Judicial Corruption Info for Qualified Visitors

     Why should competent and responsible "qualified visitors" in upstate SC take time to carefully review the educational information presented in this department? 
     What do American citizens need to know about judicial systems in America that they don't already know?    
     Do they need to know why it can be dangerous for SC citizens to travel anywhere outside of their home county? 
     Do they need to know why it can be much more dangerous to travel into another USA state? 
     Do they need to know why judicial systems in the United States of American can easily be extremely unfair, unethical, and corrupt in ways that are self-serving for self-appointed "elitist, aristocratic" members of the legal brotherhood?  (attorneys, lawyers, and judges)
     Do "qualified visitors" need to learn some very important information  about how they can help protect themselves from unfair, unethical, and corrupt "elitist, aristocratic" members of the legal profession?
Objective of this Department
     The objective of this very important department is to help educate "qualified visitors" about some unfair, unethical, corrupt, and fraudulent attorney (lawyer) and judicial actions that can occur in trial courts and appellate courts throughout the United States of America. 
     The author of this educational department, and this entire website, is Lonnie E. Willoughby, Jr. (Lon Jr. or Lon) who was born a long time ago - on June 5, 1936 (now age 85). 
Some of Lon's Litigation Experiences
      Visitors will learn herein that Lon Jr. has many thousands of hours of litigation experiences in Florida courts - that occurred over a period of 20+ years of related litigation actions.
     Lon and his wife Janie lived in Mauldin, South Carolina (near Greenville) when Lon was forced into civil litigation in Florida in March of year 1989.  
     Lon was a co-trustee of two family member Florida Trust Agreements that had been established in January 1983 by his parents who lived in Putnam County Florida (Palatka).  Palatka is about 65 miles southwest of Jacksonville, Florida.
     The plaintiff in the lawsuit was Lon's mother, Leona Willoughby (age 74).  She was a beneficiary of one of the Marital Trust Agreement Estate, and she brought the lawsuit because she claimed that she needed more monthly income from the Marital Trust Agreement Estate than co-trustee Lonnie Willoughby, Jr. had allowed her to receive.
     Lon knew that her complaint was not valid because she had  normally been receiving all of the income generated within the Marital Trust Estate, which was plenty of income for her normal lifestyle when added to her usual Social Security monthly income.  In addition, Lon knew that Leona had more than $200,000 cash assets in her personal bank accounts (in a local Palatka bank account).
     The plaintiff in the lawsuit lived in the San Mateo area (Putnam County)  about six miles south of downtown Palatka and the lawsuit was filed in the Putnam County circuit court located in Palatka.  The two Trust Estates cash asset values (several hundred thousand dollars) were in bank accounts in Palatka, Florida (located in the north eastern part of Florida).  
     The Putnam County Courthouse is located in Palatka, Florida (the county seat). The very large St. Johns River passes through the Palatka area on its way to Jacksonville and into the Atlantic Ocean near Jacksonville.
     The lawsuit was about a very foolish family member trust estates  management dispute that was caused by unfair and irresponsible co-trustee actions by Lon's younger brother, Larry Willoughby, the other co-trustee of two family member trust estates [the Marital Trust Estate (for beneficiary Leona Willoughby) and the Family Trust Estate (for beneficiary brothers - Larry Willoughby and Lonnie Willoughby)].  
     You will learn herein that Lon Jr. had done many very important things to help his aging parents, and those extraordinary family actions had also helped Larry and his family (wife and three children still attending public schools in North Carolina).  However, Larry was very resentful of Lon Jr's very helpful family actions, and Larry foolishly created serious co-trustee management problems for Lon Jr. wherever possible. 
     You will also learn herein that Larry was an incompetent co-trustee who knew nothing about his co-trustee duties and responsibilities. He had no responsible appreciation for the very complex and difficult work that Lon Jr. had accomplished for the family over several years (from the spring of 1982 into the year when a serious dispute arose between the two brother co-trustees during year 1988).    
     Co-trustee Larry had caused several foolish difficulties for brother co-trustee Lon Jr., and Lon had taken the only practical and sensible action that is available to an abused co-trustee to try to stop those kinds of foolish abusive co-trustee actions by Larry - Lon Jr. started charging reasonable co-trustee fees for his very important co-trustee actions.
     Prior to that time in 1988, he had not charged any fees for his very important and very valuable co-trustee actions.
     Lon and Larry were at ages 51 and 50 respectively when the co-trustee dispute began in year 1988.  There is about 20 months difference in the ages of the two brothers (they were the only children of their parents).   
     You will learn herein that Lon Jr. had provided very important estate planning and estate management services for his parents that had an estimated value of more than $225,000 in potential federal estate tax savings and potential Florida probate attorney fee savings of more than $80,000 over the period of both parent's lifetimes
     Co-trustee Larry then acted in a very stubborn, hard-headed manner in 1988 by refusing to agree to pay older brother Lon Jr. anything at all for the very reasonable co-trustee fees that he started charging for his co-trustee services for the two trust estates (fees due to Larry's abusive actions).  
     Co-trustee Lon Jr. then took the only practical and sensible action that was available to him - he stopped the disbursement of monthly income checks from the two trust estates to the three beneficiaries until his small very reasonable co-trustee fees were agreed upon for consideration and payment by co-trustee Larry (to be paid by a prorated reduction in amount of each monthly income disbursement check to Leona and Larry as trust estates beneficiaries).   
      Co-trustee Larry then acted in a very stubborn, hard-headed manner  again (still in year 1988) by still refusing to agree to pay older brother Lon Jr. anything at all for the very reasonable co-trustee fees that he had started charging for his co-trustee trust estate management services.  
     Leona and Larry cooperated with each other to use that monthly income distribution dispute as the basis to start civil litigation against co-trustee Lon Jr. as Equity Court litigation in the Circuit Court for Putnam County, Florida in late February 1989.  
     They were both willing to spend many thousands of dollars in litigation expenses rather than simply agree to responsibly pay co-trustee Lon Jr. a few hundred dollars for his charged co-trustee management fee expenses.
     Co-trustee Lonnie Willoughby, Jr. was noticed about that law suit by first class mail on or about March 3, 1989
     Larry and his family (wife and three children) lived in one of the beach areas near Wilmington, North Carolina.  Larry was a real estate broker who sold beach area homes and properties. 
     At that time in March 1989, Leona Willoughby was a widow who still lived in her modest custom built 3 bedroom, 2 bath home with a garage that was waterfront property on the very large St. John's River (about a 1/2 mile wide). 
     The living room of the home had a large glass sliding door wall that provided a beautiful panoramic view of the river.  The home had a covered back porch that looked across the very good swimming pool and out to the beautiful river view and the Willoughby's private boat dock with a boat.  The home also had expensive solar energy panels on the roof. 
     Leona and her husband (Lonnie Sr.) had the home custom built to their personal specifications, and Leona had lived there for several years with her husband, Lonnie Willoughby (Sr.) until he died of a heart attack at age 71 on November 22, 1986.  He was very fond of fishing, and he had a very good outboard powered fishing boat at their private boat dock.
     That home was about six miles south of Palatka in a residential area named San Mateo.  U.S. Highway 17 goes through the San Mateo area (on its way to Deland, Florida - about 50 miles south of San Mateo). 
     The small San Mateo Post Office was right beside the U.S. Highway, and there was one restaurant and a minute market that sold basic groceries and many other items.
     The brother's father, Lonnie Willoughby (Sr.), had previously had serious heart problems for many years.  He had a pacemaker installed in his chest for several years to help regulate his heart beat rhythm, and he took medication for his heart problems.  His heart specialist medical doctor was in Jacksonville, Florida, about 65 miles to the north-east.
     Lonnie Sr. had suffered a very serious heart attack that put him in a hospital in Jacksonville, Florida in the spring of 1982, and he had a terrible stroke while still in the hospital.
     At age 66, Lonnie (Sr.) was totally paralyzed on the left side of his body, from his left shoulder area to his left foot.  He had no muscle control of his left arm and hand and no muscle control of any part of the left side of his body down to the tip of his toes.
Quick Overview Of Family Actions
     As soon as possible after his father's heart attack and stroke in the spring of year 1982, Lon Jr. and his wife Janie moved Lon's parents into their home in Mauldin, South Carolina so Lon and Janie could take good care of Lon's parents and hopefully improve their physical and emotional health.
     Lon Jr. was a serious healthcare enthusiast and he had learned a lot  about taking good care of one's health (exercise, mineral and vitamin supplements, purified drinking water, improved diet concepts, etc.).
     Lon was also able to get his father some very important rehabilitation therapy and treatment at the Roger C. Peace Rehabilitation Center in nearby Greenville (very helpful treatment for stroke victims).
     That rehabilitation therapy continued for several weeks - outpatient rehabilitation treatments, and then inpatient rehabilitation treatments, and then back to outpatient treatments. Those stroke rehabilitation treatment therapies were very helpful for Mr. Willoughby.   
     During this time, Lon learned that his parents had partial ownership in a 44 unit apartment complex located in Deland, Florida - the Penn Oaks Apartments.  The apartments were in four large two story buildings.  A local bank had a mortgage note on the property in excess of $600,000.
     The apartment complex was being managed by a retired couple who lived in the first downstairs apartment, and it's living room also served as the office for the apartment complex. 
     In the spring of 1983, Lon Jr. traveled to Deland, Florida (about 500 miles distance) to try to evaluate how well the apartment complex was being managed, and to try to evaluate to some extent what condition the apartment complex was in currently. 
     Lon learned that the apartment complex was about ten years old and had a lot of maintenance problems that had accumulated over the years in some of the apartments.  (serious air conditioning problems, appliance problems, plumbing fixture problems, carpeting problems, etc.) 
     Lon's parents had been making regular visits to the apartment complex occasionally (before Lonnie Sr's recent heart attack and stroke) to help the elderly couple get some maintenance work done as needed, but those routine visits had ceased for a number of months due to Lonnie Sr's heart attack and stroke condition. 
     Lon Jr's trip to visit the apartment complex in the spring of 1983 enabled him to determine that the elderly couple managing the apartment complex were not able to manage the apartment complex adequately. 
    Lon Jr. realized that his parent's large investment in the apartment complex was a major investment that was essentially the sum of their lifetime work and investment achievements.  He also realized that their future monthly income was dependent upon the profit income coming in monthly from the 44 apartment rentals.  Lon's father's very serious health problems now caused that situation to be precarious at best. 
     In order to help protect his parent's major investment in that apartment complex, Lon Jr. concluded that he and Janie needed to plan to move to Deland, Florida and take over the management of the apartment complex. 
     That move would cause serious problems for Lon and Janie.  She was a teacher at the local Mauldin High School which was just six blocks from their home in a nearby subdivision with a 100+ homes. 
     Janie was teaching the class subjects that she preferred to teach, and she worked for a female high school principal that she respected a lot.  Janie obviously did not want to terminate a very good teaching position that had taken her several years of responsible work to develop. 
     Further complicating that decision was the fact that Lon Jr. had started a new business venture in Greenville city just before his father had his heart attack and stroke in the spring of 1982
     Lon Jr. had invested the accumulated savings that he and Janie has managed to accumulate during the past 12 years of marriage (20,000+ dollars).  Lon realized that they would lose all of that investment if they terminated that business venture at such an early stage because there was no way he could sell and recover their investment in that new business. 
     Another important consideration was the fact that Lon's two adult sons (from a prior marriage that ended in the fall of 1970) were both in nearby colleges.  Michael, the older son was attending Furman University in the Greenville area, and Robert was attending Clemson University, in Clemson, SC (about 45 miles distance from Mauldin, South Carolina). 
     The elderly couple that were managing the apartment complex in DeLand, Florida were being furnished with a two bedroom apartment and were being paid $800.00 per month (for both of them). 
     As you can see, making a decision for Lon and Janie to move to Deland, Florida and begin managing the Penn Oaks Apartment Complex for $800.00 per month had some very serious complications for the two of them. 
     Due to Lon's father's very serious health condition, the decision was made for Lon and Janie to terminate both of their careers and move to Deland, Florida to begin managing the 44 unit apartment complex.
    Lon and Janie put their home up for lease with a local real estate company, packed up their household furniture in a large rented moving van and a large trailer and moved to Deland, Florida on July 15, 1983.
    As explained later in this report, that relocation action was very beneficial to Lon's parents, and it was also very beneficial for Lon's brother Larry and his family (wife and three children - still in public schooling). 
     Lon and Janie worked exceptionally hard for about 16 months, and Lon spent about $60,000 of Lon's parents cash assets to make a lot of badly needed improvements in the apartment complex.  Their work got the entire apartment complex in much better condition.
     The parent's original intention was to keep the apartment complex in the Willoughby family as a good long-term investment. 
     Unfortunately,  Larry Willoughby was so resentful and ungrateful toward brother Lon from August 1983 to the middle of year 1984 for the family actions they he and Janie had taken to help the parents that Lon decided that he was not going to end up being a family partner with brother Larry, with Lon and Janie managing the apartment complex indefinitely and Larry living in the Wilmington area.  Lon could see that those work conditions were not going to work well for he and Janie in future years. 
     Larry had already created some very serious problems for Lon and Janie due to his jealous emotional responses to their helpful work for the parents.  Larry seemed to deeply resent their dedicated efforts to help the parents as much as possible, so Lon decided the parents needed to try to sell the apartment complex. 
     The parents reluctantly agreed, due to the emotional problems that Larry had already caused.  Lon put the apartment complex up for sale with a local real estate company in DeLand, and they were successful in finding a suitable buyer (an investment group located in Orlando, Florida). 
     That pending sale situation enabled Janie to move back to Mauldin, South Carolina in December 1984 because she was able to get rehired at the Mauldin High School.  She resumed teaching when students returned to school in January 1985, after their Christmas school break. 
   Lon Jr. moved to San Mateo, Florida in January 1985 so he could be near his parents and continue helping them with their daily efforts to cope with Lon's father's paralyzed condition. 
Leona was a very serious problem for Lon Jr.
     Lon's mother (Leona) was a continuing source of frustration and irritation for Lon Jr. because she seriously resented his actions to relieve his father's very painful muscle cramps on the paralyzed left side of his body.
     Leona eventually adamantly forbade Lon Jr. to use the large two-hand type professional electric vibrator that Lon had purchased for his mother (or the nursing aide) to use to vibrate Lon's father's paralyzed left side of his body to stimulate lymphatic fluid flow and relieve very painful muscle cramps.  Lon Jr. had taught both of them how to use the vibrator for that purpose.
     Fortunately, Lon had studied Lymphology with Dr. Samuel West, a highly skilled Lymphologist, when he was conducting a series of seminars in the Greenville, SC area during the fall season of year 1982 (after Lon's father had his tragic stroke in the spring of year 1982).  That was during the period of months when Lon's parent's were living with Lon and Janie in their three bedroom, two and 1/2 bath home in Mauldin, SC.  Lon took his parents to a couple of those lengthy seminars by Dr. Samuel West so they could understand what Lymphology was about.
     Dr. West had written an excellent text book (hardback - well illustrated) about Lymphology, and Lon Jr. had purchased that text book and had studied it very seriously because he had learned how important lymphatic system functions can be to good body health.  Lon theorized that using a large two-hand type vibrator would likely improve lymphatic fluid flow in the paralyzed left side of his father's body and help him relieve cramps.
     Lon theorized that vibrations might stimulate lymphatic glands fluid flow, and that help get rid of the very painful cramps in the left side of his father's body, especially with his paralyzed left arm. 
     When he had cramps in his left arm, the muscle tissue would be very hard, and the heavy duty vibrator would cause the cramps to stop and the muscle tissue would then relax and become soft again.  Lon could actually feel where the painful cramped tissue was located.
     Lon could use that powerful vibrator to get rid of his father's muscle tissue cramps every time, without fail.  After Lon moved his parents back to their home in Florida, and after he moved to their San Mateo area in January 1985, Lon began using that professional two-hand typed vibrator to help his father cope with frequent serious muscle cramps. 
     Each time that Lon visited his parents - usually every other day, three times per week, his father always wanted him to use that professional type vibrator to relieve some muscle cramps and help him feel a lot better. 
     Eventually, Leona started hiding the electrical vibrator so it could not be used when Lon visited his parents, usually every other day.  Lon had purchased a second professional vibrator so he started bringing that vibrator with him each time he visited his parents.  Leona would get angry with him when he used that vibrator to help his father feel a lot better.
     She said that the elderly medical doctor (more than 70 years old) that they visited in Jacksonville, Florida at about three month intervals for a cortisone injection (for pain relief), had told her that the electrical vibrator that Lon Jr. used was what was causing Mr. Willoughby's muscle cramps. 
     Leona had explained to the elderly medical doctor how Lon Jr. used the professional two-hand type vibrator to relieve muscle cramps.
     The elderly medical doctor had apparently forgotten what he had learned in medical school about the great importance of lymphatic fluid flow for body cell health and tissue health. 
     The lymphatic system has the very important responsibility of removing waste products from all body cells and all body tissue, throughout the body (except for the brain).
     Lon Jr. then explained to his mother that the doctor's theory about the vibrator was not correct, as proven clearly by the fact that Lon's father's muscle cramps had been occurring frequently for many months before Lon purchased the professional type vibrator to help relieve those muscle cramps (after he studied Lymphology with Dr. Samuel West in late 1982).
     Due to his mother's extremely stubborn and foolish interference with Lon's frequent responsible efforts to help his father whenever possible, Lon finally moved back to his home in Mauldin, South Carolina in April 1986.
     Mr. Lonnie Willoughby (Sr.) had another heart attack on November 22, 1986 that was fatal (age 71).
Back to the Florida Litigation
     During the months that followed the start of litigation in March 1989, Lon Jr. learned that Leona and Larry cooperated with each other to cause the lawsuit with co-trustee Lonnie Willoughby, Jr. as the only defendant.  
     Lon Jr. gradually learned that their mutual objective with the lawsuit was to try to force co-trustee Lon Jr. to resign from his co-trustee responsibilities - to avoid difficult and expensive litigation in Putnam County Florida.  Lon realized that his resignation as co-trustee would have enabled co-trustee Larry Willoughby to become the sole trustee of the two Willoughby trust agreement estates (net worth of $900,000+).
     Leona and Larry apparently wanted co-trustee Lon Jr. out of the way in the trust agreement estates management so they could have total control over the two trust estate assets - to do whatever Leona Willoughby wanted to do with the trust estate assets. 
     You will learn herein that Lonnie Jr. and his wife Janie had done many things that were of great benefit to his parents, and those actions were also very beneficial to brother Larry and his wife and their three children.  
     Lon and Janie's actions of giving up their two careers in the Greenville, SC area, and moving to DeLand, Florida on July 15, 1983 so they could take over the management of the Penn Oaks Apartments had helped the parents a tremendous amount.  Lon was then only 50 miles away from the parents and his frequent visits to the parent's home also helped the parents in important ways. 
     Those actions by Lon and Janie had enabled Larry and his family to continue living their life as usual, and Larry was enabled to continue conducting his real estate business unimpeded by Larry's father's major heart attack and his tragic paralyzing stroke down in Florida.  
      In their foolish greed to try to get total control of the Willoughby trust estates assets, Leona and Larry conveniently forgot about Lon and Janie's very helpful family actions, over a period of several years.  They both ignored the fact that Lon and Janie had helped all Willoughby family members a tremendous amount by their actions to help the parents.
     There was a Marital Trust Estate and a Family Trust Estate.  Leona Willoughby was the sole beneficiary of the Marital Trust Estate.  Larry and Lonnie Jr. were the primary beneficiaries of the Family Trust
     Lon Jr. realized that his mother (Leona) was a very stubborn and hard headed person who expected to have her way with any family type idea that came into her mind.  She and Lon Jr. had conflicts several times about the domineering and overbearing way that she cared for her paralyzed husband (Lon's father).
     Leona was very helpful to her husband in many situations, but she also treated him like her paralyzed slave in many situations -  which caused him a lot of serious emotional stress. 
     Lon Jr. had tried to help his father cope with those serious domineering and overbearing emotional situations numerous times - from June 1982 through March 1986
      Lon Jr. had initially helped both parents get their inter vivos trust estate agreements developed by an estate planning attorney in Daytona Beach, Florida.  He drove to Florida and was with his parents when they signed those trust agreement documents in January 1983 at the attorney's law firm office in Daytona Beach, Florida.   (1,000 miles round trip).
      Lon Jr. had also been very successful with the operation and management of the Penn Oaks Apartments for about 18 months.  He and Janie had made many improvements to the apartment complex. 
    Lon was also successful with the sale of the apartment complex at a very good price.  He had also been successful with his personal negotiation efforts with the second mortgage note arrangements that his parents had taken with the sale of the apartment complex. 
      Lon Jr., was a knowledgeable and responsible co-trustee of the two Willoughby trust estates, and he had not given in to Leona's unreasonable demands about management of the two Willoughby trust estates. 
     He had politely and respectfully disagreed with his mother (Leona) several times about trust estate management issues.  She wanted to be in control of the two Willoughby trust estates, but she was hard headed, stubborn, and she had no responsible understanding of the trustee duties that were involved in managing this estate properly and responsibly. 
     Leona then tried to force Lon Jr. to agree to turn all trustee management duties over to a Florida bank's trust management department.  He resisted that effort strongly and so did his father. 
     Leona did not understand that the Penn Oaks Apartment sale "second mortgage note" that had been assigned to Mr. Willoughby's trust agreement estate was subject to fail if the Florida investment group was not successful with their operation and management of the Penn Oaks Apartment Complex purchase.
     Co-trustee Lon Jr. realized that there was a serious possibility that the investment group would not be successful with that business venture.  He had managed that business for about 18 months and he was very familiar with all the duties and responsibilities that were involved. 
     Consequently, Lon Jr. realized that the Willoughby's might have to resume ownership and operation and management of that apartment complex at some point in the future (if the investment group was not successful with their management of that complex apartment business operation).
     By December 1985, Lon Jr. had learned how to develop very important amendments to the two inter vivos trust agreements (Lonnie Sr. and Leona) to enable the trust agreements to work much better for the family. 
     Lon Jr. did all of the complex work in getting his father's trust agreement funded properly with complex real estate mortgage note property transfers on December 12, 1985.  Lon realized that his father could die at any time, and would likely die in the next year or two.  That was why it was critically important to transfer real estate assets into his trust agreement estate as quickly as possible.  Those transactions had to be completed before his father's health got worse because he needed to be mentally capable of approving of those trust estate transactions.
     However, in spite of all the very important actions that Lon Jr. and wife Janie had taken to help his father and mother, Leona still treated Lon Jr. like he was her teenage son who must obey her every command. 
      Lon Jr. was now 49 years of age (late 1985 - early 1986).    
     Younger brother Larry had not done any of those very important actions that were very helpful to the Willoughby family, but Larry would always agree with and cooperate with any of Leona's opinionated demands and objectives (about anything, including trust estate management issues). 
 Lawsuit Was Flawed 
     The mutual objective of Larry and Leona for the lawsuit was severely flawed from the beginning because Lon Willoughby Jr. was the person who had initially helped his parents establish the two Willoughby Trust Agreements, and he had personally taken critically important estate planning actions that got the two inter vivos trust agreements drafted by a Florida estate planning attorney and finalized in January 1983
     Lon Jr. then did some very important work that resulted in him personally amending the two trust agreements and then funding appropriately his father's trust agreement ($700,000+).  Lon Jr. got the two amended trust agreements finalized on December 12, 1985, and he filed the amended trust agreement documents in the local Putnam County circuit court records system.  He accomplished all of those complex trust agreement amendment actions while he was living in Putnam County. 
     Co-trustee Lon Jr. had moved back to his home in Mauldin, South Carolina in April 1986.  He was not going to resign from his co-trustee duties because he knew that he was a competent and knowledgeable co-trustee, and he understood that younger brother Larry was an incompetent co-trustee who knew nothing about responsible trust estate administration and management. 
