Litigation Info Department

Lon's Litigation Experiences   

This Department was updated on December 11, 2023

     This report will explain some of the extensive litigation action experiences that Lon Willoughby has had, and also explain why Lonnie Willoughby, Jr., as president of ABC's of Health, Inc., will not allow any member of the legal profession (attorneys, lawyers, or judges) to participate in our Internet presented Natural Healthcare and Wellness Concepts Educational Services.  They also cannot become a member of our private education club, Americans 4 Justice-SC.

Relevant Background Information

     Lon Jr's parents, Lonnie Willoughby, Sr. and his wife Leona both grew up in North Carolina on their individual family's farm.  

     Both of those farms were in Columbus County and they were about 45 road miles from Myrtle Beach, South Carolina.  Each of those large families had multiple sons and daughters.

     Lonnie and Leona Willoughby had two children, sons named Lonnie Jr. and Larry.  Larry was about 20 months younger than Lonnie Jr. (Lon Jr.)

     The Home Department of this website explains about the Willoughby family's farm responsibilities up to the time that Lon Jr. was graduated from the Tabor City High School and went to college at Mars Hill Collage - near Asheville, North Carolina. 

     Many years later, the parents sold their well-developed farm and went into the real estate business.  Lonnie and Leona bought an established motel business in Charlotte, North Carolina. 

     The motel needed a lot of repairs and needed some business improvements.  Their plan was to work at the motel for two or three years, make the repairs and improvements that were needed, get the business operating much better, and then sell the business at a good profit. They would then try to find another motel to buy with similar objectives.

     That business plan was successful, and they moved to Florida when they purchased a motel business in St. Augustine, Florida.  They made many needed improvements to that motel business and later sold the motel at a good profit. 

 The parents then purchased another motel in Melbourne, Florida, and they repeated that business plan again over two years for another good profit.

     By that time, their two sons were established in their own careers.  Lon Jr. lived in the Greenville area of South Carolina, working with the Federal Aviation Administration (FAA) as a Proficiency Development and Evaluation Officer (PDEO) at the Greenville/Greer Airport FAA Sector Field Office. 

     Larry had completed his college education, and he and his wife Joyce owned and operated a motel business at one of the beach locations near Wilmington, North Carolina.  Larry also became a licensed real estate broker, and he began to buy and sell beach area properties.

     Prior to year 1980, both parents had become licensed real estate brokers, and the parents were living in Putnam County Florida, near the town of Palatka, which was about 65 road miles to the southwest of Jacksonville, Florida.  

     They had decided to continue living in Florida for the rest of their life because they liked the warmer winter weather better than the much colder winter weather that they had experienced for many years in North Carolina. 

     They had purchased a very good vacant waterfront lot beside the very large St. Johns River in the San Mateo area, which was about six miles south of Palatka, Florida.  They then had a modest three bedroom, two bath home with a garage built to their design specifications on that waterfront lot.

     When Lon's father was at age 66, In the spring of 1982, he had a very serious heart attack that caused him to be in a hospital in Jacksonville, Florida (about 65 road miles from their home). 

     While in that hospital, under the care of his regular heart specialist doctor who had treated his heart condition for several years, Lonnie Sr. also had a tragic stroke which caused him to be paralyzed totally on the left side of his body. 

     He had no muscle control of the left arm, or any part of the left side of his body - from his left shoulder to the tip of his toes on his left foot.  He was instantly a serious invalid and needed help with most bodily functions throughout the day and night.

     Fortunately, the stroke did not appear to have affected his very intelligent mind in any noticeable manner. 

     As soon as possible after the stroke, Lon Jr. temporarily moved his parents from their home in the San Mateo/Palatka Putnam County area to Lon's home in Mauldin, South Carolina, just eight road miles from the downtown area of Greenville. 

     During the six months period that the parents lived with Lon Jr. and wife Janie, they were able to help Lon's parents a lot with their health, physically and emotionally (mentally). 

     Lon Jr. had already learned a lot about taking good care of one's natural health, and he was a serious-minded natural healthcare enthusiast. 

     He was also able to get his father some very important healthcare services at the Roger C. Peace stroke rehabilitation center that was located at the Greenville Memorial Hospital area (about eight road miles from Lon's Mauldin area home).

     Lon Jr. helped his father get outpatient treatments for his paralysis condition on a frequent basis for several weeks at the stroke rehabilitation center.  Lon's father then got inpatient treatment for two weeks (where he lived within the rehabilitation center for additional physical stroke rehabilitation therapy on a daily basis. 

     The physical therapist technicians that worked at that special facility were able to help Lonnie Sr. a lot in learning how to cope more successfully with his paralysis condition (both physical help and emotional help).  

      He was unable to walk but they taught him how to use a special can that enabled him to have some mobility with some physical help from a person.

     During that six-month period of time, Lon Jr. learned that his parents had purchased a 44-unit apartment complex in DeLand, Florida, where Stetson University is located.  DeLand was about 50 miles south of their home in San Mateo, Florida via U.S. 17 highway.

      Lon also learned that a local DeLand, Florida bank had a first mortgage on the property for more than 600,000 dollars.  The property had four two story buildings that housed the 44 apartments.   

     Lon estimated that his parent's total estate value at that time was more than a million dollars, and he realized that his parents needed to take some important estate planning actions. 

     At one point in previous years, Lon Jr. had been a licensed life insurance sales representative, and he had studied estate planning fundamentals to some notable extent.  

     Consequently, he understood that his parent's estate value could likely benefit in some important financial respects if they implemented some good financial planning for their substantial size jointly owned estate values. 

     Lon Jr. suggested that the parents should talk with their local bank trust department (in DeLand, Florida) to obtain a recommendation for an estate planning attorney who could talk with them about their estate planning needs.

      Lon Jr. subsequently communicated by phone with the estate planning attorney that the bank trust officer had recommended.  The attorney was located in Daytona Beach, Florida, just 20 miles from DeLand, Florida.

     The attorney subsequently completed the estate planning actions by developing two mirror image Inter Vivos Trust Agreement documents (Living Trusts) - one trust agreement for each parent.   

     The parents then chose to appoint sons Lon Jr. and Larry as co-trustees of their two Inter Vivos Trust Agreements. 

     Brother Larry was not involved in any of those initial financial planning actions because he knew nothing about those estate planning complexities, and he was located in one of the Wilmington, NC beach areas (about 640 miles away from his parent's home in Putnam County, Florida). 

     After the two trust agreement documents were finalized and signed in January 1983, Lon reviewed those documents very carefully.  He gradually realized that the estate planning actions that had been implemented in January 1983 for his parents were inadequate estate planning actions for their estate planning needs. 

     The attorney had not developed any practical way for the parents' estate planning actions to help minimize federal estate taxes on their substantial size jointly owned estate values (those taxes could amount to $200,000+ at some point in the future). 

     Lon also gradually realized that the attorney had not developed any practical way for the co-trustees of the two trust agreement estates to take actions that could reduce Florida probate expenses for each parent when they died.  

     Lon had already learned that typical probate expenses in Florida on substantial size estate values were usually about 8% of a person's total net estate value. 

     By that time, Lon Jr. had learned more information about his parent's total net estate value, and he then estimated that it was about 1.2 million dollars.  That meant that eventually, Florida probate expenses for his parent's jointly owned estate value could amount to about 90,000 dollars (and maybe more than that).

     Fortunately, Lon Jr. was knowledgeable enough about estate planning to recognize those major deficiencies in the estate planning actions taken by the Florida attorney.  Consequently, Lon Jr. did not trust the estate planning attorney who had allowed those serious deficiencies in estate planning to remain in effect, without explaining anything to Lon's parents or co-trustee Lon Jr., about how they could use the two Inter Vivos Trust Agreements to substantially improve those estate planning conditions.

     The attorney apparently wanted to retain financial benefits for some member of the Florida legal profession for those potential lucrative probate legal expenses (perhaps for himself as a likely probate attorney for the two Willoughby jointly owned estate values). 

     Unfortunately, Lon found it necessary to begin searching for another Florida estate planning attorney to help his parents improve their estate planning actions so they could overcome the very serious estate planning deficiencies created by the first estate planning attorney's actions.    

     During the next 24 months, Lon Jr. had great difficulty in trying to locate another nearby Florida estate planning attorney who could/would amend the two Inter Vivos Trust Agreements for his parents to provide those badly needed estate planning improvements in the two Trust Agreement estate plans. 

     Lon Jr. discussed those estate planning objectives with several other Florida estate planning attorneys, but he did not locate any attorney that appeared knowledgeable about how to amend the two Trust Agreements to achieve those estate planning objectives (enable the co-trustees to take specific actions that could minimize federal estate taxes on the parent's total estate value and also take specific actions that could minimize potential probate expenses). 

     Timing was critical here because Lon Jr's father was in very poor health, and he was likely subject to die at any time.  Those two Trust Agreement amendment improvements needed to be made as quickly as possible - while both of Lon's parents still had good mental abilities to responsibly consider and then approve those needed amendment changes to their Trust Agreement estate plans. 

     During years 1983, 1984, and 1985, Lon was unable to locate a Florida estate planning attorney that he trusted as being competent to develop the amendments needed for the two Trust Agreements.    

     Due to those serious difficulties, Lon Jr. finally purchased some legal books about estate planning, and he studied and learned how to amend the two Inter Vivos Trust Agreement documents to help the two co-trustees take needed actions to achieve those estate planning objectives. 

     Lon Jr. personally developed and typed the amendment documents for each Trust Agreement on a portable typewriter at his parent's home near Palatka, Florida.  He then got each amendment document signed by each parent at their local Palatka area bank, along with a notary public witness, who also signed those amended Trust Agreement documents. 

     Lon Jr. then took the signed and notarized documents to the local Putnam County Circuit Court "Clerk of Court" for filing, along with original documents of both parent's Inter Vivos Trust Agreement.

     He completed those Trust Agreement amendment actions for his parents, with their joint approval, on December 12, 1985. 

     Those additional estate planning actions enabled the two co-trustees to more effectively manage the two Trust Agreements that had been established and implemented initially in January 1983.  

It had taken almost three years for Lon Jr. to finally take the actions needed to accomplish those very important estate planning actions.  (Actions that should have been accomplished by the estate planning attorney who had initially drafted the two Trust Agreements.)

     The two co-trustees would now be able to take very important estate planning actions for their parents' amended estate planning Trust Agreements that could reduce and minimize potential federal estate taxes on the parent's total jointly owned estate value. 

     The two co-trustees would also now be able to take very important estate planning actions that could reduce and minimize potential Florida probate expenses on the parent's total net estate values. 

     Co-trustee Lon Jr. then took the actions that were needed to fund the Inter Vivos Trust Agreements properly with real estate asset value transfers and cash asset transfers to accomplish the very important estate planning objectives that are stated above. 

    The very important estate planning actions taken by co-trustee Lon Jr. in December 1985 enabled the reduction of potential federal estate taxes on the parents' total estate value from about $225,000 downward to approximately zero dollars.

   The very important estate planning actions taken by co-trustee Lon Jr. also reduced potential Florida probate expenses for the Willoughby joint estate value from about $90,000+ to less than $1,000.  

     Co-trustee Lon Jr. completed those additional estate planning actions promptly while he still lived near his parent's home in Putnam County Florida. 

Leona Caused Serious Problems

     Leona Willoughby had caused numerous emotionally stressful problems for Lon Jr., in his continuing efforts to help reduce the painful muscle cramps that his father suffered with daily on the left side of his body.  

     Leona did not want Lon Jr. to use a heavy-duty electrical massage vibrator that he had purchased to help stimulate his father's lymphatic glandular system in an effort to relieve those very painful muscle cramps.  He responsibly took those very effective massage vibrator actions each time he visited his parents' home - usually every other day. 

     Leona claimed that the massage vibrator that Lon used to reliably remove those painful muscle cramps was what was causing the muscle cramps to occur.  

     Lon had explained that those painful muscle cramp had occurred for weeks and then months before he bought the heavy-duty massage vibrator to help activate his father's lymphatic system. 

     He has studied Lymphology under Dr. Samuel West, a prominent Lymphologist, and that's why he decided to experiment with a heavy-duty massage vibrator to stimulate the lymphatic glands in the paralyzed portions of his father's body.  The vibrator massages worked like a miracle because they reliably relieved the very painful cramps that his father had daily (day and night). 

     Mother Leona was such a continuing stubborn and unrelenting emotional problem for Lon Jr. to repeated have to cope with that he finally decided to move back to his now recently vacated rented home in Mauldin, South Carolina.  

     He and wife Janie had been living separately since December 1984, when Janie had moved from DeLand, Florida back to Mauldin, SC so she could fill a vacant teaching position at the Mauldin High School in January 1985.

     A teacher pregnancy situation caused a teacher vacancy to occur at the Mauldin High School during the December 1984 Christmas school break, and that enabled Janie to be able to regain a teaching position at the Mauldin High School (starting in January 1985). 

     She had moved from the apartment complex in DeLand, Florida to the Mauldin, SC area in December 1984 to resume teaching school at the Mauldin High School when students returned from their December 1984 Christmas holiday break. 

     Janie had been living during year 1985 in the Mauldin area with a female teacher who was a good friend because Janie's Mauldin home was currently leased through March 1986.

     Lon Jr. moved back to their home in Mauldin, SC in April 1986 (their home had been rented since July 1983 - but was now vacant). 

     About seven months after Lon moved from the San Mateo/Palatka area to his home in Mauldin, South Carolina, Lon's father suffered another heart attack and died on November 22, 1986.

Litigation in Florida

     The litigation in Florida began for Lon Jr. in March 1989 when his mother (Leona), as the beneficiary of the Marital Trust Estate, initiated a lawsuit against her eldest son, Lon Jr. because a dispute had developed between the two co-trustee brothers about the proper responsible method of making monthly distributions of trust estate income to Lon's mother and to Larry and Lon Jr. on a monthly basis as beneficiaries of the two trust estates (the Marital Trust Estate with sole beneficiary Leona Willoughby and the Family Trust Estate with the beneficiaries of brothers Larry and Lon Jr.). 

     The co-trustee dispute had been caused by Larry's incompetent co-trustee actions and his gross lack of appreciation for the complex and difficult estate planning work and the personal expenses that Lon Jr. had responsibly accomplished during years 1982, 1983, 1984, 1985, 1986, 1987, and into year 1988 - as the knowledgeable and competent co-trustee for the two Trust Agreement estates that had been established as a result of Lon Jr's personal encouragement to his parents in year 1982 about the need for some very important estate planning actions.

     Instead of Larry showing some appreciation (at age 50) for Lon Jr's very competent and very responsible actions that had benefited the Willoughby family substantially (as explained briefly above), Larry's incompetent co-trustee actions made Lon's co-trustee actions more difficult and more frustrating and more time consuming than they needed to be. 

     In order to stop those kinds of frustrating and irritating incompetent co-trustee actions by Larry, co-trustee Lon Jr. did the only thing that was available to him as an abused co-trustee - he started charging nominal co-trustee fees for his ongoing monthly co-trustee actions in 1988. 

     Previously, he had not charged anything for any of his very important and very valuable co-trustee actions in 1983, 1984, 1985, 1986, 1987 and into 1988 - when the monthly income distribution dispute occurred.

     Instead of Larry learning something from that situation (to stop his incompetent co-trustee actions of frustrating and irritating co-trustee Lon Jr. at every opportunity), he increased those frustrating co-trustee actions by stubbornly refusing to agree to pay co-trustee Lon Jr. anything for his very competent and responsible co-trustee actions that were routinely occurring on a monthly basis. 

     Brother Larry was about 20 months younger than Lon Jr., and he was obviously Mother Leona's favorite son because he always acquiesced and agreed to cooperate with anything she wanted done.  

     Larry even acquiesced and agreed with anything she proposed regarding management and operation of the two Trust Agreement estates, the Marital Trust Estate (with Leona as the sole beneficiary) and the Family Trust Estate (with Larry and Lon Jr. being the two primary beneficiaries). 

      Unfortunately, Leona had an inadequate understanding of the complex and difficult estate planning actions that co-trustee Lon Jr. had completed responsibly for those several years (1983 through 1987 and into year 1988).  She had no responsible appreciation for his very beneficial and very successful co-trustee actions. 

     Leona wanted to be in control of all trust estate financial issues, and she demonstrated that she had no responsible respect for Lon Jr's effective guidance and leadership in helping the family with very complex financial planning matters. 

     Lon Jr's co-trustee actions were dependent upon highly specialized knowledge that he had diligently managed to acquire from legal system books about relevant estate planning issues.

     Leona apparently agreed with co-trustee Larry that co-trustee Lon Jr. should not be paid anything for his nominal cost monthly co-trustee services (that he had started charging for during year 1988 -  but Lon Jr. had not been paid anything by co-trustee Larry - out of trust estate funds). 

     Larry and Leona collusively cooperated with each other to use that relatively small dispute issue as a basis for Marital Trust Estate beneficiary Leona to sue co-trustee Lon Jr.   Apparently with the objective of trying to have him removed as a co-trustee of the Marital Trust Estate. 

     Leona and Larry apparently intended to leave incompetent co-trustee Larry as the sole co-trustee of the Marital Trust Estate. 

     That situation would have enabled Leona Willoughby to effectively have control of the Marital Trust Agreement estate value ($400,000+).  She still had ownership control of her waterfront home in San Mateo, Florida, and she had more than 200,000 dollars in her Palatka bank accounts.

     Leona did not have legal standing to complain about the way co-trustee Lon Jr. had participated in the management of the Family Trust Estate - unless her litigation actions alleged and then proved during trial litigation that co-trustee Lon Jr. had been dishonest or incompetent in his co-trustee actions in ways that affected both Trust Agreement Estates.

Litigation Goes to Trial

     Leona's Florida attorney (in Palatka, Florida) corrupted the Florida trial court litigation badly by getting the trial court judge and co-trustee Lon Jr's defense attorney to "cooperate with" his extremely unfair, unethical, and outrageously corrupt litigation scheme to ambush co-trustee Lon Jr. with surprise complaint issues during the one-day non-jury "Equity Court" Trial that was conducted on September 8, 1989.  (Florida trust estate litigation must be conducted in an "Equity Court" trial, and an Equity Court trial does not allow any jury participation - it is strictly a bench trial with the circuit court judge acting as the judge and jury.) 

     During that trial, Lon Jr. was on the witness stand for hours because he was ambushed during the trial with five additional complaint issues that had not been noticed in the plaintiff's pleadings. 

    The trial judge required co-trustee Lon Jr. to give defensive testimony about each of those additional complaint issues, as well as give testimony about the two complaint issues that had been noticed in the plaintiff's (Leona's) pleadings.

     Although co-trustee Lon Jr's defense attorney was a very smart attorney with more than 20 years' experience as a Florida trial attorney in that county (Putnam), he repeated failed to object properly during the trial to the plaintiff's attorney's unfair and unethical litigation scheme to ambush co-trustee Lon Jr. during trial with surprise complaint issues that had not been noticed properly to defendant co-trustee Lon Jr. in the plaintiff's pleadings (plaintiff Leona Willoughby).

     More than a year after that trial, Lon Jr. learned that the Supreme Court of Florida had issued a landmark legal case ruling, years before that trial, that surprise complaint issues were not to be allowed during trial - unless both parties agreed to litigate additional issues that had not been noticed properly in the plaintiff's pleadings. 

     That situation clearly shows how unfair, unethical, and outrageously corrupt the trial court litigation was for co-trustee Lon Jr.  

     During that "equity court" trial, the trial attorney for Marital Trust Estate beneficiary Leona Willoughby promoted an extremely unfair, unethical, and outrageously corrupt litigation scheme and tactic to ambush defendant co-trustee Lonnie Willoughby, Jr. during the trial with five surprise complaint issues that had not been noticed in the plaintiff's pleading for said trial.  

     That ambush scheme was "cooperated with" by the trial court judge and "also cooperated with" by co-trustee Lonnie Jr's very smart and very competent and very experienced defense attorney.

     Co-trustee Lon Jr. had personally paid about $1350 for the 672-page transcript two-volume record of that trial .  He did that so the official transcript record would be available on appeal - if he needed to file an appeal of the trial court's litigation actions (which he did in a timely manner). 

     The detailed transcript record showed that co-trustee Lon Jr's highly skilled defense attorney effectively allowed the plaintiff's attorney to maliciously and ruthlessly conduct an extremely unfair, unethical, and corrupt "ambush complaints scheme" during the one-day equity court trial (a non-jury type trial - where the circuit court judge is both the judge and the jury.   

      During the trial proceedings, Lon's defense attorney objected four times to the introduction of those additional complaint issues.  Therefore, it was obvious to the trial court judge that the two parties had not mutually agreed to litigate those additional complaints against co-trustee Lon Jr. 

     During the one-day trial, co-trustee Lon Jr. did not understand what type of legal objections his defense attorney should be presenting to surprise complaint issues.  This was his first Florida litigation trial, and he did not know anything about trial court objections to surprise complaint actions. 

     However, many months later, Lon Jr. learned  that the four objections presented during the trial by his defense attorney were weak objections. That helps explains why the trial court "circuit court judge" instantly denied each of his trial objections.

     The Final Judgment for the litigation process was rendered weeks after the trial, and the trial court judge ruled in co-trustee Lon Jr's favor on the two complaint issues that were noticed in the plaintiff's pleadings. 

     However, the judge also ruled against co-trustee Lon Jr. on three of the five surprise complaint issues that were introduced during the trial.  Lon Jr. had given responsible defensive testimony during the trial about those five surprise complaint issues. 

      His trial testimony was not as detailed and complete as it would have been if he had been noticed properly and timely before trial about those additional five complaint issues.  

     During the trial, he was having to instantly remember events and situations that had occurred in years 1/1983 through 12/1985 about the five surprise complaint issues - events that had occurred several years before the trial conducted on September 8, 1989. 

     However, the trial transcript showed that co-trustee Lon Jr. was the only person in the trial who had a competent knowledge about the estate planning actions that had been taken for the two Willoughby Trust Agreements (events involved with the five surprise complaint issues.) 

