Joseph R.

Crussiah
Pro Se Plaintiff
9701 Cottrell Terrace
Silver Spring, MD 20903
240-475-7737
crussiah@yahoo.com
Blankingship & Keith P.C.
Attn: Kevin F.X. DeTurris
Counsel for Defendant Inova
RE: Joseph Crussiah v. Inova, Initial Joint Status Report Urgent Due Date June 27, 2016
Dear Mr. DeTurris:
My understanding is that the issues at hand require a response by the plaintiff and the
defendant. Then with cooperation, both responses are to be jointly submitted to the court by
either Inova or by Crussiah. Then with the due date upon us and your access to electronic filing;
I request that you file the report with the court.
Point 3: Plaintiff wishes to participate in a mediation session with a United States Magistrate
Judge; with a target date of August 27, 2016 or earlier.
Point 2: Plaintiff does not consent to all further proceedings being put before a United States
Magistrate Judge. However; Plaintiff foresees a complex and lengthy discovery process and
thinks that The Court should put those proceedings before a Unites States Magistrate Judge.
Points 1 and Points 4 are related: Modifications and Discovery; Plaintiff requests that all due
dates commencing with the August 1, 2016 due date be postponed by a period of 8 months.
The Plaintiffs position is that of restating The Courts conclusions regarding the controversy:
Inova, by deploying a large scale operation, interfered with the standard process by which a
patient who suffers injuries in the medical environment; seeks redress. Plaintiff only had a lone
physician. This was Dr. Sonalee Kulkarni. Dr. Kulkarni, as The Court recognized for the
Maryland physicians; has duties to not breach her contractual obligations to her patient. This is a
special type of contract; involving fiduciary duties to her patient. Information asymmetry in this
type of contract; is a given. States; license and regulate physicians, such that, problems dont
occur, in the first place.
Dr. Kulkarni had the duty to give her patient all the facts that she possessed about his
injuries, which occurred under her care. Even if her patient was at the same time, also obtaining
medical services from other providers and suffered injuries under their care, or if the injuries
predated the relationship; Dr. Kulkarni still owes to patient, the facts. Dr. Kulkarni, during the
initial visit; lived up to this standard. Her records speak about an old injury being caused by
another physician, whose hands slipped. Then, the injuries transformed during a drug treatment
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regime, that may have been excessive, by another physician. There is some diplomatic way to
get out the necessary facts, but also seek to minimize blame and guilt. This is the manner in
which Dr. Kulkarni, stated the facts. This is okay.
The instant controversy commenced when Plaintiff suffered injuries by the hands of a third
party medical provider. But this was not something Plaintiff did on the side. This was a part of
Dr. Kulkarnis orders. The report from Capital Imaging notes that Dr. Kulkarni is the referring
physician It must also be observed that Capital Imagings report does not mention Inova or
Dr. John Cochran. This observation alone supports Plaintiffs argument that Inova, and no one
from Inova, not even Dr. John Cochran, the head of the practice; is a part of Dr. Kulkarnis
contract with her patient. The same argument, which is a well established standard in the
medical profession; is also supported by The Courts recognition of states licensing and
regulating doctors. Nothing to do with some giant healthcare system.
Inovas massive undertaking included committing up to $3 billion, which as a non-profit; it
has accumulated but cannot stuff into anyones pockets. But is can be used for the undertaking
against a lone patient. Inova, when requesting a change of venue, stated that it possesses
quantities of evidence, so large, that there may be a logistical problem, transporting the
evidence to Greenbelt. This will be the initial request. Even if Inova, immediately, is
forthcoming, Plaintiff needs time to review the tangible items. Inova is a corporation with
16,000 employees. Plaintiff can commence with depositions with Dr. Sonalee Kulkarni; but then
Plaintiff has to select the few, most prominent persons, most connective to the tangible evidence
Inova also stated the many of its physicians will be witnesses. Inova used some of the $3
billion to buy off some off the local elected officials, who sent police to not only intimidate
Plaintiff into accepting merely a speck of his total health records, but also to participate in a
scheme to literally conceal, by using whiteout to conceal only a single fact from this limited set
of records. The fact related to Capital Imaging. Virginia Commonwealth Universitys Virginia
School of Medicine, runs a med school that is a collaboration with Inova. Inovas status is that
of a contractor. Plaintiff advised this state institution about the same facts which The Court
stated to be the malfeasance of Drs. Kulkarni and Cochran. Plaintiff showed the state institution
that Dr. Kulkarni was rewarded by Dr. Cochran for her participation in malfeasance; with the
rewards being paid out of the assets of the state institution. Additionally, by Dr. Kulkarni being
grossly unqualified; the appointment is harmful to the med school students and the public.