     Lon Jr. also knew that Leona and Larry and five Willoughby grandchildren needed Lon's competent and responsible management of the two Willoughby Trust Agreement estates (Marital Trust Estate and the Family Trust Estate).
    Lonnie Jr. also realized that his deceased father would not have wanted him to resign as a co-trustee of the two Trust Agreements.
     In January 1986, while Lon was still living in San Mateo, his father wanted Lon Jr. to take him to ride (as they occasionally did).  Those ride situations enabled Lonnie Sr. to enjoy being out of the house for a while (instead of being in his bed, or in his lazy boy chair, or in his wheelchair).  He looked forward to those rides, and he really enjoyed the scenery of their rides around local river areas. 
     Those automobile rides also enabled Lonnie Sr. to privately express his serious frustrations and distress about the way that Leona treated him in a domineering and overbearing way - which caused him a lot of serious emotional stress. 
     During their ride that day in January 1986, Lon's father specifically warned him that a "takeover of the trust estates situation" might occur at some point in the future. 
     Lon's father explained that Leona might try to get Larry to cooperate with her in some way to get Lon removed as a co-trustee from the trust estate management.  Lonnie Sr. explained that he did not want Lon to allow them to accomplish that objective, whenever Leona and Larry attempted to cause that situation to occur.  Lon's father seemed confident that it would occur at some point in the future. 
     Lon knew that he and his wife Janie had done many things that were very helpful to both parents and those actions were also very helpful to brother Larry and his family.
    Consequently, Lon did not believe that there was any real danger of a "trust estates takeover situation" occurring with his mother and Larry - cooperating with each other for that purpose.
     Never-the-less, Lon Jr. realized that his father must have had some reason for seriously warning him about that potential situation.  Lon did not forget about that prophetic conversation. 
Leona's Lawsuit Against Lon Jr.
     Lon Jr. understood that his mother's lawsuit was a really bad idea, but he also realized that she was a very stubborn person that he could not reason with in a responsible manner.  She usually treated him like he was still her teenage son who was obligated to cooperate with her opinions.
     That is why Lon Jr. talked with brother Larry by telephone and tried to get him to talk with Leona about terminating the lawsuit.  Lon Jr. explained to Larry that the lawsuit could cost the Willoughby family members $50,000 or more before the litigation was completed.
     Larry routinely cooperated with any of Leona's demands, and Lon Jr. realized that his mother (Leona) would likely be more inclined to listen to Larry's opinion about this litigation issue rather than listen to Lon Jr's opinion about this litigation issue.. 
     Lon Jr. was the family member who had taken complex estate planning actions in 1982 - 1983 to get the two inter vivos trust agreements established with an attorney in Daytona Beach, Florida. 
     Lon Jr. then took additional co-trustee actions during years 1983 to 1985 to get the Two Trust Agreements amended properly so thet could work much better for the family. 
     By December 12, 1985, Lon Jr. had learned how to take critically important trust agreement funding actions that would ultimately enable the two trust agreements to legally minimize federal estate taxes on the jointly-owned marital estate value for his parent's (about $1,200,000).    
     The federal estate tax law that was applicable at that time could have cost the Willoughby family about $225,000 over the life of both parents, but Lon's careful estate planning actions for his parents had reduced that potential federal estate tax down to zero dollars
     Lon Jr. had also taken responsible co-trustee actions to enable the two trust estates to minimize Florida probate expenses and complexities for the parent's total estate value. 
     Those probate expenses could have eventually been about 8% of the parent's total marital estate value of about $1,200,000 (8% of $1,200,000 = $96,000 - typical Florida probate attorney expenses).    
         Due to Lon Jr's very good estate planning actions, the total probate process expenses for Mr. Willoughby's probate-able estate value in 1987 was about $800 (a real estate appraisal fee for the value of a vacant residential lot, and one necessary attorney fee).     
     Consequently, Lon's estate planning actions with his parents from January 1983 to December 12, 1985 had been very successful, and those actions were obviously very important financial actions for the Lonnie E. Willoughby (Sr.) family. 
     Lon Jr. had been a very competent and responsible trustee of the two Willoughby inter vivos Trust Agreement Estates (the Marital Trust and the Family Trust).  
     Lon realized that his mother (Leona Willoughby) and his brother (Larry Willoughby) did not understand or appreciate the complex and very  beneficial estate planning actions that he had taken for the parents, at substantial cost and difficulty for Lon Jr. (in time and complex efforts over several years). 
     Lon also realized that Leona and Larry did not understand that one major part of the two Trust Agreement assets, a large "second mortgage note" from the sale of the apartment complex, was actually quite risky  because it was subject to fail at some time in the future. 
     Lon realized that the mortgage note might default in the future, and that action would greatly reduce the monthly income for the two trust agreement estates - due to the total loss of income from that "second mortgage note."
     Lon's careful co-trustee actions had tried to responsibly conserve the monthly income being produced in the trust estates by that large "second mortgage note." 
     Unfortunately, that "second mortgage note" did default later, and the Willoughby's had to resume ownership of the apartment complex in DeLand, Florida (that had been sold in January 1985). 
Leona's Income Situation
     Co-trustee Lon Jr. also understood that Leona did not really need more monthly income from the Marital Trust.  Lon knew that his mother's normal monthly income from the Marital Trust and her monthly Social Security income payments were more than sufficient for her routine monthly living expenses.  Lon Jr. also realized that she had direct access to more than 200,000 dollars in her personal bank accounts located in Palatka, Florida. 
     Lon also knew that her very good riverfront home was completely paid for and her like new 98 Oldsmobile automobile was also paid for.  She did not have any expensive medical problems or other unusual expenses.  Leona just had normal living expenses for one person (food, and normal utilities, home insurance, and auto insurance expenses, etc.). 
     Lon Jr. also realized that brother Larry was not knowledgeable about his co-trustee duties and responsibilities.  Larry had not demonstrated any significant co-trustee knowledge with his actions for the two trust estates since the two Trust Agreements began in January 1983
     As shown above, Lon Jr. had been the active co-trustee, and he had taken care of practically all co-trustee actions competently and responsibly.
     The only co-trustee actions that Larry had taken was to sign the two Trust Agreements after they were mailed to him after their inception in January 1983 that designated him as a co-trustee.  Larry also co-authorized the monthly trust income payments that Lon had established for Leona, Larry, and himself as primary beneficiaries of the two trust agreement estates.
     When Lon received mailed notice about the lawsuit against him on March 3, 1989, he communicated with Larry by telephone and tried to persuade him to talk with Leona and quickly terminate the lawsuit. 
     Lon explained that the lawsuit could cost the family $50,000 or more.  That is when Lon learned that Larry wanted the lawsuit to continue against brother Lon as a co-trustee.  
     Leona and Larry and Lon Jr. had no knowledge about litigation complexities and procedures.  They did not have any responsible understanding at that time of the terrible litigation disaster that would begin to occur to the Willoughby family members and the Willoughby family trust estate value due to that foolish lawsuit. 
     They had no practical understanding of the extremely unfair and unethical and outrageously corrupt attorney litigation actions that would be taken against co-trustee Lonnie Willoughby, Jr. in the upcoming litigation process.
     Lon Jr. was not knowledgeable at that time about litigation practices and procedures, and he did not realize that his mother's trust beneficiary Complaint Litigation would set some greedy Florida litigation attorneys loose that would maliciously and ruthlessly try to destroy Lon Jr. in an outrageously unfair, unethical, and corrupt manner.  Lon Willoughby Jr. had no idea that the litigation process would continue for many years. 
     This website department reports some of the unfair, unethical, deceitful and devious criminal-minded litigation schemes and tactics that occurred in the Circuit Court litigation in Putnam County during year 1989 and for many years after that year.
     A one-day Equity Court trial (non-jury trial) occurred on September 8, 1989, and it turned out to be an extremely unfair, unethical, corrupt and fraudulent litigation process where Leona's attorney (plaintiff's attorney) verbally introduced five surprise "ambush" complaint issues into the trial - about complex trust estate planning and/or trust estate management issues.
     The plaintiff's Complaint Pleadings (prepared and filed by the plaintiff's attorney - attorney # 1) had been noticed to co-trustee Lonnie Willoughby, Jr. in South Carolina by USPS mail in March 1989.  The plaintiff's Complaint pleadings identified two specific complaints against co-trustee Lonnie Willoughby, Jr.
Attorney Services Membership
     Co-trustee Lonnie Willoughby, Jr. (Lon Jr. or Lon) had a membership in a national legal services program so he contacted that service to see if they had a recommended attorney in the Putnam County area.  Yes, they had a recommended attorney in Palatka, Florida. 
     Lon promptly contacted that attorney by telephone, and Lon informed him that he was a member of the legal services plan and he needed an attorney to represent him in civil litigation in Putnam County.  Lon explained very briefly about the trust estate litigation case where Lon was the non-resident defendant co-trustee.
     The attorney (attorney # 2) said he would look at the litigation case (at the local courthouse) and get back with Lon soon. 
     He contacted Lon by phone within a few days and said that he had gone to a "bar luncheon" (a luncheon meeting for legal profession members located in Putnam County) where he had been able to talk with the plaintiff's attorney (attorney #1). 
     Attorney # 2 had already decided that he did not want to get involved in the trust estate litigation, but he cautiously warned Lon that the plaintiff's attorney had encouraged him to defend Lon Jr. in the case - but on the verbally agreed basis that he (attorney # 2) would help the plaintiff's attorney cause co-trustee Lonnie Willoughby, Jr. to lose in the case.
     Lon thanked the attorney for that information.  He was very grateful that the attorney had enough integrity to warn him about that potential situation. 
     That possibility came as a shock to Lon Jr.  He had not considered that "competing attorneys" would "cooperate" with each other to deliberately cause a litigant to lose a case.
     WOW!!!  Lon realized that an agreement of that type (between opposing attorneys) would be extremely unfair and unethical and corrupt.
     After thinking about that treacherous situation, Lon decided to try to find an attorney in Jacksonville, Florida (about 65  - 70 miles from Palatka).  He realized that would cause the litigation process to be more expensive because a Jacksonville attorney might need to make several trips to Palatka, Florida to participate in the litigation process.  His travel times would be billable hours
     When Lon contacted a law firm in Jacksonville and tried to explain  briefly what his litigation situation was in nearby Putnam County, the attorney (attorney # 3) quickly interrupted and explained that he could not represent a litigant in Putnam County. 
     When Lon asked why, he explained that he had tried that in the past with litigation cases in other judicial areas (outside of the local Duval County area) and those cases never worked out well for his clients.
     The attorney explained that the judges in other judicial jurisdictions always treated him as if he was an undesirable invader into the judge's local judicial domain, and those situations never worked out well for his clients.     
     Lon thanked the attorney for his helpful information about those judicial domain situations.  Lon was beginning to understand that a judicial domain was a closed operation, only available for local trial attorneys who provided legal services within that judicial domain.    
     Lon had a friend that lived near Daytona Beach, Florida (about sixty miles from Palatka, Florida).  He called the friend by telephone and explained that he was looking for an attorney to represent him in litigation in nearby Palatka, Florida (about 60 miles away).   
Lon asked the friend if he knew any attorneys in the Daytona Beach area.  Yes, he had an attorney friend, and he recommended that Lon contact that attorney.  Lon's friend in the Daytona area looked up the attorney's law firm name and office phone number and gave that information to Lon.
    Lon decided that he would try one more time to retain an attorney that was not a part of the local Palatka attorney domain clubHe called the phone number in Daytona Beach and was able to talk with the recommended attorney briefly. (attorney # 3
     Lon began explaining his civil litigation situation in Putnam County briefly, but the attorney interrupted him and said he could not represent Lon in Putnam County.
     Lon then asked him why?  He said he had tried to represent a client in Putnam County once before, and it turned out badly for his client. 
     He explained briefly that the local judge was not fair and impartial with him as a defense attorney, and the case ended badly for his client. 
     He also explained that he had learned over the years to only litigate in the local Daytona Beach County judicial area.  (The local judicial domain.)
     At that point, Lon realized that he was going to have to retain an attorney that worked in the Putnam County "judicial domain." 
     He then called another law firm in Palatka, Florida and talked with an attorney, and explained briefly what his civil litigation situation was in Palatka, Florida.
     The attorney (attorney # 4) explained that he could probably represent defendant co-trustee Lon Willoughby in the case, but he would need a $10,000 retainer payment upfront to begin that attorney representation.  Lon declined that offer as being too expensive for his litigation situation.
    Lon then called another law firm in Palatka, Florida and talked with an attorney (attorney # 5).   Lon explained his civil litigation situation very briefly.  That attorney was not familiar with trust estate litigation but recommended another local attorney for consideration.  Lon then called that law firm and talked briefly with the recommended attorney.  (attorney # 6)
     Yes, he had some experience with trust estate litigation, and he could probably represent co-trustee Lon Willoughby in that case, but he would need to review the litigation case in the courthouse record.
     When attorney # 6 called Lon later in the week, he explained that he could probably represent co-trustee Lonnie Willoughby in the case, but Lon would need to come to Palatka so they could talk about the family member dispute that caused the lawsuit.
     Lon later traveled the 450 miles to Palatka, Florida and met with the attorney in his office (attorney # 6). His office was across the street from the Putnam County Courthouse. 
     Lon learned that his mother's attorney (attorney # 1) had at one time worked with this attorney in the same law firm in Palatka. 
     They knew each other well, and attorney # 6 was confident that he could represent defendant co-trustee Lonnie Willoughby well in the local litigation case opposing that attorney (attorney # 1). 
     The attorney wanted a $1,000 retainer fee to begin the litigation process.  Lon Jr. signed a legal contract to retain that prominent attorney to represent him as the defendant co-trustee in that civil litigation case. 
     Co-trustee Lon wrote a $1,000 check in the Family Trust's bank account (a local bank in Palatka).  Lon then left Palatka, Florida to drive the 450 miles back to his home in Mauldin, South Carolina. 
     Several weeks later, the two opposing attorneys (attorney # 1 and attorney # 6) scheduled a deposition for the plaintiff (Leona Willoughby) and defendant co-trustee Lonnie Willoughby, Jr. to attend at the local Putnam County Courthouse location.
     Co-trustee Lon Willoughby traveled 450 miles back to Palatka, Florida and participated in that deposition (with a court reporter present to transcribe everything that was said during the deposition of both parties to the lawsuit - Leona Willoughby and Lonnie Willoughby, Jr.). 
     The deposition enabled Lonnie Jr. to meet his mother's attorney (attorney # 1) - who seemed to be a reasonable and sensible person.
      Lon's attorney started the deposition by asking the plaintiff (Leona Willoughby) a series of questions, and she answered all of the questions.  One of those questions asked if she felt that co-trustee Lon Jr. had taken any actions as a co-trustee that were dishonest or unethical?  She answered NO.
     He also asked Leona Willoughby if she believed that co-trustee Lonnie Willoughby, Jr. had mismanaged the trust estates in any way.  She answered NO.
      The plaintiff's attorney (attorney # 1) then asked co-trustee Lonnie  Willoughby, Jr. a series of questions, and he answered all of those questions in a knowledgeable and responsible manner. 
     After the trial that was conducted on September 8, 1989, Lon learned that neither attorney had requested that the court reported make a transcript of that deposition testimony.  Consequently, a transcript of that deposition testimony was not entered into the records of the litigation case, as should have been done.
     Presumable, Lon's attorney came to trial prepared to defend co-trustee Lonnie Willoughby, Jr. against the two complaint issues that were noticed (identified clearly) in the plaintiff's Complaint Pleading
     During the trial, the plaintiff's attorney (attorney # 1) began introducing surprise "ambush" complaint issues that had not been noticed in the plaintiff's Complaint Pleading.  The plaintiff's attorney gradually introduced five surprise "ambush" complaint issues as the trial progressed.
     Consequently, co-trustee Lon Jr. had not been noticed (notified) properly about the additional surprise complaint issues that the plaintiff's attorney introduced into the trial litigation as the trial was taking place. 
     Those additional complaint issues should have been introduced (noticed) in the plaintiff's pleadings, or they should have been introduced during the discovery process that occurred weeks before the trial date. 
     NOTES:  Lon Willoughby now understands that the discovery process is a routine standard process (in Florida litigation) that is supposed to enable both sides of the litigation (plaintiff and defendant) to discover all of the complaint issues for litigation and also discover an overview of the evidence that the plaintiff intends to present against the defendant during the upcoming trial. 
     The deposition testimony for the plaintiff (Leona Willoughby) and defendant co-trustee Lonnie Willoughby, Jr., taken many weeks before the trial, was a very important part of that discovery process.
     The routine Florida discovery process is supposed to enable the opponents (plaintiff and defendant) to responsibly consider and decide whether or not they can agree to settle the complaint issues before trial and avoid the additional complexities and much greater expenses of a trial process. 
     Lon understands these discovery issues now, but he did not understand any of this before the trial that was conducted on September 8, 1989
     His "defense attorney" did not explain anything to Lon about discovery, and he did not explain anything to Lon about what he should anticipate in the upcoming trial.   
     If co-trustee Lon Jr. had been noticed (notified) properly about those additional five complaint issues during the discovery process, he would have realized that he needed to arrange for testimony during trial by a trust estate planning and trust estate management expert attorney.
     Lon Jr. probably could have located such an expert attorney in nearby Jacksonville, Florida (65 to 70 miles distance) to participate in the trial as an expert witness for defendant co-trustee Lonnie Willoughby, Jr.  However, Lon Jr. was not noticed about those additional complaint issues until the trial was in progress on September 8, 1989
     Defendant co-trustee Lon Willoughby, Jr. was ruthlessly denied basic "due process of law legal standards" about those surprise complaints.
      Prior to trial, Lon knew that he had been a competent and responsible co-trustee, and he was confident that he had not done anything wrong as a co-trustee, as alleged in the plaintiff's Complaint.  The plaintiff's Complaint did not claim that there was any mismanagement by the defendant.
     Defendant co-trustee Lon Willoughby, Jr. was confident that his personal testimony at trial could defend him responsibly about the two complaints that were noticed in the plaintiff's Complaint Pleading
     Over the years prior to trial, Lon had learned that trials are not supposed to allow any "smoking gun issues" (surprise "ambush" complaint issues).
      Co-trustee Lon Jr's "defense attorney" was obviously a very intelligent person, and he had explained to defendant Lon Jr. that he had more than 20 years experience as a Florida trial attorney. 
     He was apparently a prominent attorney in the Palatka area (probably the most prominent attorney in Putnam County), and Lon was confident that his "defense attorney" would ensure that he would get a fair and responsible trial process.
     During the trial, the defense attorney objected four times to the plaintiff's attorney's verbal actions of bringing surprise complaint issues into the trial. 
     The defense attorney's first objection about a surprise complaint issue was "that is not why we are here today." 
     The trial court judge immediately denied each of his objections about the introduction of surprise complaint issue into the trial. 
     The circuit court judge required co-trustee Lonnie Willoughby, Jr. to give testimony about each surprise complaint issue when it was introduced during the trial.  The surprise complaints were about trust estate planning issues and trust estate management issues that were several years old - some of them were four or more years old. 
     That unfair and unethical judicial action was taken even though defendant Lonnie Willoughby, Jr. had been denied "due process of law legal standards" about being notified about those issues prior to trial, in time to prepare his defensive arguments (or retain a trust estate expert attorney witness to testify on his behalf about trust estate planning and management issues - issues contained in the surprise complants). 
     Some of the surprise complaint issues were about trust estate planning issues that had occurred prior to December 12, 1985 (about four years before the trial on September 8, 1989).  Some of the surprise complaint issues were about trust estate management issues that had occurred after December 12, 1985.  
     Lon had not gone back and recovered from storage those old records.  He had not reviewed his old records of those complex trust development events and old trust estate management issues before the trial because he had not been noticed that there would be additional complaint issues introduced during the trial about those old trust administration records.
     Defendant co-trustee Lon Willoughby, Jr. did not know at that time that the Florida Supreme Court had issued a case law decision years before that strictly prohibited surprise complaint issues being presented during trial, unless both sides (plaintiff and defendant) clearly agreed to litigate about those specific additional surprise complaint issues during a trial. 
     Many months after the trial, Lon discovered that critically important landmark judicial decision while he was doing important legal research work while he was developing an appeal case to the Supreme Court of the United States.  The Florida Supreme Court case decision established a mandatory requirement standard for all litigation trial courts in Florida.
     During the trial conducted on September 8, 1989, the trial court judge surely knew about that relevant mandatory case law decision, and the plaintiff's attorney surely knew about that mandatory case law decision, and Lon's very smart and very knowledgeable "defense attorney" surely knew about that mandatory case law decision
     However, with four objections to the introduction of surprise complaint issues into the trial, the "defense attorney" did not remind the trial court judge about that landmark mandatory case law decision.
     The trial court judge had a duty to be aware of that case decision and to conduct the trial in full compliance with that mandatory decision
     The "plaintiff's attorney" also had a duty to be aware of that case decision and to conduct trial litigation in full compliance with that mandatory decision 
     Lon's "defense attorney" also had a duty to ensure that the trial litigation was conducted in full compliance with that mandatory decision.
     It is very important for "qualified visitors" to understand that a mandatory case law decision by the Florida Supreme Court was "conveniently ignored or overlooked" by both of the "opposing" attorneys and by the circuit court judge. 
     That critically important situation illustrates clearly how extremely unfair, unethical, and corrupt trial court litigation can be with educated, trained, and experienced members of the self-appointed "elitist and aristocratic" legal profession.  (attorneys, lawyers, and judges)
     The plaintiff's attorney (attorney # 1) introduced those five surprise "ambush" complaint issues in a deceitful, unfair, and unethical effort to show that co-trustee Lonnie Willoughby, Jr. had "mismanaged" the Marital Trust Estate. 
     Plaintiff Leona Willoughby "cooperated" with that trial strategy and tactic in any way that she could, but her previous deposition testimony  stated that co-trustee Lon Jr. had not mismanaged the trust estate
     Lon realized during the trial that the plaintiff's deposition testimony should have been used to impeach some of the plaintiff's dishonest testimony during the trial.
     When Lon asked his "defense attorney" after the trial why he didn't try to impeach plaintiff Leona's dishonest testimony using her deposition testimony, the attorney said "the judge knows she was lying."
     After the trial, Lon learned that a transcript had not been made for that deposition testimony (by request of either attorney - attorney # 6 or attorney # 1).  They both failed to request the court reporter to make a transcript of that very important deposition testimony.
     Because the transcript was not made and filed in the case records for the litigation, Lon's "defense attorney" was not able to use that "missing transcript" to impeach some of plaintiff Leona Willoughby's dishonest and misleading testimony during the trial. (Testimony that directly contradicted some of her deposition testimony.)
     Therefore, Lon's "defense attorney" could not defend co-trustee Lon Willoughby, Jr. responsibly during the trial about some of plaintiff Leona's  misleading and dishonest testimony during the trial.
     That transcript situation is another illustration of how the two "competing" attorneys had "cooperated" with each other to deceitfully "ambush" defendant co-trustee Lonnie Willoughby, Jr. during trial in an extremely unfair and unethical and fraudulent manner.
     Lon Jr. also learned many months later that the four objections that his defense attorney presented during the trial were "weak objections" that would not protect defendant co-trustee Lon Jr. well in his later appeal of the FINAL JUDGMENT rendered for the one-day trial.
      Lon Jr. also learned months after the trial that none of the defense attorney's four objections during the trial had explained how defendant co-trustee Lonnie Willoughby was being harmed or injured (in any way) by the introduction of surprise "ambush" complaint issues
     Co-trustee Lon Jr. had been ruthlessly denied fundamental "due process of law standards" because he had not been noticed properly in the plaintiff's pleadings about all complaint issues, and he was not noticed properly during discovery proceedings about those five additional plaintiff complaint issues
     That unfair and unethical surprise complaint situation had denied defendant co-trustee Lon Willoughby, Jr. a fair and responsible opportunity to prepare defensive argument for each of those five surprise complaint issues.
     He had also been denied a fair opportunity to retain a trust estate expert attorney to testify on his behalf during the trial, and that issue turned out to be a critical mistake issue during the one-day trial.
