Petition for Writ of Certiorari — Silas Salyers, aka Silas Salyer, Petitioner v. Clifford B. Walker, Personal Representative of the Estate of Evelyn Walker

Supreme Court briefSep 8, 2025

Ask Donna

What actually matters in this document.

Text

No. ___________

_________________________________________________

In the

Supreme Court of the United States

_____________________

Silas Salyers,

Petitioner/Defendant

Clifford B. Walker,

Respondent/Plaintiff

___________________

On Petition For a Writ Of Certiorari To The

Michigan Supreme Court

________________________________________

PETITION FOR A WRIT OF CERTIORARI

_______________________________________

Elena A. Paremsky (MI P62996)

Counsel Of Record/Attorney for Petitioner/Defendant

993 Bray Road Williamston, Michigan 48895

email: eparemsky@hotmail.com

Tel. 517-575-7123

QUESTIONS PRESENTED

Did the State of Michigan by its

judiciary violate Petitioner's due process and equal

protection rights by ruling contrary to the binding

rule of law that resulted in a legally/ factually

impossible ruling when property trespass damages

were ordered against Petitioner Silas Salyers, the

deed holder and the property record owner, and to

Respondent Walker who as courts confirmed has no

transfer deed in his name?

II.

Did the State of Michigan by its

judiciary violate due process/equal protection rights

and the U.S. Constitution Contract clause when they

declared null and void Petitioner's property

documents, while Respondent filed no complaint

regarding such deeds and while Petitioner's counsel

was heavily ($3,500) fined despite compliance with

orders and ordered to pay $2,500 to Respondent's

attorney to prepare the document actually prepared

by the Petitioner's attorney??

III.

Did the State of Michigan by its

judiciary violate the U.S. Constitution Contract

clause and Petitioner's fundamental right to contract

when they awarded trespass damages to Respondent

despite confirming that there was no transfer deed in

Walker's name, and required Petitioner's vendor to

pay contract proceeds to Walker while Walker was

not a party to the Petitioner Salyers' contract?

IV. Did Michigan state officials enable

Respondent's scheme of getting Petitioner's property

without paying for it while Respondent Walker had

no transfer deed to Petitioner's farm, which violated

the RICO1 Act?

PARTIES TO THE PROCEEDINGS

Petitioner Silas Salyers, Defendant/Appellant, is a

deed holder and the property record owner of the

subject property. Petitioner's Appendix, pp. 56a66a (deeds, county property record).

Respondent Clifford B. Walker, Plaintiff/Appellee, is

a personal representative of Evelyn Walker's estate

who in this land trespass action "failed to produce a

deed transferring the 79-acre parcel from Salyer to

the Estate," as confirmed by the courts. Petitioner's

Appendix, pp. 12a (COA opinion).

CORPORATE DISCLOSURE

Petitioner is an individual and is not a subsidiary or

affiliate of a publically owned corporation.

RELATED PROCEEDINGS

Walker v. Salyers, No. CC 22-463-CH, Ingham

County Circuit Court. Final Orders entered on July

27, 2023, August 1, 2023, and August 25, 2023.

Walker v. Salyers, No. 367231/367691, Michigan

Court of Appeals. Opinion issued on April 9, 2025.

Walker v. Salyers, No. 168535-6, Michigan Supreme

Court. Order was entered on July 25, 2025.

Racketeer Influenced and Corrupt Organizations Act, 18

U.S.C. 96

TABLE OF CONTENTS

QUESTIONS PRESENTED ................................................. i

PARTIES TO THE PROCEEDINGS ........................ ii

CORPORATE DISCLOSURE ................................... ii

RELATED PROCEEDINGS ..................................... ii

TABLE OF CONTENTS .......................................... iii

APPENDIX TABLE OF CONTENTS ................................. v

INDEX OF AUTHORITIES ............................................... vi

PETITION FOR A WRIT OF CERTIORARI ............ 1

OPINIONS BELOW .................................................. 2

JURISDICTION ........................................................ 3

CONSTITUTIONAL PROVISIONS INVOLVED .... 3

STATEMENT OF THE CASE ................................... 4

REASONS FOR GRANTING THE WRIT ............ 5

To avoid deprivations of property without due

process and violations of the substantive due

process right to contract, this Court should grant

review and order reversal of the Michigan state

judiciary's decisions which are in direct violation of

the binding rule of law and the U.S. Constitution ... 5

A. Michigan Judges David L. Jordon, Christopher

M. Murray, Michael J. Kelley, and Noah P. Hood

Violated Petitioner's Due Process Rights ........... 6

1. Michigan Judges David L. Jordon,

Christopher M. Murray, Michael J.

Kelley, and Noah P. Hood Ruled Against

the Rule Of Law and Evidence ................. 6

a. Courts Confirmed In This Land Trespass

Action That Respondent Walker Has No

Transfer Deed In His Name ................. 8

iii

b. Michigan Judiciary In This Action

In Clear Error Used Deemed Admissions

From the Prior Action Directly Contrary

To MCR 2.312(D)(2) ........................... 10

2. Michigan Judges David L. Jordon,

Christopher M. Murray, Michael J. Kelley,

and Noah P. Hood Violated Petitioner's

Fundamental Right to Contract .............. 13

3. Michigan Judges David L. Jordon,

Christopher M. Murray, Michael J. Kelley,

and Noah P. Hood Violated Petitioner's

Substantive Due Process Rights By Their

Corrupt Conduct In Refusing to Follow the

Binding Law ............................................. 15

B. Michigan Judges David L. Jordon, Christopher M.

Murray, Michael J. Kelley, and Noah P. Hood's

Orders of Removal of Petitioner's 5-31-22 Deeds

Violated Due Process/Contract Clause ...............16

1. State Judiciary Had No Jurisdiction to

Provide Relief To Respondent Walker

For Claims Not Stated In His Complaint. 16

2. State Judges Orders/Affirmation of

Removal Of Petitioner's Deeds From

the Register of Deeds Violated His

Fundamental Right to Contract .............. 18

3. State Judges Sanction Orders, Issued

Contrary to Binding Law, Violated Due

Process ....................................................... 18

C. Michigan Judges David L. Jordon, Christopher M.

Murray, Michael J. Kelley, and Noah P. Hood

Violated Petitioner's Equal Protection Rights ... 19

D. Michigan Judges David L. Jordon,

Christopher M. Murray, Michael J. Kelley,

And Noah P. Hood Violated the Contract

Clause of the U.S. Constitution ......................... 20

E. Respondent Clifford Walker, A Resident of

Florida, His Attorney Martin G. Lozier, and

Non-party Pamela Griffith's Activities In

Violation of RICO Act To Get Petitioner Salyers'

$600k Home And Farm Without a Transfer Deed

And Without Paying For It ................................. 23

CONCLUSION AND RELIEF REQUESTED ........ 27

APPENDIX (Separate Volume, Enclosed)

Appendix Table of Contents

Michigan Supreme Court's Order (July 25,

2025) Denying Petitioner's Application for

Leave to Appeal of the Lower Courts' Award of

Trespass Damages and sanctions contrary to

law and evidence ........................................... 1a

Michigan Court of Appeals Decision (April 9,

2025) .............................................................. 2a

Orders from the Michigan 30th Circuit Court

following Motion for Summary Disposition

(July 27, 2023, August 1, 2023) .................. 32a

Post-Judgment Order (August 25, 2023)

Following Motion for Clarification ............. 36a

Interim August 30, 2022 Circuit Court Order

(Excerpt) ...................................................... 42a

Interim August 5, 2022 Circuit Court Order

(Excerpt) ...................................................... 44a

Transcript of the July 27, 2023 MSJ ......... 46a

10.