Inovas in-house law practice, the same which represents it in the instant case, within 3 hours of
Plaintiffs email to VCU; sent a letter to Plaintiff in which; Inova ordered Plaintiff to not contact
VCU. Inova ordered Plaintiff to not contact anyone at Inova. But Dr. Kulkarni has a contract
with Plaintiff. Additionally, with this contract Plaintiff gets access to Inova s waiting room at
the office where Dr. Kulkarni practices. Plaintiff gets access to the support staff who help Dr.
Kulkarni. With this order from Inova and by using the police to intimidate; Plaintiff was denied
what Dr. Kulkarni owed to him. Inova assembled a risk management team, the one that
Plaintiff labeled death panel. There is such a thing as a risk management team at most
hospitals. This is a cover-up squad for medical malpractice occurring in the hospitals. But there
is no such thing for a doctors office. Inovas letter also spoke on behalf of Capital Imaging.
Inova said that Plaintiffs statements were defamatory against third parties. Here again; Inova
wraps itself around Capital Imaging. One time while this death panel was in the middle of a
meeting in mid-November 2013; Plaintiff called and asked to speak to his doctor, Dr. Kulkarni.
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The nurse who Plaintiff spoke to said that Dr. Kulkarni was in a meeting with other doctors and
this would mean doctors, even outside of the neurology practice. This would also include
doctors from a cardiology practice, which is mainly owned by Inova. This same group also runs
and staffs the heart program at Washington Adventist Hospital, the closest hospital to Plaintiffs
home. Additionally; this hospital is owned by the same church organization, from which a
pastor, using, the tax-exempt church facilities delivered a sermon of no value from a religious
perspective and of no value from a medical perspective. The sermon was used to mislead
Plaintiff about the nature of the injuries that Inova is responsible for. Subsequent to Plaintiffs
court filings and some YouTube videos; in what could be inferred to be nothing less than guilty
as charged; the church, removed the video of that church service from the internet and replaced
it with a shortened podcast of the sermon. With the new version, even containing some entirely
new words. There was large defamatory statement, placed in the lead page of Plaintiffs
medical records. Inova argued that Plaintiff has to identify the individual who placed the
statement. But this open field of candidates who may have placed this statement are all Inova
agents; none of whom were lawfully even permitted to access Plaintiffs medical records; let
alone write into it. When Ms. Seegers read the letter; the only thing which she told Plaintiff
directly is that the statement directs Plaintiff to the termination letter which Dr. Cochran signed
on behalf of Dr. Kulkarni. But Dr. Kulkarni never signed the letter. This letter was mailed on the
same day which Plaintiff had phoned-in and was told of the large meeting. Capital Imaging is
owned by Dr. Jeff Jacobson. It is plausible that Dr. Jacobson is one of the doctors participating
in that death panel. The nurse also said that there were other people who she does not know.
It is plausible that the entire small staff of Capital Imaging was present. Perhaps Dr. Jacobsons
attorney was present.
None of these things are the work of Dr. Kulkarni, alone. All this is even much more than the
work of Dr. Cochran. This is a large scale Inova operation; with a commitment of billions of
dollars if needed. When Inova filed its Answer, it somehow failed to recognize that The Court
not only approved a Tortious Interference Claim for it conduct with Plaintiffs physicians in
Maryland, but it The Court also approved a Tortious Interference claim for Inovas interference
with Dr. Kulkarnis contract with Plaintiff.
The Court, after finding that doctors; are causing additional bodily injuries upon Plaintiff by
deliberately giving poor care; itself, essentially, did the same thing. The Court, arbitrarily, denied
most of Plaintiffs requests for preliminary injunctive relief and ignored the rest, in both of
Plaintiffs cases. The same wrongdoing which The Court acknowledged, went full-steam ahead.
The Tortious Interference claim in Maryland is consolidated. It relates to several medical
providers and then what could be several separate claims attributable to those same witnesses.
The defendants from the related case called case, sprawling.
The First Amended Complaint was filed on February 24, 2015. The timeline of facts, being
controlled by time alone, abruptly ends on that day. But even with the argument and evidence
from that early day, The Court found that Dr. Anjanna Dhar and Dr. Luc Oke were two of the
Maryland doctors who carried forward Inovas scheme. The two doctors were not chosen by
Plaintiff. This was part of a, somewhat, new way to deliver medical care for the Medicaid
program. The contractor, Medstar Family Choice has labeled these doctors to be our
physicians. MSFC filings, exhibit and Plaintiffs exhibits that were letters from MSFC show
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that Plaintiffs medical care in Maryland is no longer of a physician and state license model, but
instead; physicians who the mere subordinates of the contractor MSFC, which is a shell company
and is wholly that of Medstar. This fact is also apparent in those letters. Both Medstar, which is
another giant health system and Medicaid and Maryland are identified. The leader of the efforts
against Plaintiff and the lead defendant in the related case was recorded in a telephone call. Attia
is very evasive about a simple privacy disclosure, by Plaintiff asking to name the individual with
whom Plaintiffs information has been shared. She wants the aid of counsel and some extensive
manipulation, first and only then to make disclosures. The inference presents that the Medstar
institution has joined the scheme with the Inova institution.
More recently, the giant Medstar Health System that has a contract for running this social
welfare type endeavor for Maryland, and whose agents are the Drs. Dhar and Oke found in this
case; are inseparable from Drs. Dhar and Oke and inseparable from Inova; engaged in several
acts and omissions which help Inova. Many are listed in Plaintiffs filings in both cases. Several
have not been stated and Plaintiff here, states on recent set of actions, which though bizarre;
shows the everything and the kitchen sink approach:
. Although MSFC and Medstar only have a presence in Maryland and DC, substantial parts of
MSFCs operations are in Milwaukee. Attia ordered some of these employees to: get on to
websites, go through a lengthy manual registration process, and give Plaintiffs email address: A
spam attack. What Nurse Ratched did not take into consideration is that these sites take note of
the IP address. Consequently, several of these thousands of spam emails, took into account the
Milwaukee location. An example: Uber needs drivers in Milwaukee.
With the Medicaid contractor group, Plaintiff in First Amended Complaint did not make any
specific allegations against the lead physician assigned to Plaintiff, Dr. Anthony Macarthy.
Plaintiff did note that in the timeline, his duties commenced, in between Drs. Dhar and Oke.
Macarthy was the continuation of Dhar and Oke was the cardiologist to which Macarthy and
MSFC sent the Plaintiff. Dr. Oke, by way of filing an unsolicited malpractice claim of behalf of
Plaintiff, attests that the time period that coincides with Plaintiffs litigation and the same time
period of The Court denying Plaintiffs requests for injunctive relief. The relied sought was to
remedy the primary problem identified by The Court, that of, deliberate poor care causing
additional bodily injuries.
Dr Macarthy, in a recorded Medicaid medical visit; not only supported these statements but
also attested to injuries, directly to the brain. The Court had stated that the actions and injuries
done by Capital Imaging, are with the brain. Dr. Macarthy attested that Plaintiff has injuries in
the entire region from the heart to the brain. He further attested that the underlying causation is
fully from the actions of the people at the MRI facility. The official position of Capital
Imaging was delivered by Ms. Michelle Miller and it was submitted with Plaintiffs evidence,
even with his original Complaint. Ms. Miller attested that there can be only 2 types of
complications which could arise from the procedure which was done. One is an allergic reaction
and the other is infiltration of the injected material into the muscle surrounding the injection site.
And Ms. Miller, herself, stated that Plaintiff did not have these complications.

The Court said it was injuries to the brain. In the original Complaint: There were 2 succinct
quasi-opinions from a surgeon and a veterinarian who is a surgeon. The usage of the word
justice could not be a reference to traditional malpractice. The usage of the word person
again points to people other than the state licensed radiographer who was the only person
Plaintiff saw in the room while he was conscious and also outside the sealed MRI tube. The
words also say that the person should have his license revoked. And this is, virtually, never
even in consideration, with traditional malpractice. 3 out of 4 non-management physicians at the
Inova neurology practice, resigned as part of a mass resignation, causing severe disruption to
patients and to the training of med school students. No one can show that such a thing has
occurred at any other medical practice. Dr. Kulkarnis records from the first return visit,
following the MRI test, reports what she read out of the interpretation for that test. At the same
time, the basic clerical function of reconciling the document to the top of the line records system
was not done. But this clerical function is actually done my the software, itself, when the test
results are put into the folder for test results. Although, Plaintiff stated that when he returned, Dr.
Kulkarni figured out what occurred, by his presence there; Plaintiff could not have known about
Inovas procedures and the medical records softwares procedures. This would be revealed
during Discovery, in the time period of more that a year since filing his First Amended
Complaint; Plaintiff figured this out from online research. The software caused an active order
for the test to be spit out. The whiteout related to this. The look of astonishment on the face of
the front desk employee, Ms. Charlene Seegers could not have been about a defamatory
statement about some violent tendencies of Plaintiff, because after; as Plaintiff reported in his
Complaint; the police went straight into the back with the Inova official, Carole Jones; entirely
ignoring Plaintiff. Ms. Jones said that the police were there for something in the back. What
happened in the back was at least actions equal to being accessories after the fact to nontraditional malpractice, which are criminal offenses. Injuring Plaintiff at Capital Imaging and
rendering him unconscious for a lengthy period of time is non-traditional malpractice, criminal
offenses. No reasonable person thinks that sex assault is not on the list of motives. Then, what
caused the look of astonishment to Ms. Seegers is that she was reading about some bizarre sex
play, attributed to Plaintiff and furthermore said to be the underlying cause of Plaintiffs injuries.
