated because he is racist, I state so due to his actions 

and what he said to be prejudicially. His actions shows he is bias against fathers in court, I do not 

know him personally however he has been stalked and it has been in the newspapers due to his 

actions. 

143. Judge George Sarduy violated Title 42 U.S. Code§ 1983 

144. Every person who, under color of any statute ordinance, regulation, custom, or by usage, of 

any State or Territory, subjects, or causes to be subjected, any citizen of the United States o~ other 

person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities 

secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in 

equity, or other proper proceeding for redress. Every person shall be liable in an action at law suit in 

equity ~o exclusion for judges by any act of congress United States Code, Title 42, Section 1985 (3). 

If two or more per persons ... conspire for the purpose of depriving any person of equal protection of 

the laws the party so injured or deprived may have an action for the recovery of the damages against 

one or more conspirators no exclusion for Judges by any act of Congress United States Title 42, 

Section 1986. Every person who, having knowledge that any of the wrongs are about to be 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 41 of 50
committed and having knowledge that any wrong doings are about to be committed, and having 

power to prevent the aid. in preventing the commission of the same, neglects or re.fuses so to do ... 

shall be liable. 

145. Judge George Sarduy kept a 20 month year old baby away from a loving father just based 

off what the bitter mother said with no evidence in support of and he stated it on the record. 

146. In direct the defendant while her lawyer questioned her stated that the father pinch her 

thighs, squeezed her fingers and during this line of questioning there was no dates or times 

everything that was testified to was vague but when the plaintiff was testifying dates had to be spot 

on. 

147. On direct examination plaintiff questioned her asking a line of questioning as to what is 

the definition of extremely violent because what the mother was stating seem to be emotional 

violence. The plaintiff was trying to get clarification of physical violence or emotional violence. 

During the line of questioning the transcript will show while questioning the witness the Judge 

disrupted the plaintiff for no reason stating how is that going to help you today. Not the attorney 

objecting but it shows the bias situation where it was a 2 lawyers and a Judge against the prose 

Plaintiff who was trying to get the truth out. Was a violation of the constitutional rights the right to 

question the accuser. 

148. The transcript will show that the George Sarduy told the plaintiff he is ruling but when it 

was ~he defendant they were allowed to keep speaking and they were heard. The plaintiff was not 

allowed to be heard against his constitutional rights. 

149. Judge George Sarduy violated the plaintiffs liberty to be a father, violated the plaintiffs 

right to question the witness, violated his rights regarding ex parte communication as well as signed 

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an ex-parte court order that restricted access to child by supervised visits even though he stated on 

the record they have not shown that he is a harm to the child. 

150. Judge George Sarduy should be upset at the two attorneys who falsified his court order and 

gave partial documents not the person who brought fraud to his knowledge and is exercising his 

constitutional rights the transcript will.show that Judge George Sarduy was retaliating. 

151. During the court hearing the defendant and her attorney filed fraudulent tax returns and 

affidavit. Judge William Haury stated in a court order that he would address it in a final judgment, 

and he has not. During Child support hearing with general magistrate Carlos Fernandez was shown 

and judged off of false financial affidavit' as well as fraudulent tax returns. The bank statements were 

shown that the tax returns were fraudulent. In his report General Magistrate Carlos Fernandez states 

that the bank account shows that she makes an undermining amount which was not true. 

152. On May 16, 2022 Judge William Haury sent the parties to hearing officer to address child 

support. The fraudulent financial affidavit was used again by Leslie Puzo and Priscille Duvalsaint. 

The plaintiff showed bank records that she exaggerated her taxable income to lower child support 

making fraud on the court again. The defendant stated in 2018 she made 208k and net 64k. She 

stated she had no cost of goods sold and she showed no receipts in court for child support and case 

law was given by the plaintiff. The fraud cost the plaintiff attorney fees and $30k in arrears and $366 

month child support. 

153. In 2019 the defendant Priscille 1099s shown in court she made 158k the GM Carlos 

Fernandez stated that she makes $5,346.00 dollars per month due to her fraudulent tax returns and 

financial affidavit. 

154. In 2020 the defendant Priscille Duvalsaint made 118,000 dollars 1099 will show. Her 

financial affidavit states 54k. 

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155. In 2021 the defendant Priscille J:?uvalsaint made $99,000 dollars. 

156. During the child support hearing and the plaintiff showed the amount she wrote off on 

taxes and what was stated on the taxes did not incur and her tax returns were fraudulent. The general 

magistrate Carlos Fernandez stated on the record that she wrote off expenses on her business and 

then turned around and wrote those same expenses on her personal tax return. General Magistrate 

violated court the best interest of the statue which states what is allowed to be written off. 

