Filing # 73203375 E-Filed 06/06/2018 11:28:15 PM
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Filing # 73203375 E-Filed 06/06/2018 11:28:15 PM IN THE SUPREME COURT OF FLORIDA CASE NO. SC10-1745 MERYL M. LANSON, PRO SE Petitioner, VS. LAURI WALDMAN ROSS, ESQ. ELLIOT H. SCHERKER, ESQ. ROBERT M. KLEIN, ESQ. LEWIS N. JACK, JR., ESQ. CHARLES W. THROCKMORTON, ESQ. RONALD C. KOPPLOW, ESQ. MARC COOPER, ESQ. SONYA L. SALKIN, ESQ. THOMAS D. HALL, ESQ. JOHN F. HARKNESS, ESQ. NOTICE OF FILING: O N COMPOSITE EXHIBIT "D" TO: ADA-PROTECTED PRO SE PETITIONER'S "VERIFIED" MOTION TO VACATE AND SET ASIDE SUPREME COURT OF FLORIDA'S SEPTEMBER 29, 2010 ORDER PURSUANT TO RULE 1.540(b)(4) AS ORDER IS VOID FOR VIOLATING GUARANTEED FEDERAL CONSTITUTIONAL RIGHTS IN STATE COURT PROCEEDINGS COMES NOW ADA-Protected Pro Se Petitioner,Meryl M. Lanson, and hereby files Composite Exhibit "D" to ADA-Protected Pro Se Petitioner's "Verified" Motion to Vacate and Set Aside Supreme Court of Florida's Copyrighted Reg. #TXu l-785-263 1 r September 29, 2010 Order Pursuant to Rule 1.540(b)(4) as Order is Void for Violating Guaranteed Federal Constitutional Rights in State Court Proceedings. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was furnished by electronic mail via the Florida Courts e-filing portal and via e-mail to all parties listed on the below Service List on this 6_th of June, 2018. Meryl . Lanson, pro se SERVICE LIST Hon. Jeri Beth Cohen W. Todd Boyd, Esq. 1351 NW 12th St Ste 405 Frank Colonnelli, Jr., Esq. Miami, FL 33125-1630 Laura C. Douglas, Esq. [email protected] Craig J. Shankman, Esq. Marisa Eve Wiggins, Esq. Boyd Santini Parker & Colonnelli 100 S.E. 2"d Street, 36"' Floor Miami, Florida 33131 [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] Hon. Thomas Rebull Brian Scott Behar, Esq. Dade County Courthouse Robert J. Edwards, Esq. 73 W Flagler St Ste 800 Behar,gutt & Glazer,P.A Miami, FL 33130-1722 1855 Griffin Rd Ste A350 [email protected] Dania, FL 33004-2210 [email protected] [email protected] Copyrighted Reg. #TXul-785-263 2 Hon. Bronwyn C. Miller Peter M. Bernhardt, Esq. 73 W Flagler St Ste 412 McDonald Hopkins, LLC Miami, FL 33130-1715 Flagler Town Center United States 505 S Flagler Dr Ste 300 [email protected] West Palm Beach, FL 33401-5942 [email protected] Marc Cooper, Esq. Thomas D. Hall, Esq. 411 Walnut St # 5912 The Mills Firm Green Cove Springs, FL 32043-3443 The Bowen House mare [email protected] 325 N Calhoun St Tallahassee, FL 32301-7605 [email protected] John F. Harkness, Esq. Lewis N. Jack, Jr., Esq. PO Box 996 Law Office ofLewis N. Jack, Jr., P.A. Tallahassee, FL 32302-0996 Town Center One - Suite 1601 [email protected] 8950 SW 74th Ct Miami, FL 33156-3171 [email protected] James Kaplan, Esq. Robert M. Klein, Esq. Kaplan Zeena LLP 9130 S Dadeland Blvd Ste 2000 2 South Biscayne Blvd. Miami, FL 33156-7809 One Biscayne Tower, Suite 3050 [email protected] Miami, Florida 33131 james.kaplan@,kaplanzeena.com Ronald C. Kopplow, Esq. Justus W. Reid, Esq. Ronald C. Kopplow, P. A. Justus Reid & Associates, LLC PO Box 56 1065 D/B/A REID BURMAN LEBEDEKER Miami, FL 33256-1065 PO Box 2926 [email protected] West Palm Beach, FL 33402-2926 [email protected] Lauri Waldman Ross, Esq. Sonya L. Salkin, Esq. Ross & Girten The Salkin Law