Mtion To Supplement The Record - Court Stamp

UNITED STATES COURT OF APPEALS
FOR THE EIGHTH CIRCUIT
_______________________________________________________________
Lee Michael Pederson, Appeal No. 18-3195
Plaintiff / Appellant,
v. PLAINTIFF / APPELLANT'S
Phillip Frost, OPKO Health, Inc., Brian MOTION
Keller, and CoCrystal Pharma, Inc.
Defendants / Appellees.
_______________________________________________________________
Plaintiff / Appellant's Second Motion

To Supplement the Record by Judicial Notice
Plaintiff hereby moves the Court to allow supplementation of the record by
judicial notice with the document described below. The Court may approve this
request under its inherent equitable authority to advance the principles of fairness,
truth, and judicial efficiency. (Harris, George C. and Li, Xiang (2013)
"Supplementing the Record in the Federal Courts of Appeals: What if the Evidence
You Need is not in the Record?" The Journal of Appellate Practice and Process,
Vol. 14, No. 2, pp. 317-333 at p. 323)
Plaintiff moves the Court to Supplement the Record by Judicial Notice with
Exhibit 1 - Opko Registration in Minnesota. This public record of the Minnesota

1
Appellate Case: 18-3195 Page: 1 Date Filed: 11/06/2018 Entry ID: 4723114
Secretary of State shows that (a) Defendant Opko was registered to do business in
Minnesota; and (b) Defendants submitted a false declaration to the Minnesota
District Court in an attempt to defeat jurisdiction of the Court.
Exhibit 2 is the sworn declaration of Kate Inman, General Counsel of
Defendant Opko, to the Minnesota District Court. (Exhibit 2 - Inman declaration)
The Inman declaration is already in the court record as Document 37 in the District
Court docket. Paragraph 5 of the Inman declaration says, "OPKO is not registered
to do business in the state of Minnesota." The Inman declaration was signed on
January 29, 2018.
Exhibit 1 is a public record from the website of the Minnesota Secretary of
State (Exhibit 1 - Opko Registration in Minnesota). Exhibit 1 shows that Opko was
registered to do business in Minnesota on the date that the Inman declaration was
signed. Exhibit 1 shows that Defendants submitted a false sworn declaration to the
District Court. The false declaration relates directly to the issue of jurisdiction, the
sole issue on appeal before the 8th Circuit Court of Appeals. The proof of Opko's
registration to do business is material to this case. The proof that the Inman
declaration is false is material to this proceeding.
Plaintiff requests by motion that Exhibit 1 - Opko Registration in Minnesota
be added to the record of this case. The attached declaration of Plaintiff / Appellant
Lee Pederson attests to the source of Exhibit 1, and the circumstances of Exhibit 1
being introduced at this time.
A.B.A. Model Rule of Professional Conduct 3.3 (Candor Toward the
Tribunal)1 says:
(a) A lawyer shall not knowingly:
(1) make a false statement of fact or law to a tribunal or fail to correct

a false statement of material fact or law previously made to the tribunal
by the lawyer; … or
(3) offer evidence that the lawyer knows to be false. If a lawyer, the
lawyer’s client, or a witness called by the lawyer, has offered material
evidence and the lawyer comes to know of its falsity, the lawyer shall
take reasonable remedial measures, including, if necessary, disclosure
to the tribunal. A lawyer may refuse to offer evidence, other than the
testimony of a defendant in a criminal matter, that the lawyer
reasonably believes is false. (italics added)
When Plaintiff became aware of the existence of Exhibit 1, Plaintiff contacted
Defendants' attorney Joe Dixon and offered Mr. Dixon the opportunity to comply
with Rule 3.3. (see Exhibit 3 - email to Joe Dixon) Mr. Dixon did not respond.
Fraudulent, misleading, unethical and deceptive actions are the themes of the
Defendants in this case. (See Plaintiff's declaration, Exhibit 3, and Exhibit 4) The
Plaintiff's underlying complaint against the Defendants is fraud. The SEC has
referred to the Defendants as "Fraudsters" for their roles in various alleged securities
frauds. The Defendants used a false narrative to mislead the District Court in this
1
Minnesota Rule of Professional Responsibility 3.3 is essentially the same.
3
case. The Defendants are trying to exclude information relating to their alleged
frauds from the court records in this case. The Defendants submitted a false sworn
declaration to the District Court in this case. The Defendants have not withdrawn
their false declaration. Once again, Plaintiff is forced to file a motion to counter
Defendants' deceptive and unethical practices.
For the reasons stated above, Plaintiff moves the Court to accept Exhibit 1
into the record by judicial notice.
Respectfully submitted,
Date: November 6, 2018 Plaintiff/Appellant’s Signature

