In an almost laughable response to the Motion for Sanctions, attorney Keith Hill, of the firm Heyl Royster, has filed an answer that... well, you have to read it to believe it.
But let’s walk through this slowly — and clearly — so readers can understand why his latest filing isn’t just contradictory, it’s self-incriminating.
The Motion for Sanctions was about Keith Hill’s abusive and unprofessional behavior in emails — plain and simple.
He:
Demanded corrections to a disabled adult pro se litigant in a manner of chastising a student or an English teacher grading a midterm,
Tried to intimidate and lecture me on my legal theories,
And fired off bullying, condescending messages that violate basic standards of professionalism.
But here's the kicker: in two of those emails, Hill angrily claimed he “never initiated mediation.”
So I attached the proof — his own email — where he clearly did.
In that message, Keith Hill asked me to provide a dollar amount that would cover all of the state court cases and the federal case in which he represents the City. That wasn’t casual chit-chat — that’s a direct move to initiate mediation.
To be clear: the state court judge asked us to mediate. I agreed. And then Hill agreed in court but then HE CHOSE TO INITIATE AND INCLUDE THE FEDERAL CASE— by asking me for numbers to settle everything, including his federal case.
Rather than address the actual misconduct — that he sent unsolicited, intimidating emails after being told to stop — Keith Hill’s 11-page response reads like a frantic smokescreen. He throws everything at the wall to see what sticks, dragging in irrelevant filings, stricken pleadings, and petty distractions — all while never once acknowledging the heart of the sanctions motion: his own behavior.
Let’s break this down.
To defend himself against accusations of harassment, Hill attempts to:
Re-litigate past filings completely unrelated to the motion.
Cite a stricken document (Doc. 28) that the Court already tossed out as improper — yet he treats it as proof of misconduct.
Fixate on “misquoted cases” and “citation formatting” — as if a typo justifies badgering a disabled litigant via email.
Lecture the plaintiff for not withdrawing her motion — while ignoring the fact that he escalated after it was filed.
He even speculates that she might be using AI to write briefs — as if that somehow excuses his decision to bypass legal channels and send correction lists directly to her inbox like a digital hall monitor.
He never denies sending multiple correction emails after being told to stop.
He never addresses the specific warning issued on June 30.
He never explains why he sent another email on July 28 — after the sanctions motion was filed.
👉 When cornered, a bully won’t apologize — he’ll double down, point fingers, and try to make the victim look like the problem.
“I wasn’t harassing you — you just misunderstood me. Also, look at these other things you did wrong.”
Keith Hill wants the court — and the public — to believe he’s the victim of an unfair sanctions motion. But in doing so, he:
Weaponizes irrelevant filings that are already moot,
Distracts from his own conduct by nitpicking formatting and phrases,
And attacks the plaintiff’s credibility rather than answering a single core accusation.
This is the behavior of someone who knows he crossed a line and is trying to bury it under noise.
And in the end, it proves the point:
He cannot justify the emails — so he tries to shift the blame.
That’s what bullies do.
Let’s be very specific. In his email attacks - Keith Hill calls the plaintiff basically a liar for stating he initiated mediation discussions that include the federal case.
The state court judge asked the parties if they would consider mediation. I agreed.
Keith Hill — who is representing the City of West Frankfort in federal court only — responded by asking me for a dollar amount that would resolve all state claims and the federal claim he represents.
The state court did not ask him to do this - they have no authority over a federal case - it was SOLELY THE INITIATION OF KEITH HILL that brought the federal case to the table for discussion.
That is the textbook definition of initiating mediation. You don’t ask for settlement terms for a federal claim — in writing — unless you’re participating. You definitely don’t do it while claiming you never agreed to mediation.
This isn’t complicated. It’s like saying you didn’t order a pizza while holding the receipt and a half-eaten slice.
To ensure transparency, I’m sharing all three key filings. Read them yourself:
📄 [My Motion for Sanctions]
📄 [Keith Hill’s Answer]
📄 [My Rebuttal]
→ Documents are labeled and entered at bottom of this article. As you read through them, you will understand the shock.
This goes beyond simple legal maneuvering. When an attorney lies to the court and tries to twist basic facts — especially regarding mediation — it’s a form of bad-faith litigation. It wastes court resources, violates professional ethics, and harms the plaintiff who is already under enormous strain.
Even more disturbing: Hill’s argument tries to confuse jurisdictional lines. The state court ordered mediation. Federal involvement came in only because he brought it up — trying to use the mediation process as leverage across both cases.
If the court allows this kind of behavior to go unchallenged, it sets a dangerous precedent for attorneys to weaponize dishonesty with impunity.
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