October 23, 2008
PRIORITY MAIL WITH PROOF
OF DELIVERY – TO ALL PARTIES
ON THIS COVER PAGE SERVICE LIST
Federal Bureau of Investigation
Attention: Special Agent Jeff Danik
505 South Flagler Drive
Suite 500
West Palm Beach, Florida 33401
Katherine Fernandez-Rundle
Miami-Dade State Attorney
E.R. Graham Building
1350 N.W. 12th Avenue
Miami, Florida 33136-2211
Bill McCollum
Office of Attorney General
State of Florida
The Capitol – PL-01
Tallahassee, Florida 32399-1050
Chief Financial Officer Alex Sink
Florida Department of Financial Services
200 East Gaines Street
Tallahassee, Florida 32399-0300
The Office of Inspector General
Florida Department of Law Enforcement
2331 Phillips Road
Tallahassee, Florida 32308
The Office of Inspector General
Attention: Kenneth A. Chambers
Supreme Court Building
500 South Duval Street
Tallahassee, Florida 32399-1905
Brooke S. Kennerly
Executive Director
Judicial Qualifications Commission
1110 Thomasville Road
Tallahassee, Florida 32303-6226
John F. Harkness
Executive Director
The Florida Bar
651 East Jefferson Street
Tallahassee, Florida 32399-2300
Michael L. Schneider
General Counsel
Judicial Qualifications Commission
1110 Thomasville Road
Tallahassee, Florida 32303-6226
Theodore P. Littlewood, Jr., Esq.
The Florida Bar
651 East Jefferson Street
Tallahassee, Florida 32399-2300
Detective Luis Robainas
Miami Dade Police Department
Public Corruption Investigations Bureau
8899 N.W. 18th Terrace
Doral, Florida 33172
Chief Judge Joseph P. Farina
Eleventh Judicial Circuit of Florida
Miami Dade County Courthouse
73 West Flagler Street
Miami, Florida 33130
This is to supplement my previous letter to you, dated September 17, 2008, whereby Notice was given that violations of 831.04 f.s., constituting a felony of the third degree, may have been committed by attorneys Ronald C. Kopplow, Marc Cooper, Sonya L. Salkin, and their counsels, Charles W. Throckmorton, Lauri Waldman Ross, Robert M. Klein, Lewis N. Jack, Jr., and Reggie Sanger.
It has been brought to my attention that another State Criminal Statute may have been committed by attorneys Ronald C. Kopplow, Marc Cooper, Sonya L. Salkin, and their counsels, Charles W. Throckmorton, Lauri Waldman Ross, Robert M. Klein, Lewis N. Jack, Jr. and Reggie Sanger with the acquiescence of Judge Jeri Beth Cohen.
F.S.A. § 831.02 - Uttering Forged Instruments
Whoever utters and publishes as true a false, forged or altered record, deed, instrument or other writing mentioned in F.S. § 831.01 knowing the same to be false, altered, forged or counterfeited, with intent to injure or defraud any person, shall be guilty of a felony of the third degree, punishable as provided in s.775.082, s. 775.083, or 775.084.
Since May 30, 2008, Judge Jeri Beth Cohen has known that attorneys, Kopplow, Cooper, Salkin, and their counsel, Throckmorton, Waldman-Ross, Klein, Jack, and Sanger have been using a document, deemed to be fraudulent by an expert witness, to support a Summary Judgment Motion, for the benefit of their clients, the attorney defendants, and to the detriment of the Plaintiffs in a legal malpractice lawsuit in Miami-Dade County Circuit Court, Case No.99-21062 CA 15.
The defendants have never refuted the expert witness’ declaration that the documents, which they are relying upon to injure the Plaintiffs, are fraudulent. Nor have the defendants retained their own expert witness to refute that the documents that they have been relying upon are fraudulent. Nor have the defendants and their counsel withdrawn the fraudulent documents in violation of Florida Bar Rule 4-3.3(a)(4).
Since May 30, 2008, the Plaintiffs have been seeking, through numerous written and ore tenus Motions, to strike the Defendants Pleadings for “fraud on the court” for knowingly using fraudulent documents to support their clients’ position. This activity is in violation of the Rules Regulating The Florida Bar, 4-3.3(a)(4) which:
Prohibits a lawyer from offering false evidence and requires the lawyer
to take reasonable remedial measures when false evidence has been
offered. This is subordinated to the criminal statute violation.