/s/ Lee Pederson
Lee Michael Pederson

Pro se
MN Atty. No. 225605
2126 Lyndale Ave S #6
Minneapolis, MN 55405
952-836-7949
LeeMPete@aol.com
_______________________________________________________________
Phillip Frost, OPKO Health, Inc., Brian DECLARATION
Keller, and CoCrystal Pharma, Inc.
_______________________________________________________________
Plaintiff / Appellant's Declaration
I, Lee Michael Pederson, declare as follows:
1. My name is Lee Pederson. I am the Plaintiff / Appellant in this case. I am acting
pro se.
2. This case has attracted some national media coverage and my contact information
is available in the public court filings. As a result, I have occasionally been contacted
by people regarding the case.
3. On November 2, I was contacted by a person referred to herein as "H." H's life
has been affected by Frost gang insiders, and H was seeking legal representation
and/or a referral for legal representation.
4. H is familiar with my case (Pederson v Frost).
5. H is familiar with news stories about the Frost gang.
6. During our initial discussion, H said that their own research had produced some
public documents which might be useful to me.
7. On November 3, H provided me with the documents. One of the documents is
Exhibit 1 (Exhibit 1 - Opko registration to do business in Minnesota).
8. After receiving Exhibit 1 from H as a pdf file, I independently searched the
Minnesota Secretary of State website to see if the document was authentic. I found
the exact same document on the Minnesota Secretary of State website.
9. Document 37 from the Minnesota District Court docket is the Declaration of Kate
Inman, the General Counsel of Opko. (Exhibit 2 - Inman declaration) Paragraph 5
of the Inman declaration says, "OPKO is not registered to do business in the state of
Minnesota." The Inman declaration was signed on January 29, 2018.
10. Exhibit 1 shows that Opko was registered to do business in Minnesota on the
date that the Inman declaration was signed.
11. Exhibit 1 shows that Defendants submitted a false sworn declaration to the
District Court. The false declaration relates directly to the issue of jurisdiction, the
sole issue on appeal before the 8th Circuit Court of Appeals.
12. The false declaration is material to this proceeding.
13. On November 4, I emailed Defendants' attorney Joe Dixon to inform him that I
knew of the existence of Exhibit 1 and that the Inman declaration was false. (Exhibit
3 - email to Joe Dixon) In that email, I offered Mr. Dixon the opportunity to
withdraw the false Inman declaration as required by Minnesota Rule of Professional
Responsibility 3.3(a).
14. The November 4 email (Exhibit 3) further offered Mr. Dixon the opportunity to
take other remedial actions to address other of Defendants' attorneys' ethical lapses
in their representation of Defendants.
15. The Defendants' attorneys have failed to take any remedial measures as required
by the Rules of Professional Responsibility.
16. The Defendants are engaging in a continuing series of fraudulent and dishonest
actions, including actions before the Court.
(a) The Plaintiff's underlying complaint against the Defendants is for fraud.
(b) The SEC has referred to the Defendants as "Fraudsters" for their roles in
various alleged securities frauds.
(c) The Defendants used a false narrative to mislead the District Court in this
case.
(d) The Defendants are trying to exclude information relating to their alleged
frauds from the court records in this case.
(e) The Defendants submitted a false sworn declaration to the District Court
in this case.
(f) The Defendants have not withdrawn their false declaration.
17. Mr. Dixon's failure to withdraw the false Inman declaration violates Minnesota
Rule of Professional Responsibility 3.3(a)(1) and Minnesota Rule of Professional
Responsibility 3.3(a)(3).
18. The Defendants' attorneys' violations of Minnesota Rule of Professional
Responsibility 3.3(b) are described at pages 7-8 of Plaintiff / Appellant's Reply to
Opposition, filed October 31, 2018.
19. The Defendants' attorneys' violations of Minnesota Rule of Professional
Responsibility 1.7 are described in an email chain between Plaintiff and Defendants'
attorneys. (Exhibit 4 - email chain).
I declare under the penalty of perjury that the forgoing is true and correct. Executed
on November 6, 2018.
/s/ Lee Pederson
Respectfully submitted,

