EXCERPTS FROM DOCKET NO. 59, FILED BY LANA C. KEETON ON MAY 18, 2015 IN THE FOLLOWING CASE:
UNITED STATES DISTRICT COURT FOR THE
SOUTHERN DISTRICT OF FLORIDA, MIAMI DIVISION
SR. JUDGE JAMES LAWRENCE KING
CIVIL ACTION No. 1:15-cv-20442-JLK
LANA C. KEETON,
Plaintiff Pro Se
#1 - Johnson & Johnson
#2 - Ethicon, Inc.
#3 - Gynecare Worldwide (now known as Ethicon’s Women’s Health and Urology)
#4 -Ethicon Sarl, Neuchatel, Switzerland
#5 - Mr. Peter Cecchini
#6 - G. Willy Davila MD
#7 - Delos Cosgrove, MD
#8 - Cleveland Clinic Foundation
#9 - Jeffrey B. Shapiro
#10 - Neville M. Leslie
#11 - Arnstein & Lehr LLP
#12 - David Krause and
#13 - U.S. Food & Drug Administration Center for Devices & Radiological Health (CDRH)
PLAINTIFF PRO SE LANA C. KEETON RESPONSE TO ECF 42, DEFENDANTS JOHNSON & JOHNSON, ETHICON, INC. and PETER CECCHINI’S MOTION to STRIKE PLAINTIFF’S MASTER ANSWER to MOTIONS to DISMISS [ECF 35] TO ECF45/47 NOTICE of JOINDER, JEFFREY B. SHAPIRO, ARNSTEIN & LEHR, LLP TO ECF 48 NOTICE OF JOINDER, CLEVELAND CLINIC DEFENDANTS; And TO ECF 49 NOTICE OF ADOPTON, NEVILLE M. LESLIE
"THE FACTS AS ACTUALLY PRESENTED IN THE COMPLAINT"
"Although Plaintiff is characterized by Defendants in this case as having mythical legal skills, those skills are highly exaggerated. Plaintiff Pro Se Lana C. Keeton is simply a woman inspired by the movie, “Amazing Grace”, the story of Wilhelm Wilberforce, a member of the British parliament who spent 36 years of his life to stop the slave trade in England, who is seeking justice for the crimes committed against her regardless of the time and energy and commitment it takes.
Defendants conspiracy in the crimes they have committed, and continue to commit, in their association in fact RICO enterprise, damaged Plaintiff’s business and property when they defrauded her and the U.S. Bankruptcy Court, an arm of the government, through the testimony of Dr. G. Willy Davila, an employee of the Cleveland Clinic Foundation under the supervision of Dr. Delos Cosgrove at the medical negligence trial in December 2009.
The Bankruptcy Trustee did abandon the Product Liability lawsuit in September 2007, after Defendants Johnson & Johnson, Ethicon, Inc., Gynecare Worldwide, Jeffrey B. Shapiro, Neville M. Leslie and Arnstein & Lehr, LLP defrauded the Bankruptcy Court in their Motion for Summary Judgment in Case 1:06-cv-21116-UU Document 138-1 Entered on FLSD Docket 07/23/2007 rendering the claim worthless.
The medical negligence claim against Dr. Bernard Cantor and Mt. Sinai Medical Center was an asset in the Bankruptcy Case No. 03-16521 and was not abandoned by the Bankruptcy Trustee, Mr. Drew Dillworth. Dr. G. Willy Davila testified at the medical negligence trial in December 2009 and made false statements in violation of U.S.C. 1603 to the Honorable State Court of Florida, the Plaintiff, the Bankruptcy Court, attorney Darryn Silverstein, an officer of the court, and the jurors.
The verdict awarded to Trustee Dillworth and Plaintiff Keeton, $275,000.00, only paid $30,000.00 to the creditors of the Keeton Bankruptcy after attorney costs and fees, which included business creditors to Lana C. Keeton in the amount of over $203,000.00 on a bi-monthly basis. The loss of the credit availability to Keeton’s 30 year old steel brokerage eventually led to the complete closing of the business in April 2013, which at one time had grossed more than one million dollars ($1,000,000.00) yearly."