11.

Interim Oct. 3, 2022 Order Re: Stay .......... 47a

Court's Correspondence Confirming Stay .. 50a

Respondent's Complaint for Trespass ........ 52a

Chain of Title to the Subject Property

in Petitioner's Name, Exh.1 to D's Emerg.Mtn. 56a

12.

County Receipt/ Property Record, Attach. 4

to Defendant's 7-27-22 Emergency Motion 65a

13.

Petitioner's 2021 Contract For His Timber,

Attachment 1 to Defendant's 7-27-22

Emergency Motion ....................................... 67a

14.

7-09-22 Police Report Re Trespass which

resulted in no charges, Exhibit 2 to

Defendant's Answer to Complaint ...............68a

15.

Notice to Clifford Walker about the Defective

quitclaim deed to 1 acre with a non-matching

erroneous legal description, Exhibit 1 to

Defendant's Response to Plaintiff's Motion for

TRO................................................................. 73a

16.

CC 20-162-CH Final Court Orders, Not

Ordering Reformation of the Defective 2015 $1

quitclaim deed ............................................. 80a

17.

Walker's Request for Relief in his CC 20-162CH Motion for Summary Disposition which

did not include defective deed reformation into

Walker's name ............................................. 86a

18.

Clifford B. Walker's 2019 Text Message .... 87a

19.

August 31, 2025 Pictures of the Respondent

Walker's Eviction of Petitioner out of

Petitioner's home and farm ........................ 88a

INDEX OF AUTHORITIES

United States Constitution

U.S. Constitution. U.S. Const., art. I, §10. ......... 3, 20

U.S. Constitution. U.S. Const., art. VI, §2 ................ 3

U.S. Const. amend. V ....................................... 3, 6, 19

U.S. Const. amend. XIV ....................................3, 6, 19

THE FEDERALIST No. 78, at 470 (Alexander

Hamilton) (Clinton Rossiter ed., 2003) ..................... 7

United States Code

18 U.S. Code § 873 ........................................................... 23

18 U.S.C. 96 § 1341 .................................................. 23

18 U.S.C. 96 § 1343 .................................................. 23

18 U.S.C. 96 §1962(c) ............................................... 23

28 U.S.C. §1257 ........................................................ 3

United States Supreme Court Cases

Lochner v. New York, 198 U.S. 45 (1905) .......... 13, 18

Shelley v. Kraemer, 334 U.S. 1, S.Ct. 836, 92 L. Ed.

1161, 3 A.L.R. 2d 441(1948) ...... 4, 5, 14, 19, 20

Willowbrook v Olech, 528 U.S. 562, 120 S.Ct. 1073;

145 L.Ed.2d 1060 (2000) ............................... 19

United States 6th Circuit Cases

Ercegovich v. Goodyear Tire & Rubber Co,

154 F.3d 344, 352 (6th Cir. 1998) ................. 19

Michigan Supreme Court Cases

Dawson v. Falls City Boat Club, 125 Mich. 433,

84 N.W. 618 (1900) .................................... 8, 13

Grievance Administrator v. Underwood,

462 Mich. 188; 612 N.W.2d 116 (2000) .......... 7

In re AGD, 327 Mich. App. 332,

933 N.W.2d 751 (2019) .................................. 15

Hinkle v. Wayne County Clerk, 467 Mich. 337,

654 N.W.2d 315 (2002) .............................. 7, 15

In Re Attorney Fees and Costs, 233 Mich. App. 694,

593 N.W.2d 589 (1999) .................................. 10

People v. Hunt, 171 Mich. App. 174,

429 N.W.2d 824 (1988) .................................. 12

People v Mitchell, 428 Mich. 364,

408 N.W.2d 798 (1987) .................................... 6

vii

Radtke v. Miller, Canfield, Paddock & Stone,

453 Mich.413, 419; 551 N.W.2d 698 (1996) . 10

Roberts v. Mecosta Co. Gen. Hosp., 466 Mich. 57,

642 N.W.2d 663 (2002) ................................... 7

Sipes v. McGhee, 316 Mich. 614,

25 N.W.2d 638 (1947) ...................................... 5

Spitzley v. Spitzley, 477 Mich. 989,

725 N.W.2d 464, (2007) ....................................... 10

Michigan Court of Appeals Cases

BJ's & Sons Construction Co. v. Van Sickle,

266 Mich. App. 400, 700 N.W.2d 432 (2005) ..... 10

In Re Attorney Fees and Costs, 233 Mich. App. 694,

593 N.W.2d 589 (1999) .................................. 10

Marina Bay Condominiums, Inc v. Schlegel,

167 Mich.App.602, 423 N.W.2d 284 (1988). 13, 21

Mettler Walloon v. Melrose Twp, 281 Mich. App. 184,

761 N.W.2d 293 (2008) .................................. 14

People v Coutu (On Rem) 235 Mich. App. 695,

599 N.W. 2nd 556 (1999) ............................... 15

People v. Hunt, 171 Mich. App. 174,

429 N.W.2d 824 (1988) .............................. 7, 11

Thomas v. Dutkavich, 290 Mich. App. 393,

803 N.W.2d 352 (2010) .................................... 7

Michigan Statutes

MCL 566.106 ...................................................... 13, 21

MCL 566.108 ...................................................... 13, 21

MCL 600.605 ............................................................ 16

MCL 600.2919(1)(a)(c) ............................................... 8

Michigan Court Rules

MCR 2.111(B) ........................................................... 16

MCR 2.312(D)(2) .................................... 10, 11, 13, 21

MCR 7.215(C)(2) ..................................................... 7

Treatises

Perkins & Boyce, Criminal Law (3d ed.) ................ 15

viii

PETITION FOR A WRIT OF CERTIORARI

Real estate fraud is on the rise.1 Real estate

fraud for farm land, strategically located close to oil

companies, is even bigger. What is real estate fraud?