     The trial court judge and the two opposing attorneys (the plaintiff's attorney and Lon Jr's defense attorney) had no responsible knowledge about the complex estate planning issues that co-trustee Lonnie Willoughby, Jr. had competently managed for his parents during those years. 

     This was probably the first time that any of the three "officers of the court" had ever been involved in litigation about such complex trust estate issues.

     The two opposing trial attorneys and the trial court judge knowingly and willfully participated in an extremely unfair, unethical, and outrageously corrupt litigation scheme that maliciously and ruthlessly denied co-trustee Lonnie Willoughby, Jr. basic and fundamental "due process of law standards" for a litigation trial process.

     The three "officers of the court" also totally ignored the mandatory Florida Supreme Court landmark case ruling that clearly forbade the introduction of "surprise complaint issues" during trial (unless there was mutual agreement of the parties to litigate those unnoticed complaint issues). 

     The Final Judgment removed both brothers (Lon Jr. and Larry) as co-trustees of the Marital Trust Estate and the Family Trust Estate (which was not even involved in the trial proceedings). 

Successor Trustee Appointed

     A successor replacement trustee was appointed by the trial court judge for both trust estates in the person of the Certified Public Accountant (CPA) who had come to trial as a witness for plaintiff Leona Willoughby.

     This was the CPA that Lon Jr. had personally selected to complete the filing of the Willoughby parent's Federal Form 1014 income tax return for year 1985.  The CPA continued doing that for each successive tax year prior to the trial date that occurred on September 8, 1989. 

      During the trial, Lon Jr. recognized that the CPA had likely given perjured testimony about Leona's Form 1040 federal income tax returns for the two tax years prior to the trial. 

      After the trial, Lon Jr. obtained copies of those two tax returns from his mother.  The CPA had completed the accounting processing and filing of those two Form 1040 Tax Returns.  

     When Lon Jr. reviewed those two tax returns, he saw clearly that the CPA had under-reported plaintiff Leona's income for those two tax years by several thousands of dollars for each year. 

     Those Form 1040 tax reports also showed that Leona had been giving about $5,000 per year to charitable causes.  However, the CPA's testimony during the trial had falsely claimed that plaintiff Leona did not have adequate income to sustain her in a reasonable manner. 

     The trial transcript showed that the CPA willingly "cooperated with" Leona's trial attorney to try to falsely show that co-trustee Lon Jr. had deprived beneficiary Leona of adequate income from the Marital Trust Estate. 

     That was also perjured testimony because Leona had always been paid monthly the full amount of income that was earned monthly in the Marital Trust Estate (interest income from the Penn Oaks Apartment mortgage note and cash assets interest income) - up to the point in time when co-trustee Larry foolishly caused the dispute about monthly trust income distributions. 

     After the Final Judgment was rendered, co-trustee Lon Jr. gradually realized that his defense attorney had betrayed him badly during the trial by "cooperating with" the plaintiff's attorney's unfair, unethical, and outrageously corrupt litigation scheme to ambush co-trustee Lonnie Willoughby, Jr. during the trial by presenting five surprise complaint issues against co-trustee Lon Jr. during the one-day trial proceedings. 

     Co-trustee Lon Jr. had not been noticed about those additional five complaint issues prior to trial so he was deceptively denied any opportunity to responsibly prepare his defensive testimony about any of those five surprise complaint issues. 

     He had also been denied any opportunity to have an expert trust estate planning and administration attorney (from nearby Jacksonville, Florida) come to trial and give defensive testimony about Lon Jr's surprisingly competent non-attorney co-trustee actions in amending and managing the two Willoughby Trust Agreement estates.  (The Marital Trust Estate and the Family Trust Estate.)

     Consequently, co-trustee Lonnie Willoughby Jr. had been denied basic "due process of law standards" for an "equity court" trial. 

     After the Final Judgment was rendered and then received by first class U.S. mail by Lon Jr. (in Greenville County, SC), he had to quickly learn how to file a Notice of Appeal timely for the Final Judgment rendered by the Circuit Court Judge. 

     He managed to do that competently and that timely filed Notice of Appeal enabled Lon Jr. to have some time to find and retain an appeal attorney (located in Daytona Beach, Florida, where the Fifth District Court of Appeal was located). 

     The deceitful unfair, unethical, and outrageously corrupt trial attorney that had represented plaintiff Leona during the trial also represented her as the Appellee during Appellant Lon Jr's appeal case.

     Actions by Appellant Lon Jr's appeal attorney subsequently showed that the attorney knowingly and willfully "cooperated" with Leona's appeal attorney to cause the appeal case to be conducted in an extremely unfair, unethical, and corrupt manner.  

     Lon Jr's appeal attorney had a copy of the trial transcript record which showed clearly that co-trustee Lon Jr. had been maliciously and ruthlessly ambushed during trial with five additional surprise complaint issues.   Furthermore, the Final Judgment showed that the trial court judge ruled against co-trustee Lon Jr. on three of those five improper surprise complaint issues. 

     The appellant appeal brief that the attorney filed for Appellant Lon Jr. did not report that co-trustee Lon Jr. had been ambushed during trial with five surprise complaint issues. and that appeal brief also did not report that the trial judge had ruled against co-trustee Lon Jr. on three of those five surprise complaint issues. 

     That appellant appeal brief also failed to cite and present an argument issue to show that the Florida Supreme Court's directly on-point landmark case ruling had specifically forbidden the introduction of surprise complaint issues during trial. 

     Those unfair and unethical appellant attorney actions caused appellant Lon Jr. to lose an appeal case that should have been easy for his appeal attorney to win (as shown above briefly).  

     But you see, Lon Jr's appeal attorney did not want to show on appeal that the two trial attorneys and the circuit court judge had willingly "cooperated" with an extremely unfair, unethical, and corrupt litigation scheme to ambush co-trustee Lon Jr. during the one-day "Equity Court" trial. 

     Lon Jr's appeal attorney simply ignored all of that extremely serious miscarriage of justice in the trial court below.  Those actions and inaction's knowingly and willfully caused appellant Lon Jr. to lose his appeal when it should have been easy for the attorney to win that appeal case for Lon Jr. 

      That very serious appeal case situation shows clearly how corrupt legal profession members can be by totally ignoring clearly outrageously unfair, unethical, and corrupt litigation actions by other members of the legal profession. 

      Lon's appeal attorney had a copy of the trial transcript that Lon Jr. procured and purchased for about $1,350.  That transcript was also a part of the Record on Appeal that was presented to the three-judge appellate panel. 

     The trial transcript record clearly showed that defendant co-trustee Lon Jr. had been maliciously and ruthlessly ambushed during trial with five additional complaint issues - complaint issues that had not been noticed in the plaintiff's pleadings.  Consequently, co-trustee Lon Jr. had been denied basic and fundamental "due process of law standards" for a Florida "Equity Court" trial.     

     The three-judge appellate panel knew that such an unfair and unethical trial litigation scheme and tactic was strictly forbidden by the relevant landmark Florida Supreme Court case ruling that strictly prohibited the unfair litigation tactic of introducing surprise complaint issues during a trial procedure. 

     The trial transcript record showed clearly that both opposing trial attorneys and the trial court judge had totaled ignored that mandatory Florida Supreme Court case ruling during the one-day trial. 

     When Lon Jr. lost that appeal case, it was clear to him that the three-judge appellate court panel had not bothered to review the first part of the trial transcript record which clearly showed an extremely unfair and unethical ambush complaints scheme had caused an unfair, unethical, and outrageously corrupt "Equity Court" trial. 

     At that point in time, Lon Jr. had been betrayed by two prominent and experienced litigation attorneys (the trial court litigation and then the related appellate court litigation).  

     Lon Jr. decided that he would have to begin representing himself during any further litigation actions because he had learned that he could not trust any Florida litigation attorney to represent him in a fair, honest, and responsible manner.

     That type of ruthlessly corrupt litigation process was then continued until year 2010 (20+ years), as explained herein.  

     Lon Jr. had to drive his personal car about 9,000 mile traveling to and from Florida for scheduled litigation hearings and trials - where he repeatedly had to cope with disgustingly unfair and unethical corrupt scheming attorneys (lawyers), and also multiple unfair, unethical, and corrupt trial court judges, and also multiple unfair and unethical self-serving appellate court judges. 

     Lon Willoughby had to cope with more than 20 years of extremely difficult and stressful malicious and ruthless "related litigation actions" in the state courts of Florida.

Review of Unfair, Unethical Attorney Actions

     
     The first Florida attorney that betrayed Lon Willoughby, Jr., and betrayed both of his parents, was the estate planning attorney that the bank trust department in Deland, Florida had recommended for estate planning actions for Lon Jr's parents.  

     That attorney drafted two mirror-image Inter Vivos Trust Agreements for Lon Jr's parents (one for each parent), but they were essentially useless documents because the attorney did not offer any advice about funding those trust agreements to make them effective estate planning documents. 

     Consequently, those two trust agreements were as worthless as two separate bank accounts that have no funds in the accounts.  Trust Agreements that have not been funded are useless Trust Agreements (until they are properly funded with assets that can be managed by the trustee or co-trustees).  

     As reported previously at this website, prior to Lon's subsequent pro se litigation actions, he had also been unfairly, unethically, and corruptly   betrayed by two prominent Florida litigation attorneys that he had retained for two separate litigation cases in the State of Florida. 

     The first litigation case was in the civil "Equity Court" litigation conducted in Putnam County Florida during year 1989. 

     The next litigation attorney betrayal action was in the following appellate court case (in 1989 - 1990).  That appeal case was supposed to report the extremely unfair, unethical, and outrageously corrupt trial court actions that had occurred in year 1989 against co-trustee Lonnie Willoughby, Jr. 

     As explained previously, Appellant Lonnie Willoughby, Jr's appeal case attorney deceitfully failed to report the trial court attorneys' (two opposing attorneys) extremely unfair, unethical, and corrupt litigation actions that caused co-trustee Lonnie Willoughby, Jr. to lose a civil litigation "Equity Court" trial case that his prominent very smart defense attorney should have won easily. 

     Appellant Lon Willoughby, Jr. also lost his appeal case about that unfair and unethical trial court case because his appeal case attorney knowingly and willfully betrayed Lonnie Willoughby, Jr's litigation interest in that appeal case - as explained below. 

     The attorney deceitfully failed to report on appeal the extremely unfair and unethical litigation actions that the trial court transcript clearly showed had occurred against defendant co-trustee Lonnie Willoughby, Jr. in the circuit court civil litigation case that had occurred below.

     Appellant Lonnie Willoughby, Jr. learned that an appeal attorney will likely act to protect unfair, unethical, and disgustingly corrupt "opposing trial court attorneys" in an appeal case - rather than honestly and ethically report and expose the unfair, unethical, and corrupt opposing trial court attorneys' litigation actions that occurred during the litigation process that is being appealed. 

     Lon learned that appellate court litigation can be easily corrupted in a self-serving manner because the appellant's appeal attorney is not "supposed" to honestly and ethically report (expose) in an appeal case legal brief unfair, unethical, and corrupt attorney litigation actions, schemes and tactics that occurred in the trial court litigation process. 

