STATE FARM AUTOMOBILE INSURANCE COMPANY AND ITS CORPORATE ATTORNEY RUSSELL KARR YOUR #GOOD NEIGHBOR ?

November 16, 2015

Mr. Russell B. Karr, Esq.
Attorney for State Farm Mutual Automobile Insurance Company
Ayenn C. Stark & Associates
One S.E. Third Avenue, Suite 1800
Miami, FL 33131

Re: Case No. 11-36542-CA-06 Lana Keeton v. State Farm Automobile Insurance Company
11th Circuit Court, Miami-Dade, County

Dear Mr. Karr,

I have not read your typical 100+ page motion practice abuse answer, you yourself personally filed today at 3:15 p.m., to Plaintiff’s Motion to Compel discovery but it seems to be standard Corporate Culture and Practice of State Farm’s ACE “Achieving Claims Excellence” policy or the PP&R scheme of State Farm Mutual Auto Insurance Company. State Farm and its Corporate Tactics through your actions are no longer invisible to the public as they were years ago before the age of the internet. Your actions are unconscionable.

“These tactics are an entrenched part of the company’s approach to dealing with liability lawsuits by “harass[ing] and intimidat[ing] opposing claimants, witnesses, and attorneys.” Pet. App. 19a. The company uses its size and wealth to carry out these policies. Id. (“State Farm actually instructs its attorneys and claim superintendents to employ ‘mad dog defense tactics’ – using the company’s large resources to ‘wear out’ opposing attorneys by prolonging litigation, making meritless objections, claiming false privileges, destroying documents, and abusing the law and motion process.”). In all, “State Farm repeatedly and deliberately deceived and cheated its customers via the PP&R scheme.” Id. 18a.

No. 01-1289 IN THE Supreme Court of the United States State Farm Mutual Auto Ins. Co., Petitioner, v. Curtis B. Campbell, et al., Respondents.” October 17, 2002

“201. State Farm knowingly manipulated its data, documents, procedures, claims adjusters, engineers, and engineering firms to produce results that minimized and understated both Katrina wind damage and State Farm’s liability for that damage under homeowner policies it issued to policyholders in Mississippi. “Mississippi Complaint” P. 40-41”

Mississippi ex.rel. Jim Hood, Attorney General for the State of Mississippi, Plaintiff, v. State Farm Fire and Casualty Company, Defendant. Case No. 25C11:15-cv-00221-TTG April 21, 2015

Regardless of orders you may have from your superiors at State Farm, it seems your actions as an officer of the court have reached a point where you, and possibly your firm, are preventing “due administration of justice” in violation of 18 U.S.C. 371 and 18 U.S.C. 1503:

United States of America, Plaintiff, -against- Richard A. Lundwall and Robert W. Ulrich, Defendants. 97 Cr. 0211 (BDP)
UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK 1 F. Supp. 2d 249; 1998 U.S. Dist. LEXIS 4466

“The words 'due administration of justice' import a free and fair opportunity to every litigant in a pending cause in federal court to learn what he may learn (if not impeded or obstructed) concerning the material facts and to exercise his option as to introducing testimony or such facts. The violation of the law may consist in preventing a litigant from learning facts which he might otherwise learn, and in thus preventing him from deciding for himself whether or not to make use of such facts.”

“Richard A. Lundwall and Robert W. Ulrich, two former officials of Texaco, Inc., are charged in a two count Superceding Indictment with conspiring to obstruct justice in violation of 18 U.S.C. 371 and with obstruction of justice in violation of 18 U.S.C. 1503. They move to dismiss on the ground that 1503 does not apply to civil discovery matters. Since we conclude that 1503 reaches the willful destruction of documents during civil litigation, defendants' motion is denied

“Next, defendants argue that the Indictment violates due process because it amounts to a retroactive extension of the law, and deprives them of "fair warning" that their conduct was criminal. A statute gives no "fair warning" if it "fails to give a person of ordinary intelligence fair notice that his contemplated conduct is forbidden by the statute." Papachristou v. City of Jacksonville, 405 U.S. 156, 162, 31 L. Ed. 2d 110, 92 S. Ct. 839 (1972) (quoting United States v. Harriss, 347 U.S. 612, 617, 98 L. Ed. 989, 74 S. Ct. 808 (1954)). In this case, however, defendants' conduct falls well within the unambiguous text of 1503 and consequently gave the defendants ample warning that their conduct was prohibited. See United States v. Howard, 569 F.2d 1331, 1336-37 (5th Cir. 1978) ("Since the omnibus clause of the statute quite clearly proclaims that all obstructions of justice are prohibited, we conclude that section 1503 gives 'fair notice' of the offending conduct") (citations omitted).”

