George Raymond and Edward Raymond, proceeding pro se, filed an emergency motion for preliminary injunction in Miami federal court seeking to stop the Miami-Dade County Sheriff from executing a writ of possession at their commercial property at 7101 NW 7th Avenue. The brothers claim U.S. Bank National Association obtained a foreclosure judgment through fraud, submitting what they characterize as a digitally manipulated promissory note to state court.
Edward Raymond, who describes himself as a forensic expert with degrees including BSEE, MSEE, MBA, JD, and LL.M., claims he conducted a pixel-level analysis of the note filed in state court and identified 'inconsistent pixel resolution and compression artifacts inconsistent with a genuine wet-ink scan' and 'layering inconsistencies indicative of digital copy-paste manipulation.' The motion alleges that defendant attorney Paul A. Giordano certified under oath that the original note exists at his firm's Fort Myers office, which the plaintiffs argue proves the court-filed document was not a genuine scan.
The plaintiffs face imminent eviction under a writ of possession verbally granted April 9, 2026, in Miami-Dade Circuit Court. Edward Raymond holds title to the property through a quit claim deed recorded May 16, 2005 - 16 years before the Velocity Commercial Capital mortgage was executed in August 2021. The motion emphasizes that 'Edward Raymond was never named as a defendant in the state court foreclosure. He was never served with process. His recorded title interest was never challenged, adjudicated, or extinguished in the state court proceedings.'
The case stems from a state court foreclosure action where U.S. Bank obtained a default judgment against the property. The plaintiffs argue the judgment is void because George Raymond was never properly served under Florida Statute § 48.031, and because he signed the promissory note solely as corporate president without any personal guaranty. They cite BugWare, Inc. v. Williams for the principle that 'the mere signing of an agreement as a corporate officer does not impose personal liability.'
U.S. Bank acquired its interest for $300 at what the motion describes as 'a non-competitive aborted auction in which no competitive bidding occurred - thirty seconds after the auction commenced, it was cancelled.' The plaintiffs claim they have funding to satisfy the full $1,929,000 mortgage obligation within 20 days and argue the balance of equities favors them given the property's estimated $3.5 million value versus the bank's minimal investment.
The motion seeks to overcome the Anti-Injunction Act's general prohibition on federal courts enjoining state proceedings, arguing three exceptions apply: that the injunction is necessary in aid of federal jurisdiction over the property, to protect future federal judgments, and because civil RICO under 18 U.S.C. § 1964 is expressly authorized by Congress. The plaintiffs filed a notice of lis pendens against the property and argue enforcement of the state writ would render their federal declaratory judgment action 'illusory.'
The emergency motion requests an immediate temporary restraining order and preliminary injunction blocking enforcement of the writ pending resolution of their federal RICO, fraud, and declaratory judgment claims. The plaintiffs also allege U.S. Bank's agents previously entered the property by force on March 30, 2026, cutting locks and damaging the gate without legal authority, prompting a police report.