Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 1 of 17

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND
JOSEPH CRUSSIAH.
Plaintiff
v.

CAROL ATTIA,
ANTHONY MACARTHY.
ASMIR SYED,
LUC OKE, and
ANJANA DHAR

Civil Action No. TDC-15-25l6

Defendants

PLAINTIFF JOSEPH CRUSSIAH'S OPPOSITION TO DEFENDANT LUC OKE'S

MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT (ECF-I2)
AND MEMORANDUM IN SUPPORT

..

Plaintiff further supports the instant motion with facts and laws stated in Plaintiff's
Opposition

to Defendant Anjana Dhar's Motion to Dismiss.

Tortious Interfernee

Claim with same facts and nexus has already survived, in related case

With Plaintiff s related case. a tortious interference claim has survived the initial motions.
And for Defendant Oke. Plaintiff. for the most part, cut/pasted from the related case. The claim
supported by the allegation: that Inova. led by Dr. John Cochran interfered with Dr. Oke's
obligations to Plaintil1~ for the purpose of thwarting a likely malpractice claim against Inova and
others; survived.
And when Dr. Oke acted to help (nova with its el1arts, Dr. Oke also was interfering with the
expectant lawsuit. By the time Plaintiff tiled the instant complaint. new facts were recognized

Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 2 of 17

and all that has really changed is that the expectant suit would have instead, related to personal
injuries, resulting from criminal ofTenses and not "medical injuries".
This Court amended the title of the self-represented PlaintifTs Tortious Interference Claim
and Defendant should have noticed that PlaintifT is self-represented, in the instant case, as well.
It is the exact same allegations and facts; only that Inova and Defendant Oke arc being
sued in two separate cases.
Tortious Interfernce

claim, alone can support Conspiracv

the unjust enrichment

Claim and discoven' can reveal

The contact between Inova and Defendant Oke was improper and unlawful, under federal
patient privacy laws; and this supports the Conspiracy Claim. Defendant Oke conspired,
backwards, with individuals responsible for the original wrongdoing.

Defendant Oke is linked to

Defendant Attia and Defendant Macarthy, both parties with very recent contact with Plaintiff;
and actively, forwarding the wrongdoing.
Plaintiff's

duties in state court action includes pursing instant federal case

The instant and related cases could be said to be derivatives of the '"main event", which may
be a combination of criminal action and civil action in state court. BecllUse the evidence of the
wrongdoing

was discoverable

by a medical process, Plaintiff consulted with physicians to

perform the investigation.

The Maryland courts recognize that counsel does not work for free, and unless the party is a
health system and part of its culture is to misappropriate healthcare dollars for their own
wrongdoings; the Maryland courts recognize that individuals have to do much of the "leg work"
on their own.
Lumsden ct al. v. Design Tech Builders No. 112 (1999) "A claimant reasonably should know of
a wrong if the claimant has knowledge of circumstances which ought to have put a person of
ordinary prudence on inquiry lthus, charging the individual] with notice of all facts which such
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as investigation would in all probability have disclosed ifit had been properly pursued.
Reasonably diligent investigation. Three years-for reasonably diligent inquiry and for making a
decision as to whether to file suit. To investigate further, obtain expert opinion discuss
settlcment and lile suit. Should the plaintiff fail to seek out the facts supporting a cause of
action, it can fairly be said that the plaintiff has inexcusably slept on his rights When a plaintilf
has knowledge of circumstance indicating that he may have been harmed, the law imposes a
duty on that plaintiff to investigate whether in fact he has been harmed".