The Campbell case is from 2002 but the State of Mississippi “Katrina Fraud” case is April of 2015 for losses to the State of Mississippi for almost $500 million dollars, not to mention State Farm policy holders losses. Your “mad dog defense tactics” are without doubt Bad Faith.

Yours truly,
Lana C. Keeton
Plaintiff Pro Se
1602 Alton Road, #423
Miami Beach, FL 33139

lana@lanakeeton.com
305-671-9331 phone

STATE FARM'S BAD FAITH POLICIES EXPOSED, copied from MIKE MORSE LAW FIRM

Hello again #GoodNeighbor
State Farm Mutual Automobile Insurance Company
(205.166.218.67) [Label IP Address]

"ADVANCING CLAIMS EXCELLENCE" ADDS $30 MILLION A YEAR TO STATE FARM PROFITS BY DENYING AUTO ACCIDENT BENEFITS TO POLICYHOLDER, SO THEY SAY...

ARE THE "ACE" POLICIES BEING EMPLOYED BY STATE FARM ATTORNEY RUSSELL KARR IN UNINSURED MOTORIST LAWSUIT?
LANA KEETON V. STATE FARM AUTOMOBILE INSURANCE COMPANY
CASE NO. 11-36542-CA-06
IN THE CIRCUIT COURT of the 11TH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA

Abuse of its policyholders seems to be company policy when you read this post by Mike Morse.

"STATE FARM'S BAD FAITH POLICIES EXPOSED"

Posted by: The Mike Morse Law Firm http://www.855mikewins.com
November 10, 2014 in Michigan Car Accident Lawyer

FOR A COPY OF THE ACE DOCUMENTS, CONTACT: Mike@855mikewins.con

"In our work as attorneys specializing in Michigan’s No Fault Act, we have been battling State Farm Insurance Company for more than 20 years to make sure they pay our clients the No Fault benefits they are contractually and legally entitled to. They have been extremely aggressive in their attempts to withhold payments and benefits and we’ve been working for months to publicly reveal their outrageous tactics to do this. Recently we were finally able to get a judge to remove a protective order that was long in place hiding what State Farm was doing to its customers and our clients.

Here’s what was happening. In the 1990s, State Farm insurance company began using a plan called “Advancing Claims Excellence” (or ACE) to handle its customers’ auto accident insurance claims. The ACE program outlined how State Farm could save as much as $30 million per year, by finding reasons to deny auto accident benefits to policyholders. How did they do it? By using lots of shameful tactics against their own policyholders such as:

◾Questioning their customers about their claims before they have a chance to hire a lawyer;
◾Hiring their own doctors to examine accident victims, and write reports saying there are no injuries related to the car accident
◾Prolonging the process by refusing to settle month after month then insisting on a trial
◾Offering their policy holders way less than the estimated value of a case during settlement negotiations;
◾Dragging their feet and causing unreasonable delays cases, especially where the injured person is a child, because the case would likely lose value over time.

The ACE program allowed State Farm insurance adjusters to go to all kinds of lengths to deny payment of benefits like medical bills and wage loss. In fact, we learned the adjusters were actually trained to deny these claims by using very specific policies outlined in the ACE program."

ALSO SEE RULING IN BARTEN V. STATE FARM MUTUAL AUTO INSURANCE COMPANY, No. CIV 12-399 (D. Ariz. Jan. 31, 2014) for other ACE INFO.

To be continued....

Defrauded by State Farm and/or Mr. Karr or Dr. Warren Grossman? Please contact me at 305-671-9331 or lana@lanakeeton.com. Call me...write me...

All the best, Lana C. Keeton
Permanently injured uncompensated
Ex-State Farm Auto Insurance policy holder

"CORPORATE CRIMINALS" IN AMERICA AND THEIR ATTORNEYS, AND THEIR IT DEPARTMENT! Part III

State Farm Mutual Automobile Insurance Company
(205.166.218.67) [Label IP Address]
(0 returning visits)

See you were out and about in the neighborhood yesterday.

How much do you pay your IT Department to troll the internet?

How much do you pay Attorney Russell Karr?

How about paying your policy holders their claims?

Be the #GoodNeighbor @StateFarm advertises!

It is such a sad state of affairs that you continue to pay Attorney Russell Karr to make false statements in court.

To be continued....

Defrauded by State Farm and/or Mr. Karr or Dr. Grossman? Please contact me at 305-671-9331 or lana@lanakeeton.com. Call me...write me...