It is when someone obtains someone else's property

without paying for it or without paying a fair price,

and against the landowner's will. This is such a case

concerning Petitioner Silas Salyers' $600,000 farm

and home in Stockbridge, Michigan.

Petitioner Silas Salyers, the deed holder and

the property record owner of the subject property

(Petitioner's Appendix, pp. 56a-66a), by his

attorney Elena A. Paremsky, petitions this Court for

a writ of certiorari to review the record of the

Michigan Supreme Court that affirmed the lower

courts' orders awarding $60,000 alleged trespass

damages to Respondent Clifford Walker who actually

"failed to produce a deed transferring the 79-acre

parcel from Salyer to the Estate," as confirmed by

the courts. Petitioner's Appendix, pp. 12a. By

awarding trespass damages against the legal owner

of the land, the state judges denied Petitioner Silas

Salyers due process and equal protection, as they

ruled contrary to the statutes and clear precedents,

violated his fundamental right to contract and the

Contract Clause of the U.S. Constitution.

In its post-judgment orders affirmed on

appeals, the courts continued ruling against the

binding rule of law by requiring a $3,500 fine for

alleged non-compliance with the stayed interim

order, after the issuance of the final order which did

https://www.fbi.gov/contact-us/field-offices/newark/news/fraudstersare-stealing-land-out-from-under-owners.

not include any interim order requirements, and

which was complied with before the post-judgment

show-cause hearing, and ordered Petitioner's counsel

to pay $2,500 to Respondent's counsel to draft a

document undisputedly drafted by the Petitioner's

counsel (!!). The courts also required removal of the

Petitioner's estate planning and corrective deeds

while Respondent has not filed a complaint regarding

them, which further violated Petitioner's Due

Process and fundamental contract rights.

The damages keep mounting - on November

14, 2025, in the 55th district court Case 24-1075-LT,

Judge Jordon re-appeared and at pre-trial, without

any trial, let alone by jury which Petitioner

demanded, issued a judgment of possession with an

order of eviction to Clifford Walker despite Res

Judicata and the fact that "Walker failed to produce

a deed transferring the 79-acre parcel from Salyer to

the Estate," as confirmed by the courts. Petitioner's

Appendix, pp. 12a. Respondent Walker evicted the

86-year-old Petitioner Silas Salyers on August 25-29,

2025 out of Mr. Salyers' own home and farm, and

had put the lifetime worth of Petitioner's possessions

out to the curb, although Petitioner Silas Salyers is a

deed holder and a record owner of the subject

property (Petitioner's Appendix, pp. 56a-66a; 8890a). This is an egregious violation of Petitioner's

constitutional rights and the binding rule of law.

OPINIONS BELOW

On July 25, 2025, the Michigan Supreme Court

issued Order No. 168535-6, which affirmed the Court

of Appeals Orders No. 367231, 367691 and Ingham

County 30th Circuit Court Orders in No.22-463-CH

(Petitioner's Appendix, 1a-45a).

JURISDICTION

Petitioner's Application to the Michigan

Supreme Court for Leave to Appeal the Court of

Appeals' order was denied on July 25, 2025, leaving

lower courts' rulings to stand, by which the state

judiciary denied Petitioner due process and equal

protection rights, and violated the Contract Clause of

the U.S. Constitution. Petitioner invokes this Court's

jurisdiction under 28 U.S.C. §1257, having timely

filed this petition for a writ of certiorari.

CONSTITUTIONAL PROVISIONS INVOLVED

United States Constitution, Article VI,

Clause 2: "This Constitution, and the Laws of the

United States... shall be the supreme Law of the

Land; and the Judges in every State shall be bound

thereby, any Thing in the Constitution or Laws of

any State to the Contrary notwithstanding."

United States Constitution, Amendment V:

"No person shall... be deprived of life, liberty, or

property, without due process of law."

United States Constitution, Amendment

XIV: "No State shall make or enforce any law which

shall abridge the privileges or immunities of citizens

of the United States; nor shall any State deprive any

person of life, liberty, or property, without due

process of law; nor deny to any person within its

jurisdiction the equal protection of the laws."

United States Constitution, Article I,

Section 10: "No state shall pass any Law impairing

obligation of contracts."

STATEMENT OF THE CASE

Due process and equal protection clauses of

the U.S. Constitution guarantee that no state or

private actors under the color of state law would take

away property without due process of law. In Shelley

v. Kraemer, 334 U.S. 1, S. Ct. 836, 92 L. Ed. 1161, 3

A.L.R. 2d 441(1948), this Court affirmed that

judiciary are state actors who must comply with the

due process and equal protection requirements. The

doctrine of stare decisis precludes judges from

discriminating against litigants as it imposes a strict

duty to apply the binding law to all claimants,

affording each person the requisite due process.

This case presents a complete failure of the

Michigan state judges to afford due process or equal

protection to Petitioner/Landowner Silas Salyers

when they ruled that he is liable in trespass damages

for his trees he got harvested on his own property

(Petitioner's Appendix, pp. 56a-66a (deeds, county

property record)), to Respondent Walker who as

courts confirmed "failed to produce a deed

transferring the 79-acre parcel from Salyer to the

Estate," Petitioner's Appendix, pp. 12a.

In its post-judgment orders affirmed on

appeals, the courts continued ruling contrary to the

rule of law by requiring a $3,500 fine for alleged noncompliance with the stayed interim order, after the

issuance of the final order which did not include any

interim

order

requirements

(Petitioner's

Appendix, pp.32a-42a), ordered Petitioner's counsel

to pay $2,500 to Respondent's counsel to draft a

document undisputedly drafted by the Petitioner's

counsel. Petitioner's Appendix, p. 41a.

REASONS FOR GRANTING THE WRIT

To avoid deprivations of property without

due process and violations of substantive

due process right to contract, this Court

should grant review and order reversal of the

State judiciary's decisions in violation of the

binding rule of law and the U.S. Constitution

In Shelley v. Kraemer, 334 U.S. 1, S. Ct. 836,

92 L. Ed. 1161, 3 A.L.R. 2d 441(1948), the United

States Supreme Court expressly affirmed that the

action by the judiciary is a state action:

[T]he action of state courts and judicial officers

in their official capacities is to be regarded as

action of the State within the meaning of the

Fourteenth Amendment is a proposition which

has long been established by decisions of this

Court.... 'It is doubtless true that a State may

act through different agencies, either by its

legislative, its executive, or its judicial

authorities, and the prohibitions of the

amendment extend to all action of the State

denying equal protection of the laws, whether it

be action by one of these agencies or by

another.'

In the consolidated case Shelly v. Kraemer,

Supra, this Court also required a reversal in a

Michigan case Sipes v. McGhee, 316 Mich. 614, 25

N.W.2d 638 (1947) ruling that the action of Michigan

judges as state actors violated the claimant's

constitutional rights and must be reversed.