157. The Defendant made 34k in 2018, 54k in 2019, 34k in 2020, and 15k in 2021 according 

to 1099s and tax returns. 

158. General Magistrate Carlos Fernandez refused to allow the plaintiff to question the 

plaintiff on her false domestic violence injunction which interfered with time sharing and 

concealment. Violating the plaintiff constitutional rights. 

159. The plaintiff stated that the general magistrate sustained his objection when he asked the 

defendant Priscille Duvalsaint why she did not bring her expenses with her like the case law states. 

General Magistrate Carlos Fernandez started asking the plaintiff if he is a lawyer. General 

Magistrate Carlos Fernandez the transcript will show was violating the plaintiff constitutional rights 

to represent himself. The plaintiff interpreted his comments that he is not allowed to state the law or 

case law if he is not a lawyer. 

160. The General Magistrate and Leslie Puzo were doing ex parte conversations, the court date 

was unilaterally set. When brought to the JA attention she stated that we usually go with the 

attorney's schedule due to their schedules and conflicts. The plaintiff reminded the JA that he is to 

be t~eated like a lawyer when pro se. The JA refused to cancel the court date and the plaintiff missed 

out on a job opportunity that he was awaiting 8 months for. 

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161. The plaintiff told the general magistrate when he walks into a court room he is to be treated 

fair and impartial. The General magistrate read the plaintiff fraudulent domestic violence injunction 

and said you were stalking her before you went there but the domestic violence injunction did not 

say that. The plaintiff stated that the injunction was dismissed he stated that doesn't mean that you 

didn't stalk her. Malicious prosecution states all it has to be is the charges are dropped. I would like 

the court to take how bias this general magistrate is he read something and testified to something not 

in the document as well as how the fraudulent DV allegations has legally harmed the plaintiff. 

162. The plaintiff would not allow the plaintiff to question the defendant on the kidnapping which 

was important due to case law of concealment. The plaintiff was stating concealment on the basis of 

Hoffman vs Foley, the plaintiff is believed that General Magistrate Carlos Fernandez violated the 

plaintiffs rights. 

163. The plaintiff was retaliated against with his ruling, the plaintiff told the General magistrate 

due to him being discriminated against for being black and a man in Miami. The plaintiff contacted, 

the administrative Judge Scott Bernstein and he got involved and moved his case to Broward due to 

him not being given court dates and not being treated fairly. The plaintiff asked the general 

magistrate how the case was in Miami Dade for 1 year and 7 months and did not see the minor child. 

When the case was moved to Broward the plaintiff seen daughter with set dates and times in less 

then 4 months the plaintiff cited discrimination and racism. A father who is a basketball coach at 

Booker T. Washington, was in Big Brothers Big Sisters, works with autistic children but cannot see 

his child even though the Judge has stated on the record the father is not a threat to the child. The 

defendant Priscille Duvalsaint violated numerous court orders that was put in place for the best 

interest of the child. 

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164. The general magistrate did not follow the case law by taking in affect the defendant's 

behavior during child support. General magistrate Carlos Fernandez administered with an evil eye 

and a heavy hand was discriminatory and violated the Equal protection has awarded the defendant 

with arrears in child support of 30k and after showing her fraudulent tax returns with no receipts or 

that expenses incurred 366 dollars a month. GM Carlos Fernandez also did not take into 

consideration the plaintiff legitimate business expenses. 

165. Leslie Puzo has had over 13 extensions through this litigation process delaying time with 

daughter. A Lawyer should not request rescheduling, cancellations, extensions, or postponements 

without reasonably legitimate reasons and never solely for the purpose of delay or obtaining unfair 

advantage. 

166. The final judgement was done March 16, 2022, Leslie Puzo filed an intent to appeal April 

18, 2022. On September 12, 2022 Leslie Puzo filed for an extension to the appeal. The appeal is 

supposed to be turned in 70 days after the intent. On September 19, 2022 Leslie Puzo turned in the 

appeal. Leslie Puzo is doing nothing but delaying the case and billing her client making money off 

her ignorance. Leslie Puzo now at the moment is attempting to defraud the appeals court the 

Supreme Court. This has affected the plaintiff in Priscille Duvalsaint has messed up the clients credit 

and the plaintiff has not taken ownership of the house, and child support has not been finalized. 

167. General Magistrate Carlos Fernandez stated he needed to get advisement. With the proper 

discovery it is my belief Judge George Sarduy made this ruling or gave the advisement and 

whomever did make the ruling I should be allowed to depose. 

168. : The plaintiff showed exactly where the defendant, Priscille Duvalsaint money went to 

and it wasn't to the things she wrote on her tax returns they were not business expenses. It was 

personal expenses that were to bring up her income about to her gross. 

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169. Judge George Sarduy violated my constitutional and civil rights as a father. 