     Lon also learned that appeal attorneys are not "supposed" to fairly, honestly, and ethically report (expose) in an appeal case unfair, unethical, and corrupt judicial actions by the trial court judge in the trial court case that is being appealed.

     Theoretically, "officers of the court" (attorneys, lawyers, or judges) will not knowingly and willfully perpetrate those kinds of unfair, unethical, and corrupt actions during trial court litigation. 

     However, If they do perpetrate those kinds of unfair and unethical litigation actions, schemes or tactics during trial court litigation, it is not professionally polite (therefore not appropriate) for an appellant's attorney to report (expose) those kinds of improper litigation actions in the severely abused appellant's appeal legal brief argument issues to the appellate panel of judges (typically three appellate court judges). 

     That situation illustrates the extreme level of deceit, fraud, and appeal case hypocrisy that is routinely "expected" of an appellant's appeal case attorney in a Florida appeal case litigation. 

     A review of appellant Lon Willoughby's appeal case attorney's appeal litigation actions show that the attorney conducted Lon's appeal case litigation in compliance with those "unwritten, but clearly understood, self-serving deceptive appeal litigation procedures."

     Appellant Willoughby's attorney did his loyal "attorney duty" to responsibly support the "legal profession" by deliberately failing to report the unfair, unethical, and corrupt litigation "ambush complaints" scheme and tactic that caused co-trustee Lonnie Willoughby, Jr. to lose the litigation dispute in the circuit court civil litigation below. 

     Lon's appeal case should have been easy to win - if Lon's appeal case attorney had been honest and ethical about reporting on appeal the unfair, unethical, and corrupt "ambush complaints" litigation scheme and tactic that was used by the "two opposing trial attorneys." 

     The twp volume trial transcript showed that the two opposing trial court attorneys had collusively "cooperated with each other" during the litigation process to willfully cause co-trustee Lonnie Willoughby, Jr. to lose in the trial court litigation when his "defense attorney" should have won that case (without any reasonable doubt). 

    Lon's appeal case attorney should have also reported in Lon's appeal legal brief argument issues the obviously unfair, unethical, and corrupt actions of the trial court judge below. 

     The trial transcript showed that the judge knowingly and willfully approved of and cooperated with the very unfair, unethical, and fraudulent and outrageously corrupt trial court litigation scheme and tactics used by the plaintiff's attorney during the one-day "equity court" trial court actions.

     At the time that Lon's appeal case was being presented to the Fifth District Court of Appeal in Daytona Beach, Florida, appellant Lon Willoughby did not realize that appellate court litigation can easily be conducted in a very unfair, corrupt, deceitful and fraudulent manner.

    Lon learned this information from the way his first appeal case was conducted in 1989 - 1990. 

    He also learned more about the unfair, unethical, and self-serving ways that appeal cases can be adjudicated by three appellate court judges in the other seven appeal cases that Lon Willoughby presented in his pro se capacity and lost unfairly and improperly during his Florida litigation actions over a period of 20+ years.

Corrupt County Court Scheme

     In year 1994, Lon had to defend himself from an extremely unfair, unethical, and corrupt County Court Judge who worked collusively with the local "state prosecutor" (called a "solicitor" in South Carolina) to punish Lon Willoughby in malicious and ruthless ways.  Why did they do that? 

     They were continuing ruthless and malicious punishment for non-resident Lon Jr.  for having helped his aging parents develop an excellent estate plan that had minimized federal estate taxes and had also minimized potential probate expenses for both parents. 

     The County Court Judge and the local "state attorney" located in Palatka, Florida were also ruthlessly and maliciously punishing non-resident litigant Lonnie Willoughby, Jr. because he had courageously and responsibly used his appeal case legal briefs several times to expose and report to the appellate court judges extremely unfair, unethical, and disgustingly corrupt judicial actions against him that occurred in Putnam County Florida courts.

     The County Court Judge and the local state "prosecuting attorney" worked together collusively in trying to put non-resident litigant Lonnie Willoughby, Jr. in the local Putnam County Jail for about nine months, knowing that that "lock up jail action" would effectively prevent litigant Lonnie Willoughby, Jr. from filing his own pro se appeal case legal briefs. 

     They collusively used a false and extremely unfair "criminal contempt of court" complaint  against litigant Lonnie Willoughby, Jr. even though he was still living in Greenville County South Carolina. 

     They then prosecuted a fraudulent conviction of that complaint in the Putnam County County Court without non-resident Lonnie Willoughby, Jr.  participating in that "criminal contempt of court" trial. 

Lon's Appeal Case

     Fortunately, defendant Lonnie Willoughby, Jr. was able to competently appeal that "criminal contempt of court conviction" in his pro se capacity (where he was litigating without benefit of assistance of an attorney). 

   The local Putnam County "state attorney" was represented in that unfair, unethical, and extremely corrupt County Court "criminal contempt of court" litigation by a female "assistant state prosecutor" who was as dishonest, as unfair, as unethical, and as corrupt as she could have been in that "criminal contempt of court" litigation case. 

     When defendant Lonnie Willoughby filed his appeal case about that corrupt fraudulent "criminal contempt of court" conviction, the same female "assistant state prosecutor" represented the local Putnam County "state prosecutor" in Appellant Willoughby's appeal case. 

     She continued with her unfair and unethical litigation actions throughout that appeal process.  As stated previously, the County Court Judge and the local "state prosecutor" were unfairly and unethically trying to cause non-resident defendant Lonnie Willoughby, Jr. to be incarcerated in the local Putnam County Jail (for about nine months). 