     The very intelligent, prominent "defense attorney" had more than twenty (20) years of Florida litigation experience, but he pretended during the trial that he did not know how to object properly and responsibly to surprise "ambush" complaint issues against his client.    
     The FINAL JUDGMENT document rendered for the trial (weeks later)  showed that the trial judge ruled in co-trustee defendant Lonnie Willoughby, Jr's favor on the two Complaint issues noticed properly in the plaintiff's Complaint Pleadings
     However, the circuit court judge also ruled improperly against defendant co-trustee Lonnie Willoughby, Jr. on three of the five surprise "ambush" complaint issues
     The Final Judgment Order removed both co-trustees from both Trust Agreement Estates, and also appointed a local CPA (certified public accountant) as the successor trustee for both Trust Agreement Estates. 
     There were two trust estates for the Willoughby family - a Marital Trust Estate for plaintiff Leona Willoughby where she was the only beneficiary and the Family Trust Estate with Larry and Lonnie Jr. as the primary beneficiaries. 
     The Family Trust Estate was not actually involved in the litigation process because neither beneficiary had filed a legal complaint about how the Family Trust Estate had been operating or managed.
     The CPA that the circuit court judge appointed as the successor trustee for both trust estates had been a witness for the plaintiff during the trial.  He had previously prepared the annual Federal Form 1040 tax reports for Lon Jr's parents for several years (after Lon Jr. had personally selected him to do his parent's annual income tax return accounting work). 
     The CPA had also prepared the final federal estate settlement tax report for deceased Lonnie Willoughby (Sr.) in 1987.  That federal tax report showed that there was no federal estate tax due on the taxable estate value for the deceased Lonnie Willoughby (Sr.). 
    That same CPA came to trial as a witness for plaintiff Leona Willoughby, and that situation was not disclosed to defendant co-trustee Lonnie Willoughby, Jr. during the discovery process (as it should have been). 
    During the trial, the CPA testified about some of the trust estate surprise "ambush" complaint issues when he answered questions about those complaint issues - questions that were asked by the plaintiff's attorney. 
     That situation proved clearly that the CPA's participation in the trial was a pre-planned scheme to "ambush" defendant co-trustee Lonnie Willoughby, Jr. during trial with surprise complaint issues about the two Willoughby trust agreement estates (the Marital Trust Agreement Estate and the Family Trust Agreement Estate).
     It is very important to understand that the CPA was not considered an "expert witness" about the complex trust estate planning and administration issues that were introduced during trial as surprise complaint issues.  The CPA made no pretense of being knowledgeable about those specific trust estate planning and management issues.
    His testimony about those trust estate issues always contained the easy disclaimer "I think so."  He was not confident about his answers to questions about complex estate planning issues or complex estate management issues - he clearly was not an expert about those issues
     The CPA acknowledged during his testimony that his understanding about those trust estate planning and management issues came from his previous verbal telephone communications with co-trustee Lonnie Willoughby, Jr. (while the CPA was preparing the final Federal Tax Report for deceased Mr. Willoughby's estate tax status during year 1987).
     The CPA's testimony during trial was then challenged by defendant co-trustee Lonnie Willoughby Jr's testimony about estate planning and management issues because Lon Willoughby, Jr. recognized that some of the CPA's answers or statements about the surprise complaint issues were flat out wrong information. 
     The CPA, as a witness for the plaintiff, had been questioned by the plaintiff's attorney about those issues in ways that would offer some support for the surprise "ambush" trust mismanagement issues
     Co-trustee Lon Jr's "defense attorney" did not question the CPA hardly at all about those issues.  The "defense attorney" apparently had no significant knowledge about the complex trust estate planning and administration and management issues that had been injected into the trial as surprise "ambush" complaint issues
     In addition to that very serious defense deficiency, defendant co-trustee Lon Willoughby's "defense attorney" gave him very little opportunity to defend himself during those specific trial issues.
     NOTE:  It is important to explain at this point that trial attorneys and CPA's are not generally knowledgeable about complex trust estate planning or trust estate administration or management issues. 
     That is highly specialized knowledge that they have not been educated about, and they usually have no experience with.  Generally speaking, that specialized knowledge is only known competently by attorney's who specialize in trust estate planning and trust estate administration work.
     Co-trustee Lonnie Willoughby, Jr. had educated himself about those complex trust estate planning issues during year 1985 because he had been unable to find a nearby Florida attorney that he trusted to help him develop amendments to the two inter vivos trust agreements that would enable the two co-trustees to take additional trust estate planning actions for his parent's complex jointly-owned real estate mortgage note values. 
     Consequently, Lon knew, beyond a reasonable doubt, that the CPA's testimony about the surprise trust estate planning and management complaint issues was misleading and inaccurate testimony that was obviously intended to help support the "ambush" complaints scheme that was being introduced into the trial by the plaintiff's attorney (attorney # 1). 
     Defendant co-trustee Lonnie Willoughby, Jr. explained during his trial testimony that the CPA's testimony was not correct about certain trust estate issues (surprise "ambush complaints" issues). 
     The CPA also gave perjured testimony about plaintiff Leona's income, by falsely indicating that she needed more income from the Marital Trust Estate (where she was the sole beneficiary) than the income that she had normally received monthly.  
     Co-trustee Lon Jr. knew that Leona had previously been getting all of the monthly income produced in the Marital Trust Estate - before co-trustee Larry Willoughby's extremely unfair and irresponsible co-trustee actions caused a dispute (that was later used as the basis for Leona's lawsuit against her older son Lon Willoughby, Jr.).
     After the one-day trial, Lon Jr. quickly obtained copies of the last two years of Federal Form 1014 tax reports from his mother.  Those tax reports had been prepared by the CPA who gave testimony during the trial about those two income tax years. 
     Those two tax reports showed that Leona had thousands of dollars more income per year than the CPA had testified about during the trial, and the two tax reports also showed that she had been giving about $5,000 per year to charitable organizations. 
     It was therefore clear to co-trustee Lon Jr. that the CPA's testimony during the trial about Leona's income issues was perjured testimony.  
     The CPA had attempted to influence the trial court judge to be strongly opposed to defendant co-trustee Lonnie Willoughby, Jr. by indicating that his disputed co-trustee actions had denied his mother adequate income for her normal income needs.
     The CPA's testimony during trial about surprise "ambush" trust estate issues should not have been allowed because he was not qualified as an "expert witness" about trust estate planning and management issues. 
     The judge improperly allowed the CPA to give testimony about those issues during trial.  However, his improper "non-expert" testimony should not have influenced the outcome of the trial. 
     The subsequent FINAL JUDGMENT indicated that the trial judge  allowed the CPA's non-expert testimony about three of the five surprise ambush complaints to influence the judge - because the trial judge ruled against defendant co-trustee Lonnie Willoughby, Jr. on three of those five surprise complaint issues
     Defendant Lon Jr. had given competent and responsible testimony about those surprise "ambush" issues, as best he could from memory of events that were several years old.
    The CPA and defendant co-trustee Lonnie Willoughby, Jr. were the only witnesses to present testimony about the five surprise complaint issues.
An Extremely Corrupt Trial
      After the trial, co-trustee Lon Jr. gradually realized that his "defense attorney" had knowingly and willfully betrayed him badly during the trial. 
     The trial was an extremely unfair and unethical disgustingly fraudulent scam proceeding where the defense attorney had effectively "cooperated" with the opposing plaintiff's attorney to deliberately cause defendant co-trustee Lonnie Willoughby, Jr. to lose an Equity Court trial case that should have been easy for the defense attorney to win for defendant co-trustee Lonnie Willoughby, Jr. 
     That was the type of unfair and unethical litigation situation that attorney # 2 had very briefly warned Lon Jr. about by telephone months before the trial.   
     Lon Willoughby has shown herein that the initial litigation process was conducted in an extremely unfair, unethical, corrupt and fraudulent manner
     Attorney # 2 had enough attorney integrity to warn Lon Jr. about that potential situation, but he did not have enough attorney integrity to responsibly represent defendant co-trustee Lonnie Willoughby during the litigation and prevent that unethical litigation situation from occurring.
     Lon Willoughby understands now that the judicial domain situation in Putnam County was so unfair and so unethical and so disgustingly corrupt that attorney # 2 probably realized that he could not afford to be honest and responsible as a "defense attorney" for co-trustee Lonnie Willoughby, Jr. because the attorney realized that he would have to continue working as an attorney in that corrupt judicial domain after the trial was over. 
     Attorney # 2 probably realized that he would have to continue litigating in the local Putnam County courts with unfair, unethical, and corrupt local judges, and if he opposed their corrupt judicial actions in a serious way, his attorney career in that judicial domain (and likely in the entire state of Florida) could be severely injured. 
     His career as an attorney could be effectively damaged severely in the USA.  Lon Jr. realizes that's how unfair, unethical, and corrupt litigation situations can be in courts in the United States of America.
     After years of litigation experiences, Lon Willoughby realizes that judicial systems in the entire USA are probably controlled and corrupted to that extreme extent.  Trial attorneys are likely victims of corrupt judges, as shown below. 
Lon's Appeal Actions
     Lon Willoughby, Jr. timely appealed the extremely unfair and unethical FINAL JUDGMENT rendered for the case.  He had to quickly learn how to file a Notice of Appeal, pay the local appeal filing fee, and then also file his Notice of Appeal in the Fifth District Court of Appeal in Daytona Beach, Florida (about 60 miles away) and simultaneously pay that court's appeal filing fee. 
     Those litigation actions had to be taken in a timely manner and Lon Jr. had to quickly learn how to take those actions pro se (acting as his own attorney). 
     After he completed those litigation actions successfully, he had a reasonable amount of time in which to locate and retain a different attorney to represent him in his appeal case.  He retained an attorney to represent him in his appeal case that was located in Daytona Beach, Florida - where the appellate court is located.
     Normally, an appellant would want his "defense attorney" to represent him in an appeal case because that attorney is already familiar with a lot of very important information about the trial court litigation. 
     However, Lon did not ask his "defense attorney" to represent him in his appeal case because Lon had learned that the attorney had knowingly and willfully represented co-trustee Lon Jr. in a deceitful incompetent and irresponsible corrupt manner during the trial. 
    That "defense attorney" had also failed to represent defendant co-trustee Lonnie Willoughby, Jr. responsibly in very important post-trial litigation actions - actions that Lon Jr. had requested that he accomplish,  and he refused to take those critically important litigation actions
     Consequently, Lon Willoughby, Jr. did not ask his "defense attorney" to represent appellant Lonnie Willoughby, Jr. in the appeal case that he planned to file within the 30 days time limit. 
     That situation placed appellant Lonnie Willoughby, Jr. in a very bad position because he had to retain a new attorney to represent him in the appeal case.  The new attorney had no knowledge at all about the entire litigation process in the trial court.  He would only have a copy of the 267 page trial transcript to report what happened in the trial on 9/8/1989
     Lon's appeal attorney would have many litigation billable attorney hours just to get a responsible understanding of the main argument issues that should be presented in appellant Lonnie Willoughby, Jr's initial appeal legal brief. 
     Lon's "defense attorney" would have already had that kind of trial action knowledge, but he could not represent Lon Willoughby in the appeal because Lon Jr. now realized that his trusted "defense attorney" had knowingly and willfully betrayed him badly during the trial court litigation (just as attorney # 2 had warned him about - months before the trial). 
     The "defense attorney" (attorney # 6) had also refused to represent defendant Lonnie Willoughby, Jr. responsibly in very important post-trial actions. (Litigation actions after the trial.)  Lon Jr. had to quickly learn how to take those very important post-trial litigation actions in his pro-se status (without attorney assistance).
     It is important to remember that those were attorney betrayal situations that attorney # 2 had cautiously warned defendant Lon about after the bar luncheon where he had talked with the plaintiff's attorney (attorney # 1). 
     Attorney # 1 was also a prominent attorney in the Putnam County judicial domain, and he apparently convinced attorney # 2 that the case against non-resident co-trustee Lonnie Willoughby, Jr. had already been decided with the local judge (to defeat the co-trustee - months before the trial was conducted).  This is a very important indication of how extremely unfair, fraudulent, and corrupt trial court civil litigation can be.
Appeal Litigation
     Appellant Lonnie Willoughby, Jr. knew nothing about appeal litigation practices and procedures, and the appeal attorney that he had retained did not ask him what he thought the appeal argument issues should be in his initial appeal brief
     Lon tried to discuss with the retained appeal attorney some of his disappointments in the way the trial court litigation had been conducted, and he explained how he had been ambushed at trial with five surprise complaint issues about trust estate planning and management issues.
    The initial appeal brief that the attorney filed for Lon's appeal showed that the arrogant know-it-all attorney had paid no responsible attention to Lon Willoughby, Jr's expressed opinions about the unfair and unethical trial court actions.
     When Lon reviewed the appeal brief that had been filed by his appeal attorney, Lon did not see how he could possibly win that appeal with the argument issues presented for him. 
     The prominent attorney in Palatka, Florida that had represented plaintiff Leona Willoughby in the Putnam County trial court also represented her in Lon Jr's appeal case. 
     Subsequent appeal events showed that Lon's appeal attorney knowingly and willfully sabotaged Lon Jr's initial appeal brief argument issues.  He had refused to responsibly expose in appellant Lonnie Willoughby, Jr's initial appeal brief that defendant co-trustee Lonnie Willoughby, Jr. had been unfairly and unethically ambushed badly during trial with five verbally introduced surprise complaint issues
     Lon Jr's review of the initial brief prepared and filed in the appeal case by his appeal attorney showed that the attorney had deceitfully and deceptively betrayal appellant Lonnie Willoughby, Jr. 
     The appeal attorney had failed to present competent and responsible argument issues about the way that defendant co-trustee Lonnie Willoughby, Jr. had been unfairly and unethically "ambushed" during trial with five surprise complaint issues about complex trust estate planning and management issues.  He had not been allowed a fair opportunity to retain the services of an estate planning expert attorney to testify on his behalf about those additional "surprise" complaint issues.
     Lon's appeal attorney also failed to report that the CPA that testified about those surprise complaint issues during trial was not an "expert witness" and his testimony about those complex trust estate issues should not have been allowed into the trial by the trial court judge.
     At that time, Lon had not learned about the Florida Supreme Court case law decision that prohibited surprise complaint issues being introduced during a trial procedure.  However, Lon's appeal attorney surely knew about that mandatory landmark case decision
     Any competent, responsible trial attorney (or appeal attorney) in Florida would have surely been informed about that very important landmark mandatory case law decision.
     If a transcript had been made for the "Leona - Lon deposition testimony" and properly filed in the case litigation records, as should have been done, the transcript document would have been included in the Record on Appeal for Lon Jr's appeal case. 
     An honest and responsible appeal attorney (for appellant Lon Jr.) would have been able to use that deposition transcript to show how the plaintiff (Leona) had given dishonest testimony during the trial by helping her attorney present surprise "mismanagement complaints" against Lon Jr. 
     However, without that deposition transcript, Leona could make statements during trial testimony that conflicted with her testimony in that deposition, and there would not be a good way for Lon's defense attorney to impeach her trial testimony about those issues during the trial. 
     He could have stated that her trial testimony was in conflict with her deposition testimony, but the "defense attorney" did not even do that. 
     The "defense attorney" could have also challenged the plaintiff's attorney to admit during the trial that Leona's deposition testimony had clearly stated that she had no "mismanagement" complaint against co-trustee Lon Jr.  However, the "defense attorney" also failed to take that defensive action during the trial.
     Obviously, Lon's retained appeal attorney was not able to use the "missing" deposition transcript during appellant Lon Jr's appeal case regarding the surprise "ambush" mismanagement complaints.
     Those litigation events showed that the two opposing attorneys (plaintiff's attorney and defendant co-trustee Lon Jr's defense attorney) had knowingly and willfully "cooperated" with each other to deliberately fail to get a transcript record developed for that very important "discovery" deposition testimony.
     That "missing transcript" could have also helped appellant Lon Willoughby win that appeal case if it had been used properly by Lon's retained appeal attorney. 
     But you see, the two competing attorneys in the trial court case had "cooperated" with each other to also make it more difficult for Lon Willoughby to win an appeal case for the trial court's Final Judgment.
     Appellant Lon Willoughby then insisted that his retained appeal attorney withdraw from the appeal case because of his incompetent appeal attorney actions
     Appellant Lon Willoughby then attempted to amend his appeal brief argument issues to show that he had been ambushed badly with five surprise complaint issues during trial.
     Lon also wanted to show that the CPA witness was not an "expert witness" about trust estate planning issues and his testimony during trial should not have been allowed.  Lon's "defense attorney" had objected to his testimony on that specific basis, but the trial court judge overruled that objection and allowed the CPA's testimony anyway. 
     Appellant Willoughby also wanted to show that the CPA had given perjured testimony during trial about the plaintiff's income for two tax years, as proven by the Federal Form 1040 Tax Report records that Lon had obtained from his mother (the plaintiff in the trial court case).
No Amendments To Initial Appeal Brief
     The appellate court refused to allow appellant Lon Jr. to amend his appeal argument issues in any manner - because the opposing party had already filed their responsive appeal brief. 
     Consequently, Lon's appeal attorney's deceitful and deceptive "cooperative actions" with the opposing appeal attorney caused appellant Lon Willoughby, Jr. to lose that very important appeal case
Florida Landmark Case Law Decision
     One very important illustration of the deceitful and deceptive sabotage of Lon's appeal argument issues was the fact that Lon's appeal attorney did not cite and use the Florida Supreme Court's landmark case law decision that strictly prohibited surprise complaint issues being introduced for the first time after the trial was in progress. 
     The appeal attorney surely knew about that landmark mandatory case law decision, but he did not cite and use that relevant case law decision in Lon's appeal.  He could have easily exposed the unfair and unethical litigation scheme and tactic that had been used to ruthlessly "ambush" co-trustee Lon Willoughby during the trial with five surprise complaint issues.  
     Lon's appeal attorney had refused to make an argument issue about the unfair and unethical surprise "ambush" complaint issues - as appellant Lon Willoughby had strongly recommended. 
     That one Florida Supreme Court case, cited and used properly, would have enabled appellant Lon Willoughby to win that appeal case.  He would have then gotten a revised FINAL JUDGMENT for the case that would have shown that defendant co-trustee Lonnie Willoughby, Jr. had been denied fundamental due process of law standards and the FINAL JUDGMENT would have been modified to show that co-trustee Lonnie Willoughby, Jr. had won the trial court litigation contest.
     It is also very important to understand that the three appellate court judges, that reviewed the appeal arguments from both sides of the appeal, also had a duty to recall and use that mandatory Florida Supreme Court case law decision.  They surely knew about that landmark mandatory case law decision
     Competent and honest appellate court judges would have enabled appellant Lonnie Willoughby, Jr. to win that appeal, even with the deceptive deficient and incompetent argument issues presented by appellant Lonnie Willoughby, Jr's appeal attorney.
     You see, the true purpose of a trial court litigation process is to provide fair and ethical justice as the outcome of the litigation process.  Participants on both sides of the trial litigation and the trial court judge have ethical responsibilities to do whatever is needed to provide a fair and ethical justice outcome for the trial litigation. 
     Those same ethical justice standards apply in appellate court litigation for attorneys and for appellate court judges. 
     But you see, what is supposed to happen in a litigation process (fairness, impartiality, and dispensation of responsible justice) and what actually happens in the litigation process can be very different, as happened in Lon Jr's appeal case and as happened in the trial court litigation below. 
      In Lon Willoughby's appeal case, the three appellate judges had the official trial transcript in the official Record on Appeal documents.  (267 pages in two volumes that cost Lon Willoughby about $1,350 dollars for that transcript record.) 
     The primary purpose of that transcript record was to have it available if an appeal case was filed after the trial court litigation.
     The three appellate court judges certainly knew about the Florida Supreme Court's landmark case law decision that strictly prohibited surprise complaint issues being presented during a trial proceeding.     
     Did the three appellate court judges make a responsible effort to review the trial transcript and see how the trial had been conducted?  Obviously not!!! 
     If the three judges had made a responsible effort to review just the first 40 pages of the trial transcript, they would have learned about the unfair, unethical, and extremely corrupt litigation scheme and tactic used by the plaintiff's attorney to ruthlessly "ambush" defendant co-trustee Lonnie Willoughby, Jr. with surprise complaint issues.
    If the three appellate court judges had reviewed the first part of the transcript for the trial, they would have learned that surprise "ambush" complaints were introduce during the trial, and the "defense attorney" objected to those surprise complaints being introduced into the trial proceeding.  Therefore, it was very clear that the defendant had not agreed to litigate those surprise complaints.
     It is also important to understand that trial transcripts are prepared in a format that is similar to double spaced lines.  Therefore, 30 pages of a transcript is similar to reading about 15 pages of single-spaced lines.
     You can now see why it was critically important for Lon Jr's appeal attorney to make a very clear argument issue about those unfair and unethical and corrupt trial court surprise complaints "ambush" actions - as the major argument issue in appellant Lon Willoughby's initial appeal brief arguments.  
     That critically important argument issue would have clearly brought that extremely unfair and unethical trial court scheme and tactic to the attention of the three appellate court judges. 
     The three judge panel would have then been prompted to carefully review the trial transcript's record of the plaintiff's attorney's unfair and unethical scheme and tactic of "ambushing" defendant co-trustee Lonnie Willoughby, Jr. during trial with surprise complaint issues
     The Florida Supreme Court's case law decision that strictly prohibited the scheme and tactic of presenting surprise complaint issues during a trial would have enabled the three judges to rule in appellant Lonnie Willoughby, Jr's favor for his appeal case.
     They would have then ordered the trial court judge to reconsider the Final Judgment, delete the judge's ruling against defendant co-trustee Lonnie Willoughby on three surprise complaint issues (with testimony by a non-expert CPA witness) and that judicial action would have enabled defendant co-trustee Lonnie Willoughby to win the trial court case.
     But you see, Lon's appeal attorney betrayed him deceitfully and deceptively by "cooperating" with the opposing appeal attorney (for Leona Willoughby). 
     Lon's appeal attorney failed to make a major appeal argument issue in appellant Lon Willoughby's initial appeal brief about the outrageously unfair and unethical "ambush" during trial with five surprise "ambush" complaints about complex estate planning and management issues. 
     The entire appeal process was a fraudulent sham proceeding, from beginning to the end, and it cost Lon Willoughby a lot of money, and a lot of time, and a lot of effort, and a lot of severe emotional stress. 
     Lon was so disappointed in the appeal attorney's deficient attorney actions that Lon refused to pay the attorney anything for his extremely deceitful and deceptive corrupt and fraudulent attorney services. 
     The appeal attorney made no effort to collect thousands of dollars for his appeal actions from appellant Lon Willoughby.  He knew that he had betrayed his client and had willfully caused him to lose an appeal that the attorney should have won easily.
     That disgusting appeal situation is another illustration of how "opposing attorneys" will cooperate with each other to prevent a litigation process from exposing unfair, unethical, deceitful, and fraudulent litigation actions by members of the legal profession during a trial.
Attorney Duty and Responsibility
     It is important to understand that trial attorneys and appeal attorneys are usually trying to make the legal profession look good and responsible, even when it is obviously unfair, unethical, and corrupt.  If an attorney needs to betray a client badly in order to accomplish that objective, that will very likely will be done. 
     It is also very important to understand that judges (trial courts and appellate courts) will likely find ways to punish attorneys who responsibly expose how litigation actions were very unfair and unethical and corrupt.   Exposing those actions is very dangerous territory for trial attorneys or appeal attorneys.
     You will learn herein later how Lon's appeal attorney's deceitful and deceptive appeal actions helped other Florida attorneys wreck Lon Willoughby's career and his life for 19 years.
Betrayed Again
     Lon had been betrayed again by a member of the Florida legal profession, and he was determined to not let that happen to him again.  In any future litigation, he would represent himself in his pro se capacity (a litigant who chooses to represent his own legal arguments - without assistance of an attorney). 
     Lon realized that he was not an educated and trained and experienced attorney, but he also realized that he now knew how to represent himself much better than either attorney that he had retained had represented him (in the trial court case and in his first appeal case).


