Anthony Lewis v. HCA Florida Lawnwood Hospital
This petition seeks the following three-fold procedural and constitutional review:
1. Whether the district court deprived Dr. Lewis and his counsel of their statutory or procedural right to amend the First Amended Complaint without leave of court pursuant to Fed. R. Civ. P. 15 (a)(1)(B).
2. Whether the district court violated Dr. Lewis's and his counsel's First Amendment right to petition pursuant to the holding in NAACP v. Button, 371 U.S. 415 (1963) (First Amendment) and its progeny.
3. Whether the district court violated Dr. Lewis's and his counsel's Thirteenth Amendment right to petition pursuant to the holding in Civil Rights Cases, 109 U.S. 3, 22 (1883) (Thirteenth Amendment; Civil Rights Act of 1866) and its progeny.
Whether the district court violated petitioner's statutory right to amend pleadings under Federal Rule of Civil Procedure 15(a)(1)(B) and his First and Thirteenth Amendment rights to petition for redress of grievances