Prior to being forced bv federal and Marvland governments to transfer his investigation,
!which is the same as basic medical care, and more specificallv the components of basic
medical care that are of getting answers and an appraisal) to this pack of 5 defendants,
Plaintiff had success in overcoming wrongdoing and getting some results

Dr. Dormu conspired with the wrongdoers. but he was "playing both sides". Had Plaintiff
thought that criminal offenses were the cause of the injuries. it could be said that Dr. Dormu
gave sufficient facts for Plaintiff to take facts to the police and also to an attorney for civil action.
Plaintiff received some minor swellings underneath his eyes following the MRI test. Dr.
Donnu told him that those bumps are only seen in hospitalized patients with some very serious
conditions. Dr. Dormu told Plaintiff "you are young and you can survive these things". Both
these statements were intended to communicate that some life threatening actions occurred
during a simple MRI test.
Dr. Dormu told Plaintiff that there is nothing wrong with the veins in the arms. The pretext
for gaining access to give a second injection. one of a malicious nature, for initializing those
criminal offenses at the MRI facility was that the first intravenous injection was said to be
unsuccessful.
The most important piece of the facts. was that the ulnar artery in the leli arm had "blown".
Dr. Dormu. very likely, promised the wTongdoers that he would not reveal this fact. But Dr.
Donnu staged some theatrics. Dr. Dormu is a sole practitioner and he has a nurse and a
physicians' assistant on his staff; but he did not nced them in the exam room with Plaintiff.
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Dr. Donnu took 10 minutes to teach this medical oddity to these other medical professionals.
Dr. Dormu showed the physicians' assistant how to check for the ulnar pulse on the right ann
and then to check the left arm and find this oddity. The PA was a quick study but the nurse
needed a lot of help. Dr. Dormu used this bit of theatre to convey the message that this is the key
evidence and also that it is not something that occurs in the field of medicine.
Plaintiff had consistently said that he was mainly okay with the injuries from the MRI facility
and that it was the injuries to the heart. done by Dr. Kulkarni is what would produce a fruitful
malpractice action. On that front; Dr. Donnu suppressed all material facts.
But Plaintifrs

progress was stopped in its tracks when he entered into the government

assistance medical care program.

Even before Plaintiff visited Dr. Donnu. Plaintiff was aware

that beginning in 2014. he was eligible for Medicaid; consequent to the new laws related to
medical insurance.
What bothered The pJaintifTwas that. in the Medicaid system. the federal government, state
government, Maryland's contractor and subcontractor physicians; all would have all of
Plaintiff's medical information and this would include very detailed information. These people
would have the information in real-time. And even if Plaintiff got out of Medicaid, all this
privacy would be forever. lost. And Dr. Cochran and [nova were still lurking in the shadows.
Plaintiff who was not working, even misreported on the health exchange website where the
uninsured can purchase health insurance. that he was employed and gave income numbers to
support that. And yet, the system crosschecks with all databases.

[t would not permit

Plaintiff to purchase health insurance and directed 1}I:,intiff to Medicaid, which is not
health insurance.

It "gives healtheare",

exactly as stated in Medstar Family Choice's

glossary from their Washington. DC manual.

Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 5 of 17

Plaintiff. never in his life. needed emergency medical care. but in 2014 he was very
conscious of the heart injury and knew that even if entered an emergency room, personnel would
sign him up for Medicaid. Prior to 2014, there were alternative means to get emergency care.
But with the new laws and the ways of implementation
channeled

into Medicaid.

was that Plaintiff would be

Plaintiff selected Medstar Family Choice because Dr. Dormu told

him that it was the only substantial plan that served his region.
And the law only requires the state to give recipients access to two of these contractors.

So

even though. presently, there are more than two, for reasons such as consolidation. things can
change with little notice. Additionally, in light of the heart problem, Washington Hospital
Center, a Medstar Hospital that specializes in the type of heart problem seems to be the
appropriate site for treatment as the condition, worsens.
Despite vears of vigorous and aggressive investigation
co-conspirators,

bv Plaintiff, defendants

and their

all who had duties and obligations, to I'laintiff, to deliver facts, instead did
just the opposite

We are at the three year mark of the commencement of all these unlawful acts against The
Plaintiff. The serial wrongdoing moves forward, unabated; with no end in sight. The civil case.
part of the "main event" has still not been filed in state court. Plaintiff will likely succeed
against a motion to dismiss based on statute of limitations by arguing the "discovery rulc" and
tolling and such. But all this is additional work that only came about because of defendants'
tortious conduct. These are compensable damages.
Then. with criminal prosecution,

that; also was disturbed

by these defendants.

said that these 5 defendants are fully united. both; lawfully and unlawfully.