The statement is called the large defamatory. However the defamation and other claims need
not have survived; because all this comes under Inovas Tortious Interference to the contract
between Plaintiff and Dr. Kulkarni, which also included Dr. Kulkarnis support staff.
Furthermore, the defamation claim was dismissed on the grounds that statute of limitations had
expired by a week. The Court called the actions of the MRI technician, suspicious, which is not
within the scope of traditional malpractice. The Court used the term malfeasance and not
malpractice to describe Inovas conduct, starting with the act and omissions of Dr. Kulkarni,
during the first return visit. Malfeasance is not traditional malpractice. The only place where
The Court used the term malpractice is in stating how where Plaintiff could have sued for
monetary damages. In some ways, things are like with an auto accident. Even if; the other
driver deliberately rams your car; the other driver may not have a dime to his name. But to meet
the immediate needs of medical care, fixing the car and paying the bills; victims make a claim to
insurance and not rely on some meager victims assistance fund.
In the instant case; it is left to the victim of wrongdoing to uncover the cover-up by entities with
billions of dollars. In another case, widely in the news; David Rosenbaum, a recently retired
journalist for the NY Times was the victim of a violent mugging. For several hours, he did not
receive care and then died, but kept alive for a couple more days with machines. DCs IG
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conducted an investigation and issued a report. This powerful and well financed office, easily
found the faults of DC Police and EMS. The faults of the police were minor but those of EMS
were major. There was moderate blame for the nurses at the hospital ER add up. A concept well
seen in the instant case was stated. The IG wasnt fooled by the 2 doctors in the original report
and thought they did something minor. Then a couple of months later, the IG issued an
addendum. But the IG never suspected that these 2 doctors, with no help; on their own did
something major and then proceed to carry out an elaborate hoax. The doctor who was
responsible for the patient with deliberate indifference ignored him, knowing the he would die
without care. She was also the head of the ER and to help her out the second doctor, a part timer,
who was the mayors appointee and the medical director of EMS. But his loyalties were not to
the mayor. He threw the mayor and the rest of his administration under the bus to suck up to his
boss at the hospital. In middle of the night doctor #2 summoned high level official from EMS
and showed the nearly dead Mr. Rosenbaum to them; in an effort to get the ambulance crew
disciplined and lay all the blame on them. It include some blood on the patients head which
may have been intentionally placed for dramatic effect. Then these doctors put these stories into
the media the EMS employee was fired. But then, she got her job back. All this also goes back
to information asymmetry; if one asked any doctor [who was willing to answer honestly]; they
would say that that the patient was treatable after arrival to the ER and the EMS employees
wrongdoing was not the cause. Nurses are not at fault because the doctor is responsible.
As a component of several requests for injunctive relief; Plaintiff has made a very easy
to fulfill and to measure request. And this relates to documents and other tangible items.
Plaintiff has requested that The Court enforce Virginias health records laws and the
Medicaid personal information disclosures in Maryland.
Plaintiff needs time to review and understand what Inova promises to be a large volume of items.
Plaintiff needs the ready access to the depositions which The Court already has allowed for. And
both things go together. Plaintiff may seek to have some witnesses and Inova disclose phone
logs or give a pathway to obtain those records from the carriers. Plaintiff is certain of: a lengthy
or multiple depositions from Dr. Sonalee Kulkarni, a quick deposition of Ms. Charlene Seegers,
depositions of Manuel [aka Anthony] Papel of Capital Imaging, Dr. Luc Oke, one of the
Maryland doctors from the Medicaid program.
Proposed Deadlines
June 27: Initial Joint Status Report/ July 5: Rule 16 Conference call/ April 3, 2017: Motion to
Amend Pleadings or for Joinder/ April 18, 2017: Plaintiffs Expert Disclosures/
May 16, 2017: Defendants Expert Disclosures/
May 30, 2017: Plaintiffs Rebuttal Expert
Disclosures/ June 6, 2017: Supplementation of Disclosures and Responses/ July 3, 2017:
Completion of Discovery, Submission of Post-discovery Joint Status Report/ July 1, 2017:
Request For Admission/ August 4, 2017: Dispositive Pretrial Motions
Sincerely,
Joseph Crussiah
June 27, 2016