Frim 9130 S Dadeland Blvd Ste 1612 PO Box 15580 Miami, FL 33156-7851 Plantation, FL 3331 8-5580 [email protected] [email protected] Copyrighted Reg. #TXul -785-263 3 Reggie David Sanger, Esq. Elliot H. Scherker, Esq. Reggie David Sanger, P.A. Greenberg Traurig 3256 E Grapeleaf Ln 333 SE 2nd Ave Ste 4400 Inverness, FL 34452-9206 Miami, FL 33131-2184 [email protected] [email protected] Charles W. Throckmorton, IV, Esq. Mark R Osherow, Esq. Kozyak Tropin & Throckmorton Osherow, PLLC 2525 Ponce De Leon Blvd F1 9 1801 N Military Trl Miami, FL 33134-6039 Boca Raton, FL 33431-1811 [email protected] [email protected] Dania Saavedra, Esq. Jeremiah Richard Jones, Esq. Gray Robinson, P.A. American Maritime Officers 333 SE 2nd Ave Ste 3200 2 W Dixie Hwy Miami, FL 33131-2191 Dania Beach, FL 33004-4312 [email protected] [email protected] Copyrighted Reg. #TXul-785-263 4 COMPOSITE EXHIBIT D Filing # 70320198 E-Filed 04/05/2018 04:54:57 PM IN THE CIRCUIT COURT OF THE 11442 JUDICIAL CIRCUIT OF FLORIDA IN AND FOR MIAMI-DADE COUNTY GENERAL JURISDICTION DIVISION NORMAN LANSON, CASE NO.: 06-09516 CA 13 MERYL LANSON, and BARON'S STORES, INC., a Florida Corporation, Plaintiffs, vs. JUSTUS W. REID, JUSTUS W. REID, P.A. MARK R. OSHEROW, MARK R. OSHEROW, P.A., PETER BERNHARDT, and REID, METZGER & BERNHARDT, P.A., Defendants. SECOND SUPPLEMENT TO: ADA-PROTECTED PRO SE PLAINTIFF, MERYL M. LANSON'S VERIFIED MOTION AGAINST DEFENDANTS JUSTUS W. REID, ESQ., PETER M. BERNHARDT, ESQ., THEIR RESPECTIVE FIRMS; DEFENSE COUNSEL FRANK COLONNELLI, JR., AND THE FIRM OF BOYD, RICHARDS, PARKER, COLONNELLI, FOR DEFENDANTS INTENTIONAL MALICIOUS BAD FAITH 57.105 MOTION WHICH WAS FILED AS A WEAPON OF INTIMIDATION AND ABUSE, IN DEFENDANTS' ONGOING UNCONSCIONABLE FRAUD ON THE COURT SCHEME IN HOPES THAT PLAINTIFFS WOULD HAVE WITHDRAWN THEIR LEGALLY COGNIZABLE CORRECTED AMENDED COMPLAINT ADA-Protected Pro Se Plaintiff, Meryl M. Lanson ("M. Lanson") hereby files this "Second Supplement": to the Verified Motion against Defendants and their Counsels for Defendants Intentional Malicious Bad Faith 57.105 Motion, which Defendants, and their Counsel, filed as a Weapon of Intimidation and Abuse, in Defendants' Ongoing Unconscionable Fraud on the Court Scheme in Hopes that Plaintiffs would have Withdrawn their Legally Cognizable Corrected Amended Complaint. Copyrighted Reg. #TXu1-785-263 1 ADA-Protected Pro Se Plaintiff Meryl M. Lanson ("M. Lanson") reaffinns and realleges all prior filings, and statements, in this case, including all exhibits. ADA-Protected Pro Se Plaintiff Meryl M. Lanson reaffinns and realleges all Memorandums of Law which she prepared and submitted in all prior filings in this case, including but not limited to: Tennessee v. Lane, 541 U.S. 509 (2004). ADA-Protected Pro Se Plaintiff Meryl M. Lanson reaffinns and realleges the totality offilings (and exhibits) in this case relevant to the underlying legal malpractice case: No. 99-21062 CA 22, Norman Lanson, Meryl M. Lanson, Baron's Stores, Inc. v. Ronald Kopplow, Kopplow & Flynn, Marc Cooper, Cooper & Wolfe, P.A., and Sonya L. Salkin, Malnik & Salkin, P.A. And, ADA-Protected Pro Se PlaintiffMeryl M. Lanson reaffinns and realleges that everything she filed remains "Verified" under the penalties ofperjury, so help her