Let it be

Plaintiff alleged in

Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 6 of 17

his Complaint that Defendant Attia filed a false complaint with the Montgomery County Police,
the very same agency that was to handle the criminal prosecution.
But now, Plaintiff asserts that what occurred is that Defendant Attia, and Mr. Kenneth Samet,
CEO of MSFC's parent company, Medstar, conspired with local elected officials; who in tum
used the county police, an unit of county government and the Montgomery County State's
Attorney's Office, an unit of state government; and knowingly presented arrest and search
warrant applications to a Montgomery County Circuit Court Judge, who diligently studied the
applications and denied them.
There is a custom of police in Maryland, that when an individual possesses material
evidence that supports allegations of wrongdoing by police, by hook or by crook, the police seek
to destroy that evidence. But until now, such unlawful and improper conduct only occurred to
shield the police, themselves.

[n the instant case, the police have done these things for the

benefit of a private party. Medstar. And this supports Plaintiffs "bizarre" damages request.
That. he has to overcome this large entity which. perhaps. by indirect means, can buy off the
local elected officials.
In Montgomery County, two unrelated individuals. with press credentials and with one of the
incidents occurring in 2011 and the other nearly 10 years earlier. One involved a nationally
known. local television reporter who was by legal means. gathering evidence of misconduct by a
police agency outside Montgomery County. The second related to a White House photographer
who became a witness to wrongdoing by Montgomery County Police.
Both these individuals reported the exact same thing that Plaintiff also reported. Police were
sitting outside Plaintiffs house for a lengthy period of time. Both these individuals with very
good reputations, one with even special clearance from the Secret Service; reported something

Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 7 of 17

that may make it appear that they are a little "paranoid",

They alleged that police were sitting in

front of their residence, in an effort to intimidate them.

But what Plaintiff thinks happened is that warrant applications were given to ajudge and the
police are sitting with "itchy fingers". ready to execute those warrants, without any delay.
Defendants use money, power, whatever it takes
Around the time, August 21. 2015 that Plaintiff filed the instant suit, the state contractor.
Medstar Family Choice relocated their office to a new office that is less than a mile away from
where the Marshals Service attempted to serve Defendant Attia, via certified mail.
Offices that serve the indigent, whether a county social services agency or a contractor's
office could be said to be anywhere from "austere" to "dilapidated".

MSFC already had a good

quality office at the address on Sandpiper Circle. The new office on King Avenue is a more
expensive piece of real estate.

Additionally, relocation costs would have been at least $30,000.

The oflice also holds vast quantities of sensitive personal data. necessitating a painstaking
transfer to the new office.
Medstar Family choice wasted all this money that was to be spent on giving health care to the
indigent and others in Maryland and Washington. DC; in an effort to frustrate "service".

This

organization that is to be transparent and accessible, did not update their address on several data
bases of note; the state office from Maryland DHMH that has given the contract to MSFC,
Maryland Board of Physicians and with U.S. Health and Human Services that issues a NPI
number [national provider identification].

The NPI network allows for MSFC to log on and to

update the address.