Second Litigation Report
Background Info: Lon's First Trial
     NOTE:  This report presents some information that has already been reported in this department.  In time, Lon Willoughby will try to integrate these two litigation reports to remove any duplicate information, but he has not had time to accomplish that very complex and time consuming task. 

     In his first Florida trial court case, defendant co-trustee Lonnie Willoughby, Jr. (a resident of Greenville County South Carolina) was forced into litigation by a disgruntled trust agreement estate beneficiary who lived in Putnam County Florida with litigation in the Putnam Count Courthouse located in Palatka, Florida. 

     Defendant co-trustee Lonnie Willoughby had considerable difficulty in obtaining an attorney to represent him in that litigation, but he finally retained a prominent local attorney in Palatka who had more than 20 years of litigation experience in Florida courts. 

     During the one day Equity Court trial (bench trial - jury not allowed) conducted on September 8, 1989, the plaintiff's attorney apparently understood that he had a very weak complaints case against defendant co-trustee Lonnie Willoughby. 

     The 267 page trial court transcript record shows that the attorney came to trial prepared to ambush the defendant during trial by introducing five surprise complaint issues that had not been noticed in the plaintiff's pleadings and that had not been brought forth during discovery

     Discovery is the standard litigation procedure for the plaintiff's attorney to disclose to the defendant's attorney all complaint issues and disclose the evidence that supports those complaint issues - prior to going into a trial procedures.  In this routine process, the case may be decided ahead of a trial procedure and may avoid the additional attorney times and expenses of a trial.

     During the one-day trial that occurred, the plaintiff's attorney introduced five surprise ambush complaint issues against co-trustee Lonnie Willoughby, Jr. 

     The defense attorney objected four different times during the trial to surprise complaint issues being introduced in the trial against his client (co-trustee Lonnie Willoughby).  In his first objection, he stated "that is not why we are here today."

     The trial court judge, a circuit court judge (the highest level trial court judge in Florida), immediately denied each objection presented by the defense attorney.  The judge required that defendant co-trustee Lonnie Willoughby give testimony about each surprise complaint issue raised by the plaintiff's attorney. 

     The plaintiff's attorney also brought in a local Certified Public Accountant (CPA) to giving supporting testimony for the plaintiff about the surprise complaint issues, as well as other trial issues. 

     That situation proved conclusively that the surprise ambush complaints scheme was a pre-planned ambush scheme

     However, the CPA was not brought in as an expert witness about trust estate issues, because he was not an expert about any of the surprise complaint issues.  In fact, his trial testimony disclosed that he had very little knowledge or understanding about the surprise complaint technical trust administration issues.  The fact that he was not an expert witness meant that his testimony should not have had any influence on the trial court judge. 

     The surprise complaint issues were about actions that co-trustee Lonnie Willoughby had taken back in 1985, about four years before the trial. 

     Even though he had not been noticed properly about the five surprise complaint issues before trial, and he had not had a fair and responsible opportunity to go back four years and review those five complaint issues in his records related to those issues, defendant co-trustee Lonnie Willoughby, Jr. was able to remember enough about his actions regarding those five issues that he was able to give some responsible testimony about each of those issues. 

     He also testified that the CPA's testimony about those surprise issues was incorrect information.  

     Weeks later, when the FINAL JUDGMENT for the case was rendered, the trial court judge ruled in defendant co-trustee Lonnie Willoughby's favor on the two complaint issues that had been notices in the plaintiff's complaint pleading, but the judge improperly ruled against co-trustee Lonnie Willoughby on three of the five surprise complaint issues

     The trial judge removed co-trustee Lonnie Willoughby, Jr. and his younger brother, Larry Willoughby, as the other co-trustee of the two Willoughby trust agreement estates, the Marital Trust Estate and the Family Trust Estate. 

     The FINAL JUDGMENT also selected the incompetent CPA witness as the successor trustee of both of the Willoughby trust agreement estates. 

     It is important to note here that the Willoughby Marital Trust Estate was involved in the litigation, but the Willoughby Family Trust Estate was not actually involved in the litigation process. 

     No beneficiary of the Willoughby Family Trust Estate had filed a complaint against co-trustee Lonnie Willoughby, Jr. so it was not proper for the trial court judge to remove co-trustee Lonnie Willoughby, Jr. and brother co-trustee Larry Willoughby as the two co-trustees of the Willoughby Family Trust Estate. 

     The trial court judge's actions during the litigation case proved that he was incompetent to adjudicate those complex trust estate administration issues.  He obviously knew nothing about trust estate administration or trust estate federal taxation issues.  Furthermore, the trial court judge should not have allowed the plaintiff's attorney to ruthlessly ambush co-trustee Lonnie Willoughby, Jr. during trial with five surprise complaint issues

     Consequently, Lonnie Willoughby, Jr. needed to appeal those unfair and improper judicial actions. 

     Note:  many months after that one-day Equity Court trial, Lonnie Willoughby, Jr. learned with his own detailed legal research that the Supreme Court of Florida had previously issued a landmark appellate court decision that specifically stated that no surprise complaint issues should be allowed during a trial unless both parties agreed to litigate those issues

     Lon then realized that during the trial in September 1989, both trial court attorneys and the trial court judge had improperly ignored that long-standing landmark decision that was a "controlling decision" (a legal ruling that must be complied with during all future trials in the State of Florida).

Lon's First Appeal Case

     Appellant Lonnie Willoughby's first appeal case (in year 1989-1990) had an appeal attorney representing him.  Lon gradually realized that the attorney knowingly and willfully betrayed him by "cooperating" with the opposing party to cause appellate Lonnie Willoughby to lose that appeal. 

     The appeal should have been easy to win if the appeal had been conducted competently in a responsible manner. 

     If the three appellate court judge panel had been competent, honest, and responsible, Lon could have still won that appeal because the "record on appeal" evidence and the controlling relevant legal case law argument (the landmark controlling Florida Supreme Court decision that strictly prohibited surprise complaint issues during trial) was so strongly in appellant Willoughby's favor that the three judges should have ruled in his favor, in spite of the incompetent appeal actions of his appeal attorney. 

     However, the three judge appellate panel took the easy way out, they paid no responsible attention to the "record on appeal" evidence (did not bother to read the first 25 pages of the trial court transcript - 267 pages long in two volumes) and they also ignored the controlling Florida Supreme Court case law decision that was relevant (the Supreme Court of Florida case law decision that prohibited surprise complaint issues during a trial).  Due to their incompetent and irresponsible actions, they ruled against appellant Willoughby without writing a legal opinion for the appeal case. 

Betrayal By Attorneys and By Judges

    Due to the betrayal actions of his trial attorney in 1989 and the betrayal actions of his appeal attorney in 1989-1990, Lonnie Willoughby decided that he would represent himself in his pro se capacity in any further litigation actions in any courts (trial courts or appellate courts). 

     Appellant Willoughby won the first appeal case that he personally prosecuted in his pro se capacity (without any attorney assistance).  That appeal case proved that Lonnie Willoughby had learned how to competently prosecute a  complex appeal cases (from the beginning to the end). 

     That very important appeal case clearly exposed an extremely unfair, unethical, and outrageously corrupt circuit court judge, and also exposed an extremely unfair, unethical, and outrageously corrupt trial court attorney and his Putnam County (Palatka) law firm. 

     That is a published appeal case decision that is available for review in law libraries throughout the United States of America and also available on the Internet using special legal research software programs such as West Law Research (available for use free at some public libraries in South Carolina).

     That very important appeal case proved clearly, beyond any doubt whatsoever, that the circuit court judge (the highest level trial court judge in Florida courts) had knowing and willfully falsified a very important Summary Judgment Order in order to wrongfully dismiss Lon Willoughby's very important Counterclaim litigation case against his previous defense attorney. 

     That Counterclaim litigation case had sued the attorney and his law firm for deceit, fraud, and legal malpractice, and the outrageously corrupt circuit court judge had dismissed that Counterclaim case, by improperly claiming that the case was time-barred by the Florida statute of limitations. 

     During the summary judgment motion hearing that had been conducted in June 1993 before that judge, Counterclaim plaintiff Lonnie Willoughby had proven convincingly, beyond any doubt whatsoever, that his Counterclaim case was not time-barred by the Floridan statute of limitations.

     Lon Willoughby had presented the circuit judge with photocopies of three "controlling" Florida appellate court case law decisions that proved beyond any doubt that a counterclaim case of that specific type was not time-barred by the statute of limitations. 

     The first appeal case for appellant Lon Willoughby, Jr. had delayed the running of the statute of limitations until that appeal case was concluded.

     The attorney involved had drafted the unfair, unethical and fraudulent Summary Judgment Order for the judge to sign (standard trial court procedure).  Drafting and filing an unfair, unethical, and fraudulent judicial order is a crime in Florida by statutory law

     The circuit court judge and the attorney had collusively presented an unfair, unethical, corrupt and fraudulent Summary Judgment Order, so they were both involved in filing that unfair, unethical, and fraudulent Summary Judgment Order.  

     The three judge panel of appellate court judges had conclusive documentary evidence of that very serious criminal action, but they did nothing responsible about requesting an investigation and prosecution of that criminal level judicial action.  Consequently, a criminal investigation of that criminal judicial action (fraudulent Summary Judgment Order) was not initiated, and nothing was done about that very serious criminal judicial action by two members of the Florida legal profession.

     The three appellate judges ignored that very serious criminal action, even though appellant Lon Willoughby presented an abundance of documentary evidence that the Summary Judgment Order was outrageously unfair, unethical, and fraudulent. 

     That corrupt appellate court situation illustrates clearly why there is so much unfairness and corruption in the judicial systems in the USA.  

      During 20 years of litigation actions, Lon learned that unfair, unethical, and corrupt actions by trial court attorneys (lawyers) and trial court judges are routinely ignored.  Consequently, there is no investigation and no punishment for such serious corrupt litigation actions. 

     Lon learned that unfair, unethical, and corrupt self-serving judicial actions are apparently common practice in litigation courts.

     With a fair and impartial trial court judge in September 1989, Lon would not have needed to initiate a complex and difficult and expensive appeal case that ended unfairly, unethically, and corruptly in 1990

     With a fair and impartial trial court judge for the Summary Judgment hearing in June 1993, Lon would not have needed to initiate pro se a complex and difficult and expensive appeal case that ended fairly in 1994, but the three appellate court judges unfairly and unethically ignored the very serious judicial corruption that appellant Lon Willoughby exposed with his pro se prosecution of his appeal case. 

     With fair and impartial trial court judges, Lon would not have needed to file and prosecute any of his ten complex and difficult and expensive appeal cases.   

     With fair and impartial appellate court judges, he would have won all ten of those appeal cases, instead of winning only two of his appeal cases. 

     Appellant Lon Willoughby found that appellate court judges were usually much more interested in defending and protecting unfair, unethical, and corrupt trial court judges than they were in responsibly reviewing and deciding appeal cases in fair and reasonable ways. 

     The two appeal cases that Lon Willoughby won were so rock solid that his appeal argument issues did not leave the appellate court any room to navigate a decision except to rule in appellant Willoughby's favor
    The eight appeal cases that appellant Lon Willoughby lost were all appeal cases that had no filed written appeal opinion (by the three judge appellate panel) about Lon's multiple appeal argument issues
     In each of those appeal cases, the three appellate court judges unanimously ruled against appellant Lon Willoughby without providing a written appeal decision that stated the legal basis they used for ruling against his appellant argument issues.
     Why was there no written appeal opinion about each appeal case that Appellant Lon Willoughby lost?  Three  reasons are presented below: 
     1.  That was the easy and lazy way for the three judge appellate panel to end the appeal case in favor of the appealed judgment rendered by the trial court judge.
     2.  There was no honest legitimate way for the three appellate court judges to explain why they ruled against Appellant Willoughby. 
     An appeal decision based upon the appeal "record evidence" and the relevant "controlling case law standards" would have been in Appellant Willoughby's favor, but the three judges obviously wanted to defend and support the improper and unfair (unethical?) trial court judge's judgment.
    The appellate court judges just simply ruled against appellant Lon Willoughby in those eight appeal cases - without taking a little time to provide a written appeal opinion that would explain why he lost his appeal case.  
     3.  So the three appellate court judges unanimously agreed to rule against Appellant Lon Willoughby's multiple appeal argument issuesThey agreed to provide an unfair, unethical appeal decision.  They lied
     That is a very convenient way the appellate court has given itself, in a very self-serving way, the option of not providing a written appeal decision explanation as to why an appellant lost their appeal case. 
    The three judge panel did not bother to provide even one or two sentences that explained the legal basis that they used to unanimously rule against all of appellant Willoughby's appeal argument issues (usually three or more argument issues for each of his appeal cases). 
     During related litigation actions in Florida, that occurred over a period of 20 years, litigant Lonnie Willoughby learned that the best thing to do with American courts (trial courts and appellate courts) is to avoid them wherever possible.   
     He therefore educates A4J club members about practical and sensible actions that he has learned to take to help him accomplish that important objective.
 Lon is Sued Again
     Lon's trial court "defense attorney" had sued him, and also sued the appointed CPA trustee, trying to collect the additional $3,280 dollars that he had billed co-trustee Lon Willoughby for after the extremely unfair, unethical, and outrageously corrupt trial that had been conducted on September 8, 1989.  
     That situation shows how self-appointed "elitist, aristocratic" attorneys will deliberately betray a litigant during litigation and then have the audacity to bill the betrayed litigant as if he/she had been represented in a competent and responsible way. 
     You see, "elitist" attorneys have been educated to believe that they have a right to be paid, even when they betray a client in a ruthless and outrageously corrupt manner during litigation.
     Lon had paid attorney # 6  $1,000 by trust check when he first retained the attorney, but Lon then refused to pay the attorney's additional billing fee ($3,280) for his unfair, unethical, and fraudulent trial litigation attorney actions.  The deceitful dishonest and corrupt attorney then sued Lonnie Willoughby in an effort to collect that $3,280 litigation fee.
     Lon Willoughby, still living in Greenville County, South Carolina, responded to that new Florida lawsuit in his pro se capacity (without assistance of an attorney). 
     Lon subsequently filed a Counterclaim Complaint for 600,000 dollars in alleged damages for the attorney's deceitful unfair, unethical, corrupt and fraudulent litigation actions in that prior trial court case.  You will learn herein later why the attorney's deceitful and fraudulent litigation actions justified that amount of damages to Lon Willoughby, Jr.
      Lon's Counterclaim Complaint sued the attorney for deceit, fraud, and legal malpractice.
     The unfair, unethical, and fraudulent FINAL JUDGMENT had been drafted for the trial court judge's signature by Leona Willoughby's trial attorney.  The same attorney that had unfairly, unethically, and ruthlessly ambushed co-trustee Lonnie Willoughby, Jr. during trial with five surprise complaint issues
     The plaintiff's attorney had including a statement in the FINAL JUDGMENT document that said Lonnie Willoughby, Jr. represented a person where a little knowledge was a dangerous thing.  (That statement falsely implied that Lon Jr's estate planning actions had been incompetent and ineffective). 
     However, that attorney had acknowledged during trial that the deceased Mr. Willoughby's estate had avoided probate administration, and the attorney probably knew that Mr. Willoughby's federal estate value had also avoided federal estate taxes completely.  The CPA witness during the trial was the CPA who had prepared and filed he final federal estate tax return for Lon Jr's deceased father.  Consequently, that attorney could have easily determined that Lon Jr's estate planning actions had been very successful.
     That situation is a further illustration of the malicious and ruthless litigation actions of trial attorneys who will do anything possible to win a litigation case, including ruthlessly destroying an innocent and competent litigant's personal reputation and their relationships with all family members.  
     That false statement and other unfair and unethical false statements in the FINAL JUDGMENT destroyed Lon Willoughby, Jr's reputation with his family members, on both sides of his family (his father's relatives and his mother's relatives - Lon's aunts, uncles, cousins, nieces, and nephews). 
     His reputation as an honest and responsible person was destroyed for all of relatives forever.  There is no practical way to undo that reputation damage with those relatives.  That situation illustrates how malicious and ruthless trial court attorneys can be in a litigation process. 
     That false reputation damaging information eventually got passed on to some of the people that Lon Jr. had gone to high school with, and he even lost those friendships due to that severe reputation damage.
     The overall damage to his reputation was enormous, and it will last the rest of his life.  There is no practical reasonable way that Lon Willoughby can restore his good personal reputation with all of those people.
Lon Willoughby is a Fighter for Truth and Justice