170. General Magistrate Carlos Fernandez violated my constitutional as well as civil rights with 

stating that I am not an attorney in which has the right to represent myself pro se even though it was 

not by choice. 

171. Marie Liautaud had knowledge that the plaintiff did not consent, abducts and did not give the 

minor child to the legally entitled to its custody and did not return to the parent after Priscille left the 

house is subject to liability to the parent. 

Wherefore plaintiff prays this Court issue equitable relief as follows: 

172. General Magistrate Carlos Fernandez held liable for declaratory and injunctive relief as well 

as attorney fees for attorney used before the General magistrate. Review of their cases and decisions 

based of discrimination, gender, and constitutional rights violated. 

173. Issue declaratory relief as this court deems appropriate just. 

174. Issue other relief as this court deems appropriate and just. 

175. Judge George Sarduy held liable for declaratory and injunctive relief as well as attorney fees 

u~ed before the Judge to correct his actions. Review of their cases and decisions based of 

discrimination, gender, and constitutional rights. 

176. Reverse money court recommended by GM Carlos Fernandez paid due to the use of 

fraudulent tax returns. 

117. .Money paid to the plaintiff for emotional pain, suffering, and companionship. 

178. Money paid to the plaintiff NCG minor child for emotional pain, suffering, and 

companionship. 

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179. All attorney fees paid through civil court for house, domestic violence court, appeals 

court, transcripts, and divorce by way of vexatious litigation. 

180. I ask that the defendants be found jointly and severally liable to the compensatory 

damages. I request the judge assess exemplary damages against the mother, defendant's mother, 

court reporter, judge, general magistrate, and attorneys a specific amount. 

181. Money for ex parte court order unconstitutionally signed and what it has caused. 

182. $100,000 compensatory damages and individual punitive damage for intentional 

emotional distress. $300,000 for Malvin Garnett $100,000 compensatory damages and intentional 

emotional distress individual punitive damages for NCG minor child $100,000. $30,000 dollars in 

attorney fees. $6,000 dollars in therapist fees. $50,000 dollars for the time damage ex parte court 

order has caused. $75,000 dollars for the false domestic violence case has caused. $4,000 dollars on 

transcript that were paid to correct the defendants lies. $200,000 dollars for violating the plaintiffs 

civil and constitutional rights unlawfully. 

183. Recovered damages that naturally flow from a civil conspiracy. 

184. Injunction from daughter from Leslie Puzo the defendant has my daughter around this 

person 

who has done the harm in this litigation. 

185. The wrongs committed in the instant case fall within the Florida rules damages are 

recoverable for mental suffering unaccompanied. By physical suffering when the wrong complained 

of is a willful one intended by the wrongdoer to produce mental anguish or from which such result 

coulo be reasonably anticipated as a natural consequence. 

' 

186. The deprivation to the parent of the society of the child is itself an injury that the law 

redrysses without showing loss of service. 

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187. The parent can recover for the loss of society of his child i:lnd for emotional distress resulting ... .. ;,. 

from-its abduction or enticement. 

188. Loss of service actually not performing service the parent is requesting loss of the service 

that he could have required of the child during the period of its absence. 

189. Cost of litigation 

190. Whatever the court has to do to remove the false. DV injunction off of the plaintiffs name at 

the defendants cost. 

'CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and corrected copy of this Motion was served on Defendant, 

Priscille Duvalsaint, Leslie Puzo, Diksha Sharma, Yasmin Morshedian, Judge George Sarduy, 

General Magistrate Carlos Fer:nandez at the following address. 

Leslie Puzo 1175 NE 125TH ST #618 North Miami, FL 

Dlksha Sharma 500 East Broward Blvd. Suite 1710 Fort Lauderdale, Florida 33394 

Priscille Duvalsaint 2321 Laguna Circle #709 Miami, FL 33181 

Marie Liautaud 2321 Laguna Circle #709 Miami, FL 33181 

Yasmin Morshedian 1 E Broward Blvd SUITE 700, Fort Lauderdale, FL 33301 

General Magistrate Carlos Fernandez 175 NW 1st Ave #1726, Miami, FL 33128 

Judge George Sarduy 175 NW 1st Ave #1925, Miami, FL 33128 

~ Malvin Garnett 

Malvin Garnett 

£437 SW 3rd ST #4 

Miami, FL33130 

BKBRIDGE718@AOL. COM 

.I 

Case 1:22-cv-23543-RKA Document 12 Entered on FLSD Docket 11/02/2022 Page 49 of 50
,. 

437 SW 3rd St #4 

Mfamr, a ·33130 

786-368-8079 

Statement of Verification 

-:1 

I have read the above complain and it i~ correct to the best of my knowledge. 

tkd. 

.J 

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