A. Michigan Judges David L. Jordon,

Christopher M. Murray, Michael J. Kelley,

and Noah P. Hood Violated Petitioner's Due

Process Rights

The U.S. Constitution prohibits state

governments from depriving its citizens of their

private property without due process. "No person

shall... be deprived of life, liberty, or property,

without due process of law." U.S. Const. amend. V.

Under U.S. Const. amend. XIV:

No State shall make or enforce any law

which shall abridge the privileges or

immunities of citizens of the United States; nor

shall any State deprive any person of life,

liberty, or property, without due process of law;

nor deny to any person within its jurisdiction

the equal protection of the laws.

1. Michigan Judges David L. Jordon,

Christopher M. Murray, Michael J.

Kelley, and Noah P. Hood Ruled

Against the Rule Of Law and Evidence

The constitutional due process requires courts

to rule according to the clear language of the

statutes, court rules, binding precedents and the

evidence to afford litigants constitutional due process

guaranteed by the U.S. Constitution, U.S. Const.

amend. V, XIV. Under the doctrine of stare decisis:

"A decision of the majority of the justices of our

Supreme Court is binding on all lower courts.

People v Mitchell, 428 Mich. 364, 369; 408

N.W.2d 798 (1987). "A published opinion of the

Court of Appeals has precedential effect under

the rule of stare decisis." MCR 7.215(C)(2).

"The circuit court is bound to follow the

published decisions of the Court of Appeals and

the Michigan Supreme Court." People v. Hunt,

171 Mich. App. 174, 180; 429 N.W.2d 824

(1988). "There is no requirement that a circuit

judge follow the decision of the other" [emphasis

added]. Id.

“A ... court may read nothing into an

unambiguous statute that is not within the

manifest intent of the Legislature as derived

from the words of the statute itself.” Roberts v.

Mecosta Co. Gen. Hosp., 466 Mich. 57, 63; 642

N.W.2d 663 (2002); Thomas v. Dutkavich, 290

Mich. App. 393, 803 N.W.2d 352 (2010).

We are required to apply general principles of

statutory construction when interpreting the

meaning a of a court rule. Hinkle v. Wayne

County Clerk, 467 Mich. 337, 340; 654 N.W.2d

315 (2002). When the language of the rule is

clear and unambiguous, we must enforce the

meaning plainly expressed. Hinkle, supra,

citing Grievance Administrator v. Underwood,

462 Mich. 188; 612 N.W.2d 116 (2000).

The rule of law and the concept of stare decisis

are the core of our judicial system. See THE

FEDERALIST No. 78, at 470 (Alexander Hamilton)

(Clinton Rossiter ed., 2003):

“To avoid an arbitrary discretion in the

courts, it is indispensable that they should be

bound down by strict rules and precedents,

which serve to define and point out their duty

in every particular case that comes before

them; and it will readily be conceived from

the variety of controversies which grow out of

the folly and wickedness of mankind, that the

records of those precedents must unavoidably

swell to a very considerable bulk, and must

demand long and laborious study to acquire a

competent knowledge of them.”

This case is a flagrant disregard of the binding

rule of law, where state judges had awarded $60,000

trespass damages against Petitioner Silas Salyers,

the deed holder and the official property record

owner (Petitioner's Appendix, pp. 56a-66a (deeds,

county property record)), to Respondent Walker who

as courts admitted "failed to produce a deed

transferring the 79-acre parcel from Salyer to the

Estate" (Petitioner's Appendix, p.12a) and has not

paid anything to Petitioner Silas Salyers for his land.

a. Courts Confirmed That In This

Land Trespass Action

Respondent Walker Has No

Transfer Deed In His Name

Pursuant to the trespass law, MCL 600.2919(1)(a)(c):

(1) Any person who: (a) cuts down or carries

off any wood, ..., trees, or timber or despoils or

injures any trees on another's lands, ... is liable

to the owner of the land ... for 3 times the

amount of actual damages.

"The plaintiff, claiming the right to recover as

the owner of this land, is required, in order to

establish that claim, to prove her title. It is necessary

for her to show a title to the property before she can

recover in any case." Dawson v. Falls City Boat Club,

125 Mich. 433, 84 N.W. 618 (1900). "[T]the burden

of proof is on the plaintiff, and, in order to recover at

all, she must prove that she is the owner of the land

by a series of deeds coming down ..., accompanied by

possession and claim of ownership..., by a

preponderance of evidence [emphasis added]." Id.

In this case, as courts confirmed, Respondent

Walker had undisputedly "failed to produce a deed

transferring the 79-acre parcel from Salyer to the

Estate." Walker v. Salyers, an unpublished opinion

per Curiam of the Court of Appeals, decided on April

9, 2025 (Dockets No. 367231/367691), at 6.

Petitioner's Appendix, pp. 12a (COA opinion). The

deeds in the chain of title and the official property

record are in the Petitioner Silas Salyers' name

(Petitioner's Appendix, pp. 56a-66a). Michigan

state judges made a clear error of binding land

ownership and trespass law when they ordered

Petitioner Salyers, the deed holder and the record

owner, to pay trespass damages for his own property

and his harvested trees to Respondent Walker who

has no transfer deed in his name, and has not paid a

dime to Petitioner Silas Slayers for his property.

b. State Judiciary In This Action

In Clear Error Used Deemed

Admissions From the Prior

Action Contrary To MCR 2.312(D)

The fatal error of Michigan Judges David L.

Jordon, Christopher M. Murray, Michael J.

Kelley, and Noah P. Hood was that they applied

deemed admissions from the prior 20-162-CH action2

to the subsequent action, which is expressly

prohibited by the binding rule of law as stated in

MCR 2.312(D)(2):

An admission made by a party under this

rule is for the purpose of the pending action

only and is not an admission for another

purpose, nor may it be used against the party

in another proceeding.

