Wednesday, November 18, 2015


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)

“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
305-671-9331 phone

No comments: