COURT INFORMATION
Trial is on December 17-19 2003 at 9:00 a.m.
Camden County Sheriff
Sheriff John W. Page (1993 - Present)
"Together We Can Make A Difference"
Phone(573) 346-2243, Fax (573) 346-2063
Email sheriff@dam.net
I have been informed that the Sheriff has changed his
email address shortly after this posting
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Meet The Prosecutor Who Will Not Prosecute The Thugs
But helps Trumps Up Bogus Charges Against Their Victim Instead
James Icengle of Camden County Mo
Phone 573 346-4440, Fax 573 346-0823
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Here Is The Court
Who hopefully, will not allow This Travesty To Go Forward
Wanda Tyree, Circuit Clerk, Laclede County Courthouse
200 N. Adams, Lebanon, Missouri 65536, (417)532-2471 (telephone)
(417)532-3683 (facsimile)
Larry Winfrey, Jr., Associate Circuit Judge
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Dr Ramona Miller's case # CR302-1508-M
Motions are to be heard on December 3rd, 2003 if needed in Lebanon Mo at 1:30 p.m.
Court Watchers Needed
Trial is on December 17-19 2003 at 9:00 a.m.
Vacationers, Come See Justice Done
Lake-Of-The-Ozarks Style Leclead Country in Lebanon, MO
______________________________________
FACTS OF THE CASE
IN THE CIRCUIT COURT OF LACLEDE COUNTY, MISSOURI
ASSOCIATE CIRCUIT JUDGE DIVISION
State of Missouri, )
Plaintiff, )
)
v. ) Court Case No.: CR302-1508M
) Motions: To Compel Discovery of Documents
Ramona A. Miller, ) To Quash or Stay Depositions
Defendant. ) To Continue
)
It is understood that Dr. Miller’s attorney is recusing himself from this matter.
Because he has scheduled a trial date without Dr. Miller’s permission and against her
specific instructions, and it does not give Dr. Miller time to prepare, a Motion to continue is included in these motions.
MOTION TO COMPEL VIA COURT ORDER, DISCOVERY OF DOCUMENTS,
[Edited]
MOTION TO QUASH OR STAY DEPOSITIONS UNTIL
AN ATTORNEY CAN BE HIRED AND PREPARED
[Edited]
MOTION TO CONTINUE THIS MATTER UNTIL AN ATTORNEY
CAN BE HIRED AND PROPERLY PREPARED FOR TRIAL
COMES NOW Ramona A. Miller, Defendant, Pro Se, and respectfully moves this court to Continue this matter until Dr. Miller can retain counsel who is not in fear of retaliation that may come upon anyone who brings forth damaging evidence against Camden County’s Sheriff’s Department. A memorandum of the facts are provided infra.
Upon advice of numerous attorneys, Dr. Miller is attempting to hire someone outside of this geographical area. Much to Dr. Miller’s surprise, her attorney had made an entry of appearance and the set a short court date and refused to prepare for trial and was insisting that he would create his strategy on the courthouse steps, indicating he was working toward rubber-stamped plea bargains, instead of actually defending Dr. Miller’s interests.
FACTS IN SUPPORT OF THIS MOTION
In May 2001, Dr. Ramona Miller was summoned to the Camden County Correctional Center (hereinafter “CCCC”) by a prisoner who was having health problems. As a part of Dr. Miller’s Osteopathic oath (similar to the Hypocratic oath), she responded to this cry for medical attention, even though she had never ventured into a prison before.
Upon examining the patient, William Mason (Case Numbers: CR2011029FX, 01-0497-CV-W-6-P, 01-0497-CV-W-6-P, and others), at CCCC, Dr. Miller discovered that the patient had serious health issues, and needed immediate hospitalization. After being stabilized, the patient was transported by ambulance and hospitalized at St. John’s Regional Health Center. The patient was admitted to Cardiology and required further treatment due to what appeared to be the extreme malfeasance and negligence by his jailers in ignoring the ordinary standard of care.
Dr. Miller also discovered that the reason Mr. Mason summoned for her assistance was because Mr. Mason knew and could prove that Camden County Sheriff's Department was full of corrupt officials, and had specific proof thereof. While awaiting transfer to the hospital, Dr. Miller was told that Sheriff Page was not going to be happy with Dr. Miller and her medical decision to transfer the patient to the hospital.
After the patient had been released back into CCCC custody, Dr. Miller was refused a follow-up visit with her patient because of an alleged change in policy requiring new physician photo identification, which was not standard issue of physicians at St. John’s Physicians & Clinics.
In connection with Dr. Miller’s work, Dr. Miller who drives a very unique and easily identifiable vehicle, was attacked by the Camden Country Sheriff’s Department while driving on the roadways. On two occasions, Dr. Miller was intentionally harassed including being run off the road by Camden County officials while they were driving in their police cars. The standard motis operandii was for the official car to zoom in behind Dr. Miller until she could not even see the headlights of the vehicle tailgating her and then the tailgater would back off from Dr. Miller. This would be repeated for several minutes and then the car would start to pass Dr. Miller and run her off the road.
On one occasion, another person witnessed this bizarre harassment. Dr. Miller’s complaint was ignored.
In the early morning hours of August 28, 2002, Dr. Miller was traveling to Versailles, Missouri (Morgan County), after finishing an evening shift at St. John’s Physicians & Clinics Urgent Care unit in Springfield, Missouri. Due to her concern over Camden Country Sheriff’s Department continuing harassment, while driving her usual route through Camden County, she noticed police activity off the side of the road and also noticed an isolated Camden County sheriff’s car parked and whose bright headlights that were shined into her driver’s side window onto her face, as she continued to drive her vehicle.
After a short while, she notice a vehicle zooming in behind her again, and where, as usuall, she could not see the headlights, and then as usual, backing off and shining its high-beam lights into her rearview mirror. This continued over the course of 10 miles. Just shy of the Morgan County line, flashing lights came on and Dr. Miller immediately pulled over. Because of the earlier harassment, Dr. Miller turned on her cell telephone calling a friend for help. Dr. Miller told her friend to tape record what happened as there would be a record of any abuses she might further experience. Dr. Miller was also asking her friend to call police outside of Camden County, and to call 9-1-1 outside Camden County in order to receive assistance and protection from the Camden County Sheriff’s Department’s abuses. Dr. Miller was in fear for her safety knowing that she had done nothing to warrant a traffic stop. Her concerns were immediately validated when the unidentified man standing by her car in pitch black darkness already knew her name and identified her as a doctor, even though he had not asked for her identification.
The unidentified person asked her to roll her window all the way down and to turn off her cell telephone. Dr. Miller stated her concern regarding rolling her window all the way down in an area known as Sunrise Beach, which was very dark and secluded without street lights and with the unidentified man shining a bright light in her eyes. Dr. Miller kept her window down approximately 1/3 of the way, kept her cell telephone on which was her only link to safety, while repeatedly asking the man what was the probable cause for him to have stopped her. The unidentified man (later claiming to be Deputy Moehle) refused to answer Dr. Miller even after she asked him and got him to focus on the question, what is the probable cause for the stop. At this point the man stood there, dumbfounded and silent for at least 15 seconds without an answer.
Without answering Dr. Miller’s question, Moehle went and called a K-9 deputy later identified as Deputy Bart Sims. Just shortly thereafter, an unidentified Laurie police car went by, however, because Laurie Police had no jurisdiction in Camden County, and because Dr. Miller could not see if this car stopped or continued on into its area of jurisdiction, Dr. Miller still could not tell if any “neutral” police were on the scene who could help her. Meanwhile, Dr. Miller continued to ask her friend to call for help from authorities outside of Camden County.
In quick sequence, Sims asked for Dr. Miller’s identification, but because Dr. Miller was concerned for her safety, she displayed her driver’s license through the window. When the officer stated he wanted Dr. Miller to hand him her license Dr. Miller complied. Instead of taking the license, however, the officer grabbed Dr. Miller by the left hand. Dr. Miller pulled her hand back into the car further putting her in fear of her safety. Dr. Miller then rolled the windows up in fear of these 2 men in this dark, secluded area, while she and her friend were trying to call for help from someone outside Camden County.
Again, in extremely quick sequence, Dr. Miller, was told she was under arrest and then within seconds he stated that she was resisting arrest. Dr. Miller again asked for probable cause as to why she was stopped, knowing she had done nothing wrong and that Moehle had performed the zooming in/backing off harassment that she had experienced in previous abuses by Camden County. Sims told her she would find out what the probable cause is in jail. At this point, Sims told the Moehle to open the passenger door with a Slim Jim and told the Laurie Police officer who must have been parked somewhere behind Dr. Miller to pull up in front of her vehicle. As this was quickly occurring, and as Dr. Miller was looking at Moehle breaking into her passenger side window, she heard and felt the impact of glass shattering on the driver’s side. As the glass poured over Dr. Miller’s head and face, the driver’s side door was ripped open, and her left arm was grabbed and jerked by Sims. As she tried to get her seatbelt off, Sims kicked her left leg so severely, that even though she had not been released from her seatbelt, her body was jerked into a head first position as she was yanked and dragged from the car. The 110 pound Dr. Miller was then thrown against her vehicle hard enough to dent it as all three officers pressed against her body and face. She was stunned and in shock. Then Sims turned Dr. Miller and rode her about eight-ten feet, drilling her into the gravel, face first, with his full body weight landing on top of her. Dr. Miller screamed in pain as her rib was broken under the force of Sim’s body weight and her right arm was struck with severe force.