Also see Radtke v. Miller, Canfield, Paddock & Stone,

453 Mich. 413, 419; 551 N.W.2d 698 (1996).

In now closed CC 20-162-CH, Mr. Salyers' attorneys Navarre

and Leon failed to secure and file timely answers to requests for

admissions, which resulted in the admissions deemed by the

court when the court established for the purposes of CC 20-162CH only pursuant to MCR 2.312(D)(1),(2) as if Mr. Salyers

transferred the 79-acre property to his late sister Evelyn

Walker, while in fact he did not. Mr. Salyers' former attorneys

in CC 20-162-CH also overlooked to file a timely motion to set

them aside. The court in CC 20-162-CH never issued an order

to change the defective $1 quitclaim 2015 deed for the 1 acre

parcel with an erroneous description into a deed for the 79 acre

parcel in Walker's name, but only awarded Walker's attorneys'

fees for alleged Slander of title by Lis Pendens in an apparent

attempt to compensate for Mr. Salyers' attorneys' issues with

discovery, although Clifford Walker's counter-claim was

frivolous because deemed admissions did not exist at the time it

was filed. COA judges Gadola, Greenleaf Maldonado, and Patel

ruled against the binding law that deemed admissions do not

form a factual basis for a frivolous claim because they simply

did not exist at the time the claim was filed. In Re Attorney Fees

and Costs, 233 Mich. App. 694, 593 N.W.2d 589 (1999). The

binding law is clear that Clifford Walker's ownership claims

were frivolous because he was on notice of the mistaken

description in the deed, and he must pay Silas Salyers attorney

fees in the lower court and on appeal. Spitzley v. Spitzley, 477

Mich. 989, 725 N.W.2d 464, 465 (2007). BJ's & Sons Construction

Co. v. Van Sickle, 266 Mich. App. 400, 700 N.W.2d 432 (2005).

This CC 22-463-CH trespass action is clearly

not the "pending action" CC 20-162-CH, which is now

closed. This trespass action is undisputedly "another

proceeding," in which the use of any deemed

admissions from another action is prohibited by the

binding law. MCR 2.312(D)(2).

Also, yet in another, 2nd (!!) trespass case that

Respondent Walker filed, DC 24-1075-LT, which is

pending on appeal at the moment, Circuit Court

Judge Aquilina had expressly agreed that there "may

have been an error" regarding the use of deemed

admissions in the subsequent two trespass actions

contrary to MCR 2.312(D), and recommended filing

an appeal with the higher courts, but declined to set

aside Walker's judgment of possession:

THE COURT:

... [M]aybe the

Supreme Court will help you further, but I am

going to affirm on all the issues. ... I think

that your arguments are compelling, but I'm

not swayed that I need to undo the history

here. It's very clear what happened in terms

of the admissions, and there may have been

an error... So I am affirming the orders of the

prior courts, and your issue then is to take it

to a higher court. Transcript of July 9, 2025

hearing, CC 24-919-AV, pp. 27-28.

However, Judge Aquilina made a clear legal

error by following the erroneous decisions of other

judges, rather than the clear language of the statutes

and binding precedents under the rule of stare

decisis:

"The circuit court is bound to follow the

published decisions of the Court of Appeals

and the Michigan Supreme Court." People v.

Hunt, 171 Mich. App. 174, 180; 429 N.W.2d

824 (1988). "There is no requirement that a

circuit judge follow the decision of the other"

[emphasis added]. Id.

Michigan judges David L. Jordon, Christopher

M. Murray, Michael J. Kelley, and Noah P. Hood had

disregarded

clear

legislative

directives

and

impermissibly applied the prior CC 20-162-CH action

deemed admissions to the present action, which

produced a bizarrely impossible result - Petitioner

Silas Salyers, the deed holder and the official

property record owner (Petitioner's Appendix, pp.

56a-66a (deeds, county property record)), was

charged with property trespass by Respondent

Walker who, according to these judges, had "failed to

produce a deed transferring the 79-acre parcel

from Salyer to the Estate." Petitioner's

Appendix, p. 12a.

According to Michigan judges David L. Jordon,

Christopher M. Murray, Michael J. Kelley, and Noah

P. Hood, Respondent Walker was relieved from

producing a valid transfer deed in the chain of title

in his name because they in clear error decided it to

be "conclusively established" through a deemed

admission from the PRIOR case CC 20-162-CH that

"[Salyer] deeded the 79-acre parcel to Evelyn."

Michigan judges David L. Jordon, Christopher M.

Murray, Michael J. Kelley, and Noah P. Hood,

contrary to MCR 2.312(D)(2) and the binding

landownership precedents, had clearly erred in

stating that Respondent Walker did not need to

produce a transfer deed of the 79-acre to him in his

trespass action when every claimant must do so to

prove land ownership to recover as a landowner:

"The plaintiff, claiming the right to recover as

the owner of this land, is required, in order to

establish that claim, to prove her title. It is

necessary for her to show a title to the property

before she can recover in any case. ...[T]the

burden of proof is on the plaintiff, and, in order

to recover at all, she must prove that she is the

owner of the land by a series of deeds coming

down.., accompanied by possession and claim of

ownership..., by a preponderance of evidence

[emphasis added]." Dawson v. Falls City Boat

Club, 125 Mich. 433, 84 N.W. 618 (1900).

2. State judges Violated Petitioner's

Fundamental Right to Contract

The Due Process Clause of the Fourteenth

Amendment protects the individual right to freedom

of contract as a substantive fundamental right.

Lochner v. New York, 198 U.S. 45 (1905). "[T]he

State, in the exercise of its powers, may not unduly

interfere with the right of the people to enter into

contracts that may be necessary and essential in the

enjoyment of the inherent rights belonging to

everyone, among which rights is the right "... to live

and work where he will; to earn his livelihood by any

lawful calling; to pursue any livelihood or avocation."

Id. at 66.

Real property contract law is clear that land

conveyance documents must be in writing, must be

certain and definite as to property and other

conveyance terms, and must be signed by the

party to be charged. MCL 566.106, MCL 566.108;

Marina Bay Condominiums, Inc v. Schlegel, 167

Mich. App. 602, 423 N.W.2d 284 (1988).

"[T]he action of state courts and judicial

officers in their official capacities is to be regarded as

action of the State within the meaning of the

Fourteenth Amendment. Shelley v. Kraemer, 334

U.S. 1, S.Ct. 836, 92 L.Ed. 1161, 3 ALR 2d 441(1948).

State judges David L. Jordon, Christopher M.

Murray, Michael J. Kelley, and Noah P. Hood had

ruled contrary to the law of real property contracts

and contrary to their own admission of fact that

Respondent "Walker failed to produce a deed

transferring the 79-acre parcel from Salyer to the

Estate." Petitioner's Appendix, p. 12a.

In addition, Michigan Judges David L.

Jordon, Christopher M. Murray, Michael J. Kelley,

and Noah P. Hood had completely obliterated

Petitioner Silas Salyers' contract with his vendor, the

logging

company,

and

affirmed/

authorized

Respondent Walker to receive and keep $10,000 for

the remaining logs that Tri-State Hardwood Co.

harvested on Petitioner Silas Salyers' farm in July of

2022 pursuant to its 2021 contract with Petitioner

Silas Salyers. Petitioner's Appendix, p. 67a.

3. State Judges David L. Jordon,

Christopher M. Murray, Michael J.

Kelley, and Noah P. Hood Violated

Petitioner's Substantive Due Process

Rights By Their Corrupt Conduct

In Refusing to Follow the Binding Law

Either "corrupt or egregious conduct that so

shocks the conscience as to give rise to a due process

claim. Mettler Walloon v. Melrose Twp, 281 Mich.