/s/ Lee Pederson

Pro se
MN Atty. No. 225605
952-836-7949
LeeMPete@aol.com
Business Record Details »
Minnesota Business Name

OPKO LAB, LLC
Business Type MN Statute

Limited Liability Company (Foreign) 322C
File Number Home Jurisdiction

670186900092 Florida
Filing Date Status

4/30/2013 Inactive
Renewal Due Date Registered Office Address

12/31/2017 2345 Rice Street, Suite 230
Roseville, MN 55113
USA
Registered Agent(s) Manager

Corporation Service Company OPKO Health, Inc.
4400 Biscayne Blvd
Miami, FL 33137
USA
Principal Executive Office Address Home Business Name

4400 Biscayne Blvd OPKO OURLab, LLC
Miami, FL 33137
USA
USA
Home Office Address

4400 Biscayne Blvd
Miami, FL 33137
USA
Filing History
Filing History
Select the item(s) you wouldCase:

Appellate like to order: Page:
18-3195 Order1Selected Copies
Date Filed: 11/06/2018 Entry ID: 4723114
Filing Date Filing Effective Date
4/30/2013 Original Filing - Limited Liability Company (Foreign)

(Business Name: OPKO OURLab, LLC)
12/10/2013 Amendment - Limited Liability Company (Domestic)

(Business Name: OPKO LAB, LLC)
2/5/2015 Registered Office and/or Agent - Limited Liability

Company (Foreign)
1/1/2018 Conversion to 322C Due to Statute Mandate –

Limited Liability Company (Foreign)
3/9/2018 Revocation - Limited Liability Company (Foreign)
© 2018 Office of the Minnesota Secretary of State - Terms & Conditions
CASE 0:17-cv-05580-WMW-BRf Document 37 Filed 01/31/1-8 Page
LTNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
LEE MICHAEL PEDERSON, Court File No. l7-cv-5580 ( w/BRT)
Plaintiff,
PHILLIP FROST, OPKO HEALTH, [NC.,

BRIAN KELLER, COCRYSTAL
PHARMA, INC. AND DOES 1-50,
Defendants.
DECLARATION OF OPKO HEALTH, INC.

IN SUPPORT OF MOTION TO DISMISS COMPLAINT
FOR LACK OF'PERSONAL JURISDICTION
Pursuantto 28 U.S.C. 5 t746,I, KATE INMAN, ESQ., hereby declare and state as
follows:
l. I am over 18 years of age. I am competent and otherwise qualified to
execute this Declaration. I have personal knowledge of the statements made herein or, in
the alternative, derive knowledge of such statements frotn OPKO Health, Inc.'s
("OPKO") business records.
2. I arn OPKO's General Counsel.
3. OPKO is a f)elaware corporation.
4. OPKO's principal place of business is located at 4400 Biscayne Boulevard,
Miami, Florida 33137.
5. OPKO is not registered to do business in the state olMinnesota.
43933s53:2
CASE 0:17-cv-05580-WMW-BRT Document 3T Filed 01-13UL8 Page 2 at 2
6. OPKO does not have any offic'es in the state of Minnesota.
7. OPKO does not own any real or personal property in the state of
Minnesota. i
8. OPKO does not have any agents or employees in the state of Minnesota.
9. OPKO does not have any'bank accounts in the stat€ of Minnesota
I declare under penalty of perjury that the foregoing is true and correct.
4^ t-'
Executed this / lday of January, 2018. ',
lnman, Esq.
General Counsel of OPKO Health, Inc.
43933953:2
11/5/2018 Pederson v Frost - new information
From: Lee Pederson <leempete@aol.com>

To: jdixon <jdixon@fredlaw.com>
Cc: leempete <leempete@aol.com>
Subject: Pederson v Frost - new information
Date: Sun, Nov 4, 2018 7:15 am
Dear Joe,
Document 37 from the Minnesota District Court docket is the Declaration of Kate Inman, the General Counsel
of Opko. Paragraph 5 says, "OPKO is not registered to do business in the state of Minnesota." The document
was signed on January 29, 2018.
Please see the record at the following link, of which I just became aware. It shows that Opko was
registered to do business in Minnesota on the date that the Inman declaration was signed.
https://mblsportal.sos.state.mn.us/Business/SearchDetails?filingGuid=5048a978-65b3-e211-82ac-001ec94ffe7f
Joe, you have now violated the following rules of professional conduct in conjunction with your representation
of Frost:
Rule 1.7 - conflicts of interest. You have violated this rule with many combinations of conflicted
representations.
Rule 3.3(b) - candor toward the tribunal. You violated this rule by misleading the court with a false narrative
about the credibility of my allegations.
Rule 3.3(b) again - candor toward the tribunal. You violated this rule by opposing my motion to supplement the
record.
Rule 8.4 - misconduct - maintaining the integrity of the profession. You violated this rule by breaking the other
rules.
Rule 3.3(a)(1) - candor toward the tribunal. You violated this rule by misleading the court with a false
declaration.
I am giving you an opportunity to comply with Rule 3.3(b) and Rule 3.3(a)(3) by taking reasonable remedial
measures, including (1) withdrawing the Inman declaration; (2) introducing the attached record from the
Minnesota Secretary of State's office into the record; (3) admitting the falsity of the Inman declaration; (4)
agreeing to jurisdiction of the Minnesota District Court over Opko; (5) agreeing to jurisdiction of the Minnesota
District Court over any other of the defendants you may ethically represent; and (6) withdrawing your
opposition to my motion to supplement the record. I am giving you an opportunity to comply with Rule 1.7 by
(7) withdrawing from all representations that pose a conflict of interest.
If you comply with Rule 1.7 by withdrawing from conflicts situations, and comply with Rule 3.3(b) and Rule
3.3(a)(3) by undertaking remedial actions, it will save me some effort that I would otherwise have to expend to
address issues you have caused with your ethical lapses.
This email is being bcc'd to Federal agents from the SEC, FBI and United States Attorney's Office.
Signed,
Lee Pederson
https://mail.aol.com/webmail-std/en-us/PrintMessage 1/1
11/5/2018 Fwd: Pederson v Frost et al - Re Brian Keller

To: mpiekarski <mpiekarski@SRF.LAW>; jdixon <jdixon@fredlaw.com>; AChiquoine <AChiquoine@fredlaw.com>; brian.miller
<brian.miller@akerman.com>; samantha.kavanaugh <samantha.kavanaugh@akerman.com>; twolinetz
<twolinetz@SRF.LAW>; drozansky <drozansky@stubbsalderton.com>; masherman <masherman@stubbsalderton.com>
Cc: leempete <leempete@aol.com>
Subject: Fwd: Pederson v Frost et al - Re Brian Keller
Date: Sat, Nov 3, 2018 5:48 pm
Dear Opposing Counsel,
In my email to you of November 1, I asked you each three very simple and straightforward
questions. It would take less than a minute for you to answer these questions honestly. At this point, I
have not yet received any response. If I do not get responses by the end of the day of November 8, I
will assume that (1) none of you represent Dr. Keller; (2) none of you know if Dr. Keller has other
representation; and (3) none of you know of any prohibition against me contacting Dr. Keller directly.
I note the following. (1) There is an ongoing SEC investigation regarding your clients (Frost,
OPK and COCP). (2) There is an ongoing DOJ investigation regarding your clients. (3) Dr. Keller
has information pertinent to these investigations. (4) Dr. Keller may potentially testify against your
clients. (5) Any representation of Dr. Keller by you would violate your obligations under the rules of
professional responsibility. (6) Any attempt to contact Dr. Keller by you, your clients, or agents of your
clients may comprise obstruction of justice.
I urge you to voluntarily get straight with your issues regarding conflicts of interest. The notices
of appearance you have filed with the Eighth Circuit show that each and every one of you is violating
Rule of Professional Conduct 1.7.
Frost is the CEO, Chairman, and largest shareholder of OPK. OPK is a publicly traded
company. There is a clear and nonwaivable conflict of interest between OPK and Frost. You cannot
proceed with joint representation of Frost and OPK unless you intend to continue to knowingly violate
Rule of Professional Conduct 1.7.
Frost is on the Board of Directors at COCP. Frost has numerous connections with and
influences over other board members and corporate officers at COCP. COCP is a publicly traded
company. There is a clear and nonwaivable conflict of interest between COCP and Frost. You cannot
proceed with joint representation of Frost and COCP unless you intend to continue to knowingly
violate Rule of Professional Conduct 1.7.
Resolution of your conflict issues in Pederson v Frost et al is straightforward. Each party simply
needs their own counsel, including their own local counsel.
Resolution of your conflict issues in SEC v Honig et al will be more interesting. I am waiting to
see who will represent Southern Biotech, where Frost, Honig and Brauser are all owners.
A.B.A. Rule 8.4: Misconduct
Maintaining The Integrity Of The Profession
It is professional misconduct for a lawyer to:

(a) violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another
to do so, or do so through the acts of another; …
(d) engage in conduct that is prejudicial to the administration of justice;
Elliot Maza and Harvey Kesner are two examples of attorneys who have worked for Frost.
Both were present at the meetings in Miami in 2012 that marked the start of Frost's frauds at
BioZone/COCP. Both violated their duties of professional responsibility by putting Frost's interests
ahead of the interests of their other clients. Both are now defendants in civil cases for such actions.
Enough said about Maza and Kesner, for the time being.
As before, this email is being bcc'd to Federal agents from the SEC, FBI and United States
Attorney's Office.
Signed,
Lee Pederson
-----Original Message-----
To: mpiekarski <mpiekarski@SRF.LAW>; jdixon <jdixon@fredlaw.com>; achiquoine <achiquoine@fredlaw.com>;
brian.miller <brian.miller@akerman.com>; samantha.kavanaugh <samantha.kavanaugh@akerman.com>; twolinetz
<twolinetz@SRF.LAW>; drozansky <drozansky@stubbsalderton.com>; msherman <msherman@stubbsalderton.com>
Sent: Thu, Nov 1, 2018 10:15 am
Subject: Pederson v Frost et al - Re Brian Keller
Thank you for your non-responses and your evasive responses. It provides me the opportunity to put some
things down for the written record.
First, I note that you all have issues with conflicts of interests. There are a number of active and potential
lawsuits that involve your clients and/or firms, including:
1. Pederson v Frost et al (Frost, Opko, Keller and COCP are all defendants)
2. SEC v Honig et al (Frost, Opko and Keller are all defendants)
3. MabVax v Sichenzia et al (Sichenzia firm is a defendant, and Frost and Opko are both potential defendants)
4. COCP class actions (Frost, Keller and COCP are all defendants)
5. OPK class actions (Frost and Opko are both defendants)
6. potential DOJ criminal actions (Frost, Opko, Keller and COCP are all potential defendants)
Joint representation of Opko and Phillip Frost is just one of your many conflicts issues. When Frost is forced
out of Opko (an absolute certainty), new management might want reimbursement for legal fees that Opko spent
for Frost's benefit. If your firm is in a conflicted situation, you are likely to be viewed as a possible source for
such reimbursement. Further, the Frost/Opko conflict is not waivable for at least as long as Frost controls
Opko. Looking on the bright side for you, your Frost/Opko conflict situation will probably become the subject
of one or more scholarly legal articles.
Second, I note that Brian Keller might "flip" and testify against Frost, including in the event of criminal charges
being brought.
Third, I note that if Brian Keller is not represented by counsel, then I can contact him directly.
I request that each of you provide direct, non-evasive answers to the following questions:
1. Do you or your firm presently represent Brian Keller in any capacity?
2. Do you know if Brian Keller is represented by other counsel? If so, please provide details.
3. Do you know of any reason why I might be prohibited from contacting Brian Keller directly?
This email is being bcc'd to Federal agents from the SEC, FBI and United States Attorney's Office.
Signed,
Lee Pederson
PS to Mr. Piekarski: I still have the voicemails that you and Harvey Kesner (individual defendant in MabVax v
Sichenzia) left me on November 22, 2017, including the voicemail in which Kesner threatened me with an ethics
complaint. In those voicemails, you and Kesner both indicated that you represented Keller.
-----Original Message-----
From: Mendy Piekarski <mpiekarski@SRF.LAW>
To: 'Lee Pederson' <leempete@aol.com>; jdixon@fredlaw.com <jdixon@fredlaw.com>; achiquoine@fredlaw.com
<achiquoine@fredlaw.com>; brian.miller@akerman.com <brian.miller@akerman.com>;
samantha.kavanaugh@akerman.com <samantha.kavanaugh@akerman.com>; Thomas Wolinetz <twolinetz@SRF.LAW>;
drozansky@stubbsalderton.com <drozansky@stubbsalderton.com>; msherman@stubbsalderton.com
<msherman@stubbsalderton.com>
Sent: Wed, Oct 31, 2018 12:46 pm
Subject: RE: Pederson v Frost et al - Re Brian Keller
Mr. Pederson,
Sichenzia Ross Ference LLP does not represent Mr. Keller in this appeal.
Thank you,
Mendy Piekarski, Esq.