All the best, Lana C. Keeton
Permanently injured uncompensated
Ex-State Farm Auto Insurance policy holder

#GOODNEIGHBOR ATTORNEY RUSSELL KARR FILES MOTIONS FOR SANCTIONS AGAINST LANA KEETON OPENS THE DOOR TO STATE FARM'S ONLINE REVIEWS OF FRAUD! Part II

Follow up to "Corporate Criminals" in America and Their Attorneys Part I....

Today Attorney Russell Karr filed a Motion for Sanctions against (EX) STATE FARM POLICY HOLDER LANA C. KEETON, further abusing its customer. Easy for him to make false statements in court on a regular basis but is offended by a normal reaction to six (6) years of abuse by State Farm Automobile Insurance Company's policies.

I have a right to search for potential witnesses to fraud via the internet in other cases where Dr. Warren Grossman, has testified as an "expert witness" for State Farm. Not only does Mr. Karr make false statements to the court, Mr. Karr is, and has been involved in, substantial Motion Practice Abuse in Lana Keeton v. State Farm Automobile Insurance Company 11-36542-CA-06 11th Judicial District State of Florida since at least 2013. Despite repeated requests via the discovery process, Mr. Karr and Dr. Grossman will not provide a list of other cases with a legal citation.

NOW MR. KARR FILED A MOTION TO STOP ME FROM EXERCISING ONE OF MY RIGHTS AS AN AMERICAN TO FREEDOM OF SPEECH!

HE MOVED THE COURT TO HAVE ME REMOVE THE POSTINGS! GOOD LUCK WITH THAT ONE! (Think the grotesque Westboro Baptist Church Supreme Court ruling that allowed them to protest and say vile things in front of soldiers funerals.)

#GoodNeighbor #StateFarm has opened the door to online information from other abused State Farm Policy Holders about its abusive auto insurance policies which will be used in an answer to his Motion for Sanctions. Open the door in court and STATE FARM has to answer in court.

So who notified Mr. Karr because it is highly unlikely Mr. Karr even reads the internet? He is working on his medical ignorance relating to the Glasgow Coma Scale. At a hearing on November 3, 2015, Mr. Karr stated Ms. Keeton has a PERFECT Glasgow Score of 15. I nearly laughed out loud. ANY SCORE ON GLASGOW COMA SCALE IS A DIAGNOSIS OF TRAUMATIC BRAIN INJURY. And Mr. Karr has now admitted in court he has no understanding of basic diagnostic testing proving causation of injury to Ms. Keeton.

That along with the fact Mr. Karr calls the sacroiliac "low back" at deposition is indicative of his to inability to apply the facts to the law in his job as an in house defense attorney for State Farm.

Mr. Karr, the truth hurts!

To be continued...

Defrauded by State Farm and/or Mr. Karr or Dr. Grossman? Please contact me at 305-671-9331 or lana@lanakeeton.com. Call me...write me...

All the best, Lana C. Keeton
Permanently injured uncompensated
Ex-State Farm Auto Insurance policy holder

"CORPORATE CRIMINALS" IN AMERICA & THEIR ATTORNEYS! Part I

RUSSELL KARR, IN HOUSE ATTORNEY FOR STATE FARM INSURANCE COMPANY IN MIAMI, FLORIDA today defended his actions in court on his choice of DR. WARREN GROSSMAN, ORTHOPEDIC SURGEON IN HOLLYWOOD, FLORIDA AS AN EXPERT WITNESS.

State Farm paid Dr. Grossman's ORTHOPAEDIC ASSOCIATES OF SOUTH BROWARD PA over $1,850,000.00 in less than a four (4) year period and says Dr. Grossman is not biased in favor of the STATE FARM AUTOMOBILE INSURANCE COMPANY.

Maybe Mr. Karr would not have selected Dr. Grossman as an "expert" if knew the anatomy of the spine. Of course, why would Mr. Karr learn the anatomy of the spine when he has his go to guy, Dr. Grossman to "prove" no causation at trial.

It will be quite interesting when Mr. Russell Karr loses to Pro Se Plaintiff Lana C. Keeton at trial in January 2016. You can not fool jurors with innuendo as Mr. Karr is so famous for in his pleadings and at hearings.

And I wonder how he will come out on the grievance against him. And I wonder how Mr. Karr and Dr. Grossman will come out when the State of Florida investigates them for Insurance Fraud.

To be continued...

Defrauded by State Farm and/or Mr. Karr or Dr. Grossman? Please contact me at 305-671-9331 or lana@lanakeeton.com. Call me...write me...

All the best, Lana C. Keeton
Permanently injured uncompensated
Ex-State Farm Auto Insurance policy holder

STAND WITH ME AGAINST ABUSE BY CORPORATE CRIMINALS IN AMERICA!!