MSFC did not place a forwarding request with the U.S. Postal Service. Had this been done,
the mail would have "seamlessly" been served at the new address. Apparently, the letter carrier

Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 8 of 17

went to the old address and attempted delivery. But somehow figured out the new address and
forwarded the letter.
It must be noted that in Washington, DC, the law imposes a very minor hurdle for plaintiffs
filing medical malpractice action. Plaintiffs are to mail the proposed complaint to the medical
provider, 90 days prior, to filing suit. When The Marshals Service attempted to serve the
Summons and Complaint upon Defendant Syed, the lone Washington DC defendant, via
Certified mail: Defendant Syed lied to the Postal Service and stated that Dr. Syed had moved and
provided no forwarding address.
Had Plaintiffs action been actually, medical malpractice, Plaintiff would not have able to
follow the medical malpractice laws of Washington, DC. And perhaps, Defendant Syed' s codefendants should provide a lesson about conforming to malpractice laws, to Defendant Syed.
It should also be noted that when Plaintiff in the related case, filed a motion to compel these
same defendants, under their corporate unifying title of Medstar Family Choice, to perform on
their obligations; they filed with This Court exhibits showing very detailed information from
several postal certified mail receipts, even though; defendants obligations were to, perform on
federal and state laws related to Medicaid, and not in mail delivery.
PlaintifTalso had provided evidence and directed to evidence that is on YouTube, that shows
the when Plaintiff's

medical condition worsened, he scheduled an appointment with Defendant

Macarthy. Macarthy contacted Attia. Attia conspired with DHMH, the M:lryland agency
that was supposed to mediate disputes between Plaintiff and these defendants.
employee of DHMH, in the words of another state worker "knocked
system".

And he was deprived of his medical care entitlement,

An

II'laintiffl out of the

altogether,

Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 9 of 17

This state agency has not responded to any of Plaintiffs written complaints and does not
answer the telephone.
There has been an effort that has cost a large sum of money. has included several unlawful
acts and has involved many individuals. All this, could not be done without the authorization
and assistance of Mr. Kenneth Samet, the CEO of Medstar.
Plaintiff has the intention to file suit in state court, stating a primary count of "battery",
against individuals whom PlaintifTbelieves, and has evidence to support; engaged in that act on
February 15,2013 at Capital Imaging in Bethesda and also in May, 2013, related to the
prescription for the drug Verapamil given by Dr. Sonalee Kulkari, from Inova.
Because of the circumstances and the evidence, which includes evidence of falsified
documents, no alibi can be reliable. Plaintiff can reasonably assert that no one engages in the
extensive effort to conceal somebody else's criminal offenses, but rather, their own.
Plaintiff should allege that Mr. Samet was at Capital Imaging on February 15,2013.
It was the intent of Dr. Jacobson to produce a stroke, and one does not necessarily cover all
bases by having Dr. Jacobson control the facts at Suburban Hospital or Dr. Kulkarni controlling
facts as Plaintiffs personal physician. Had Plaintiff suffered that stroke, he would have become
covered by Medicaid in 2013, even under the old rules, because of physical and mental
incapacitation.

And much like with the heart condition of today and with Plaintiffs

place of

residence, he very likely would have been enrolled into the Medstar MCO, Medstar Family
Choice and also would be required to utilize Medstar hospitals and these hospitals are also the
designated centers for severe cardiovascular conditions.

Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 10 of 17

For the sake of the instant case, the most plausible explanation of the facts is that Dhar, Oke
and Macarthy made deals with those that committed all those criminal ofTenses. Plaintiff was
making slow progress with getting these 3 defendants to perfonn their state obligations.
Plaintiff followed the rules and complained to MSFC and then Attia who assembled this
unscrupulous group of physicians, in order to; protect her own investment and reputation;
stopped all the progress in its tracks, and attacked the Plaintiff in all those stated ways in this
motion, The Complaint and in Plaintiffs other filings; all which very easily are Section 1983
deprivations.

Additional actors also arrived on the scene, who worked hand-in-hand with Attia,

most notable is Syed.

During the first minute of contact with Oke, he figured everYthing out and was scheming to
unjustlv enriching himself at his patient's
Plaintiffs

expense

final engagement with lnova occurred on December 17,2013.

Medical records

with whiteout on page numbers was released, in an effort to conceal a very basic fact; that: The
PlaintifTwas undergoing a very simple and hamlless medical procedure at Capital Imaging. The
legitimate process of that medical procedure, that. which consists of the patient being sealed in a
capsule and that which involves injections; allowed for the medical process to be easily hijacked
by a criminal process.
The actions included rendering the victim unconscious by depriving the brain of oxygen by a
complex mechanical process and because the intent could be nothing other than sexual assault.
that in itself is a sexual assault.
The psychiatrists who produce a manual that lists and describes all psychiatric disorders, also
release policy statements as to how they decided what is a disorder and what is not. One could
either, singularly or consensually with others, construct and execute actions, which in one's own

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Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 11 of 17

mind one believes is what they need to do, in order to; obtain the sexual satisfaction of their
choosing. It can only be a disorder if it results in permanent injury.
The manual does not allow for similar things with drug use, but for illustrative purposes, the
use of LSD can be cited. Having something of a "designated driver", helps the user get the most
out of a "tripping on acid" session. The "designated driver" can safeguard the user from perhaps,
jumping out of a window. Additionally, LSD, alone, does not do the trick; the user needs the
"designated driver" to stimulate the production of the hallucination.

The "designated driver"

may tell the user to look into a mirror, next say that the user is the devil and has horns. The user
will actually see these things.
Inova had conceded that there was a large statement on the front page of Plaintiffs medical
records that when read by Ms. Charlene Seegers, the front desk employee of Inova, caused her to
have an expression on shock on her face. The Plaintiff had also stated that Ms. Seegers needed
to re-read the statement several times.
This is because Dr. Cochran, who has acquiesced to Plaintiffs; public, front page, internet,
conclusory statements that Dr. Cochran, himself, was present, and physically, committed sexual
assault at 4927 Auburn Avenue, Bethesda on February 15,2013 and Dr. Cochran would be said
to suffer from a sexual paraphilia. where one harms others; stated on The Plaintiffs medical
records which he had no right to ever access; that it was Plaintiff who was suffering from a
sexual paraphilia. that caused him to harm. himself. This included the complicated mechanics
that Ms. Seegers found di fficult to learn.
On December 3, 2014, Plaintiff had his first visit with Dr. Oke. Dr. Oke. immediately
understood that he "won the lottery", "struck gold", and such. Dr. Oke did not complete a full
initial assessment.

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Dr. Oke scheduled another visit, 2 weeks away. because he wanted to make deals; to sell his
professional opinion. that he owed Plaintiff. both by the physician-patient contract and the well
coditied version of those same principles that are found in the laws that relate to Medicaid.
which are presented as rights. duties. obligations. responsibilities and such. within 2 separate
manuals published by Medstar Family Choice. the Medicaid contractor that carries out functions.
and also obligations. to Plaintitl that are of state government.
A second physician in some form of internship capacity works as Dr. Oke's assistant. The
first name is Brittany and the last name may be "Davis". With this second physician as a
witness. Dr. Oke made a crude joke that presented the same concepts in Dr. Cochran's
"defamatory statemenf".

Plaintiff does not assert that Dr. Oke and Dr. Cochran had already

communicated.
Dr. Oke very easily understood the history. much more that even Plaintiff knew of at the
time. as he is an expert; a heart surgeon. Dr. Oke'sjoke

reflected the history. Dr. Oke. when he

instructed his patient to return after 2 weeks also added the line "don't do anything to make
yourself pass-out during those 2 weeks", with a grimace on his face. When Plaintiff suggested to
Dr. Oke that he did not understand what Dr. Oke. meant; Dr. Oke was caught dumbfounded.
PlaintifTwas holding his relevant past medical records in his hands. in a folder and yet Dr.
Oke needed 2 weeks to gather records? Those same records were already given to Dr. Macarthy.
the assigned primary care. whose office could have easily faxed them over. Plaintiff went to Dr.
Macarthy's office. either that same evening or the following evening. Dr. Macarthy's employee
told Plaintiff that she had already faxed the records to Dr. Oke. and she said that she did so
before PlaintifTs visit with Dr. Oke. While Plaintiff witnessed. the employee again faxed all the
records to Dr. Oke. These things will appear on the phone company logs during discovery.