Partner
Sichenzia Ross Ference LLP
1185 Avenue of the Americas | 37th Floor | New York, NY 10036
T 212-930-9773 | F 212-930-9725
mpiekarski@srf.law www.srf.law
From: Lee Pederson [mailto:leempete@aol.com]

Sent: Tuesday, October 30, 2018 12:32 PM
To: jdixon@fredlaw.com; achiquoine@fredlaw.com; brian.miller@akerman.com; samantha.kavanaugh@akerman.com; Mendy
Piekarski; Thomas Wolinetz; drozansky@stubbsalderton.com; msherman@stubbsalderton.com
Subject: Pederson v Frost et al - Re Brian Keller
Joseph T. Dixon III (#0283903)

Alexander D. Chiquoine (#0396420)
Fredrikson & Byron, P.A.
200 South Sixth Street, Suite 4000
Minneapolis, MN 55402-1425
Telephone: 612.492.7000
Facsimile: 612.492.7077
jdixon@fredlaw.com
achiquoine@fredlaw.com
Attorneys for Defendants OPKO Health, Inc.,
Phillip Frost, Brian Keller, and CoCrystal

Pharma, Inc.
Brian P. Miller (admitted pro hac vice)

Samantha J. Kavanaugh (admitted pro hac vice)
AKERMAN LLP
98 Southeast Seventh Street, Suite 1100
Miami, FL 33131
Telephone: 305.374.5600
Facsimile: 305.374.5095
brian.miller@akerman.com
samantha.kavanaugh@akerman.com
Attorneys for Defendants Phillip Frost and
OPKO Health, Inc.
Mendy Piekarski (admitted pro hac vice)

Thomas Scot Wolinetz (admitted pro hac vice)
SICHENZIA ROSS FERENCE KESNER LLP
1185 Avenue of Americas, 37th Floor
New York, NY 10036
Telephone: 212.930.9700
Facsimile: 212.930.9725
mpiekarski@srfkllp.com
twolinetz@srfkllp.com
Attorneys for Defendant Brian Keller ???
Michael Sherman (admitted pro hac vice)
Dan Rozansky (admitted pro hac vice)
STUBBS ALDERTON & MARKILES, LLP
15260 Ventura Blvd., 20th Floor
Sherman Oaks, CA 91403
Telephone: 818.444.4500
Facsimile: 818.444.4520
drozansky@stubbsalderton.com
msherman@stubbsalderton.com
Attorneys for Defendant CoCrystal Pharma, Inc.
From Defendants' Certificate of Service filed on October 25, it appears that Dr. Brian Keller is not currently
represented by counsel in Pederson v Frost et al. Further, according to court filings, Dr. Keller is acting pro se in
SEC v Honig et al.
Do any of you or your firms currently represent Dr. Brian Keller in any capacity? Do any of you know if Dr.
Keller has any other legal representation? Please provide this information.
Both Fredrickson and Sichenzia represented Keller at some point. I request that all of your firms clarify your
current relationship with Dr. Keller.
Signed,
Lee Pederson
Pro se
Disclaimer
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others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking
action in relation of the contents of this information is strictly prohibited and may be unlawful.
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_______________________________________________________________
Phillip Frost, OPKO Health, Inc., Brian CERTIFICATE OF
Keller, and CoCrystal Pharma, Inc. COMPLIANCE
_______________________________________________________________
CERTIFICATE OF COMPLIANCE
I certify that Plaintiff / Appellant's Second Motion to Supplement the
Record, filed on November 6, 2018, conforms to type-volume limitations for
Motions filed under Rule 27. The length of the Motion is 764 words. The Motion
was prepared using Microsoft Word 2010 and the word processing program has
been applied specifically to include all text, including headings, footnotes, and
quotations for word count purposes.
/s/ Lee Pederson