God. On January 19, 2018, ADA-Protected Pro Se Plaintiff, Meryl M. Lanson filed the "First Supplement: to the January 12, 2018 filing of the "Verified Motion against Defendants and their Counsels for Defendants Intentional Malicious Bad Faith 57.105 Motion, which Defendants, and their Counsel, filed as a Weapon of Intimidation and Abuse, in Defendants' Ongoing Unconscionable Fraud on the Court Scheme in Hopes that Plaintiffs would have Withdrawn their Legally Cognizable Corrected Amended Complaint." On Page 8 of that "First Supplement," M. Lanson stated that she would be filing a "Second" supplement, God willing, no later than the end of the week of January 26, 2018. 1 What prompted M. Lanson to file the "Trial by Proxy," in this instant case, on February 1, 2018, was the "Closing" statement she made in the "First Supplement," which was filed on 1 Obviously, God was not willing for M. Lanson to file the "Second" supplement to the initial Verified Motion until today, April 5, 2018, and the reason for M. Lanson's February 1, 2018 filing of the "Trial by Proxy." Copyrighted Reg. #TXu1-785-263 2 January 26, 2018, as follows, alerting this Court as to the timeline of events that led up to the preparation and ultimate final product of the "Trial by Proxy." "I cannot end this filing, without speaking directly to the Defendants, Justus W. Reid, Peter M. Bernhardt and Mark R. Osherow, and asking the question, WHY? Why couldn't one of you just come to Norman and Meryl Lanson, and tell them: we are being pressured by the Bar, and we are afraid of what the Bar will do to us, to our lives, and to our livelihoods, so we are going to have to withdraw, abandoning you, because we are cowards, and we have to put our interests, and our families' needs, and our lives before our clients, and their interests, and their lives, and their livelihoods - So, you see, Norman and Meryl, what we suggest you do is retain an attorney outside of Florida, who is not threatened by the unchecked conflicted abusive power of the Florida Bar. At least, you would have been honest, and the escalated substantial damages, including the wrongful death of Norman Lanson, that you are all jointly and severally liable for, would not have happened." THE MULTI-MILLION DOLLAR QUESTION IS AND REMAINS: Why would an attorney, (any attorney, all the attorneys) take Plaintiffs' case on a contingency, all costs included; defeating the Defendants' Motion to Dismiss; be in possession of Orders by State and Federal judges, as to the law, and the right for their clients, Plaintiffs, to recover all legally cognizable claims against attomeys for their negligence; having had perfected all Bad Faith claims against all the parties, lawyers, and their firms with their respective malpractice carriers; proven Plaintiffs damages as stated in Comprehensive Expert Forensic Damage Reports, which has never been refuted; and a whole lot more ammunition against the Defendants, and their counsels, and their insurance carriers, and the Bar, and then, abandon their clients at the time of restitution? THE ANSWER IS: Because the Damages, including the Bad Faith claims, were to be paid by the Florida Bar's created/owned/operated malpractice carrier, Florida Lawyers Mutual Insurance Company; and, Copyrighted Reg.