     Defendant Lon Willoughby realized that he and wife Janie could suffer serious financial consequences if he lost that appeal case and had to go to jail for about nine months in Putnam County, Florida. 

     If Lon was prevented from operating and managing the corporately owned ABC of Health store in Greenville County, South Carolina for a nine months period of time, the store would have been forced to close.  But Lon Willoughby would have still had an active lease of the store facility which he would have still been responsible for paying monthly lease payments for (and he would have been in jail in Putnam County, Florida and unable to manage that really bad financial situation). 

     His absence from the business for nine months would have effectively destroyed the small health store business, causing Lon and Janie Willoughby to lose hundreds of thousands of dollars of invested money. 

     They would have also lost a lot of invested diligent work that had developed the business's credibility and reputation since Lon opened the business about five years earlier on January 4, 1999. 

Outcome of Lon's Appeal Case

     Fortunately, Appellant Willoughby won that very important appeal case against the local Putnam County "state prosecutor" by showing on appeal that the local County Court Judge did not have valid "subject matter jurisdiction" to prosecute defendant Lonnie Willoughby, Jr. about the "criminal contempt of the county court complaint" because that contempt complaint would have had to be prosecuted in the Putnam County Circuit Court, not in the Putnam County County Court.  

     Appellant Lon Willoughby also showed on appeal that there had not been any criminal contempt of the circuit court - the criminal contempt of court complaint and conviction in the county court was an unfair, unethical, and corrupt fabricated complaint by the local County Court Judge and the local Putnam County state prosecutor. 

     Non-resident litigant Lonnie Willoughby had not taken any litigation action that was a contempt of any Florida court.  Those charges were totally false and were a malicious and ruthless fabrication of alleged evidential facts. 

     The local Circuit Court Judge, sitting as the appellate court judge for Appellant Lon Jr's appeal case, dismissed the "criminal contempt of the county court" complaint and dismissed the unfair, unethical, and fraudulent "criminal contempt of county court conviction" of non-resident defendant Lonnie Willoughby, Jr.

     NOTE:  It is very important to understand that appellant Lonnie Willoughby, Jr. would not have been able to accomplish an appeal case like that (in his pro se capacity) in the State of South Carolina. 

     The Supreme Court of this state has prohibited an appellant from filing an appeal case in their pro se capacity.  The high court ruled, more than 80 years ago, that an appellant is required to have a South Carolina attorney represent the appellant in any appeal case.

     Consequently, any appeal case in this state must be represented by a licensed attorney in this state (at a cost of thousands of dollars for attorney fees).  An appeal litigant is not allowed to represent their own appeal, even if they are competent to present their appeal (as Lon Jr. is competent to do).

     If a litigant is not able financially or not willing to spend several thousand dollars for an appeal attorney to represent their appeal case, the litigant cannot prosecute an appeal in the South Carolina Appellate Court (in Columbia, SC).  It has been this way for more than 80 years - by South Carolina Supreme Court edict. 

     Lon Willoughby has researched that legal edict situation in depth, and he is convinced that the high court's self-serving legal edict is contrary to and in conflict with the clear litigation guidance presented in the Constitution of South Carolina. 

    Lon Willoughby has argued that issue twice in the appellate courts of South Carolina.  The judges simply ignored his competent legal argument issues in unfair and unethical self-serving ways.

     Lon Willoughby has reported herein two very important appeal cases that he won in the State of Florida courts proceeding pro se - cases that he could not have won proceeding pro se in South Carolina's appellate court procedures - simply because the South Carolina Supreme Court justices chose to deny any litigant any opportunity to present their own appeal court argument issues.  

     Lon has carefully researched this situation in South Carolina Law, and he firmly believes the SC Supreme Court's ruling about that issue is in direct conflict with litigation guidance that is clearly presented in the Constitution of South Carolina. 

     He has presented his argument issues about that very important subject to the Supreme Court of South Carolina.  However, in an unfair self-serving way, they simply ignored his responsible legal argument issues.

     That is one of the judicial issues that Americans 4 Justice-SC will work on improving in the future - through education of members of the South Carolina General Assembly (both house and senate representatives).

Extreme Emotional Stress Over 20+ Years

      As stated previously, the Florida litigation process began for co-trustee Lonnie Willoughby, Jr. in March 1989.  That litigation process was deliberately continued unfairly, corruptly, maliciously and ruthlessly, year after year, by Lon Willoughby's Florida litigation opponents into year 2010.  (20+ years)

     Severely abused and harassed defendant Lonnie Willoughby did not file another appeal case in the ongoing extremely corrupt litigation process during year 2010, and that effectively caused a termination of the corrupt litigation process.

     He had endured 20 years of extremely stressful unfair, unethical, and corrupt Florida litigation, and he realized that there was no practical reason for him to continue the litigation process with another appeal case.

     He had proven several times with his ten appeal cases that the Florida judicial system was usually extremely unfair, unethical, and outrageously corrupt to him - except for the two appeal cases that he managed to win in his pro se capacity. 

Very Important Stress Factors

     Lon could not have survived all of that extreme emotional stress (during those many years of ongoing related unfair, unethical, and outrageously corrupt litigation actions) without his very special natural health-care and wellness concepts knowledge that he had acquired, and also the very helpful actions taken by his very supportive wife (Janie) throughout that 20+ years ordeal. 

     Those situations are reported in more detail in the Judicial Corruption Exposed Department at our main Natural Health-care and Wellness Concepts educational website (www dot ABCofHealth dot com). 

     "Qualified visitors" will not be able to review that very important website department.  It is only accessible by A4J club members using special security codes.