Pro se
MN Atty. No. 225605
952-836-7949
LeeMPete@aol.com

Mtion To Supplement The Record - Court Stamp

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UNITED STATES COURT OF APPEALS

FOR THE EIGHTH CIRCUIT

Lee Michael Pederson, Appeal No. 18-3195

Phillip Frost, OPKO Health, Inc., Brian MOTION

Keller, and CoCrystal Pharma, Inc.

Plaintiff / Appellant's Second Motion

Plaintiff hereby moves the Court to allow supplementation of the record by

Vol. 14, No. 2, pp. 317-333 at p. 323)

Exhibit 1 - Opko Registration in Minnesota. This public record of the Minnesota

Minnesota; and (b) Defendants submitted a false declaration to the Minnesota

District Court in an attempt to defeat jurisdiction of the Court.

Exhibit 2 is the sworn declaration of Kate Inman, General Counsel of

Defendant Opko, to the Minnesota District Court. (Exhibit 2 - Inman declaration)

to do business in the state of Minnesota." The Inman declaration was signed on

January 29, 2018.

Exhibit 1 is a public record from the website of the Minnesota Secretary of

declaration is false is material to this proceeding.

Plaintiff requests by motion that Exhibit 1 - Opko Registration in Minnesota

being introduced at this time.

A.B.A. Model Rule of Professional Conduct 3.3 (Candor Toward the

(a) A lawyer shall not knowingly:

(1) make a false statement of fact or law to a tribunal or fail to correct

When Plaintiff became aware of the existence of Exhibit 1, Plaintiff contacted

Defendants' deceptive and unethical practices.

into the record by judicial notice.

Date: November 6, 2018 Plaintiff/Appellant’s Signature

Lee Michael Pederson

Lee Michael Pederson, Appeal No. 18-3195

Phillip Frost, OPKO Health, Inc., Brian DECLARATION

Keller, and CoCrystal Pharma, Inc.

Plaintiff / Appellant's Declaration

I, Lee Michael Pederson, declare as follows:

1. My name is Lee Pederson. I am the Plaintiff / Appellant in this case. I am acting

by people regarding the case.

and/or a referral for legal representation.

4. H is familiar with my case (Pederson v Frost).

5. H is familiar with news stories about the Frost gang.

public documents which might be useful to me.

7. On November 3, H provided me with the documents. One of the documents is

Exhibit 1 (Exhibit 1 - Opko registration to do business in Minnesota).

8. After receiving Exhibit 1 from H as a pdf file, I independently searched the

the exact same document on the Minnesota Secretary of State website.

Inman, the General Counsel of Opko. (Exhibit 2 - Inman declaration) Paragraph 5

Minnesota." The Inman declaration was signed on January 29, 2018.

date that the Inman declaration was signed.

sole issue on appeal before the 8th Circuit Court of Appeals.

12. The false declaration is material to this proceeding.

withdraw the false Inman declaration as required by Minnesota Rule of Professional

in their representation of Defendants.

by the Rules of Professional Responsibility.

actions, including actions before the Court.

various alleged securities frauds.

frauds from the court records in this case.

(f) The Defendants have not withdrawn their false declaration.

Rule of Professional Responsibility 3.3(a)(1) and Minnesota Rule of Professional

18. The Defendants' attorneys' violations of Minnesota Rule of Professional

Responsibility 3.3(b) are described at pages 7-8 of Plaintiff / Appellant's Reply to

Opposition, filed October 31, 2018.

19. The Defendants' attorneys' violations of Minnesota Rule of Professional

attorneys. (Exhibit 4 - email chain).

/s/ Lee Pederson

Date: November 6, 2018 Plaintiff/Appellant’s Signature

Lee Michael Pederson