     However, Lon Jr. has a strong sense of fairness, honesty, and ethics, and he is also a strong dedicated fighter for truth and justice.  As reported herein, the litigation in 1989 started a litigation process that continued into year 2010 (20+ years) with numerous related litigation actions (trial courts and appellate courts)    
     Throughout those 20 years, Lon lived in Greenville County, South Carolina.  The ongoing litigation processes wrecked his career and his life for 20 years.  The extended Florida litigation also severely damaged Lon's wife's life and severely damaged their family life and their life with Lon's two sons from a previous marriage (that divorce occurred in 1970).
     As shown herein, Lonnie Willoughby, Jr. is determined to educate many American adult citizens about the extreme level of unfairness, deception, fraud, and disgusting judicial corruption that appears to be ordinary common practice with litigation actions in the USA.
     This report shows that the Florida attorneys who got involved in that extensive extended litigation process were like a "wrecking crew" who took a very good inter vivos Trust Estate Plan and manipulated it and misrepresented it in extremely unfair and unethical devious ways during the trial court litigation process for their own self-serving advantages.
     When non-resident Lonnie Willoughby, Jr. refused to pay his former "defense attorney" the $3,280 that he billed Lon Jr. for after the trial, he and then two of his attorney sons "greatly increasing their attorney fee actions, year after year, during the next 20 years." (To more than $126,000)
     Lon Willoughby will show herein how some of those unfair and unethical devious litigation schemes and tactics were cooperated with by a series of unfair and unethical and corrupt trial court judges throughout the 20+ years of litigation that Lon Jr. was subjected to as a defendant in self-serving corrupt Florida courts (multiple trial court litigation's and appellate court cases).  
Exceptionally Important Report
     This exceptionally important report will help "qualified visitors" in South Carolina understand why it is very easy for judicial systems in Florida, in South Carolina, and other judicial systems in America, to operate in very unfair, unethical, arrogant, pompous, self-appointed "elitist, aristocratic" self-serving despotic totalitarian and tyrannically corrupt ways
     Lon learned that such litigation can be a terrible family disaster for any naive and trusting litigant who gets caught up in their criminal-minded self-serving litigation schemes and tactics.
      Based upon Lonnie Willoughby, Jr's extensive litigation experiences over a period of 20 years, unfair, unethical, and corrupt self-serving litigation actions and judicial actions are apparently common practices in many American courts
     Visitors will learn herein that Lonnie Willoughby, Jr. (Lon) has had a lot of experiences with those kinds of litigation actions, mostly in the distant southern state of Florida, but Lon will also report herein some disgustingly unfair, unethical and corrupt litigation experiences that he had in trial courts and appellant courts in South Carolina.
More Recent Judicial Corruption Exposed
     Lon will come back shortly to this report about some of his personal litigation experiences, but he will now report briefly an alleged criminal law violation case in New Jersey that went through a federal district court's litigation process, and that was later affirmed on appeal in a federal appellate court.  
     The case was then appealed for certiorari review by the U.S. Supreme Court (located in Washington, DC).  
     Reviewing this very important alleged federal criminal law violation case will illustrate clearly the extreme level of unfair and unethical trial court litigation corruption that is possible in American federal trial courts.
     This case will also show the extreme level of unfair and unethical appellate court corruption that is possible in American federal appellate courts. 
     This federal court criminal law violation case will help naive and trusting inexperienced (litigation-wise) "qualified visitors" have more understanding and more confidence in believing the true litigation reports presented in this department by Lonnie Willoughby, Jr.
     His personal experience reports will expose some of the extremely unfair, unethical, and criminal-minded attorney (lawyer) litigation actions, schemes, and tactics that were used against defendant Lonnie Willoughby, Jr. (Lon Jr. or Lon) over 20 years of ongoing related litigation actions against him in Florida courts. 
     Lon will also report some of the collusive trial court judicial actions and appellate court judicial actions that were used to repeatedly deny Lonnie Willoughby, Jr. fair and impartial judicial forums for his defensive litigation actions in Florida courts.
     Lon realizes that most American adults naturally want to believe that American court judges are almost always ethical and honorable people.  Lon also felt that way when the litigation in Florida began in March of 1989
     However, Lon no longer feels that way.  After 20 years of extreme judicial abuse, deception, and corruption, with numerous incidents of unfair and unethical judicial actions that involved ruthlessly falsified official judicial orders, he no longer has any confidence in the honesty and integrity of attorneys, lawyers, or litigation judges. 
     The judicial reports in this department may help some "qualified visitors" to this website finally realize and understand for the first time in their life that state court level and federal court level judicial systems in America can be extremely unfair and unethical and very corrupt and fraudulent to an extreme degree.  
     The federal litigation case reviewed briefly below may help some "qualified visitors" have more confidence in Lonnie Willoughby's personal reports about unfair and unethical judicial corruption actions in American courts. 
U.S. Supreme Court Case
Kelly vs. U.S.
     On May 7, 2020, the U.S. Supreme Court unanimously reversed a federal court criminal law case decision that had been conducted in an extremely unfair and unethical criminal law prosecution of two American citizens by federal prosecuting attorneys in a federal court case.
     That was the New Jersey case that has come to be known as "Bridgegate" - about the involvement of political administrative personnel in New Jersey who allegedly took politically motivated actions to deliberately cause very serious traffic problems for Fort Lee by closing some lanes of traffic on the George Washington Bridge for days.  You can research news reports about "Bridgegate" on the Internet.  The US Supreme Court appeal case name is Kelly vs. U.S.
     It was apparently clear that the two defendants in the federal trial court prosecution case had deliberately caused grossly improper administrative actions that resulted in very serious traffic problems on the George Washington Bridge for days that caused serious harm and problems for many people.  It was apparently a deliberately caused frustrating and very serious traffic delay situation for thousands of people for multiple days.    
     We need to consider that the criminal law violation case went through a detailed federal court criminal law violation prosecution litigation process, and the two defendants were convicted of serious criminal law violation actions.  
     The defendants appealed the guilty verdicts, and they eventually went through a federal appellate court review by a panel of appellate court judgesThe federal appellate court judges upheld the trial court's guilty verdicts.
     The federal criminal law violation convictions were then appealed to the U.S. Supreme Court for certiorari review
     The odds of obtaining certiorari review by the high court in this situation is extremely low, almost zero chance of getting a certiorari review, but the high court judges did vote to review this very high profile case. 
     The nine justices vote to hear or not hear each case that comes before them.  If four or more judges vote to hear a case, the case will be heard. 
     Each of the nine justices have law clerks that work for them and make recommendations about which cases have the most merit and should be considered for a certiorari review.
      In the case of Kelly vs. U.S., the high court stated in its decision of their review of the case, the serious administrative actions that were harmful to many people that were reported by the federal prosecutors did not violate the criminal law statute(s) that the prosecuting attorneys had used to cause two very serious prison-term criminal law convictions in a federal district court proceeding.      
     Think about all of the prosecutor attorney's actions in the trial court litigation process, and then consider the defense attorney actions in trying to prevent the defendant's from being convicted improperly of alleged criminal actions
     Then think about the prosecutor attorney actions in the federal appellate court case, and also think about the defendant's (appellant) attorney actions in the appellate court case. 
     Now think about the judicial actions involved in the trial court case, and also think about the judicial actions of multiple judges in the appellate court case. 
     After carefully reviewing the case, the nine U.S. Supreme Court Justices concluded unanimously that the litigation actions taken by the prosecuting attorneys and the federal trial court judge were WRONG!!!!!  
     The nine high court justices also concluded that the prosecuting attorney actions in the appeal case, and the judicial actions taken by the multiple appellate court judges were also WRONG!!!!!
     The nine justices of the U.S. Supreme Court unanimously reversed the convictions that had been rendered in the trial court and that had been reviewed and approved by multiple judges on appealWOW!!!!  
     The high court's justices reversed (threw out) the unfair, unethical, and corrupt prosecuting attorney actions that had been allowed by the trial court judge and had then been allowed and approved by multiple appellate court judges.
     Lon Willoughby was not surprised at all about the lower court's unfair and unethical judicial actions, and he was not surprised about the appellate court's improper unfair and unethical judicial actions being overturned entirely by the U.S. Supreme Court justices unanimously
     Lon Willoughby's extensive litigation experiences (over 20+ years) had found that such unfair, unethical, and corrupt attorney actions and judicial actions are sadly  common practices in judicial systems in America
     "Qualified visitors" to this department need to understand that almost all of those unfair, unethical, and corrupt judicial decisions actually become "the law of the case" because they will not get reviewed by the justices of the U.S. Supreme Court.  It is almost impossible to get such cases reviewed by the U.S. Supreme Court Justices.
     Judges in the lower courts (trial courts and appellate courts at the state level and at the federal level) know that it is extremely unlikely that their judicial actions and decisions will be reviewed by the U.S. Supreme Court because they only hear about 45 to 55 cases per year (for the entire USA). 
     Many of those cases are mandatory hearings such as death penalty cases, legal disputes between states, etc.  That doesn't leave hardly any opportunity for a typical appeal case to be selected for certiorari review by the U.S. Supreme Court Justices. 
     The high court usually receives more than 7,000 cases per year, and almost all of those cases are rejected for review because the high court chooses to review only about 45 to 55 cases each year.
     Consequently, the high court denies almost all of the appeal cases requesting certiorari review.  Those appeal cases do not get an appeal hearing, like the very important certiorari review that the high court justices provided for the very high profile case of Kelly vs. US.
     After 20+ years of related litigation actions in a distant southern state (Florida), causing about 17,000 hours of work for Lonnie Willoughby, Jr., he has ZERO CONFIDENCE in the fairness, honesty, or integrity of trial attorneys, state prosecuting attorneys, or trial court judges or appellate court judges (state appellate courts or federal appellate courts). 
     Lonnie Willoughby realizes that there is almost no chance for getting a certiorari review by the U.S. Supreme Court of many unfair, unethical, and corrupt judicial decisions in state court litigation actions or in federal court litigation actions.  Consequently, unfair, unethical, and very corrupt judicial decisions can become the final approved "law of the case."
     During 20+ years of related litigation actions, Lon discovered that legal profession actions and judicial actions during litigation processes are typically self-serving for members of the legal profession (attorneys, lawyers, and judges).
     "Truth and justice" and "due process of law standards" are routinely ignored or violated in a disgustingly unfair and corrupt self-serving manner.  (As was done in Lon's first trial on September 8, 1989 and then in his first appeal case - 1989).  
     Some people might say "Lon, it is not always a perfect judicial process."  After 20 years of corrupt litigation experiences, Lon says "it is not even remotely close to being a perfect judicial process."  It is much closer to being a form of "organized crime" against many good citizens of the United States pf America for substantial benefits to members of the legal profession
      Those unfair and unethical litigation actions usually ensure that members of the "legal brotherhood" win in almost all cases.  It usually doesn't really matter very much what the relevant controlling legal standards should be for the issues being adjudicated in trial courts.
     The trial court attorneys (lawyers) and the trial court judge will usually make the case outcome conform to their personal self-serving judicial desires.  Lonnie  Willoughby has learned from personal experience that it is usually a very unfair, unethical, and corrupt trial court system.
     Lonnie Willoughby learned that the judicial systems in America (state courts and federal courts) can easily be corrupted badly by trial court attorneys (lawyers) and the trial court judge when they cooperate "collusively" with each other to cause the outcome for litigation that they "mutually agree to for each case outcome."  The outcome of a trial court litigation can easily be decided before the trial is actually conducted.
     Lon learned that the trial court attorneys will usually follow the trial judge's lead on those issues, but sometimes the attorneys involved (on both sides - "competing" plaintiff and defendant attorneys) persuade the judge to do what the attorneys mutually agree to as "the proper outcome" of the litigation case.
     That outcome can be outrageously unfair and corrupt in the trial court, and if a severely abused litigant is willing to spend thousands of dollars for an appeal case, the appellate court judges may be just as unfair, unethical, and corrupt as the trial court judge below was for the severely abused litigant.  
     If the trial court attorneys and the trial court judge believe the severely abused litigant has enough money to spend thousands of dollars for an appeal case, that situation may motivate them to try to force the abused litigant into a situation where he/she will need to file an appeal case.
     That situation will automatically bring in more attorney actions and more money for some legal profession members - usually in the local area of a state.  So you see, appeal cases are good business practice for some legal profession member(s) within a U.S. State.
     It is very important for competent American adults to remember what happened with case Kelly vs. U.S.  Even though the two defendant's won their appeal to the high court, they had very expensive attorney fees that they were obligated to pay for their defense attorneys in their trial court litigation, and their attorney representation in their appellate court litigation, and their attorney representation in their appeal to the U.S. Supreme Court
     The trial court defendants also went though several years of tremendous emotional stress (remember they were convicted of criminal actions and sentenced to prison terms), and they had their career work life and their personal life with family members severely affected for several years also.
     From Lon's 20 years of litigation experiences, he believes confidently that there are many such unfair, unethical, and corrupt litigation cases in American courts, and very rarely will one of them get a certiorari review in the U.S. Supreme Court
     Think about what would have happened to the man and women convicted in the trial court litigation and then their convictions were approved and upheld in their appellate court appeal case - if the U.S. Supreme Court had not decided to hear their petition for certiorari review (of the legal actions that had already occurred).
     Lon Willoughby is reasonable confident that the United States of America has thousands of convicted litigants who were not guilty of the crimes alleged against them that resulted in them becoming state prisoners or federal prisoners.
     It is truly a tragic situation, and Lon will later explain at this website how the litigation systems in the USA, at the state levels and at federal levels, actually encourage and promote unfair, unethical, and corrupt litigation actions and practices by attorneys (lawyers) and trial court judges.
     Lon Willoughby filed ten appeal cases in the Florida judicial system over 20 years of litigation actions.  It is a lot of work to prosecute an appeal case, and it is also expensive to prosecute an appeal case.  A smart responsible litigant does not attempt an appeal case unless there is substantial evidence that the trial court litigation actions were conducted improperly. 
     However, appellant Lonnie Willoughby won only two of the nine appeal cases that he personally prosecuted completely in his pro se status.  He realized that with fair and impartial appellate court judges, who honestly tried to dispense fair and impartial justice for an appeal case, he should have won all nine of those appeal cases. 
      Remember that Lon lost his first appeal case because his appeal attorney betrayed his trust and cooperated with the opposing appeal attorney to cause appellant Lonnie Willoughby, Jr. to lose that appeal - which should have been easy to win if the attorney had been fair and ethical with Lon's appeal case. 
     Lon won his second appeal case because he personally prosecuted that appeal case in his pro se status.  That case proved clearly that he had learned how to properly prosecute an appeal case - from beginning to the end of the appeal actions.
     Lon's litigation experiences in the state of Florida involved more than 17,000 hours of litigation work over a period of 20 years of ongoing related unfair, unethical, malicious, and ruthless harassment litigation actions by attorneys (lawyers) and trial court judges. 
     NOTE: That amount of hours of related litigation activity (work) is equivalent to more than seven years of full-time work at the rate of 40 hours per week.  
     That was a tremendous amount of unfair and unethical judicial interference with Lon's work in operating and managing an independent corporately owned natural health and wellness products store in Greenville County, South Carolina.
     Those extended malicious and ruthless harassment litigation actions were caused by unfair, unethical, and corrupt "officers of the Florida courts" as they repeatedly extended the litigation process, year after year, from March 1, 1989 into year 2010
     Their malicious and ruthless litigation actions harassed, persecuted, and severely punished non-resident litigant Lonnie Willoughby, Jr. in multiple ways, and they collectively caused him as much damage as they could scheme up to cause in collusive unfair, unethical, criminal-minded litigation actions that continued into year 2010 (for 20+ years of interference with his career and his personal life). 
     The Florida attorneys deliberately increased and extended their attorney actions, again and again, as they repeatedly increased their "alleged attorney fees" in the ongoing litigation processes.  They repeated used litigant Lonnie Willoughby, Jr. as their "punching bag" for unfair and unethical schemes and tactics practice.
     They apparently planned to force non-resident litigant Lonnie Willoughby, Jr. to pay for their extremely unfair and unethical criminal-minded litigation schemes and tactics when the litigation processes ended. 
Why did they do that to Lonnie Willoughby, Jr?
     The official Florida litigation records involving Lonnie Willoughby, Jr. (Lon) show clearly that those "officers of the Florida courts" (attorneys, lawyers, trial court judges, and appellate court judges) retaliated against Lonnie Willoughby, Jr. because he had responsibly helped his aging parents, living in the Palatka area of Florida, develop an inter vivos type Trust Agreement estate plan. 
     That estate plan was very effective at responsibly and legally minimizing federal estate taxes and also minimizing state probate expenses and complications for his father's estate settlement after he died (11/22/1986). Lon has already reported some information about the FINAL JUDGMENT rendered for the initial litigation case that went to trial on September 8, 1989
     The unfair, unethical, and corrupt trial court judge (a Florida circuit court judge) allowed the plaintiff's attorney to include several unfair, deceitful, and fraudulent lies in the FINAL JUDGMENT about defendant co-trustee Lonnie Willoughby, Jr. - false statements that destroyed Lon Willoughby Jr's good reputation with many relatives for the rest of his life.
     The Florida attorneys in Putnam County Florida apparently felt that Lonnie Willoughby, Jr., (Lon Jr.) living in South Carolina, had invaded their "legal territory" in Putnam County
     Litigation actions showed that the unfair, unethical criminal-minded attorneys concocted malicious and ruthless litigation schemes and tactics that damaged litigant Lonnie Willoughby, Jr. as much as possible. 
     They misunderstood (in an "extremely self-serving criminal-minded way") that the Willoughby family's estate planning actions were not their "legal territory."  Those important actions were clearly in the Lonnie Willoughby (Sr's) family legal territory.
Development of the Willoughby Estate Plan

     In late 1982, Mr. and Mrs. Lonnie Willoughby (Sr.) initially retained an estate planning attorney in Daytona Beach, Florida (about 60 miles from where they lived near Palatka, Florida) to develop inter vivos Trust Agreement documents for both Mr. and Mrs. Lonnie Willoughby (Sr.) - "Living Trust" documents. 
     That estate planning attorney had been referred to them by their bank's trust officer, after their first-born son Lonnie Jr. (age 46) had recommended that they talk with their bank's trust officer about locating an estate planning attorney who might help them take some important estate planning actions. 
     Lonnie Jr. lived about 450 miles away in Greenville County, South Carolina. 
     The Daytona Beach attorney (recommended by the bank trust officer) completed the development of the inter vivos trust estate planning documents and had them ready for Mr. and Mrs. Willoughby to sign in January 1983
     Lonnie Jr. (Lon) then traveled the 450 miles by personal automobile to his parent's home near Palatka, Florida (where his parents had lived for a number of years) so he could go with his parents to the attorney's office in Daytona Beach, Florida to review and sign the two sets of estate planning trust agreement documents.
     Lon and his parents then traveled about 60 miles to Daytona Beach, Florida, and they met with the estate planning attorney at his office location in January 1983 - as scheduled by the estate planning attorney. 
     The documents were signed by his parents and notarized at the attorney's office that day - with Lon Jr. and his younger brother Larry (his only sibling) as the two designated co-trustees of both Willoughby trust agreements (one for Mr. Lonnie Willoughby and a mirror-image trust agreement for his wife, Leona Willoughby). 
     Over the next few days, Lonnie Jr. carefully reviewed the two Trust Agreement documents.  Fortunately, he was knowledgeable enough about estate planning to recognize that the estate planning documents that the attorney had developed had started the Willoughby's estate planning project, but he realized that the trust agreements did not complete the needed estate planning project.
     When Lon carefully evaluated the two mirror image trust agreements, he gradually realized that the Inter Vivos Trust Agreement Documents would not enable his parent's jointly-owned marital estate value to minimize federal estate taxes on their sizable estate value (later determined in 1987 to be about 1,200,000 dollars - after Lon's father died on November 22, 1986).  
     Lon also realized that the two trust agreement documents would not enable his parent's jointly-owned estate value to minimize potential probate attorney fees or reduce probate processing times (presuming that his parent's would die at separate times in the future). 
     In effect, son Lon Jr. concluded that the two trust agreements were not effective estate planning documents in their present form because the trust agreements had no asset values assigned to them. 
     The estate planning documents had determined who the trustees would be, but the two co-trustees had no estate values to manage because no assets had been transferred into the two trust agreement estates.
     it was sorta like a bank checking account that has no funds in the bank account.  The checking account in that zero balance condition is a worthless account except that it will allow deposits to be made.
     None of the Willoughby's jointly-owned estate values had been transferred into either Trust Agreement. 
     The  estate planning attorney had not informed Lon's parents about the very important need to transfer as much asset value as possible into the two Trust Agreements to take advantage of their estate planning potential (minimizing potential probate expenses and possibly reducing federal estate taxes - both occurrences after the death of a trust grantor). 
     He realized of course that Lon's parents would not know how to take those needed actions, and he did not offer to help them accomplish those additional estate planning actions for additional reasonable legal fees.
     Fortunately, Lon Jr. already realized that any asset values that were transferred into the trust agreements would automatically avoid being considered as probate-able assets during a future probate process.  
     The estate planning attorney had not even asked the Willoughby's any questions about the estimated total dollar value of their jointly-owned marital assets.   
     Lon determined that some technical amendments would be needed for the two Trust Agreement documents to greatly improve their estate planning features.  However, he was not knowledgeable enough about those issues to understand what legal form those trust amendments documents would need to be in to enable him, as the active co-trustee, to accomplish real estate asset transfers into the Trust Agreements for minimization of federal estate taxes on his parent's substantial size jointly-owned marital estate value. 
     At that point in time, Lon did not know what his parent's total jointly-owned asset values would amount to, but he realized that the amount was sufficient to benefit from some responsible estate planning actions. 
     In prior years, Lon had been a life insurance salesman, and he had taken an interest in learning about important estate planning issues.
     Lon Jr. also realized that the two Trust Agreement documents also needed asset transfer actions that would enable the minimization of Florida probate processing expenses, and complications, and probate processing time when each parent subsequently died. 
     Upon coming to those very important realizations, Lon Jr. lost confidence in the estate planning attorney's competence, honesty, and integrity as an estate planning attorney because he had not discussed the need for any of those critically important estate planning actions
     The attorney had completely overlooked (or he had deliberately avoided and evaded) almost all of the major estate planning objectives of having the Inter Vivo Trust Agreements.  Consequently, Lon Jr. did not trust the attorney to develop appropriate amendments for the two "completed" Inter Vivos Trust Agreement estate planning documents.
    Over a period of several months, Lonnie Jr. located and met with other estate planning type attorneys in that part of north Florida (within 80 miles of Palatka). 
     However, Lon was not impressed favorably with any of them as being competent to amend the existing trust agreement documents, and one of them wanted to start all over and develop new Inter Vivos Trust Agreements. 
     None of the five attorneys that Lon Jr. talked with wanted to get involved in amending the existing Inter Vivos Trust Agreement documents (perhaps as a professional courtesy to the estate planning attorney - to not amend the documents that he had developed).
     The other attorneys did not appear to know how to amend the existing Trust Agreements to provide the improved estate planning features that Lon wanted to accomplish with Amended Trust Agreements (minimize federal estate taxes legally, and also minimize probate processing fees and also minimize probate process complications and probate processing time). 
     None of the five attorneys that Lon consulted with indicated that they were willing to get involved in providing the amendment features that Lon Jr. believed the estate planning Trust Agreements should provide (for the specific objectives that are explained above).
     Throughout those months of frustrating delays about amending the two Trust Agreements (during the summer and fall months of year 1983), Lon Jr. realized that his father was in very bad health, and he was subject to die at any time. 
     Consequently, Lon Jr. realized that it was critically important that the two Trust Agreement documents be amended quickly - before his father had another heart attack or had another stroke. 
     Those health conditions might kill his father, or they might mentally impair him and prevent him from making important decisions about how he wanted his personal estate values to be planned for use by family members (by his wife and by his two grown sons, and maybe by his grandchildren). 
     Lon's father had already had a very bad heart attack and a terrible stroke in the spring of 1982.  The stroke had totally paralyzed him on the entire left side of his body.  He was either in his bed or in his wheelchair. Fortunately, his mental capacities seemed to be normal - he was still very intelligent and still quick witted.
    Over a period of several months, Lon Jr. had been  unable to find another estate planning attorney to complete the estate planning project properly.  Lon realized that his father could die at any time (likely from another heart attack). 
     In July 1983, Lon Jr. and his wife Janie had given up their personal careers in Greenville County, SC so they could move to DeLand, Florida and take over the operation and management of the Penn Oaks Apartment Complex - a 44 unit apartment complex that was partially owned by Lon's parents. 
     It had a bank mortgage of more than 600,000 dollars, and the other portion of ownership by Lon's parents represented their productive lifetime of difficult work and other investment proceeds. 
     Lon realized that the apartment complex operation would be the primary source of retirement income for his parents.  He did not want them to lose their lifetime investment in the apartment complex due to continued poor operation and management of the apartments. 
     The elderly couple that had been living at the apartment complex and managing the apartment complex were doing the best that they could, but Lon's previous visit and analysis had determined that he and Janie needed to move to the apartment complex and begin managing the many duties that were involved.
     Lon and Janie began working hard with long hours because the apartment complex was about ten years old and some of the apartments had run down badly during that time.  Lon surveyed the residents and determined what deficiencies existed.  There were a lot of them.
     He was working an average of 80 to 90 hours per week, operating and managing and repairing the  apartment complex.  Janie was working an average of 60 to 70 hours per week, and they lived in the small two bedroom apartment that was also serving as the office area.  The living room was the apartment complex office.
     Lon Jr. spent about $60,000 of his parent's cash assets on repairs and improvements to the apartments and the grounds and the shrubs. 
     Lon improved the conditions greatly of the 14 worst apartments (repaired appliances, had the air conditioning compressors (Freon) repaired as needed, had the apartments painted, and then had new carpet installed. 
     Lon also personally repaired many faucets and many toilets, and he also replaced many food disposal units (throughout the total apartment complex). 
     The complex had four apartment buildings, and they were two story buildings.  Lon went up into the attics for all upstairs apartments, and repaired the duct work where it had come apart in the high summer heat (over ten years of operation). 
     Many upstairs apartments were blowing some cold air conditioned air into the attic space, rather than blowing all cold air into the apartments.  Lon also had additional fiberglass insulation installed in the attic space for upstairs apartments.  All of that work was accomplished in the hot summer months of 1983. 
     The number of repairs and improvements made to the apartment complex by Lon and Janie Willoughby in the remaining 22 months of 1983 and all of year 1984 was tremendous. 
     Lon and Janie worked very hard for about 18 months, and they got the 44 unit apartment complex in much better condition so the complex could be sold.
Sale of Apartments Complex
     A local real estate company found a buyer in December 1984, and the apartment complex sale was completed in January 1985.  Lon's parents were finally relieved of the emotional stress of being responsible for 44 apartments with a $600,000+ mortgage.
     With the anticipation of the apartment complex sale in January 1985, Janie moved back to Mauldin, SC in December 1984 because she was able to get rehired at the Mauldin High School to begin teaching again when students returned from their Christmas break in January.
     During all of that extensive work in improving the apartment complex in 1983 and 1984, Lon had no time available to look for another estate planning attorney to help him get the two Trust Agreements amended to provide the needed estate planning objectives that are explained above. 
     After the apartment sale was completed, Lon moved to San Mateo so he could be near his parents to help them with their very serious health conditions. 
     He then purchased some estate planning legal books and proceeded to study those books until he gradually learned how to develop the needed legal form documents that could amend the two Trust Agreement documents.
     Lon developed and then typed the Trust Agreement amendment documents for both Trust Agreements on a portable typewriter at his parent's home in San Mateo. 
     He had talked with each parent separately and then both parents together to determine how they wanted the two Trust Agreements amended for planned use of their jointly owned marital estate values in the future. 
     Lon got the documents signed by his parents and properly notarized at their local bank.  Lon then filed the two separate Amended Trust Agreement documents in the Putnam County Courthouse records on 12/12/1985
     That was almost two years after the two Trust Agreements had been signed in January 1983 Prior to that time (12/12/1985), Lon had transferred some cash assets into Mr. Willoughby's Trust Agreement estate, but no real estate property assets had been transferred into his inter vivos Trust Agreement estate.
     Lon Jr., as the active co-trustee of the two trust estates, also developed asset transfer documents to properly and responsibly transfer 600,000+ dollars value of jointly-owned real estate into his father's trust estate - because Lon Jr. anticipated that his father would likely die before Lon's mother would die. 
     Fortunately, in previous years, Lon Jr. had also learned a lot about improving physical health and mental health, and he was very helpful to his father and mother with their physical and mental health conditions.  Lon's father's invalid condition (paralysis) had put a lot of emotional stress on his wife - he required a lot of assistance, day and night, seven days a week. 
Healthcare Improvements
     Lon Jr. helped both parents improve their diet and health conditions, and he was able to help them cope more effectively with their family health condition (the tragic paralysis condition of his father). 
     That help started after Lon's father's heart attack and stroke in the spring of 1982 - when Lon moved his parents into his home in Mauldin, South Carolina for about six months.  Lon's health improvement actions  continued until March 1986 - when he moved back to his home in Mauldin, South Carolina.
    Over time, Lon's father had not wanted to continue taking the few mineral and vitamin nutrition supplements that Lon had recommended.  In the spring of 1986, Lon's father asked him what would likely happen if he stopped taking those nutrition supplements?  Lon Jr. explained that he would likely die within six to nine months.
Lonnie Willoughby (Sr.) Dies
    Lon's father then refused to take any more nutrition supplements.  About nine months later, he had another heart attack that was fatal (November 22, 1986).  Lon was living in Mauldin, South Carolina at that time.
     The Amended Trust Agreement Estate Plan (TAEP) legally and properly reduced federal estate taxes to zero on a substantial size jointly-owned marital estate (about 1,200,000 dollars). 
     The relevant federal estate tax laws at that time could have eventually caused the Willoughby family to be responsible for paying about $225,000 in federal estate tax.  However, co-trustee Lon Jr. had transferred sufficient estate asset values into the Amended Trust Agreement for Mr. Lonnie Willoughby to fully utilize the 600,000 dollars of unified credit that was allowed by current federal estate tax law for each parent. 
     The asset values that Lon had properly transferred into his father's Trust Agreement Estate enabled a reduction in federal estate taxes to zero dollars on the entire marital estate value of 1,200,000 dollars.    
     The TAEP also reduced Florida's probate processing expenses for Mr. Willoughby's estate value to a minimum (about $800). 
     Without the TAEP, typical Florida probate cost of 8% of estate value would have amounted to about $48,000 for a $600,000 estate value
     That estate value would have likely occurred for Mr. Lonnie Willoughby (Sr's) personal estate value because his probate-able estate value would have been one half of the marital jointly-owned estate value of about $1,200,000. 
     However, due to the 700,000+ dollars value of jointly-owned assets that co-trustee Lon Jr. had transferred into his father's Amended Trust Agreement, his personal probate-able estate value had been reduced to about 3,000 dollars. 
     Consequently, the TAEP had minimized the probate-able asset value, and thereby greatly reduced probate processing time and complexities to a minimum. 
     The local probate court processing time for that 3,000 dollars estate value was only 24 hours - instead of being many weeks or months (that would have been typical for Mr. Willoughby's estate value if it had been about 600,000 dollars - the situation that would have occurred without the TAEP).
Severe Punishment for Lon Jr.

