Motion For Sanctions Against Keith E Miller Md

Keith E Miller MD is suing me for slander! Monday, November 2, 2009 Keith E Miller MD is suing me for slander because I called him a "court whore" and had Texas Medical Board Watch give him the "Red Devil Award" for 2006 and 2007. See www.texasmedicalboardwatch.com. Court whore is standard doctors' lounge talk used when referring to a doctor who will testify to whatever he's hired to say without regard for the truth. Not only did Miller do this, his testimony was particularly influential because he was chairman of the Texas Medical Board Disciplinary Process Review Committee while he was doing it. And he did it over 100 times!! While Miller was acting in the capacity of a court whore, he knew his nurse Bridget Yvette Hughes had forged and continued to forge over fifty schedule II narcotics prescriptions. In my book, that's aiding and abetting over 50 felonies. He then obstructed justice by arranging with the Texas Department of Public Safety, the Federal Bureau of Investigation, and the US Drug Enforcement Administration to ignore her. He persuaded the Executive Director of the Texas Board of Nursing Katherine Thomas to bypass the nursing board investigatory process and to give Hughes a NON-disciplinary order. A condition of Hughes' order was that she voluntarily relinquished prescriptive authority for one year and was not supposed to portray herself as a nurse practitioner. I reported Miller to the Texas Medical Board for "unprofessional conduct". I have a personal email from current TMB Executive Director Mari Robinson telling me she was not going to investigate Dr. Miller. That means Mari Robinson is aiding and abetting multiple felonies. Each time she does it, she's committing another felony. Like Miller, Robinson hasn't committed just a few felonies, she's deluged herself in them. I've reported Robinson's multiple felonies to the Texas Medical Board in writing numerous times with no response. On February 6, 2009, I testified to the Texas Medical Board in open session at a regularly scheduled meeting and enumerated a half dozen or so of Robinson's felonies about which I had personal knowledge. On March 24, 2009, with no new complaint, no new evidence with respect to any of the multiple complaints the TMB has kept open about me for the past five years, and no complaint ever remotely relating to the quality of medical care, and no complaint ever relating to quality of medical care, the TMB held an "emergency license suspension hearing". Their main evidence was a video made by Texas DPS and altered by the medical board (another felony) - the one made of my "flight from arrest" [sic] after DPS Trooper Daniel Terronez bashed in my car window and telling me he was going to remove me by force. Terronez chose to assault me at the very moment a speeding 18-wheeler should have crashed into me. Terronez was facing the oncoming traffic.

The 18-wheeler swerved away from me and I swerved away from him at the last minute, and barely avoided a collision. I considered that Terronez made an attempt on my life. Th Instead of protecting me from monster Terronez, the Wharton County DA had me indicted for two counts of fleeing arrest with a vehicle. Back to the DPS video the Texas Medical Board used in my license suspension hearing: They removed a few seconds of my high speed "flight", duplicated it repeatedly, spliced them back to back, and showed that to the Texas Medical Board panel, which suspended my license. All the heartache and humiliation I've suffered has been worth it to expose the corruption at the Texas Medical Board and in other state agencies. The tide is turning on these criminals. They will be brought to justice.

Keith Miller MD is the worst SCUM I can imagine and everything I've said about him is true. `

DR. KEITH MILLER Plaintiff vs DR. SHIRLEY PIGOTT and DR. STEVEN HOTZE

CAUSE NO. 08-CV-29961 IN THE DISTRICT COURT OF SHELBY COUNTY, TEXAS

DEFENDANT PIGOTT’S MOTION FOR SANCTION AGAINST PLAINTIFF TO THE HONORABLE JUDGE OF SAID COURT: Now comes Defendant Shirley Pigott and moves this Court to Sanction Plaintiff and would show the Court as Follows: 1. Plaintiff has filed pleadings requesting that Dr. Pigott be enjoined from coming around Plaintiff or contacting Plaintiff; alleging that Dr. Pigott poses a danger of physical harm to Plaintiff; 2. That there is no evidence to support Plaintiff’s claim; 3. That Plaintiff’s intent is to continue his blatant conduct of retaliation against Dr. Pigott because of her work as an activist against the Texas Medical Board and against Plaintiff; 4. That Plaintiff’s has intense anger toward Dr. Pigott because of her functioning as a whistle blower against Plaintiff and his nurse Bridget Hughes, which has resulted in the State of Texas forcing both to cease improper conduct;

5. That the attached Exhibit “A,” which is made a part of this pleading for all purposes, sets out in detail the facts surrounding Plaintiff’s retaliation efforts; 6. That Plaintiff is abusing the processes of this Court and requires this Court to use its inherent power to discourage such abuse of the proceedings in this case.

Wherefore, Defendant prays for sanctions against Plaintiff in the amount of $10,000.00, which amount will cover Defendant’s costs caused by the effort of Plaintiff to use this Court for improper retaliation against Dr. Pigott. Respectfully Submitted, ____________________ Jerry S. Payne 11505 Memorial Dr. Houston, Texas 77024 St. Bar # 15658000 713-785-0677 Fax-713-781-8547

CERTIICATE OF SERVICE I certify that the parties were served a copy of this pleading and notice of hearing on 11/6/09 at 9:00am to here argument and evidence on this motion, by Fed.Express, delivered on Tuesday, 11/3/09. ________________ Jerry S. Payne