App. 184, 212; 761 N.W.2d 293 (2008). "[I]t is corrupt

for an officer purposely to violate the duties of his

office․.. Any intentional and deliberate refusal by an

officer to do what is unconditionally required of him

by the obligations of his office is corrupt as the word

is used in this connection because he is not permitted

to set up his own judgment in opposition to the

positive requirement of the law. ... [F]or nondiscretionary acts, as here3, the refusal to perform a

required duty is corruption per se․” Perkins & Boyce,

Criminal Law (3d ed.), p. 541-542, 546-547, cited

in People v Coutu (On Rem) 235 Mich. App. 695, 705706; 599 N.W.2d 556 (1999).

It was the corrupt conduct of state judges

David L. Jordon, Christopher M. Murray, Michael J.

Kelley, and Noah P. Hood who, as stated above,

refused to perform their duties to rule according to

the clear language of the statutes, court rules, and

binding precedents, that resulted in violation of

Petitioner's substantive due process rights.

B. Michigan Judges David L. Jordon,

Christopher M. Murray, Michael J. Kelley,

and Noah P. Hood's Orders Of Removal of

Petitioner's 5-31-22 Land Filings Violated

Petitioner's Due Process

1. State Judiciary Had No Jurisdiction to

Provide Relief To Respondent For

Claims Not Stated In His Complaint

Before property rights can be taken away, to

afford due process, such claim according to the law

must be brought within the court's jurisdiction. The

“[A] court must strictly follow decisions handed down by

higher courts within the same jurisdiction.” In re AGD, 327

Mich. App. 332, 339; 933 N.W.2d 751 (2019). "When the

language of the rule is clear and unambiguous, we must enforce

the meaning plainly expressed. Hinkle, supra.

jurisdiction conferred on the Circuit Court is "to hear

and determine" "claims:"

MCL 600.605 Circuit court; original

jurisdiction.

Sec. 605.

Circuit courts have original

jurisdiction to hear and determine all civil

claims and remedies, except where exclusive

jurisdiction is given in the constitution or by

statute to some other court or where the circuit

courts are denied jurisdiction by the

constitution or statutes of this state.

MCR 2.111(B) requires for the claims to be

stated in the complaint, counterclaim, crossclaim, or third-party complaint to afford a party

due process and equal protection to claimants and

defendants as prescribed by law. See MCR 2.111(B):

"Statement of Claim. A complaint, counterclaim,

cross-claim, or third-party complaint must contain

the following:

(1) A statement of the facts, without repetition,

on which the pleader relies in stating the cause

of action, with the specific allegations necessary

reasonably to inform the adverse party of the

nature of the claims the adverse party is called

on to defend; and

(2) A demand for judgment for the relief that

the pleader seeks.

The court's jurisdiction is limited to those

claims brought before it in a complaint. The only

complaint in this action is the one by Plaintiff

Walker. There are undisputedly no counterclaims,

cross-claims, or third-party complaints. The only

claims in Respondent Walker's complaint are for

trespass and conversion of timber. Petitioner's

Appendix I, pp. 52a-55a.

Michigan courts violated Petitioner's due

process and equal protection rights when they

granted relief to Plaintiff Walker on claims not

stated in his Complaint by refusing Petitioner due

process procedures for a trial, answer, discovery, etc.

afforded to other litigants under the state law, and

which were denied to him without any rational basis.

The August 30, 2022 non-final order

(Petitioner's Appendix, p. 42a) contrary to the law

required Petitioner to remove his May 31, 2022/July

20, 2022 corrective documents filed before this action

was commenced while no claim regarding such

documents was stated in the complaint (Petitioner's

Appendix I, pp. 52a-54a). Filing of such documents

is authorized by the statutes, MCL 565.451d and

MCL 565.451a. Moreover, such August 30, 2022 nonfinal order appeared to attempt to legitimize

Walker's claim of ownership by removing corrective

documents. Respondent Walker agreed that

corrective documents unequivocally indicated that

Defendant Silas Salyer owns the subject property.

Appellee admitted in his COA Appellee's Brief, §2 at

p. 33 and on appeal in a prior case cc 20-162-CH on

April 5, 2023 that as a result of the Appellant's

counsel's "deeding the 79-acre farm to Defendant

Salyers" by May 31, 2022 "Quit Claim Deed and

Affidavit," Silas Salyers "owns the 79-acre farm." 4

However, removal would not help Respondent's

Oral Argument, April 5, 2023, at 1:01:32,

https://www.youtube.com/watch?v=D-S13SWx7oE&t=2861s

"[Ms. Paremsky] ... went out and prepared and recorded her own version

of a cloud on title on that deed that reflects that her client now owns the

79-acre farm." See 1:01:24-1:1:39

alleged ownership claims either, because, as the

Court of Appeals affirmed, Respondent Walker does

not have a transfer deed in his name (Petitioner's

Appendix, p. 12a), has not paid Petitioner Silas

Salyers anything for the property, and has no

standing to force Petitioner, the deed holder and the

official property record owner, not to record

documents for Petitioner's own property.

2. State Judges Orders/Affirmation of

Removal Of Petitioner's Deeds From

the Register of Deeds Violated His

Fundamental Right to Contract

The Due Process Clause of the Fourteenth

Amendment protects the individual right to freedom

of contract as a substantive fundamental right.

Lochner, Supra. Michigan judges David L. Jordon,

Christopher M. Murray, Michael J. Kelley, and Noah

P. Hood violated Petitioners' fundamental right to

contract by ordering removal of his land conveyance

agreements that he filed for his property at the

complaint regarding such documents.

3. State Judges Sanction Orders, Issued

Contrary to Binding Law, Violated Due

Process

In the post-judgment orders affirmed on

appeals, the judges continued ruling against the

binding rule of law by requiring a $3,500 fine for

alleged non-compliance with the stayed non-final

order, after the issuance of the final order which did

not include any non-final order requirements

(Petitioner's Appendix, p. 32a-35a), and which

was strictly (i.e. "hypertechnical]ly", (Petitioner's

Appendix, p. 24a)) complied with anyway before the

show-cause hearing; and ordered Petitioner's counsel

to pay $2,500 to Respondent's counsel to prepare a

document undisputedly prepared by the Petitioner's

counsel: "Drafted by: Elena A. Paremsky (P62996)

Attorney at Law." Petitioner's Appendix, p. 41a.