The Plaintiffs have filed verified Motions to Strike Defendants Affirmative Defenses, which goes to the heart of the fraudulent documents, as a Sham, pursuant to FRCP 1.150.
Judge Jeri Beth Cohen (a member of the Florida Bar) has wilfully engaged in conduct prejudicial to the administration of justice and thereby has subverted the truth finding process that the adversary system is designed to implement by the following violations:
1) refuses to allow discovery to see which attorneys were involved in the preparation, perpetration, execution and submission of the fraudulent documents.
2) refuses to conduct an evidentiary hearing as required by law under FRCP 1.150 which states:
Rule 1.150(a) contemplates a full evidentiary hearing where the parties
have the opportunity to offer evidence on the issue of whether the pleading
attacked alleges a cause of action or defense that is false in fact. The rule
provides that “the court shall hear the motion, taking evidence of the
respective parties.” Fla. R. Civ. P. 1.150(a).
3) continues to violate Judicial Canon 3.D.2)a:
A judge who receives information or has actual knowledge that substantial
likelihood exists that a lawyer has committed a violation of the Rules
Regulating the Florida Bar shall take appropriate action. This does not
speak to the violation of criminal statutes.
4) has violated and breached an Agreed Order signed on February 14, 2008, by Senior Judge Herb Stettin, which states in part:(A copy of the Senior Judge Stettin’s signed Agreed Order is enclosed herein).
3. Plaintiffs shall have twenty(20) days from the date of this Order
to serve their response to the Amended Affirmative Defenses.
4. Plaintiffs reserve all rights to challenge the Amended Affirmative
Defenses, including, but not limited to, motions to strike, motions
for summary judgment and the like. The Plaintiffs have complied
with both requirements of the signed Agreed Order, and still Judge
Jeri Beth Cohen refuses to abide by Senior Judge Stettin’s Order.
5) has denied Plaintiffs their due process rights pursuant to an Agreed Order signed by Senior Judge Herbert Stettin.
6) has condoned the Defendants and their Attorneys breach of that Agreed Order. The Defendants (attorneys) and their counsel engaged in a knowing breach of that signed Agreed Order whereby the Defendants received the benefit of the Agreed Order and then the Defendants engaged in a scheme to deprive the Plaintiffs of the benefit that they were to receive by that signed Agreed Order......the right to attack the Affirmative Defenses by striking them as a sham under FRCP 1.150 which would require the court to conduct an evidentiary hearing.
At the hearing held on October 15, 2008, I requested that Judge Cohen adhere to her judicial responsibilities pursuant to Judicial Canons. She sat stoned faced and said “you file a Complaint,” again, in violation of her judicial duties.
Furthermore, the violations of the Rules and the law that the attorneys have engaged in, with the cooperation and coverup of Judge Jeri Beth Cohen, needs to be investigated by all the appropriate agencies, especially because such conduct has risen to the level of, what I believe to be, criminal activity. Judge Cohen continues to obstruct justice.
In the spirit of full disclosure, I want the record to reflect that I have a JQC Complaint pending against Judge Jeri Beth Cohen, No. 08411, in addition to these allegations of involvement in criminal activity. I also have a Civil lawsuit, under the ADA, pending against Judge Jeri Beth Cohen, in her official capacity, and in her individual capacity, in the United States District Court, Southern District of Florida, Case No. 08-CV-22009-JORDAN. I have also alerted the JQC, its fifteen member panel, and Governor Crist to the undue influence that Special Counsel to the JQC, Lauri Waldman Ross, has on the judiciary. Such influence is displayed regularly as Judge Cohen yields to Lauri Waldman Ross during proceedings. Lauri Waldman Ross has used her undue influence previously before the late Judge Manuel Crespo who presided over this case in 2005, for a total of two hearings, and then recused himself before expiring.. At a hearing held on October 15, 2008, Lauri Waldman Ross, Defense counsel for Marc Cooper, and a Special Counsel to the Judicial Qualifications Commission, continued violating Rule 4-3.3 - Candor Toward the Tribunal: False evidence and a duty to disclose. In addition, Ms. Ross violated Rule 4-3.4 Fairness to Opposing Party and Counsel. As a member of The Florida Bar, and as a representative of the JQC, Ms. Ross should exude the highest standard of ethics, as she, by her position, is called upon to weigh transgressions of the judiciary. How can Ms. Ross perform her responsibilities if she, herself, does not abide by the Rules of Professional and Ethical Conduct regulating The Florida Bar members? At that hearing, Ms. Ross verbally and demonstrably accused Plaintiff’s counsel, Mary Alice Gwynn, of making misrepresentations to the Court when it was Ms. Gwynn who alerted the Court about the parties’ prior agreement with regard to challenging the Defendants Affirmative Defenses. Ms. Gwynn referenced e-mails between the parties documenting such an agreement. Ms. Ross immediately started pointing her finger at Ms. Gwynn and said: “I want anything in writing from this lady because I am sick of coming in here and having misrepresentations from her.”
