Defendant State Farm and its’ in house attorneys Mr. Russell Karr and Mr. Ayenn Stark and its’ expert neurologist Dr. Julie Schwartzbard have a perverse interest in Plaintiff’s bladder, vagina and uterus. They continue to diligently search Plaintiff’s gynecological medical records from the last 15 years for the cause of Plaintiff’s migraine headaches. Plaintiff’s chronic migraine headaches have not been diagnosed as post gynecologic.
Dr. Ralph Sacco, Chairman & Professor Department of Neurology, Executive Director Evelyn F McKnight Brain Institute, Miller Professor of Epidemiology, Public Health Sciences, Human Genetics, and Neurosurgery, Olemberg Family Chair in Neurological Disorders diagnoses Plaintiff’s chronic migraine headaches as post concussive.
Dr. Hong Jiang, Neuro-Opthalomogist at Bascom Palmer Eye Institute, diagnoses Plaintiff’s chronic migraine headaches as post traumatic.
Neither Dr. Sacco nor Dr. Jiang diagnosed Plaintiff’s chronic head pain as post stroke.
Entering into a first party auto insurance policy with the intention not to pay is fraud. Policy holder Lana Keeton’s State Farm Uninsured Motorist provision for $300,000.00 remains unpaid. Every day State Farm and its employees, Attorney Russell Karr and Attorney Ayenn C. Stark, do not pay Plaintiff is another day State Farm defrauds Plaintiff.
It is clear these lawyers are completely outside the bounds of civil procedure and should be found in contempt of court for 2 reasons:
1. They did not comply with the Honorable Court’s ruling November 18, 2015 to produce discovery on November 23, 2015. Defendants did not produce the following:
a. Exhibits to Defendant’s Response to Plaintiff’s Motion to Strike and/or Exclude Testimony of Dr. Warren Grossman
b. The legal citations of all cases listed where Dr. Warren Grossman has testified and/or been deposed
c. The legal citations of all cases listed where Dr. Julie Schwartzbard has testified and/or been deposed and
d. The records subpoenaed in 2012 by State Farm of Dr. Eric Lampinstein.
e. The complete State Farm file on December 24, 2009 auto accident including repair estimates, payments for, photos of auto, etc
2. State Farm illegally obtained Plaintiff’s medical records:
a. without authorization and without notification and without consent
b. State Farm solicited and publicized un-redacted photos of pubic surgical scars of Plaintiff onto the court docket and into the public record.
Plaintiff moves the Court to find State Farm and any and all of its employees involved in these actions in contempt and for State Farm to pay monetary sanctions for the duress and public humiliation caused to Plaintiff by these actions.
*** AT A PUBLIC HEARING ON MOTION FOR SANCTIONS AGAINST STATE FARM IN-HOUSE DEFENSE ATTORNEY RUSSELL KARR BEFORE JUDGE SAMANTHA RUIZ-COHEN IN CASE NO. 11-36542-CA-06 LANA KEETON V. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY STATE OF FLORIDA. CIRCUIT COURT IN AND FOR THE MIAMI DADE COUNTY, DECEMBER 2015