While being beaten, Dr. Miller was handcuffed from behind, face down on the gravel, and was helpless. Dr. Miller not only had a broken rib, but she had a twisted left wrist due to Sim’s grabbing and twisting her hand and then when she landed on it with Sims on top of her. Dr. Miller suffered multiple injuries.
While Dr. Miller was facedown helpless and handcuffed, Sim’s then began searching Dr. Miller’s pockets, but only searched into one pocket and then rubbed her between her legs well beyond what it would take to search for objects. At this point, Sims started hovering over Dr. Miller, pointing down at her and yelling that “we’ll get your ass” and other such degrading and humiliating statements. He also stated that he wanted to make sure that she would have a criminal record that would follow her all the rest of her life.
Knowing that Dr. Miller makes a living with her hands, she was clubbed on her right arm and her hands were being rendered useless as she lie helpless on the gravel. When the officers were finished with that stage of their abuse, they lifted and carried Dr. Miller by the handcuffs, as she wenched and screamed in pain, which was totally unnecessary. Dr. Miller was taken to the Camden County Correctional Center, where she was placed into an isolated cell, and where the officers were ordered to leave her handcuffs on her even though she was incarcerated, making sure the cuffs were cutting into her circulation in her hands an additional 5-6 hours. Dr. Miller’s hands became numb and she was forced to hold her hands behind her back in a peculiar standing position in order to try to minimize the damage to her hands. In spite of her obvious injuries, she was denied medical treatment. When she specifically asked to receive medical care by a physician, she was told that she was a doctor and that she should know whether her arm was broken.
Dr. Miller remained in an isolated cell for hours. Not until close to 16 hours later, was Dr. Miller told what the charges were, after the Camden County Sheriff’s Department got their story straight. Meanwhile, Dr. Miller’s request to see a judge was also ignored.
Dr. Miller, who had not had a traffic ticket in approximately 17 years, was then given an excessive bond which kept increasing, and a warrant for her arrest was issued after the fact, while she sat handcuffed, in jail, and severely beaten at the hands of the Camden Country Sheriff’s Department. She was finally released on a $5,000.00 bond.
After her release, she was treated in the emergency room at St. John’s Regional Health Center, Springfield, MO. Dr. Miller was placed on medical leave because of the severity of her injuries, particularly those to her hands and wrists caused by the grabbing, twisting, force of landing, and prolonged use of extra tight handcuffs for 5-6 hours, all causing damage to her tendons, bones, nerves, and muscles in her hands.
Dr. Miller’s vehicle had been impounded by the Camden County Sheriff’s Department; and upon her release, Dr. Miller discovered that her medical bag, two prescription pads, medical identification, and other valuable items were missing. Dr. Miller reported this to both local and state authorities, especially since the Drug Enforcement Agency (DEA) and Bureau of Narcotics and Dangerous Drugs (BNDD) require this when the theft involves the potential for abuse of controlled drugs. Dr. Miller reported these items to appropriate authorities, but was informed by Camden County officials that no investigation would be forthcoming because the prosecuting attorney and the sheriff of Camden County refused to open an investigation of their own officers. To this date, none of the stolen items have been recovered and someone who had control of the scene is free to write prescriptions for drugs, and to utilize Dr. Miller’s identification for illegal purposes.
In summary, because Dr. Miller was just trying to uphold her oath to her profession and in doing so, treated a jailed patient who badly needed her expertise due to the poor standard of care he had received while incarcerated, Dr. Miller has been beaten, robbed, jailed, harassed, and intimidated by law enforcement officers. Dr. Miller’s ability to practice medicine has been ruined as she is unable to perform in her profession due to the intentionally inflicted abuse to her hands. If such police brutality could happen to Dr. Miller, it could happen to any one, including other physicians who are equally concerned with upholding their oaths to heal. Dr. Miller is currently facing a stacked set of charges that, if she is convicted, will set a precedent and invitation for this to happen to any one that happens to unknowingly anger Camden County law enforcement.
As for Dr. Miller, understandably, every second of this horrendous abuse has been permanently engraved in her memory due to the extreme force that was used on her small 110lb. body frame.
What happened to Dr. Ramona Miller is exactly what she feared was going to happen when she was stopped in a dark, secluded area by a Sheriff’s Department that had proven itself to be of questionable integrity in the past. Now Dr. Miller’s career is threatened, both because of her physical limitations, and because of these absurd stacked charges that threaten her license, all due to the extreme and outrageous abuses perpetrated against her by the Camden County’s infamous Sheriff’s Department. This continuing abuse must be stopped now.