     Now consider the outrageously unfair, unethical, and disgustingly corrupt Florida litigation proceedings that were used to maliciously and ruthlessly harass, and persecute, and severely punish Lonnie Jr. for more than 20 years -  because he had responsibly helped his aging parents develop a complex Amended Trust Agreement Estate Plan (TAEP) that worked to a remarkable level of competency after Lon's father died (November 22, 1986). 
    NOTE:  Lonnie Jr. is not an attorney, and he has not attended any law school anywhere, but he knows how to read the English language.  He was able to read and learn from several legal books how he could develop the appropriate forms to accomplish the estate planning asset transfer actions that were needed to accomplish the estate planning funding actions that are reported above. 
     Those were estate planning actions that he was unable to get accomplished with any of the five attorneys that he had communicated with about those types of estate planning actions.  Lon finally had to purchase some legal books and learn how to make those trust estate amendments himself. 
     Eventually, over many years, attorneys (lawyers), trial court judges, and appellate court judges also punished Lon Jr. severely, maliciously, and ruthlessly, because he  responsibly exposed (in his appeal legal briefs - in multiple appeal cases) some of the unfair, unethical, and outrageously corrupt litigation schemes and tactics that had been used against him in Florida trial court and appellate court litigation actions.
      Those unfair and unethical litigation actions cost Lon Willoughby Jr. more than $150,000 in direct costs over that period of 20 years of continuing litigation. 
     He had the costs for many transcripts as official records of motion hearings and trial hearings.  His first transcript had cost about $1,350, and many other transcripts had cost hundreds of dollars each.  He had numerous appeal case filing fees and numerous clerk of court processing fees for assembling many complex Records on Appeal (for Lon's ten appeal cases).  Lon also had about 9,000 miles of automobile travel back and forth to Palatka, Florida and also Daytona Beach, Florida (appeal actions) for various litigation actions.
    In addition to all of the listed litigation costs, Lon's  opposing litigation attorneys eventually improperly confiscated $126,000+ out of the Family Trust Agreement estate funds that his parents had set aside for Lon Jr.   
     The opposing attorneys improperly confiscated those trust estate assets to allegedly pay them for their inflated attorney fee claims (that they had deliberately caused in self-serving litigation actions over 20 years of extremely unfair and unethical litigation actions). 
     It is very important to understand that their improper confiscation of trust fund assets was approved by the Putnam County "county court judge." That unfair and unethical judicial confiscation action depleted Lon's Family Trust estate funds to near zero dollars.  
      That confiscation of trust estate funds was clearly illegal for two reasons (even though three Florida attorneys and the county court judge were involved in that confiscation of trust assets). 
     1.  The county court judge had subject matter jurisdiction for awards up to $25,000, and the $126,000+ award greatly exceeded the county court judge's subject matter jurisdiction upper limit.
     2.  The county court judge had no subject matter jurisdiction of those trust agreement funds because all trust agreement litigation must be conducted in the circuit court.  A county court judge has no subject matter jurisdiction to award trust agreement assets to anyone, including Lon Willoughby's opposing attorneys. 
     Lon was prohibited from appealing pro se that improper and unfair and unethical award of trust funds because the local Circuit Court Judge involved in that potential appeal case quickly filed an order with the local Clerk of Court that ordered the Clerk of Court to refuse to accept any documents that Lonnie Willoughby  attempted to file with the Clerk of Court.
     Consequently, Lon could not file a Notice of Appeal pro se with the Clerk of Court, and he would not be able to proceed pro se with an appeal case to the Fifth District Court of Appeal in Daytona Beach, Florida.  The Clerk of Court would not have prepared the complex Record on Appeal for pro se appellant Lonnie Willoughby. 
     It is important to report that litigant Lon Willoughby had never had any litigation actions with that circuit court judge.  The judge had no personal knowledge about Lon Willoughby, but the local Putnam County judicial system had apparently black-balled litigant Lon Willoughby so badly that the circuit court judge improperly closed down the local judicial system for Lon Willoughby and would not allow Lon to even file a constitutionally protected Notice of Appeal
     That situation shows the outrageously unfair and unethical criminal-minded manner in which the judicial systems operated in that county.  The judge was trying to force litigant Lon Willoughby to retain a local attorney at the cost of many thousands of dollars for litigation actions that could easily betray Lon Willoughby again, as all trial court litigation actions had done in the past.  
     Lon realized that he was caught up in a criminal-minded judicial enterprise that was extremely corrupt.  He refused to try to get a local attorney to represent him in any further litigation in Putnam County (at very high costs). 
     Willoughby realized that if he did that, it would have enabled the opposing unfair and unethical attorneys that he had been litigating against since year 2003 (about 17 years) to participate in additional litigation actions and thereby increase their attorney fees against non-resident litigant Lonnie Willoughby.
    He also realized that his previous litigation actions had proven convincingly, beyond a reasonable doubt, that there was no way the Florida litigation system was going to allow him to win in this disgustingly corrupt litigation process.  Consequently, he did not take any further litigation actions and the litigation process came to an abrupt halt. 
     Those unfair and unethical criminal-minded litigation actions, over a 20+ years period of time, had also cost Lon Jr. more than $300,000 in lost income while he was very busily involved in ongoing Florida litigation actions. 
     Lonnie Jr. had filed ten appellate court cases, and he responsibly reported and exposed unfair, unethical, fraudulent, and corrupt attorney actions and/or unfair and corrupt trial court judicial actions in his pro se appeal briefs. 
    The corrupt, self-serving Florida judicial system had not punished anyone for any of the unfair and unethical litigation actions that Lon had exposed responsibly. 
     The self-serving judicial system had not even reprimanded anyone for committing unfair, unethical, criminal-minded litigation schemes and tactics that prevented justice from prevailing, year after year for many years. 
     Lon's fair and responsible litigation actions had proven several times that it was an outrageously corrupt judicial system, and he was not going to take any litigation action that would cause the litigation process to continue any further. 
     It was clearly time to just walk away from a disgustingly corrupt judicial system that had caused him to suffer terrible financial losses and tremendous emotional stress over a 20 year period of time.
Highway Accident on I-95
      Lon and Janie Willoughby had a very serious automobile accident during a heavy rain storm on I-95 as they were traveling to Palatka, Florida for Lon to participate in a motion hearing the next day.  Janie was driving while Lon was reviewing and studying legal type information related to that motion hearing.
     That accident almost killed both of them, and it did injure both of them, but they were later released from the local hospital that day at their request. 
     Lon and Janie were able to continue their travel to Palatka, Florida in an old car that was available as a "rental car" at the gas station and garage that had towed their destroyed station wagon to that gas station and garage location in a small town in Georgia. 
     That small town was within a few miles from where the accident collision occurred on I-95, and the town did not have a commercial rental car facility available. 
     The three vehicle accident totally destroyed the Willoughby's like new Mercury station wagon because it was hit from the rear by a fuel tanker truck that could not completely stop before colliding with the Willoughby station wagon which was stopped in the right lane of I-95.
     That tanker truck vehicle collision forced the Willoughby station wagon into and under the rear of the moving van.  The steel "bumper bar" of the moving van truck came up the bottom of the windshield of the station wagon. 
     If that steel "bumper bar" had come three feet closer to Lon and Janie, they would have been decapitated by the truck's "bumper" steel bar.
     The moving van had completely stopped in the right lane of I-95 because the passenger car in front of the moving van had completely stopped in the right lane of the highway (apparently due to very heavy rain). 
     That car should have gotten off the highway and onto the large right side shoulder of the highway (which could have been done easily and responsibly), but the driver of the passenger car carelessly and foolishly stopped completely on the highway in front of the moving van vehicle that was right behind that passenger car. 
     After physical examinations and X-rays, Lon and Janie were released from the hospital (as requested).  Lon rented an old car from the service station owner so they could continue their travel to Putnam County Florida.  They had about 240 miles of travel to get to that destination for the motion hearing the next morning. 
     They spent a short night in a motel in Georgia because they got up early in the morning to continue their travel to Florida. 
     They arrived at the Putnam County Court House in Palatka, Florida just a few minutes before the motion hearing was scheduled to begin.  
     Janie had black and blue splotches on her face where she had collided with the steering wheel, and one eye was completely closed from swelling, and the other eye was swelled badly but not closed.  She also had injuries to one hand where bones were damaged and fingers were apparently broken. 
     Lon's injuries were less severe because his seat belt had protected him better than Janie's seat belt had protected her because she collided with the steering wheel.  They did not have air bag protection in their vehicle.
Travel Restrictions
     From this overview of some of those litigation actions, American visitors can understand why Lonnie Willoughby now refuses to travel into any other state in America. 
     He will not even voluntarily travel into his nearby birth state of North Carolina - where most of his living relatives are still residing.  Lon has not seen any of them for many years due to his self-imposed travel restrictions (due to the judicial corruption reasons explained herein). 
     Lon Jr. has been subjected to a tremendous amount of outrageously unfair, unethical, and criminal-mindedly corrupt litigation and judicial situations by "officers of the court" in the Florida courts during 20+ years. 
     Lon has also been subjected to some really bad unfair, unethical, and criminal-minded judicial actions in South Carolina courts.  He found that South Carolina courts, trial courts and appellate courts, were even more unfair, more unethical, and more corrupt in self-serving ways than the very unfair and unethical courts in Florida.  He will explain some of those situations below.

Litigation in South Carolina Courts
     Lonnie Willoughby (Lon) is the founder and president of ABC's of Health, Inc., a South Carolina Corporation, established in year 1986
    ABC's of Health, Inc., doing business as ABC of Health, initiated a civil lawsuit in the local Magistrate Court in 2017 against an LLC business that had refused to pay ABC of Health for business equipment (about $1,700) that the defendant LLC business had agreed to purchase from ABC of Health (ABC of Health closed their corporate health store in Mauldin, SC on April 24, 2014). 
     The defendant LLC business moved into the store's 3,000 square feet floor space as ABC of Health was being moved out of that retail store space. 
     Lon Willoughby, the president of ABC of Health, left many types of store equipment in the store space that were designated to be sold to the LLC business (two refrigerators, many stack-able cushioned classroom type chairs, seven classroom tables, a stainless steel type kitchen sink and 10 feet long kitchen countertop, two metal storage cabinets with doors, and several miscellaneous pieces of store equipment). 
     One of the LLC business's main employees acted as the purchasing agent, and he had verbally indicated that they wanted to purchase the equipment that Lon left for them in the store space as a convenience to them. 
     That "gentleman's verbal purchasing agreement" was not formalized in a written form until several months later - due initially to a serious health problem for the LLC business's purchasing agent. 
     He had apparently been bitten on the leg by a brown recluse spider that got infected badly and required medical type surgery and a convalesce recovery period of weeks. 
     Lon's made several responsible attempts to get the purchasing agreement identified in a written chart form.
     The purchasing agent repeatedly delayed that action for several months.  He was simply finding ways to delay and prevent Lon from getting together with him to formalize their verbal gentleman's purchasing agreement into a written form. 
     The LLC business also failed to make any payments of funds for that equipment - months went by with no payment of any funds for that equipment.
     Lon had prepared a formal written chart form that  clearly listed the many various equipment types involved with the number of each type of equipment (shown on a horizontal line in the chart), and each horizontal line listing showed the agreed upon price for each piece of equipment, and showed the total purchase price for each type of equipment on each horizontal line. 
     The chart form of written agreement also showed the total purchase price involved for all designated equipment items that the LLC business's purchasing agent had verbally agreed to purchase from ABC of Health
     Lon Willoughby eventually got the purchasing agent to meet with him at their store location, and they finally got the written chart form of the purchase agreement agreed upon. 
     However, the LLC business continued refusing to pay for any of that equipment, and that failure continued for almost three years. 
     Lon Willoughby, as president of ABC's of Health, Inc.  then filed a civil lawsuit in the locally designated Magistrate Court for that geographic area before the three years Statute of Limitation expired for filing that lawsuit.
     The Magistrate Court Judge (Summary Court Judge) that presided during the jury trial case in year 2018 (with ABC's of Health, Inc. as the plaintiff) was a law school graduate.
     She had been a member of the South Carolina Bar Association for about nine years.  Unfortunately, for ABC of Health, she was incompetent and irresponsible as a jury trial judge. 
     Her judicial incompetence and very bad judicial judgment (decisions during the trial) totally wrecked the plaintiff's responsible efforts to present their case to the six-person jury in a trial (presented to the jury by the author herein).
     The trial judge improperly allowed, and effectively assisted, the defendant LLC type business in presenting some very serious perjured testimony about issues that had not been noticed in their defensive pleading for litigation actions.
     The judge repeatedly failed to make responsible judicial objections to those extremely unfair and unethical surprise "ambush complaints" during trial by the defendant LLC
     The trial court judge repeatedly failed to inform the defendant LLC that their defensive testimony must be confined to specific litigation issues that were properly noticed for trial testimony in their defensive LLC pleadings
     The defendant LLC repeatedly introduced surprise "ambush complaint issues" into the trial and disrupted the trial proceeding badly several times. 
     The trial judge allowed all of that improper surprise "ambush" defense testimony to be presented to the six jurors without the judge making responsible judicial objections to that improper surprise testimony
     Furthermore, the trial court judge repeatedly failed to conduct the trial in compliance with the published rules of court procedure for a Magistrate Court trial.  She conducted the jury trial as if she had never read the published rules of procedure for a Magistrate Court trial.
     The one-day jury trial turned out to be a fraud and a sham jury trial proceeding, due to the judge's judicial incompetence by allowing a lot of surprise "ambush" perjured defensive testimony by the defendant's four witnesses. 
     There were also some very lazy irresponsible actions by the six-person jury (actions that had been encouraged and motivated by the incompetent trial court judge). 
     The six jurors trial verdict showed that all jurors had irresponsibly failed to read the plaintiff's detailed 23-page Complaint pleading document, and their trial verdict also showed that the six jurors had irresponsibly failed to read the plaintiff's Answer to Counterclaim (a detailed 17 page response to the defendant's extremely frivolous Counterclaim pleading - less than 1/2 page of pleading).
     Both of those very important litigation documents by the plaintiff were major part's of the plaintiff's case during the trial.  Both documents had been given to each juror appropriately by the plaintiff's trial court litigation representative during the trial (the author herein). 
     During the trial, the judge did not allow the plaintiff's representative (the author herein) to go over (review) the plaintiff's written pleading testimony for trial with the jurors (the plaintiff's two pleading documents) because the trial judge had improperly allowed the defendant LLC to take up a lot of trial time presenting their surprise "ambush complaints" testimony - testimony about defensive issues that had not been noticed in their one page defense pleadings that had been filed in the case.
     The trial court judge irresponsibly failed to instruct  the six jurors that it was very important for them to carefully read the plaintiff's two legal pleading documents because those documents contained major parts of the plaintiff's evidence during the trial. 
     The judge simply instructed the jurors by stating that "the jurors would have those documents with them" when they left the court room to deliberate their trial verdict.  (I had appropriately and responsibly given a printed copy of those two plaintiff pleading documents to each juror - as reported herein previously.)  
     A further complication about that issue was the fact that the trial judge had previously encouraged the jurors to "hurry through the trial proceeding so they could leave early and have a good afternoon." 
     From the jury verdict rendered for the one-day trial, it was clear that none of the six jurors read either one of the plaintiff's vital legal brief "plaintiff's pleading documents" for the trial.  Consequently, the jurors did not even understand responsibly what the plaintiff's pleading document argument issues were for the trial.
     Even though the plaintiff (ABC's of Health, Inc.) managed to win partially in the botched up sham and fraud of a jury trial, there were major deficiencies in the jurors' trial monetary awards verdict for the plaintiff and their very confusing award for the defendant LLC.
     Was their monetary verdict for the defendant LLC to pay them for moving hours worked in helping the plaintiff move out of the store location, or was their monetary award verdict supposed to be compensation for the defendant LLC business's alleged counterclaim argument issues. 
     The jury's monetary award for the defendant LLC did not explain what that monetary award was for.
     Month's later, the author herein finally learned that the trial judge had improperly withheld from the plaintiff the jurors' hand-written jury award calculation page.  That calculation page showed how the jury had calculated their monetary award to the plaintiff, and it showed how their monetary calculations were in error. 
     But the trial court judge willfully prevented the plaintiff from getting a copy of that calculation page after the trial - when the trial judge gave the plaintiff a photo copy of the juror's verdict form for the trial. 
     Lon Willoughby did not discover that calculation page until months later, when he was reviewing the Record on Appeal for his filed appeal case in the circuit court.  Lon  accidental discovered that the judge had filed that jury calculation page in an obscure location in the court records. 
     Those court records later became the complex Record on Appeal that Lon Willoughby properly requested the trial court judge transfer to the Circuit Court in Greenville County - the Court of Common Pleas - as the appellate court for the appeal case that ABC of Health timely initiated - filed and also served upon the respondent LLC business.
     After the jury trial, for several ongoing weeks, the plaintiff had to go through many hours of work to develop a series of post-trial motions that progressively moved the trial court judge to agree to schedule another jury trial to replace the badly botched up fraud and sham of a jury trial. 
     The unfair, unethical, incompetent, dishonest, and corrupt despotic judge would not acknowledge any of the clearly deficient trial court judicial actions that were listed clearly in the plaintiff's sequential series of post-trial motions (moving the trial court judge to schedule a replacement jury trial).  
     The plaintiff, ABC of Health, reported by motion a series of improper trial actions, and improper judicial actions, in numbered order in the plaintiff's progressive post-trial motions requesting that the judge grant a new jury trial. 
     The judge refused to grant any of the plaintiff's  progressive motions that requested a new jury trial.
     Finally, the plaintiff was left with no viable option except to pay the $150 filing fee and file a timely Notice of Appeal in the local circuit court to appeal the one-day judicial fiasco of a trial. 
     The plaintiff also took appropriate actions to have all of the Magistrate Court records for the trial court case transferred to the circuit court as the Record on Appeal for said appeal case in the Greenville County Circuit Court.
     NOTE:  An appeal from a Magistrate's Court litigation process is taken to the next court up, in this situation, to the Circuit Court in Greenville County (The Court of Common Pleas). 
     Appeal briefs in the South Carolina Circuit Court (or in the SC Appellate Court) must be drafted and word-processed in a specific detailed way, and that procedure requires a lot of time and effort to construct the required Memorandum of Law for the appeal (by the appellant - ABC's of Health, Inc.). 
     This is particularly true for a jury trial proceeding that is appealed because it is much more difficult to reverse a jury trial decision (get a new replacement trial) than to reverse a similar verdict in a Magistrate Court's bench trial (with no jury).  
     The appellant's complex appeal brief (Memorandum of Law) was timely amended, and it became an Amended Memorandum of Law that Lonnie Willoughby also developed and filed pro se (without attorney assistance), as the president of ABC's of Health, Inc. (the plaintiff in the Magistrate Court - the trial court below).
     That Amended Memorandum of Law reported in detail eleven (11) specific reasons why the appellate judge (single circuit court judge) would be justified in ordering that the plaintiff below (ABC's of Health, Inc.) would get a new trial (to replace the very badly botched up sham and fraud of a trial that occurred in the Magistrate Court below).
     The multiple relevant case law citations and relevant law case quotations that Lonnie Willoughby presented in the appellant's Amended Memorandum of Law showed a very strong factual and relevant case law basis for the appellate court judge to order a new trial - as the appeal case decision.
     It is very important to understand that the opposing party in the appeal case also did not have attorney representation in the appeal.  They also failed to file a pro se respondent's legal brief in the appeal. 
     Therefore, the business LLC (respondent) did not object to, or oppose in any way, any statements of fact or statements of law that had been presented in the appellant's detailed Amended Memorandum of Law which had been timely filed and served upon the respondent LLC business.
     In practical essence, Appellant ABC's of Health, Inc. had no opposition of any kind in the appeal process in the local Circuit Court. (the Court of Common Pleas
     Normally, in a litigation process, if a defendant does not present any defense of the complaints against him/her, the defendant automatically loses the case.  In this situation, for similar reasons, the respondent should automatically lose in the appeal case.
     The single circuit court judge, acting as an appellate court judge, apparently failed to responsibly read the appellant's carefully developed very strong 11 reasons arguments for a new trial because the circuit court judge (sitting as the appellate judge) autocratically and despotically dismissed all of the appellant's 11 appeal case argument issues - without providing any responsible judicial reason for dismissing all argument issues
     The extremely unfair, unethical, and dishonest judge failed to find any reasonable basis for a new trial, in spite of all of the solid documentary evidence that strongly supported that outcome for the appeal (the Record on Appeal contained a verbatim audio recording of the trial) rather than providing a transcript record of the trial because a Magistrate Court trial is not a court of record - with a court reporter present - as occurs in a circuit court trial.
      In addition to those strong evidence based reasons for a new trial, the appellant's Amended Memorandum of Law also presented a series of very strong legal arguments that supported the argument issue reasons for the appellate judge to order that a new trial be granted, as clearly requested in the appellant's very competent Amended Memorandum of Law
     It is clear that the appellate judge failed to responsibly read the appellant's Amended Memorandum of Law because he totally ignored the exceptionally strong evidential basis and the very strong legal basis that was presented to justify a new trial. 
     The appellant's appeal brief contained several citations of relevant appellate court law case decisions and showed relevant quotations of legal standards from those very important South Carolina Appellate Court case law decisions. 
     Those referenced South Carolina Appellate Court's case law decisions showed several relevant reasons for the judge to grant a new jury trial.
     That ABC's of Health, Inc. circuit court appeal case is a very clear illustration of how disgustingly unfair, unethical, and outrageously corrupt an appeal process can be in the State of South Carolina. 
     With an abundance of documentary trial evidence about the extremely unfair and incompetent manner in which the Summary Court Judge had conducted the one-day jury trial litigation process in the Magistrate Court below, the appellate court judge did not have the basic honesty and integrity to simply admit (or acknowledge) that the female judge had not conducted the one-day jury trial in a competent and responsible judicial manner. 
     The detailed documentary record of that trial showed that the Summary Court Judge had conducted the one-day jury trial in an extremely unfair, unethical, and incompetent manner. 
     However, the unfair, unethical, and disgustingly dishonest and unethical appellate court judge would not admit that the jury trial was a sham and fraud proceeding that clearly justified a new jury trial.
     Lonnie Willoughby, as president of ABC's of Health, Inc., was so disappointed and so disgusted with the extremely unfair and unethical dishonest appeal decision of the appellate court judge that he timely filed a Notice of Appeal of that judicial decision in the SC Appellate Court ($250.00 filing fee). The SC Appellate Court is in Columbia, South Carolina.
     Lonnie Willoughby already knew, from a previous appeal case that he had filed in year 2003, that the Supreme Court of South Carolina had decided many years earlier that any appeals filed in the SC Appellate Court, or the SC Supreme Court, had to be represented by a licensed attorney in South Carolina. 
     Lonnie Willoughby had carefully researched that high court decision previously and had found that the court's decision about that specific issue was based on previous court case law decisions that were clearly in conflict with the Constitution of South Carolina (Art. 1, Section 14). 
     That Article of the SC Constitution clearly protects the right of every person to be fully heard in his defense by himself or by his counsel or by both.  
     The SC Appellate Court responded to Willoughby's pro se Notice of Appeal filing (filed without attorney assistance) with a letter that informed Lonnie Willoughby that he would have 30 days in which to inform the appellate court that a licensed attorney had been retained to represent Appellant ABC's of Health, Inc. in the appeal case.
    Still acting in his pro se capacity, Lonnie Willoughby timely developed and filed a detailed appeal case legal brief that specifically challenged the legality of the high court's decision about that specific legal issue. 
     That appeal brief showed that the high court's two case law decisions that had previously established that precedent setting legal standard (appeal actions must be represented by a licensed SC attorney) were in direct conflict with Art. I, Section 14 of the South Carolina Constitution.
      Art I, Section 14. The Constitution clearly protects the right of every person to be fully heard in his defense by himself or by his counsel or by both
     Therefore, those two previous case law decisions by the high court, claiming that every person must be represented by an attorney, were clearly "null and void" and had no legitimate legality at all regarding the current ABC's of Health, Inc. appeal case.  That appeal brief also properly moved the Appellate Court to certify this conflict issue for review by the Supreme Court.
     NOTE:  Lonnie Willoughby understands that any South Carolina court's legal decision that is clearly in conflict with any part of the Constitution of South Carolina cannot stand, even case law decisions made by the Supreme Court of SC.  If any court's decision is in conflict with a portion of the state's Constitution, that decision is "null and void" - it clearly has no legal validity. 
     That appeal case legal brief also explained that the current situation, requiring that all appeals must have a licensed SC attorney (lawyer) represent all litigants on appeal, automatically established an appeal process that would not report serious unfair, unethical, and/or corrupt judicial actions in an appeal.
     All attorneys (lawyers) in South Carolina are dependent upon the Supreme Court (subservient to the high court) in maintaining their court approved license to practice law in South Carolina. Therefore, the attorneys (lawyers) in this state are not going to jeopardize their personal good standing with the high court by ethically and honestly reporting fully unfair, unethical, and/or corrupt judicial actions by any trial court judge. 
     Any judicial "errors" that would get reported on appeal for an appellant client would be sanitized and reduced-down in importance by the client's attorney (lawyer) so much that it would likely be considered "harmless judicial error."
     Trial court judges in South Carolina know that of course, and they understand that they can be very unfair, unethical, and corrupt with trial court litigants and get away with it every time.
Two Appeal Cases From A Distant State