C. Michigan Judges David L. Jordon,

Christopher M. Murray, Michael J. Kelley,

and Noah P. Hood Violated Petitioner's

Equal Protection Rights

Equal protection of the laws is guaranteed by

the U.S. Constitution Amendments V and XIV. "The

United States Supreme Court allows such 'class of

one' claims to be brought, but requires a plaintiff to

show that it was actually treated differently from

others similarly situated and that no rational basis

exists for the dissimilar treatment." Willowbrook v

Olech, 528 U.S. 562, 564; 120 S.Ct. 1073; 145 L.Ed.2d

1060 (2000).

The plaintiff is not required to

"demonstrate an exact correlation... in order for the

two to be considered 'similarly-situated'; rather...

[they] must be similar in `all of the relevant

aspects.'" Ercegovich v. Goodyear Tire & Rubber Co,

154 F.3d 344, 352 (6th Cir. 1998).

In Shelley v Kraemer, 334 US 1, S Ct 836, 92

L Ed 1161, 3 ALR 2d 441(1948), the United States

Supreme Court noted that the action of judiciary is a

state action that might result in violations of the

equal protection of the laws:

[T]he action of state courts and judicial officers

in their official capacities is to be regarded as

action of the State within the meaning of the

Fourteenth Amendment is a proposition which

has long been established by decisions of this

Court. ... 'It is doubtless true that a State may

act through different agencies, either by its

legislative, its executive, or its judicial

authorities, and the prohibitions of the

amendment extend to all action of the State

denying equal protection of the laws, whether it

be action by one of these agencies or by

another.' (citations omitted).

Michigan judges David L. Jordon, Christopher

M. Murray, Michael J. Kelley and Noah Hood denied

Petitioner Silas Salyers equal protection of the laws

when they ruled contrary to the clear language of the

statutes and the binding precedents, and ordered

Petitioner to pay trespass damages for the trees he

got harvested on his own property, of which he is the

deed holder and the official property record owner

(Petitioner's Appendix, pp. 56a-66a (deeds, county

property record)), to Respondent Walker who as

judges admitted "failed to produce a deed

transferring the 79-acre parcel from Salyer to the

Estate." Petitioner's Appendix, pp. 12a.

D. Michigan Judges David L. Jordon,

Christopher M. Murray, Michael J. Kelley,

And Noah P. Hood Violated the Contract

Clause of the U.S. Constitution

U.S. Constitution, Article I, Section 10

guarantees that "[n]o state shall pass any Law

impairing obligation of contracts." In Shelley v.

Kraemer, Supra, the U.S. Supreme Court affirmed

that the action by the judiciary is a state action.

An Act of February 17, 1922, amending Jud.

Code, § 237, provides:

"In any suit involving the validity of a

contract wherein it is claimed that a change

in the rule of law or construction of statutes

by the highest court of a state applicable to

such contract would be repugnant to the

Constitution of the United States, the

Supreme Court shall, upon writ of error,

reexamine, reverse, or affirm the final

judgment of the highest court of a state in

which a decision in the suit could be had."

In this bizarrely legally/factually impossible

case, Michigan judges directly violated the Contract

Clause by imposing a contract when there was none.

In order for Respondent Walker to claim

ownership of Petitioner Salyers' $600k personal

residence and farm to recover on his trespass claim,

Respondent Walker had to present a conveyance

agreement that comports to the Statute of Frauds,

signed by Appellant Salyers, the party to be charged.

MCL 566.106, MCL 566.108, Marina Bay

Condominiums, Inc v. Schlegel, 167 Mich. App. 602,

606; 423 N.W.2d 284 (1988). The Court of Appeals

had confirmed that Respondent "Walker failed to

produce a deed transferring the 79-acre parcel

from Salyer to the Estate." Petitioner's

As the courts confirmed,

Appendix, p. 12a.

Petitioner Silas Salyers had undisputedly never

signed a conveyance of his home and his 79-acre

family farm to Respondent. Yet, state judges,

contrary to the clear language of MCR 2.312(D), in

clear error had use deemed admissions imposed for

late discovery responses from the PRIOR CC 20-162CH action to this trespass proceeding, CC 22-463CH. Respondent Walker had paid $0 to Petitioner

Silas Salyers, and the larger parcel was not for sale.

The courts in this action have made a ruling

that grossly impaired Petitioner's right to contract as

they have imposed a contractual obligation on him as

if he had forgone the ownership of his $600k family

farm and his 43-year residence to the ex brother-inlaw without Respondent Walker paying for it and

while Petitioner had no intentions of selling it, let

alone giving it away to his former in-law.

Michigan officials - the police, Ingham County,

and Stockbridge Township - are 100% sure that

Petitioner Silas Salyers is the owner of his residence

and 79-acre farm because he is the holder of the

deeds in the chain of title. (Petitioner's Appendix,

pp. 56a-64a). Michigan police on July 9, 2022 refused

to charge Petitioner with trespass when Respondent

tried to have the police charge him with trespass.

Petitioner's Appendix, pp. 68a-72a.

Michigan judges - state actors - also grossly

impaired Petitioner's vendor's obligation on the

contract with Petitioner for harvesting Petitioner's

timber when they issued an order directing

Respondent Walker to collect $10,000 for remaining

Petitioner's logs on the Petitioner's property

(Petitioner's Appendix, p. 44a) that Walker had

collected. Petitioner's Appendix, p. 46a.

THEREFORE, this case presents an urgent

opportunity for this Court to restore justice

guaranteed by the U.S. Constitution that people's

property rights cannot be taken away without due

process or equal protection of the laws, and that the

state judges are not free to make contracts for people

when there are none. Absent this Court's

intervention, state judges will continue with

impunity to take property rights from whomever

they personally wish contrary to binding rule of law

and fundamental contract rights, and transfer them

for $0 to those who have not paid for the property

and have no transfer deeds in their names.

E. Respondent Clifford Walker, A Resident of

Florida, His Attorney Martin G. Lozier, and

Non-party Pamela Griffith's Activities In

Violation of RICO Act To Get Petitioner

Salyers' $600k Home And Farm Without a

Transfer Deed And Without Paying For It

RICO makes it a crime “for any person

employed by or associated with any enterprise

engaged in, or the activities of which affect,

interstate or foreign commerce, to conduct or

participate, directly or indirectly, in the conduct of

such enterprise's affairs through a pattern of

racketeering activity.” 18 U.S.C. 96 §1962(c).

“Racketeering activity” includes “any act which is

indictable under any of the following provisions of

title 18, United States Code: ...section 1341 [18

U.S.C. 96 § 1341] (mail fraud), section 1343 [18

U.S.C. 96 §1343] (wire fraud).” Id. §1961(1). 18 U.S.

Code § 873:

Whoever, under a threat of informing, or as a

consideration for not informing, against any

violation of any law of the United States,

demands or receives any money or other

valuable thing, shall be fined under this title or

imprisoned not more than one year, or both.