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When PlaintifTscheduled his initial appointment, Dr. Oke had these appointments available
on 2 days or less notice; and now Dr. Oke wants 2 weeks. Judging by his joke, Dr. Oke even
knew what was going on. Defendant Oke needed 2 weeks for negotiating a barter.

In the subsequent visit after 14 days, Dr. Oke on the records acknowledge receipt of only I
test. consisting of only a single page, when Dr. Macarthy's employee had faxed 16 pages.
The 3rd visit on December 31, 2014 is the one in which Defendant Oke launched an all out
assault on behalf of conspirator Dr. John Cochran of Inova, including plastering a migraine
headache diagnosis at multiple points of the document, and obesity diagnosis; to stand up Dr.
Kulkarni's sham. off the books, diagnosis of migraines when Dr. Kulkarni committed fraud and
caused Plaintiff to put the drug Verapamil into his body and that is the most severe of all injuries,
heart failure. And to cover all bases, the obesity and hypertension diagnosis provides an
alternative theory of causation for heart failure.
The records from this visit again makes the comment that Dr. Oke is still in a search for his
patient's historical medical records.
Dr. Oke also describes Plaintiff as a 44 male with multiple medical complaints in the
"impression column" when in the previous 2 visits PlaintifTwas said to be a pleasant 44 year old
male. The words "not substantiated" also appears. An efTort to diminish Plaintiff's credibility.
The word unsubstantiated is the term used by physicians' boards and such regulatory bodies.
when ruling on whether a particular deviation from professional standards, occurred.
But when Plaintiff requested records during the 4th visit. only 14 days later, on the records
from this visit; PlaintifT is once again said to be "pleasant".

All the migraine headache and

obesity rubbish is no longer stated. And here, finally, after 45 days and 4 visits. Dr. Oke
acknowledges receipt of all the records.

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It is well settled that when an individual is represented by counsel in the initial stages of civil
action; that the counsel and the individual, all together, are seen to be a single individual; with,
all the visible duties charged to counsel. But the individual, himself also has some duties.
Defendant's

counsel has, painstakingly,

bemoan that Plaintiffs

Complaint

decoupled himself/herself

is not comprehendible.

from Dr. Oke to

This problem is readily solved

by Dr. Oke explaining things to Mr.lMs. "undersigned".

Counsel gains several benefits when representing a physician who is, actively. a treating
physician ofa plaintiff. Even if Plaintiffs Complaint was ten. times the length. even if
Complaint was incomprehensible and most certainly if it was "bizarre"'; then. the physician
already has the professional duty to read and comprehend the communication. no matter how it
got to the physician.
Defendant's counsel. whose "bio" states expertise in the practice area of medical
malpractice; makes the definitive conclusion that Plaintiffs action is "mcdical malpractice"'.
And here. Dr. Oke is readily available to serve as a mcdical expert to his own counsel. Medical
experts regularly evaluate documents for attorneys. The typical evaluation is the study of
thousands of pages of documents. each so condensed that 70 pages of a court complaint would
only equal about 10 pages. And some of the "'freelance" experts charge by the "'inch". so with a
paltry 10 pages. even if the 70 pages was with a case. unrelated to Dr. Oke, Dr. Oke could
evaluate and report on that case within about 5 minutes. some barter possibilities.
Conversion

Claim

Defendant's cited cases have only shown that this claim is not allowed for the intangible item
of intellectual property. The cited cases allow claims for stock certilicates.

14

The value of stocks

Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 15 of 17

is always beyond the control of the possessor of stock certificates. The basic recommendation
from experts is to "diversify'" so a single stock and if it applies to all stocks. there are "penny
stocks" which are very volatile; and no one puts all their money into one of those stocks.
Plaintiff s prospective state court action would be the better investment when compared to a
single stock certificate.