     In the appellant's appeal brief that Lonnie Willoughby filed pro se for Appellant ABC's of Health, Inc., (challenging the high court's unfair self-serving monopolistic judicial actions) he also reported two appeal cases that Lonnie Willoughby had previously won in appeal courts in the state of Florida.
     Those two appeal case decisions were very relevant to the argument issues reported in Willoughby's pro se legal brief for the instant SC Appellate Court case.  
     One of those relevant appeal cases was a published appellate court case law decision from year 1995, and Lonnie Willoughby presented a photocopy of that published Florida appeal case decision in the appeal brief that he had filed pro se for appellant ABC's of Health, Inc. in the instant SC Appellate Court appeal case (in Columbia, South Carolina).
Motion For Summary Judgment
     The first of those appeal cases was about a Motion for Summary Judgment decision by a Florida circuit court judge that was clearly unfair, unethical, and outrageously corrupt. 
     That Motion for Summary Judgment Order (decision) falsely and fraudulently claimed that Lonnie Willoughby's Counterclaim Complaint against his former "defense attorney" was time-barred by the Statute of Limitations (falsely claiming that Willoughby's Counterclaim Complaint had been filed after the Statute of Limitations filing time had expired). .
     Non-resident litigant Lonnie Willoughby had scheduled a local court reporter to attend and transcribe all verbal communications for that Motion for Summary Judgment hearing in the circuit court judge's judicial chambers (in the Putnam County Courthouse in Palatka, Florida). 
     Defendant Lon Willoughby had traveled 450 miles by auto to the distant state (about 10 hours of travel time), and he participated the following morning in that judicial hearing in his pro se capacity (acting without attorney assistance) in the circuit court judge's judicial chambers.
     During the Motion for Summary Judgment hearing, Lonnie Willoughby was the Counterclaim Plaintiff.  The attorney that had filed the Motion for Summery Judgment claimed during the motion hearing that Willoughby's Counterclaim Complaint had been filed too late, after the relevant Statute of Limitations had expired. 
     Defendant Willoughby had carefully researched previous appellate court decisions regarding that issue, and he had found three Florida appellate court decisions that explained why the Statute of Limitation time limit would automatically be extended if a related appeal case had been in progress during that time period.  The Statute of Limitations time period would not begin to run until the related appeal case was decided. 
     During his verbal defensive argument presentation to the presiding judge, Willoughby presented photocopies to the judge of three relevant appellate court case law decisions that each showed conclusively that the Statute of Limitations had not expired when Willoughby's Counterclaim Complaint was filed - due to appellant Lonnie Willoughby's previous relevant appeal case circumstances. 
    Appellant Lonnie Willoughby's appeal case had extended the Statute of Limitations timing deadline for the filing of Willoughby's Counterclaim Complaint against his former "defense attorney" for deceit, fraud, and legal malpractice (actions and in-actions that had been involved in an equity court case that had occurred in that county back in 1989) - that then had an appeal case that was settled in year 1990
     At the end of the motion hearing, the judge did not announce a verbal decision about the attorney's Motion for Summary Judgment, but it was very clear that the judge should deny the motion (the three appellate court case law decisions that Lonnie Willoughby had given copies of to the judge made that a very easy decision). 
     The formal transcript of that motion hearing proved clearly that Counterclaim plaintiff Lonnie Willoughby had given the circuit court judge photocopies of three controlling Florida appellate court case law decisions that showed very clearly that the Statute of Limitations had not run (expired) at the time that Lonnie Willoughby filed his Counterclaim Complaint against his former "defense attorney." 
      Lonnie Willoughby then traveled the 450 miles back to his home in Mauldin, SC, knowing that the judge should deny the attorney's Motion for Summary Judgment
     Lon Willoughby realized that if that motion was improperly approved, it would dismiss his legitimate Counterclaim complaint against his former "defense attorney" for deceit, fraud, and legal malpractice
      When Lonnie Willoughby subsequently received the judge's order via U.S. Mail regarding that circuit court's motion hearing, the judge had knowingly and willfully failed to comply with the three controlling appellate court case law decisions that Willoughby had given photocopies of to the judge during that motion hearing. 
     The judge had no judicial authority to ignore those three controlling appeal case law decisions, but he knowingly and willfully ignored them and improperly ruled in favor of the attorney's Motion for Summary Judgment
     The judge's order had dismissed Willoughby's Counterclaim Complaint against his former "defense attorney" for his deceitful and fraudulent attorney actions that had caused co-trustee Lonnie Willoughby to lose in a one-day civil equity court trial (no jury) in September 1989 that the attorney should have won for co-trustee Lonnie Willoughby.  Therefore, Willoughby's very serious legal malpractice complaint was a responsible valid complaint against his former trial "defense attorney."
     The photocopies of three relevant appellate court case law decisions that Lon Willoughby had presented to the judge during the motion hearing were controlling appellate court case law decisions
     The circuit court judge had no ethical judicial option except to comply with each of those three controlling decisions - all three Florida appellate court decisions reported the same outcome for such circumstances regarding a Counterclaim filing date when a related appeal case was pending court action. 
     Each of those three appeal case decisions showed conclusively that the filing date for Lonnie Willoughby's Counterclaim Complaint against his former "defense attorney" had been extended until the related appeal case decision was rendered.  Therefore, his Counterclaim Complaint was not time-barred by the usual Statute of Limitations time period.  (The Statute of Limitation time period had been extended due to the time that it took for Willoughby's related appeal case to be concluded.)
     However, the circuit court judge, who was a former state prosecuting attorney, and the former defense attorney had collusively lied about the circuit court's judicial decision when they both totally ignored the three relevant controlling appellate court case law decisions that Willoughby had given photo copies of to the judge.
     NOTE:  In Florida, the winning attorney in a motion hearing, or in a trial court's Final Judgment, has the standard duty to draft the court's decision order for the judge's signature.  That is how Lonnie Willoughby knew that the attorney and the judge had collusively lied about the Summary Judgment decision
     They were both involved in finalizing the wording in that Summary Judgment judicial order (which had knowingly and willfully improperly ignored the three controlling appeal case law decisions that Willoughby had given photocopies of to the judge). 
     The judge's corrupt order granted the attorney's Motion for Summary Judgment.
     On appeal of that corrupt order, Appellant Lonnie Willoughby presented an official transcript record of the Motion for Summary Judgment hearing - the transcript that defendant Lonnie Willoughby had purchased from the official court reporter that he had responsibly scheduled to transcribe that very important motion hearing
     The official transcript record proved conclusively that defendant Lonnie Willoughby had presented the judge with a photocopy of three specifically cited relevant appellate court case law decisions that had clearly proven conclusively that the Statute of Limitations had not expired at the time that Willoughby's Counterclaim Complaint was filed against his former "defense attorney." 
     The three appeal case law decisions showed that there were some special timing considerations involved because appellant Lonnie Willoughby had a relevant appeal case that affected the Statute of Limitations timing for his subsequent Counterclaim Complaint filing deadline.    
     Consequently, the Fifth District Appellate Court ruled in appellant Lonnie Willoughby's favor about that corrupt Motion for Summary Judgment Order.  That appeal case decision properly reinstated Willoughby's Counterclaim Complaint (that had been dismissed by the circuit court judge in an outrageously unfair, unethical, and clearly dishonest and fraudulent corrupt judicial manner). 
     It is very important to report that the three-judge appellate court panel did not responsibly initiate an investigation of the criminal law violations that were clearly involved with the attorney's deceitful unethical litigation actions and the judge's deceitful and unethical corrupt litigation actions in drafting, preparing, and filing a clearly corrupt and fraudulent Summary Judgment Order
     The three appellate court judges had all of the documentary evidence that they needed in the Record on Appeal to justify initiating a very important investigation of the criminal law violations involved with the preparation and filing of that corrupt and fraudulent order.  However, the record shows that they knowingly and willfully  ignored those very serious criminal law violations (preparing and filing a known unfair, unethical, corrupt and fraudulent Summary Judgment Order).  The three appellate court judges took no reasonable and responsible judicial actions to initiate a criminal law investigation of that very serious criminal activity. 
     The three appellate judges obviously chose to ignore those very serious criminal-law violations by a Florida circuit court judge and a prominent Florida attorney
     That judicial situation illustrates how disgustingly corrupt the judicial system can be any time judges choose to ignore unfair, unethical, and very serious criminal litigation actions by members of the "legal brotherhood." (attorneys and judges)

Criminal Contempt of Court - Appeal
     The second relevant appeal case that was reported by Lonnie  Willoughby in his pro se legal brief to the South Carolina Appellate court was an appeal decision in Lonnie Willoughby's favor from a Florida appeal process about a Criminal Contempt of Court conviction.  
     That case had been improperly and corruptly prosecuted against non-resident Lonnie Willoughby in 1994 by an extremely unfair, unethical, and corrupt County Court Judge with the help of the local county's "state prosecuting attorney" whose assistant prosecuting attorney had prosecuted the outrageously unfair, unethical, and fraudulent Criminal Contempt of Court Complaint against defendant Lonnie Willoughby (who lived in Mauldin, SC). 
     The County Court Judge's Criminal Contempt of Court Complaint alleged that Lonnie Willoughby had violated a Circuit Court Injunctive Order when he wrote a brief partial-page letter to a Florida judge, explaining that he had been unable to find a local attorney willing to represent him in further civil actions in the local county court. 
     The Circuit Court's Injunctive Order had unfairly and improperly ordered defendant Lonnie Willoughby to not file any more pro se pleadings in the circuit court case in that Florida county. 
     NOTE:  A pleading is a document that attempts to move the litigation process forward in some way - such as a motion that requests some specific judicial action in the case. 
     Therefore, Willoughby's brief letter of communications to a relevant judge was clearly "not a pleading" and it was not filed in the circuit court (which is the court that the Injunctive Order was applicable to).  Consequently, Willoughby's short letter did not violate the circuit court's injunctive order.
Flashback Information
About the Injunctive Order

