IN THE DISTRICT COURT, SHELBY COUNTY, NO.

08-CV-29961

KEITH MILLER V. STEVEN HOTZE & SHIRLEY PIGOTT

EXHIBIT A

DR. MILLER’S RETALIATION AGAINST DR. SHIRLEY PIGOTT

November 2, 2009

Dr. Miller’s Current Retaliation Efforts

1. Lawsuit against Dr. Pigott and Dr. Steven Hotze claiming that their whistle blower
claims against Dr. Miller constitute slander.
2. Lawsuit against Dr. Pigott seeking a permanent injunction to stop Dr. Pigott’s whistle
blower acts against Dr. Miller and his nurse. ( Due to Dr. Pigott’s whistle blower
activity, the State of Texas has forced both Miller and his nurse to cease improper
conduct)
3. Coordinating with Wharton County District Attorney Josh McCown in an effort to send
Dr. Pigott to prison. (After being stopped at night, on a dark highway, for driving 74mph
in a 65mph speed zone, Dr. Pigott refused to open her car door before going to a public
location.)

Dr Shirley Pigott (Texas Medical Board Watch)

Dr. Pigott formed Texas Medical Board Watch and has been working with a group of whistle
blowers to expose improper, unethical conduct by the Texas Medical Board and its board
members.

Whistle Blower Group

Other participants of the project include Dr. Steven Hotze (a co-defendant in Dr. Miller’s
retaliation lawsuit), the Association of American Physicians & Surgeons (organization that has
sued TMB) and approximately 50 additional doctors and medical personnel who are aware of
the unjust conduct of the TMB and its board members.

Claims Against Texas Medical Board

The whistle blower group has accused the Texas Medical Board and its board members of
allowing: 1) Anonymous complaints from insurance companies, hospitals, pharmaceutical
companies, attorneys and competitors 2) Anonymous “expert” witnesses against physicians 3)
Kangaroo courts held in secret 4) Denial of patients’ right to testify on behalf of their doctor 5)
Prohibition of note taking and recordings in hearings 6) Denial of due process to physicians 7)
Discipline for menial and trivial records’ findings 8) Intimidation tactics 9) Forced settlements
10) Conflicts of interest.

Whistle Blower Group’s Successes to Date

The current state of the whistle blowers’ efforts and successes is:
 1. Passage of new legislation in 2007 outlawing unethical conflicts of interest by board
members of the Texas Medical Board. (This new law forced Dr. Miller to resign from
the TMB)
2. Pending lawsuit in federal court in Austin, wherein the Association of American
Physicians & Surgeons is suing the Texas Medical Board. (Dr. Miller’s conduct while a
board member will be reviewed in this lawsuit)
3. Resignation of Dr. Don Patrick, the Executive Director of the Texas Medical Board.
4. Current investigation of the conduct of the Texas Medical Board and its board members
by the Texas Legislature.

Intensity of Dr. Miller’s Anger Toward Dr. Pigott

The intensity of Dr. Miller’s anger and retaliation toward Dr. Pigott is due to Dr. Pigott’s success
as a whistle blower in wrecking Dr. Miller’s “gold mine” and Dr. Pigott’s acts as a whistle
blower concerning criminal conduct by Dr. Miller’s nurse and family member.

Dr. Miller’s “Gold Mine”

Prior to Dr. Miller’s forced resignation from the TMB, a primary source of his income was from
expert witness fees for testifying against doctors and hospitals in medical malpractice cases.
Lawyers suing doctors or hospitals sought out Dr. Miller’s testimony, which was always that the
doctor or the hospital was negligent. Dr. Miller’s opinion was extra valuable since Dr. Miller was
on the Texas Medical Board and Director of the Disciplinary Committee. He was “The Man;”
he set the standards required of doctors and hospitals. Dr. Miller was able to pack his schedule
with expert witness jobs; able to charge large fees; able to make lots of money. Dr. Miller
created a “gold mine” by unethically using his position with the Texas Medical Board.

Before 2007, Dr. Miller was criticized for having a conflict of interest by acting as a witness
against doctors and hospitals, while being on the TMB. Although the conflict of interest was
clear and obvious, Dr. Miller refused to correct his improper conduct. Only after the Texas
Legislature and the Governor of Texas declared, in 2007, that Dr. Miller’s conduct was illegal
did Dr. Miller resign from the TMB on August 30, 2007.

Dr. Pigott provided the Texas legislature with information that led to the new law that
outlawed Dr. Miller’s “Gold Mine.” (Attached: Texas Medical Board Watch, Keith Miller
MD, Conflict of Interest; Red Devil Award)

Dr. Miller’s Nurse (Bridget Hughes)

Bridget Hughes worked for Dr. Craig McMullen in 2004 and 2005. During this time, Nurse
Hughes, for her own use, forged Dr. McMullen’s name to more than 50 prescriptions for
narcotics. This was a crime in violation of the Controlled Substance Act. When Dr. McMullen
discovered her crimes, he fired Nurse Hughes.
Nurse Hughes then began working for Dr. Miller, who is believed to be Nurse Hughes’ uncle.
While working for Dr. Miller, Nurse Hughes continued obtaining narcotics for her own use. In
December, 2006, Nurse Hughes admitted her crimes and surrendered her DEA license.

Acting as a whistle blower, Dr. Pigott pursued information she had been given concerning
Nurse Hughes’ continuing to obtain narcotics, while working in Dr. Miller’s office. This
created intense anger in Dr. Miller.