Gerald Kiley 

Respondents pre hearing statements 

Pronto Pharmacy LLC v United States Drug Enforcement

HEARING JANUARY 28-31 Tampa Fla., (Federal Timberlake Building)


Gerald Kiley 61-year-old male has for the past 3 years traveled every 30 days to Pronto Pharmacy each month round trip more than 340 miles to fill his prescriptions. lives in Cape Coral, Fort Myers area 

Mr. Kiley states: 

“ I come to Pronto because the availability of his prescription medication is not down there (Ft. Myers Cape Coral area). He furthers states when he brings his prescription into a regular pharmacy such as CVS or a Walgreens they tell him they don’t have it, we don’t carry it anymore.

He fines, these pharmacy attitudes a suspect and profiling.

Mr. Kiley further states 

“ I have severe back pain, degenerative disk in his neck. Sometimes I can’t sit many times, I’m dependent on these medications and I’ve been on these medications for nearly 5 years. his pain is related to injuries in several car accidents, he was a painter and has fallen off ladders before. (see IMG_9157.mov_Gerald Kiley, 3.21 mins)

Mr. Gerald Kiley States:

He heard about Pronto Pharmacy thru a friend of his who had been coming to Pronto because he too was having a problem getting his prescriptions filled in the Fort. Meyer, Cape Coral area.

Mr. Kiley, after reviewing the statement from August 23, 2019, Order To Show Cause (OTSC-PP8-19) issue to Pronto Pharmacy,  states he pays by cash because he has no insurance, that he is not a junkie and not selling his medications and he has to pay by cash and that he is not wealthy.  He refutes the DEA assertion he is abusing his medication(see IMG_9158.mov-gerald_k_se.copy,2.52mins)

Mr. Kiley further reviewed and was read the OTSC(PP8-19) in which the DEA opined that traveling distance was a significant “red flag” and the prescriptions being filled by Pronto-Pharmacy were being diverted and should not have been filled.

Mr. Kiley, strongly disagree with the DEA’s assertion, he states: he is not abusing his medication, diverting his medication,  he says “I’m am 61 years old and falling apart,” and has not violated any State or Federal law…(see img_9159mov-GK-reviews_OTSC-pp8-19_and Don_Sullivan…copy, 3mins)

Mr. Kiley, states: He’s driving more than 200 miles to have his prescription for non-acute pain, which is typed on the prescription. Mr. Kiley, also states in this video he went to the Pharmacy next door to his physicians off, and that pharmacist told him he didn’t have the medication (see img_9162.mov-GK_identified_disease-states_copy,2.37 mins). 

Pharmacist, Norman J Clement stated at the time he believed the pharmacist next door to his physician was lying. Pharmacist, Norman J Clement latter learned the Pharmacy was “AT COST PHARMACY”, the Pharmacist was Aaron Howard PharmD. Pharmacist, Clement also learn he and Howard had worked together while both had been employed by CVS Pharmacy.  Aaron Howard had graduated from Florida A&M University College of Pharmacy with my daughter (AC Clement) in 2003.

Pharmacist, Aaron Howard spoke with Clement on December 8th, 2019 stated “Clement’s statement are correct and true,” and that he did mislead Mr. Kiley and many other patients because he was becoming increasingly afraid to fill control medication because the DEA was harassing him at his store. 


Pharmacist, Aaron Howard,  learned of the Pronto Pharmacy plight and called Clement while he was on the Golf Course Sunday morning November 24, 2019. The two struck it well and Clement learned of a 3rd DEA raid on Gulf Coast Pharmacy, 11/18/2019 where an Order To Show Cause (OTSC-GCP11-19)

was issued to Pharmacy owner Ricardo Fertil PharmD. Fertil and Howard had been business partner but separated in early 2016.

Howard and Fertil are not generally on speaking terms however realize DEA was targeting Black-Owned Pharmacies likely under the belief they were easy enforcement targets. Yet despite their difference and grievance both have united/join forces together with Clement, Guy Decker RPh., Jack Folson RPh., Walter R Clement, law enforcement, Richard C. Clement, C-Systems tech., Norman L Clement, pharm-tech., Jelani Z. Clement B.S., MBA as “THE TEAM”, our Coach is DALE SISCO Esq.

Mr. Kiley agrees he’s profiled and being punished and assigned both State and Federal Criminal Violation of the law (see img_9163.mov_Miles_Disease-states_1.04 mins).

because he is having to travel, “as far he knows everything is legal, it has the doctors DEA number on the prescriptions.”  I didn’t know there was going to be a problem (see OTSC-pp8-19),

Mr. Kiley, pulls up his shirt, show he has a large umbilical hernia, liver leaks fluid into his abdomen which causes server pain which has to have drained every two weeks especially when it fills up on my and my spine I have a couple of tears in both my neck and my spine which causes severe pain, I’m just trying to get my prescription filled. img_9185.mov_Medical-Conditions_1.31 mins). 

Mr. Kiley, states he has never been examine physically, or spoken with DEA investigator Rich Alpert, or DEA’s Pharmacist Expert Don Sullivan, or United States Attorney Beerbower. (see WM_Gerald_Kiley Profiled Copy2.21 mins). Mr. Kiley, States “I’m not a criminal”


by norman j clement rph.,dds

Living in the Spirit of Sankofa

for now, you’re within the norms

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