     The extremely unfair and unethical successor circuit court judge had made some unfair, unethical, and fraudulent statements of fact in that Injunctive Order to maliciously and ruthlessly tar-brush non-resident defendant Lonnie Willoughby badly.  Those statements severely prejudiced the Injunctive Order against litigant Lonnie Willoughby, in the event that he might appeal the extremely unfair, unethical, and fraudulent Injunctive Order.
     That successor circuit court judge had replaced the previous circuit court judge that was recused from the same case due to unfair and unethical judicial actions that were alleged by defendant Lonnie Willoughby in his timely proper Motion to Recuse The Judge - which complied with proper procedures. 
     That was the same circuit court judge that Lonnie  Willoughby later won his appeal case about the judge's unfair, unethical, and fraudulent Summary Judgment Order that was reported above. 
     Willoughby's appeal case about that Order was in the appellate court in Daytona Beach, Florida, but the appeal decision was not rendered until many months after the successor judge had had been assigned to the case.
     Non-resident defendant Lonnie Willoughby also filed a timely responsible pro se motion that moved the circuit court judge to recuse himself from the case.  The judge apparently recognized that litigant Willoughby properly reported in some detain the unfair, unethical, and corrupt judicial actions that the judge had taken in the circuit court case. 
     The judge apparently realized and agreed that litigant Willoughby has recognized and reported competently why the judge should recuse himself from the case and he promptly did so without taking any further judicial actions in the case.  .
    That is why the judicial system appointed a successor judge to continue with judicial actions in that case. 
Actions by the Successor Circuit Court Judge 
    The special judicial system provision that authorized and enabled defendant Lonnie Willoughby to file his detailed motion to recuse the circuit court judge also authorized and enabled defendant Willoughby to file a series of  motions that moved the successor judge to review and rescind any orders that had been issued by the recused judge that were unfair or unethical toward defendant Willoughby.  He promptly filed five motions for the successor judge to review and rescind five separate orders that had been filed in the case. 
     The successor judge refused to review those five orders and take judicial actions to rescind those five unfair, unethical, and offensive orders.  He improperly indicated that he could not do that - even though defendant Willoughby had cited and quoted the special judicial system provision that authorized a successor judge to take those judicial actions. 
     Lon Willoughby then filed those same five motions again but provided additional argument information to show why the five orders were very unfair and unethical toward Willoughby. 
     The successor judge again refused to review those five orders and take judicial actions to rescind those five unfair, unethical, and offensive orders.  He again improperly indicated that he could not do that - even though defendant Willoughby had cited and quoted the special judicial system provision that authorized a successor judge to take those judicial actions. 
     Lon could have appealed that improper judicial action, but an appeal is a complex litigation action that is also time consuming and expensive and generally takes months to get an appeal decision. 
     Plaintiff Lonnie Willoughby was also very busy at that time trying to prosecute his federal civil case in the federal court located in Jacksonville, Florida against five Florida attorneys.  He had no time to get involved in prosecuting another appeal case in his pro se capacity
     Defendant Lonnie Willoughby realized that the successor judge was retaliating against him for having caused the recusal of the former circuit court judge, and for litigant Willoughby's filing of an appeal that exposed to the appellate court the criminal-minded collusive actions of that judge with the extremely unfair and unethical criminal-minded collusive actions of the plaintiff attorney that was also involved in that criminal-minded fraudulent judicial action.  (Filing a clearly unfair, unethical, corrupt and fraudulent judicial order is a crime in Florida.)
     The successor circuit court judge apparently did not want to have to contend with any more of defendant Lonnie Willoughby's responsible pleading reports about an unfair, unethical, and corrupt attorney actions in the current case.
     Lon Willoughby will now illustrate just how extremely unfair, unethical, and corrupt the successor circuit court judge was on that day (December 12, 1984). 
     The (outrageously unfair, unethical, and corrupt) plaintiff attorney had filed nine motions (moving the judge to take certain legal actions in the case) that were scheduled to be presented to the successor judge on that day in a morning motion hearing.  
     In a motion hearing, the litigant that files a motion has an opportunity to present aural argument as to why the motion should be granted (the filed motion presents the party's written argument issues for each motion).
    The opposing party (Lonnie Willoughby) then has an opportunity to present aural argument (and written argument) that explains to the judge why he should not grant the legal actions that are requested by the opposing party (in this situation, the plaintiff attorney and his law firm).  This procedure is followed for each successive motion until all of the plaintiff's motions have been argued in sequence.
     Defendant Lon Willoughby had also filed seven motions (asking the judge to take certain legal actions in the case) that were also scheduled to be presented to the successor judge on that day in an afternoon hearing. 
     Consequently, each party, the plaintiff law firm and defendant Lon Willoughby,  needed to be prepared to present supporting aural argument or defensive aural argument about each of those 16 motions during the lengthy motion hearing scheduled for that day.  However, there was a huge difference between the two opposing parties during that motion hearing. 
     The plaintiff law firm's attorney simply walked across the street, from his law firm office, to the Putnam County Courthouse to participate in that lengthy motion hearing.
     Non-resident defendant Lonnie Willoughby, living in Greenville County South Carolina, had driven 450 miles to Palatka, Florida to participate in that very complex motion hearing (with 16 motions - nine by the plaintiff and seven motions by defendant Lonnie Willoughby).  That was approximately a ten hours drive.
     During the morning motion hearing, the successor judge allowed the plaintiff law firm's attorney to present his argument for each of his nine motions, and the judge also heard defendant Willoughby present his arguments opposing each of those motions, if there was any opposition.  The motion hearing was ended for the plaintiff at lunch time. 
     After lunch, the successor judge started the motion hearing for defendant Lonnie Willoughby.  Lon Willoughby began presenting his argument for his first motion, and the judge interrupted his argument very quickly by saying "Mr. Willoughby, your motion doesn't tell me what action you want me to take."
     Defendant Willoughby said calmly, "Sir, page three explains what action I requested for this motion."  The judge then became very irritated (for no known reason), and he immediately terminated the afternoon motion hearing without allowing defendant Willoughby to complete his aural argument for his first motion. 
     He did not allow defendant Willoughby to present any additional aural argument about his remaining five motions.   The motion hearing was ended abruptly with no explanation.  Defendant Willoughby had spent many hours developing the written argument presented in his seven motions (the original motions had been filed with the Putnam County Clerk of Court), and the successor judge had them in front of him during the afternoon motion hearing. 
     He interrupted defendant Willoughby claiming that he had failed to explain what action he wanted the judge to take regarding that first motion when it was clear that he had not even read the short motion. 
     Lon Willoughby left Palatka that afternoon having no idea what the judge was going to do next.   He had a 450 mile trip to get back to his home in Greenville County South Carolina.  
     When Lon Willoughby later received a mailing from the successor judge, he had issued an Injunctive Order that prohibited defendant Lonnie Willoughby from filing any more "pleadings" in the case unless the pleading is signed by a Florida attorney that was representing defendant Willoughby.  
     The injunctive order also contained some unfair and unethical false statements about defendant Willoughby that clearly attempted to "tar brush" him badly so it would likely be impossible for him to win an appeal case about those extremely unfair judicial actions. 
     Note:  A pleading is a written and filed litigation document that attempts to move the litigation in the case forward in some way.       
     On the same date as his malicious and ruthless retaliation "Injunctive Order" was filed, the successor circuit court judge also transferred the circuit court civil action case down to the county court for further litigation actions related to the plaintiff law firm's still remaining lawsuit against non-resident defendant Lonnie Willoughby. 
     The successor judge apparently assumed that defendant Lonnie Willoughby would lose the appeal that he had pending action in the Fifth Circuit Court of Appeal in Daytona Beach, Florida. 
     The plaintiff law firm was attempting to collect about $3,280 in attorney fees that Lonnie Willoughby, Jr. had refused to pay due to the former "defense attorney's" extremely deficient, unfair, unethical, corrupt, and fraudulent "defense attorney" services during the equity court trial conducted on September 8, 1989. 
     The only reason that the case was in the circuit court, rather than in the county court (where the case had been properly filed), was because of Lon Willoughby's Counterclaim Complaint against Lon's former "defense attorney" and his law firm claimed a damage amount that exceeded the $25,000 limit of the county court's constitutional authorized jurisdictional dollar limit. 
     The dollar value involved with Lon's Counterclaim Complaint greatly exceeded the $25,000 dollar value limitation of the county court's subject-matter jurisdiction.  Therefore, the initial county court case  had been properly transferred to the circuit court's jurisdiction due to Lon Willoughby's Counterclaim Complaint value being much greater than $25,000. 
     The Summary Judgment Order issued in June 1993 had dismissed Lonnie Willoughby's Counterclaim Complaint so there was now no required reason for the case to remain in the circuit court.  The case could be transferred back to the county court.
     At that point in time, Willoughby's appeal about the corrupt Motion for Summary Judgment order was in the appellate court but that appeal had not been decided by the appellate court.
    NOTES:  Non-resident defendant Lonnie Willoughby did timely file an appeal of the extremely unfair, unethical, and corrupt and fraudulent "Injunctive Order." 
     His appeal brief argued that there was no valid evidence in the limited records of those litigation events to support the circuit court judge's unfair, unethical, and fraudulent "tar-brushing" false statements of fact contained in his unfair, unethical, fraudulent, and improper Injunctive Order
     Months later, Lonnie Willoughby lost that appeal, due to the judge's unfair,  unethical, and false statements about defendant Lonnie Willoughby in the Injunctive Order.  The unfair, unethical, and fraudulent "injunctive Order" was affirmed by the appellate court judges with no written opinion for the appeal. 
     The three-judge appellate panel simply white-washed the unfair, unethical, and fraudulent actions of the successor circuit court judge.  They obviously "believed" his unfair, unethical, and fraudulent "tar-brushing" statements of fact against defendant Lonnie Willoughby (just as that judge had apparently intended).
     The successor circuit court judge realized (when he wrote that unfair, unethical, and fraudulent Injunctive Order), and the three appellate court judges realized, and Lonnie Willoughby also realized that the "Injunctive Order" had effectively swept away Lonnie Willoughby's very valid and very strong Counterclaim Complaint case against co-trustee Lonnie Willoughby Jr's former "defense attorney." 
     These litigation actions clearly illustrate how outrageously unfair and corrupt trial court judges can be whenever they choose to protect unfair and unethical attorneys from fair and reasonable complaints from attorney clients that have been unfairly and fraudulently represented by an attorney during litigation actions.  Those "protective judicial actions" help keep the cost of "legal malpractice insurance" as low as possible for practicing attorneys (lawyers). 
     This situation identifies clearly the terrible "conflict of interest" that trial court judges and appellate court judges have when adjudicating a case that involves complaints about attorney deceit, fraud, and legal malpractice.
     Lon Willoughby has learned that trial court judges, and appellate court judges, can willfully protect members of the "legal profession" from severely abused clients any time they choose to act in this manner.  You can see that such judicial actions help trial attorneys keep the cost of "legal malpractice insurance" at a lower rate.
     Due to the effects of the Injunctive Order, Lonnie Willoughby could no longer prosecute his Counterclaim Complaint pro se in the circuit court (even though Lon later won his appeal of the fraudulent Summary Judgment order and got his Counterclaim Complaint case reinstated in the circuit court for further litigation). 
     But Lonnie would now have to find a Florida trial attorney to agree to represent him in that dispute, and that attorney could charge him many thousands of dollars for that representation and still betray him in the litigation process, causing him to lose the case.
     Lonnie Willoughby had sufficient litigation experience to realize that it would be essentially impossible for him to find a competent trial attorney in the local area willing to represent him in his Counterclaim Complaint against a prominent local law firm and it's owner attorney (Co-trustee Lonnie Willoughby, Jr's former defense attorney) in the extremely unfair and corrupt one-day equity court trial (non-jury trial) conducted on September 8, 1989.
     All of the judges involved in the litigation knew (trial court judge and appellate court judges), and Lonnie Willoughby knew, that it would be impossible for him to find a Florida trial attorney who would responsibly present a "fraud, deceit, and legal malpractice" Counterclaim Complaint litigation case against a prominent local law firm and its prominent attorney owner.  
     There may be only one or two attorneys in an entire state who might be willing to attempt to do that for a wealthy resident client, but they certainly are not going to do that for an unknown and not wealthy non-resident client who lives in a distant state. 
     They certainly are not going to agree to represent a distant out-of-state client who has also demonstrated that he is capable enough in litigation to represent himself pro se in complex litigation actions.
     Lon Willoughby has proceeded pro se in several motion hearings, including a Motion for Summary Judgement litigation proceeding before a circuit court judge.  He successfully filed a complex Motion for Recusal of a Circuit Court Judge.  
     He also did the complex and difficult legal work pro se of preparing and filing and prosecuting successfully a very important appeal case that exposed the unfair, unethical, fraudulent, and outrageously corrupt actions of the circuit court judge (who was formerly a state prosecuting attorney) and the local prominent law firm and its prominent owner attorney that were collusively involved together in the criminal-minded fraudulent Summary Judgment Order that was signed and filed by the circuit court judge.
     Even if Lon Willoughby could locate an attorney at some distant location in that state who said that he would competently and responsibly represent Lonnie Willoughby in that type of legal malpractice litigation, Lon would have to contend with the very high costs involved with that type of litigation action. 
     Lon would also have to consider that the attorney would likely betray Counterclaim Plaintiff Lonnie Willoughby during the litigation process, just as two previous attorneys had betrayed him during much less difficult litigation circumstances.
     1.  The first attorney betrayal was in the civil equity court one-day circuit court bench trial (September 8, 1989) - the corrupt prominent "defense attorney" that betrayed defendant co-trustee Lonnie Willoughby by willfully allowing the opposing attorney (plaintiff's attorney) to ruthlessly ambush co-trustee Lon Willoughby with surprise "ambush" complaint issues during the trial.
     That same attorney was later involved in the extremely unfair, unethical, and outrageously corrupt  Summary Judgment litigation in June 1993
     2.  The second attorney betrayal was the appellant attorney that was supposed to represent Appellant Co-trustee Lonnie Willoughby's in the appeal case that followed the unfair, unethical, and outrageously corrupt circuit court trial on September 8,1989.
     In essence, Lonnie Willoughby realized that the circuit court judge's unfair, unethical, and fraudulent "Injunctive Order" was a fatal blow to his very valid and very strong Counterclaim Complaint - which could have brought him a jury judgment of $600,000 (or more - with punitive damages considered properly).
Flash Forward to the
Criminal Contempt of Court Issue
     Lonnie Willoughby did not appear and participate in the "trial" scheduled for that prosecution in the County Court because Lon realized that this was an extremely unfair, unethical, fraudulent prosecution case, and if he appeared at the trial, he would be convicted in the trial and would then be immediately arrested and then quickly be incarcerated in the local Putnam County Jail (for months).
     However, by USPS mail, defendant Willoughby timely appealed the County Court Order that denied his Motion to Dismiss the Criminal Contempt of Court prosecution against him.
     Appellant Willoughby's appeal brief argued that the alleged contempt of court action was not a violation of the circuit court's Injunctive Order.  Mailing a simple partial-page short letter to a relevant judge, reporting that he had not been able to locate a local attorney willing to represent him in further civil litigation in the county court, was not a "pleading" in the relevant circuit court case.  (The circuit court case involved with the Injunctive Order.)
     Consequently, there was no violation of the Circuit Court's Injunctive Order (that had unfairly and improperly denied non-resident litigant Lonnie Willoughby his constitutionally protected right to file pro se pleadings in the Circuit Court case). 
     Appellant Willoughby's appeal brief also argued that the County Court Judge did not have subject-matter jurisdiction to attempt to enforce a circuit court's Injunctive Order
     The circuit court has authority to enforce its own Injunctive Order, and it was clearly an improper judicial action for a county court judge and the local county's "state prosecuting attorney" to attempt to prosecute non-resident litigant Lonnie Willoughby for an alleged violation of said circuit court's Injunctive Order
     The case had clearly been transferred from the circuit court to the county court.  There was no litigation going on in the local circuit court about that case so Lonnie Willoughby had not attempted to file any pleading in the inactive circuit court case. 
     Defendant Lonnie Willoughby did have an appeal in progress for that circuit court case, but that appeal decision had not been rendered at that time.  (That was Lon Willoughby's appeal that reported the fraudulent Summary Judgment Order.)
     Lonnie Willoughby won his appeal case about the Criminal Contempt of Court prosecution - the appeal case where he was opposing, in his pro se capacity, the state's local county "prosecuting attorney." 
     The single circuit court judge, sitting as the appellate court judge, ruled in Lonnie Willoughby's favor in that appeal about the Criminal Contempt of Court prosecution
     The appeal judge dismissed the Criminal Contempt of Court prosecution case against non-resident Lonnie Willoughby - primarily because the county court judge did not have subject-matter jurisdiction of the alleged violation of the circuit court's Injunctive Order
     If there was an alleged violation of the circuit court's Injunctive Order, that alleged violation would have to be prosecuted in the circuit court, not in the county court.
     That appeal decision was not a published case law decision because a circuit court's appeal decision is not published in law books (like an appeal decision in the Fifth District Court of Appeal would be published).
     Consequently, Lonnie Willoughby, proceeding pro se as the legal representative of Appellant ABC's of Health, Inc. in the South Carolina Appellate Court case, could not research that appellate court decision on the Internet in Florida law books, like he had done for the first appellate court decision that is reported above (the unfair, unethical, and fraudulent Summary Judgment Order appeal decision). 
     That 1994 circuit court appeal decision was filed in a storage warehouse and Lonnie Willoughby did not have several hours of time to search for that old one page circuit court order that was more than 20 years old. 
     Lon Willoughby therefore had to report to the South Carolina Appellate Court his memory of that appeal case.  He had won that appeal in the Florida circuit court, while litigating pro se against the local county's "state prosecuting attorney."
Critically Important Relevance 
     The critically important relevance of those two appeal cases to the instant appeal action in the South Carolina Court of Appeals is this:  Willoughby could not have won either of those appeal cases if those same legal issues had been litigated in South Carolina.
     The Supreme Court of South Carolina had improperly denied all appellants in this state the right to present their own appeals in their pro se capacity.  Consequently, in each of those litigation situations, Lonnie Willoughby would have clearly lost each of those appeal cases if he had been unable or unwilling to spend thousands of dollars on attorney representation fees for each of those appeal cases.
     The South Carolina Appellant Court system would have dismissed both of Lon Willoughby's appeal cases unless he had retained SC attorney services to represent him in each of those two appeal cases.
     Even if Lonnie Willoughby had been able and willing to spend  thousands of dollars on each of those two appeal cases, there is no assurance that an appeal attorney would have won either of those appeal cases while representing Lonnie Willoughby.  However, Lon Willoughby won both of those appeal cases representing himself pro se in the respective Florida appellate courts. 
     Would a retained attorney have represented appellant Lonnie Willoughby in an honest, competent, and responsible manner against extremely unfair, unethical, and corrupt trial judges?  Not likely!!!
     The first appeal case involved an extremely unfair, unethical, and criminal-minded circuit court judge and an extremely unfair, unethical, and criminal-minded local attorney. (The extremely unfair, unethical, and fraudulent Summary Judgment Order appeal case.)
     In Lon's second appeal, an extremely unfair, unethical, and corrupt county court judge was involved (Criminal Contempt of Court case against non-resident Willoughby).  That appeal case also involved an unfair, unethical, and corrupt local county "state prosecuting attorney."  (Similar to a solicitor in South Carolina.) 
     Based upon Lon Willoughby's previous experiences with a very prominent and experienced attorney (20+ years of trial court experiences) in a civil trial court equity court litigation, and also in the appeal case that followed that extremely unfair, unethical, and corrupt circuit court litigation, Lonnie Willoughby would have lost in both of those appeals because he would have very likely been betrayed by his appeal attorney in each of those appeal cases. 
     Remember that Lonnie Willoughby had been ruthlessly betrayed by his retained attorney in each of the cases reported previously herein (the circuit court trial court case in September 1989 and the appeal case that followed that extremely corrupt trial court case in year 1990.
     In the Motion for Summary Judgment case reported above, Lon Willoughby would have lost his Counterclaim Complaint against his former "defense attorney" for deceit, fraud, and legal malpractice if he had appealed similar judicial actions in South Carolina.  Why?  Because the Supreme Court Justices in SC have improperly prohibited litigants from presented their appeal cases pro se.
     In the Criminal Contempt of Court case, if Lonnie Willoughby had tried to appeal that improper conviction in the SC judicial system, his pro se appeal actions would have been improperly dismissed, and he would have had to spend months in a county jail when he had actually done nothing wrong.
     That tragic situation would have totally destroyed the  independent corporately owned health and wellness products retail store, causing Lon Willoughby and his wife Janie to lose hundreds of thousands of dollars that they had invested in that health store business.
     Lon Willoughby's pro se reporting of those two relevant appeal cases in his SC appeal case showed that it is an extremely unfair and undesirable situation for a state's judicial system to routinely deny litigants an opportunity to represent their own cases in their pro se capacity - either as a plaintiff or as a defendant in the trial court - or as an appellant or as a respondent in an appeal case. 
     Those pro se actions will likely be the most reliable way to get the whole truth before the respective court about very important issues involving unfair, unethical, and corrupt attorney (lawyer) actions or judge actions. 
     Is that the "real reason" that SC litigants have been denied their clearly constitutionally protected right to proceed in their pro se capacity?  That unfair and unethical restriction does not occur in any federal court.
     With all of that very important reporting of relevant issues by Lonnie Willoughby to the South Carolina Appellate Court judges, they apparently ignored all of Lon Willoughby's responsible pro se reporting on appeal in the appeal case reported herein.
     The 30-day time period expired and the Appellate Court mailed  Lonnie Willoughby another letter that stated that his pro se appeal case had been dismissed because Appellant ABC's of Health, Inc. did not have attorney representation for the appeal case.
     The detailed appeal brief that Lonnie Willoughby had filed, showing why it was very important for him to be able to proceed pro se in the appeal case was apparently ignored by the appellate court judges - because they did not certify this dispute issue for consideration by the Supreme Court, - as clearly requested in Lon Willoughby's detailed relevant appeal brief
That was the end of the appeal process
for the ABC of Health appeal.
     That was the second time that Lonnie Willoughby had directly challenged, in his pro se capacity, the validity of the high court's previous case law decisions (two cases) that claimed that a litigant in a circuit court civil case must be represented by an attorney, and inferring that an appellant in a circuit court appeal (appeal from a Magistrate Court Final Judgment) must have an attorney represent them on appeal, and also proclaiming that an appeal to the Appellate Court of SC, or the Supreme Court of SC, must also be represented by a licensed attorney in SC.
     In both SC appeal cases filed by pro se by Lonnie Willoughby, the judges in the Appellate Court (and in the S.C. Supreme Court) ignored their clear duty to acknowledge and comply with the directive in Art. I, Section 14 of the Constitution of South Carolina. That Article clearly protects the right of every person to be fully heard in his defense by himself or by his counsel or by both.
     Article I, Section 14 of the SC Constitution makes it very clear to persons of ordinary intelligence that the SC Constitution clearly intended to prevent the current judicial situation - where litigants are denied their protected right to present their own pro se legal arguments and cases by themself, or present their legal arguments by an attorney, or have both situations (their pro se representation and the attorney's helpful representation).
     Willoughby has now gone through the appeal process in South Carolina two times, challenging the high court's erroneous and improper case law decisions about that very important issue
     He found that local circuit court judges were disgustingly unfair, unethical, and corrupt in an extremely "autocratic, elitist, despotic self-serving manner" toward him as a pro se litigant. They seem to enjoy deviant despotic judicial behavior that ruthlessly corrupts a judicial process in an extremely unfair and unethical manner.
     If a litigant is not financially able, or is not willing to spend several thousand dollars to retain an attorney to represent them in circuit court litigation, or in an appeal process in the circuit court, the circuit court judge will probably act in an autocratic elitist despotic manner and dismiss the civil case, or dismiss an appeal case, no matter how strong the documentary evidence is in support of the pro se litigant's Complaint legal brief, or in the pro se litigant's Memorandum of Law for an appeal case. 
     In either case, in a Circuit Court trial case or in an appeal case conducted in the Circuit Court, it doesn't really matter how strong the cited legal case law decisions are that support the pro se litigant's trial court case or support the pro se appellant's argument issues on appeal - the circuit court judge will very likely ignore the S.C. Constitution's mandate about the litigant's right to represent his own case pro se, with or without attorney assistance.  See quotation information below.
     Art. I, Section 14 shows that the S.C. Constitution clearly protects the right of every person to be fully heard in his defense by himself or by his counsel or by both.
     It is very clear to Lonnie Willoughby that the Supreme Court of South Carolina has no subject-matter jurisdiction to change any portion of the State's Constitution.  It is also clear to Willoughby that the State's Supreme Court has no legitimate authority to ignore that critically important portion of the SC Constitution.
     As shown herein, in an appeal proceeding, the appellate judge can be so unfair, unethical, and dishonest that the judge will stubbornly refuse to honestly and ethically acknowledge any serious judicial error in the Magistrate Court proceeding below. 
     In the instant appeal case for ABC's of Health, Inc., the circuit court judge acted in a grossly dishonest self-serving manner (for benefit to the legal profession) by falsely denying that the trial court judge's extremely incompetent judicial actions during trial had caused sufficient damage to the trial to justify a new trial.
     The "appeal court judge" was so unfair, so unethical, and so corrupt in a grossly self-serving manner that he apparently did not even care that his corrupt judicial actions were extremely unfair, unethical, and despotic toward litigant Lonnie Willoughby, Jr., as president of ABC's of Health, Inc.
     It is very clear that appellant ABC's of Health, Inc. lost in the appeal case (in the circuit court appeal) even though the defendant LLC (the Respondent) did not file an opposing appeal brief.
     Consequently, all of the "record evidence" before the appeal court judge strongly supported the appellant's request for a new trial.  Furthermore, all of the legal citations and quotations of relevant legal standards also strongly supported the appellant's request for a new trial. 
     With all of that relevant information strongly supporting the appellant's eleven (11) argument issues for a new trial, the appellate court judge (circuit court judge) unfairly and unethically and despotically denied the appellant's appeal arguments, and thereby refused to order that a new trial be granted. That is outrageously unfair and unethical appellate court action for an appeal case. 
     At that point in the appeal process, Appellant ABC's of Health, Inc. had no viable alternative action except to appeal that obviously unfair, unethical, and corrupt "appeal decision" to the Appellate Court of South Carolina, as related above.
     Appellant Lonnie Willoughby, Jr. (Lon) had taken an earlier appeal case to the Supreme Court of South Carolina (in year 2003) because he was disgusted with the unfair, unethical, and corrupt elitist autocratic despotic judicial actions of the circuit court judge in that civil case. 
     Willoughby's Final Appeal Brief to the high court (filed pro se in year 2003 - without attorney assistance) requested that the circuit court order be reversed, and also requested that the despotic trial court judge be removed as a circuit court judge.
     Lonnie Willoughby discovered with that appeal case that the justices of the SC Supreme Court were also unfair, unethical, and disgustingly dishonest (corrupt) in an elitist, autocratic, despotic, self-serving manner.  They knowingly and willfully violated their oath of office regarding their duty to comply with the judicial standard that is stated clearly in the Constitution of South Carolina at Art. I, Section 14. (quoted above)
     If the five justices had honestly and responsibly acknowledged that relevant cited and quoted constitutional judicial standard, the five justices would have ruled in the appellant's favor, enabling  the appellant to win that very important appeal case
     However, the five justices unfairly and unethically agreed to deny that appeal case - their collusive action totally ignored the clearly cited relevant judicial standard in the SC Constitution  at Art. I, Section 14
     They obviously ignored the cited relevant judicial standard and pretended that the quoted standard did not actually exist in the SC Constitution.  But the five justices knew that the cited and quoted legal standard did exist!!!
     That extremely unfair, unethical, and despotic totalitarian self-serving judicial action by five justices of the SC Supreme Court caused the appellant to lose that appeal case, when it was very clear that the appellant should have won that very important appeal case
     That very important appeal case proved that unfair, unethical, despotic totalitarian self-serving judicial actions in South Carolina courts go all the way up into the SC Supreme Court. 
     How long have the judges and trial attorneys in South Carolina been getting away with this grossly unfair, unethical, and disgustingly corrupt despotic totalitarian monopoly type judicial situation?  About 80 years!!!!!
Removal of a corrupt Circuit Court Judge
 
     That very important appeal case was apparently helpful in getting an extremely unfair, unethical, egotistical autocratic despotic "elitist" corrupt circuit court judge in Greenville County removed as a judge in South Carolina.     
     The appellant's pro se filed appeal brief included a copy of the trial court transcript (that Lon had purchased from the court reporter).  That transcript provided indisputable official trial court transcript proof that the circuit judge was so abusive and so unfair and unethically despotic toward Lon Willoughby, as the defendant's pro se legal representative in that motion hearing, that the circuit court judge should be removed (fired). 
     The judge had many years of experience as a solicitor (state prosecuting attorney) in Greenville County, but he was so mentally despotic toward a pro se litigant (Lonnie Willoughby) that he was unable to conduct that motion hearing in a reasonably fair and ethical judicial manner.  (As president of the defendant SC corporation, Lonnie Willoughby was the pro se litigant representative for the defendant corporation.)
     The transcript record clearly proved that the judge failed to provide basic "due process of law standards" for the motion hearing.  The judge was so clearly despotic during the motion hearing that he was not ethically fit to be a circuit court judge, or to be any other kind of judicial system judge in South Carolina.
     The five South Carolina Supreme Court justices who reviewed the defendant corporation's pro se appeal brief (detailed report about the trial court's grossly improper motion hearing) did remove the despotic circuit court judge, as the appellant's final appeal brief had strongly recommended and requested.  
     Did that appeal brief and the evidential transcript record of that motion hearing help cause the judge's removal?  Apparently so, but we will never know the facts about that circuit court judge's removal. 
Avoid Travel in South Carolina
     Lon and Janie Willoughby understand why it is very important to stay within their home county (Greenville County, SC - since first moving here in September 1977).  They choose to use these travel precautions in order to minimize possible litigation actions, and also minimize litigation difficulties and expenses in South Carolina. 
     Lon and Janie also understand how hazardous and risky it can be to travel into other counties within the State of South Carolina, due to the extreme level of unfair, unethical, and corrupt judicial actions that Lon has experienced in some courts in this state. 
    Lon and Janie Willoughby understand that as one travels in South Carolina, from one location to another within one county, and when one travels into other SC counties, the magistrate court system jurisdiction is frequently changing from one location to another. 
     Lon and Janie realize that there are more than 300 magistrate court judges in this state.  Lon's limited experiences with magistrate court litigation actions left him disgusted with their level of administrative incompetence, and their lack of judicial competency, and their extreme deficiency of responsible judicial actions in a jury trial litigation process.
     Lon Willoughby has learned that Magistrate court judges have a broad assortment of judicial duties and responsibilities, and they should be respected for the broad range of judicial duties and responsibilities that they have.  It is important to understand that Magistrate court judges in South Carolina are not required to be law school graduates.
    Based upon his limited experiences with Magistrate court actions, Lon realizes that some of the technical judicial information that magistrate court judges need to learn can likely be learned on the job in a practical and sensible way by people who have demonstrated above average intelligence levels.  Lon also understands that they do have some required education and training services within the court system.
     Lon understands that not requiring magistrate court judges to be law school graduates helps greatly in reducing the potential high cost of having 300+ magistrate court judges within the state of South Carolina.
Summary of Judicial Corruption Exposure

    Lon Willoughby had reported herein very important information about how the litigation systems in the USA really work, at the State level and at Federal level. 
   He has shown how the litigation systems effectively encourage and promote unfair, unethical, and corrupt litigation practices by attorneys (lawyers), trial court judges, and appellate court judges.  That is shown because the litigation systems do not provide practical responsible punishment actions when "officers of the court" are exposed for conducting unfair, unethical, and corrupt litigation actions. 
     Lon has shown herein how attorneys (lawyers) are actually rewarded generously for having created unfair, unethical, and corrupt litigation schemes and tactics
     After thousands of hours of difficult and tedious litigation work, and nine appeal cases that Lon Willoughby prosecuted pro se, he exposed a lot of unfair, unethical, and corrupt attorney schemes and tactics
     He also exposed a lot of unfair, unethical, and corrupt judicial actions that cooperated with and improperly allowed those attorney schemes and tactics to be conducted during very important litigation actions.   Lon can honestly report that no disciplinary judicial actions were taken against any attorney or any judge during that 20+ years period of time that he has reported herein.  As far as he has seen, those attorneys and judges were essentially rewarded for their unethical actions.
     Looking back at those 20+ years of unfair, unethical and corrupt litigation actions, Lon Willoughby now considers the judicial systems that he has been confronted with in the State of Florida, and in the State of South Carolina to generally be a "criminal enterprise" conducted routinely for benefits to members of the legal profession and their employees and their associates.
     In general, Lon's extensive litigation experiences over a period of 20+ years in the State of Florida, and a few years in the State of South Carolina, found that the State controlled judicial systems in both states are a heinous FRAUD UPON THE PUBLIC. He confidently believes that similar unfair, unethical, and corrupt litigation and judicial actions are likely to occur in any States within the United States of America
     Consequently, he will not voluntarily travel in any State in the USA, and he will not likely offer our natural healthcare concepts educational services in any other State in the United States of America.  
    Lon Willoughby has limited the geographic area in this State where we offer our natural healthcare concepts educational services in selected ZIP Code areas - where natural-born American adult citizens who are Christian-oriented, and also patriotic about America, have their primary and permanent home or residence address with ZIP Codes of 296 - - or 293 - - .


Healthcare Education Services

      Being in the healthcare and wellness education business for 15+ years enabled Lon Willoughby to acquire a lot of the advanced natural healthcare and wellness concepts knowledge that Lon now presents to our "A4J club members" (qualified American adult citizens who live in selected ZIP Code areas of upstate South Carolina).   Lon Willoughby helps them learn how to take much better care of their precious natural health.

     PHONE CALLS:  We routinely prefer that inquiries to us be made by Email or by Fax because these communications do not interrupt our very busy daily work scheduleHowever, if these type communications will not work reasonably well for you, please telephone our office with your well prepared inquires. 

      If we are unable to answer the telephone at times during our business hours, it indicates that we are busy with other client services.  However, our commercial quality voice mail system will take your call, during business hours. 

      When it is convenient for you, please leave us a voice mail message about your inquiry.  We will call you back as soon as possible (at the day and time and phone number that you specify as the best way for us to try to contact you by telephone).

    Thank you for your interest in the very valuable educational services offered by Americans4Justice-SC for patriotic-minded American adult citizens living in the upstate area of South Carolina (have a permanent home address Zip Code of 296 _ _).  

     Americans4Justice is providing leadership, incentives, motivation, and guidance to patriotic-minded American adult citizens with an education services plan to help patriotic-minded American adult citizens in our local area of South Carolina protect, defend, preserve, strengthen, and improve upon the American Dream for themselves, for their loved ones, and for future generations of American citizens.

     May you live long and prosper well in good health, as a brave and courageous American patriot,

Lon Willoughby, founder and director of Americans4Justice-SC



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    4.  We promote truth as much as reasonably possible, wherever possible, and we responsibly encourage the Pursuit of Health, Wellness, and Happiness for each club member of Americans 4 Justice-SC.  

     Important words are listed below that club members are encouraged to incorporate into their belief structure and honor and strive to live by these standards on a daily basis:
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This department was updated
on December 2, 2021.