Plaintiff had cited a case that went to trial in Fairfax County in2015 and

it is well known that the venue is the most difficult for plaintiffs and yet a case moved through
the full process. including trial. in less than 6 months time. The plaintifTwas awarded $600.000
by a jury that was limited by a statutory cap on punitive damages. All that happened was that the
plaintiff: while under anesthesia was mocked by a physician; and the jokes were funny and
applicable to the plaintifTand it was the plaintiff who publicized the matter and yel won a
defamation case. There is a genuine issue for trial
Defendants argument are contradicted on sevcral claims
Oke seeks to defeat the fraud claim by stating that Plaintiff understood all ofOke's

lying,

deceptions and such. If that were so then Oke concedes that he committed these malicious acts.
which support the Section 1983 Claim and Tortiuous Interference Claim.
Oke presents the Plaintiff as being vague. ambiguous. bizarre and this really was the theme.
perhaps delusional; a very poor psychological profile. Then how it that the same Plaintiff
analyzed and understood all the lies and deceptions of an expert. a heart surgeon?
For the lIED Claim. this same Dr. Oke gave him good marks in the pysch category during
the medical encounters and now PlaintifThas become a serious psych case. When Oke argues
"bizarre nature" of Complaint, written by a self-represented party who is also his patient. then
what Oke is saying is that his patient suffered some serious harm to his thought process and such.

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Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 16 of 17

All this means that all of Plaintiffs claims should survive at this stage and should survive all
the way into trial. These are all genuine issues for trial.
According to Oke. as evidenced by the first doctors' notes on December 3, 2014 and then all
the way through MSFC's filings in This Court, responding to a Motion To Compel in the related
case; Plaintiff was physically and psychologically okay. but very quickly; Plaintiff became
perhaps even insane and also has all these "medical injuries", even though Oke did not do any
surgery and only prescribed a drug. that his patient declined.
Plaintiff further supports the instant motion with faets and laws stated in PlaintifPs
Opposition to Defendant Anjana Dhar's Motion to Dismiss.
Conclusion
In light of the foregoing. Plaintiff Joseph Crussiah, respectfully, requests that Defendant
Oke's Motion to Dismiss. be denied. Additionally, in light of the persistent tortious conduct of
defendants, which includes a large sum of money earmarked for indigent health care that was
utilized to relocate a large oflice. in order to; obstruct service, which was ordered by This Court;
that all requests for costs by these defendants be denied.
Respectfully Submitted.

A!R.i~~

Dated February 12.2016

Pro Se Plaintiff
9701 Cottrell Terrace
Silver Spring. MD 20903
Montgomery County
240.475.7737
crussiah@yahoo.com

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Case 8:15-cv-02516-TDC Document 21 Filed 02/12/16 Page 17 of 17

CERTIFICATE OF SERVICE
I hereby certify that on this, the 12th day of February, 2016, a copy of the foregoing was
mailed, via U.S. Mail to:
Goodell, DeVries, Leech and Dann, LLP
One South Street
20th Floor
Baltimore, MD 21202
Nichole Nesbitt, Counsel for Anjana Dhar
Goodell, DeVries. Leech and Dann, LLP
One South Street
20th Floor
Baltimore, MD 21202
Kelly Hughes Iverson, Counsel for Luc Oke
Goodell, DeVries, Leech and Dann, LLP
One South Street
20th Floor
Baltimore, MD 21202
Lucas Chrencik. Counsel for Luc Oke
Carol Attia
Medstar Family Choice
5233 King Avenue
Rosedale, MD 21237
Anthony Macarthy, M.D.
10230 New Hampshire Avenue Suite 103
Silver Spring, MD 20903
Asmir Syed. M.D.
106 Irving Street, NW Suite 218
Washington, DC 20010
Respectfully submitted,

Joseph R. Crussiah
Pro Se Plaintiff
970 I Cottrell Terrace
Silver Spring, MD 20903
Montgomery County
crussiah@vahoo.com 240-475-7737