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!!...in more than half a dozen states!

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 relinquish prescriptive authority for one year and was not supposed to portray herself as a nurse practitioner.

Professional ethics and the law dictat that Miller assist Hughes in complying with her nursing board order.

Yes, Keith Miller MD is the court whore...and much worse.

CAUSE NO. 08-CV-29961

DR. KEITH MILLER IN THE DISTRICT COURT

Plaintiff

vs OF

DR. SHIRLEY PIGOTT and

DR. STEVEN HOTZE 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