Ms. Ross sat silent and failed to disclose that, in fact, the parties did have an agreement that was reduced to an Agreed Order signed by Senior Judge Herbert Stettin on February 14, 2008 which was actually drafted by Lauri Waldman Ross, and forwarded directly from Ms. Ross to Judge Stettin.
I, Meryl M. Lanson, on October 16, 2008, via e-mail, requested that Ms. Ross report her misrepresentations to Judge Cohen. Ms. Ross refused to do so which further violates the ethical rules governing The Florida Bar members. A Notice of Filing of the exchange of e-mail communications between Plaintiff, Meryl M. Lanson, Pro Se, Plaintiff, Norman Lanson’s counsel, Mary Alice Gwynn, and the Defendants counsels, Waldman Ross, Throckmorton, Klein, Jack and Sanger was sent to the Court for filing on October 22, 2008. (A copy of the Notice of Filing with attachment is enclosed herein). Furthermore, a Motion (A copy of the Motion is enclosed herein)was sent, via Federal Express, to the Court for filing on October 22, 2008 which outlines what transpired at the October 15, 2008 hearing and the violations of Ms. Ross, with the acquiescence of Judge Cohen, and the silence of attorneys, Throckmorton and Jack, who were also party to the Agreed Order signed by Senior Judge Stettin. Robert Klein, Esq. and Reggie Sanger, Esq. were not present at that hearing but are party to the Agreed Order and was party to the e-mail communications, and all communications filed with the Court. A copy of all filings have been sent to all Counsel of Record. The Defendants and their Counsel continue to engage in obstruction of justice and do so in knowing violation of the Rules Regulating The Florida Bar.
I have asked Judge Cohen, on three occasions, to disqualify herself. She refuses to do so. Her rulings in this case appears to be that she is using her position, to not only retaliate against me for the actions I have taken against her, but also to sabotage the civil litigation for the benefit of the attorneys and to the detriment of the Plaintiffs, Meryl Lanson, Norman Lanson and Baron’s Stores, Inc., and its beneficiaries, the Creditors.
As mentioned in my previous Notice dated September 17, 2008, the Courts have turned a blind eye to the submission of fraudulent documents in violation of the Rules and the Law for, what I believe to be, the protection of certain well connected professionals.
This matter involves both state and federal agencies as the alleged criminal violations involve the transmittals of the fraudulent documents through electronic mail, Federal Express and the United States Postal Service.
I have made serious allegations against these attorneys and Judge Jeri Beth Cohen. I stand by each one of my allegations as I have the documents, the transcripts, the tapes - the evidence to support my position. Finally, every agency in receipt of this letter has a duty to protect the public from unethical conduct, negligence, fraud and/or corruption. When such unethical conduct, negligence, fraud and/or corruption involves officers of the court, specifically attorneys and judges, the tolerance level should be at zero and the priority to investigate should be at the top of your agenda. I trust that your investigations will be properly handled without regard to whom the individuals are.
Respectfully submitted,
Meryl M. Lanson
Telephone: 561-488-2740
Facsimile: 561-488-2861
E-Mail: mlanson@bellsouth.net
Enclosures:
1) Copy of Senior Judge Herbert Stettin’s signed Agreed Order dated February 14, 2008.
2) Copy of Notice of Filing dated October 22, 2008 with attachments.
3) Copy of Plaintiff, Meryl M. Lanson, Pro Se, Supplement to Plaintiff’s Response to Defendants Motion for Summary Judgment and Objection to Any of the Defendants Proposed Orders and Request for an Evidentiary Hearing Pursuant to Senior Judge Herbert Stettin’s February 14, 2008 Order.
cc: Governor Charlie Crist with attachments