The current criminal enterprise scheme to get

Petitioner's $600k farm and home without paying for

it started out when Respondent Clifford Walker, a

resident of Florida, in 2019 texted Petitioner Silas

Salyers an extortion/blackmailing threat to coerce

him into giving up his home and farm to Respondent

Clifford B. Walker in exchange for Respondent's not

reporting Petitioner to authorities about his SSI

application. Petitioner's Appendix, pp. 87a. The

allegation was not true, but coercion was forceful and

real. Respondent Clifford Walker's threats and

coercive actions continued. In 2022, Respondent

Walker's daughter, Pamela Griffith, called the police

on Petitioner Silas Salyers telling them to charge

him with criminal trespass of Petitioner's own

property. Pamela Griffith made false statements to

the police that allegedly Petitioner was renting from

Respondent Walker, and has not paid rent for

awhile. Pamela Griffith also made false statements

that Respondent Walker was a fee simple owner of

the property. Pam failed to produce a transfer deed

in Respondent Walker's name. None exists. The

Court of Appeals confirmed that "Walker failed to

produce a deed transferring the 79-acre parcel from

Salyer to the Estate." (Petitioner's Appendix, p.

12a). The police refused to charge Petitioner Silas

Salyers, the deed holder and the official record owner

with trespass. Petitioner's Appendix, pp. 87a.

Respondent Clifford Walker and his attorney

Martin Lozier had repeatedly intimidated the

Stockbridge and Ingham County tax authorities

pressuring them to put the property record in the

Respondent Clifford Walker's name, but the

authorities refused because Respondent Clifford

Walker does not have a transfer deed in his name as

the courts confirmed that "Walker failed to produce a

deed transferring the 79-acre parcel from Salyer to

the Estate." (Petitioner's Appendix, pp. 12a).

The

three

attempted

schemes

were

not

working for Respondent Clifford B. Walker - (1)

Petitioner would not give in to Respondent Clifford

Walker's blackmail/extortion threats, (2) the police

would not charge Petitioner with trespass because he

was the holder of the deeds in the chain of title

(Petitioner's Appendix, pp. 56a-64a, 68a), and

Michigan county officials affirmed that based on

deeds in the chain of title that Petitioner Silas

Salyers is the owner of his home and farm.

Petitioner's Appendix, p. 65a. Thus, in July of

2022, Respondent Clifford Walker continued his

harassment scheme by filing a civil trespass action

alleging damages for trees that Petitioner's vendor

harvested on the Petitioner's farm pursuant to

Petitioner's 2021 contract. (Petitioner's Appendix,

p. 67a) that Respondent Walker was not part of.

Respondent Walker's attorney Martin G.

Lozier, repeatedly misrepresented in open court and

in his pleadings that his client was the owner of the

Petitioner's home and farm, without producing a

transfer deed in his name. Despite the fact that it

was Petitioner Silas Salyers who owned the property

as the deed holder and the property record owner

based on his undisputed deeds in the chain of title

submitted to the court (Petitioner's Appendix, pp.

56a - 66a), a retired visiting judge David L. Jordon

awarded property trespass damages to Respondent

Walker without stating any basis for such ruling and

heavily fined Petitioner's attorney because Petitioner

was indigent. Court of Appeals judges Christopher

M. Murray, Michael J. Kelley, and Noah P. Hood,

despite their own admission that Respondent

"Walker failed to produce a deed transferring the

79-acre parcel from Salyer to the Estate"

(Petitioner's Appendix, pp. 12a-13a), affirmed the

property trespass damages.

This is the 3rd case in the Court of Appeals

that Attorney Martin Lozier (64) had before Judge

Christopher Murray (61). Judge Christopher Murray

is a graduate of the small private Michigan college

(1400 students) where Attorney Lozier's children,

Martin G. Lozier, Jr. and Kelsey Lozier, also received

their degrees. In all three court of appeals cases

concerning land disputes, Judge Christopher Murray

ruled for Attorney Martin Lozier's clients on land

ownership claims when the judges stated that they

were fee simple owners, while they did not pay for

the properties (adverse possession despite permissive

use)5 and despite the declaration documents clearly

stating that the ownership was to the surface waters

but not for the land strip in question.6

Judge Murray said that the Court of Appeals

was ruling for Clifford Walker and that "it may

happen again, from this Court, from this Panel,"7

and that if Petitioner and his counsel would continue

to defend against trespass on appeal, they will be

German v LeForge, unpublished opinion of the Court of Appeals, Per

Curiam, decided on May 24, 2007 (Docket No. 274224).

(https://www.courts.michigan.gov/c/courts/coa/case/274224), when

ownership to a strip of land which was an access easement was ordered to

be transferred from the property owners to Attorney Lozier's clients who

did not pay for it (adverse possession).

Scollard v Columbia Lake Association, unpublished opinion of the

Court of Appeals, Per Curiam, decided on October 22, 2015 (Docket No.

322574). (https://www.courts.michigan.gov/c/courts/coa/case/322574),

where Association was ruled a fee owner of a strip of land past the water's

edge, although its ownership according to its "Declaration of

Restrictions, recorded November 8, 1965, in Liber 741, Page 421,

Jackson County Records, the authority of [the Association] extends only

to the surface waters and bottom lands of Lake Columbia."

https://www.youtube.com/watch?v=c0B5sQzCgSI, at 59:10

"going at [their] own peril,"8 which is authoritative

intimidation with "peril"9 of undisclosed nature

hanging in the air over this farmer and his counsel.

As a consequence of the state judges' ruling in

violation of binding law, the 86-year-old Petitioner's

situation is extremely dire. As of August 31, 2025,

his 86-years worth of possessions have been

scattered and crumbled by a 12-person eviction crew

on his front lawn, left to deteriorate (Petitioner's

Appendix, pp. 88a-90a), in front of the house that

he had built, which he had never transferred to

Respondent Walker, and for which Respondent

Walker has not paid a dime to Petitioner Salyers.

CONCLUSION AND RELIEF REQUESTED

Petitioner is respectfully requesting that this

Court issue a writ of certiorari to review the record of

the Michigan Supreme Court which denied

Petitioner's Application for leave to appeal the lower

courts' decisions that violated his due process/ equal

protection rights, his fundamental right to contract,

and the Contract Clause of the U.S. Constitution.

Respectfully Submitted,

/s/ Elena A. Paremsky

Elena A. Paremsky (MI P62996)

Petitioner's Counsel Of Record

993 Bray Road, Williamston, MI

Tel. 517-575-7123

https://www.youtube.com/watch?v=c0B5sQzCgSI, at 1:00:47

"peril" defined as 'with full understanding that what one is doing

is dangerous and that one is responsible for one's own safety : at

one's own risk' Merriam-Webster online, https://www.merriamwebster.com/dictionary/at%20her%20own%20peril

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.