STATE OF MICHIGAN: IN THE COURT FORTHE COUNTY OF WAYNE SOBHEY SAFAA and BADLA Jointly and Individually, Plaintiffs, ABIR AYYAD, TAYFUR RIFAT AYALP, MD., EUROPEAN TANNING CLUB, a domestic limited liability company, and TAYFURR.AYALP,MD.,PLLC, a domestic professional limited liabil Defendants. As of January 8, 2020, Plaintiff. [NNN has dismissed her claims against all of the Defendants and all of Plaintiff's have dismissed their claims against all of the defendants except Abir Ayyad. (SB Atssikcar and a On March 31, 2004, Defendant, Abir (“Abby”) Ayyad, was licensed as an Esthetician The Salient Facts of the Matter as to Plainti under the Occupational Code, as amended; MCL 339.1201-1218. Pursuant to a written supervisory agreement with Defendant, Tayfur R. Ayalp, MD, a Board cettified plastic surgeon, from March 21, 2011 through sometime in 2015, Abby operated a skin care clinic in the doctor's office. During that period, according to Dr. Ayalp, Abby performed various non-invasive skin care treatments with the utmost professionalism and care. The doctor has advised that Abby attended seminars and workshops for dermal fillers and that he trained her as to how to inject them. Doctor Ayalp has stated that he supervised her directly while she performed these procedures and that he found that Abby became proficient in injection techniques; he also found her to be competent and capable of employing her skills in any office under a physician's supervision. Abby left the employ of Dr. Ayalp and rented space in a beauty salon where she practiced her craft as an esthetician, believing that the 2011 agreement with Dr. Ayalp was valid 1and that she could still consult with him by phone, email and/or by text message. Abby purchased Juvederm filler from Dr. Ayalp’s office manager In September, 2016, Plaintiffs, Sobhey I CSE") a/k/a “Susu”, her mother, Safaa HEE SA”), and Sobhey’s aunt, Badia JM CBA”) visited Abby at the beauty salon, seeking Juvederm (a non-silicone filler) injections. For SE, this was not her first treatment with Abby, nor was it the first time she had sought Juvederm treatment from anyone, including from Abby. Alll three of these women had filled out a detailed medical history and signed informed consent forms as to the injection after being made aware of some of the risks Abby injected Juvederm into the faces and/or lips of all three of these women who appeared to be quite satisfied. Sometime thereafter, SE carried on and bad mouthed Abby. claiming injury from an “unapproved * product containing silicone which she later claimed was “found” not only in her lips, but on her mother's face also. Despite this false claim, Abby agreed to refund Plaintiffs money, which offer was summarily rejected. SE then took the following actions against Abby: SE filed a complaint against Abby with the State of Michigan; SE demanded $20,000. from Abby or threatened to “go public” on ‘Channel 7, which she ultimately did, and, later in a phone call, SE demanded $5,000. from Abby. After being rejected by several law firms, SE retained the Sam Bemstein Law Fim. The Bemstein Law Firm later withdrew from the case which is now being handled by a firm in St. Clair Shores, MI During their depositions, all of these women admitted to having had previous injection of product to their faces; in addition, over the past five years, SE had numerous visits with plastic surgeons, allergists, and dermatologists for more filler and she also had plastic surgery for ‘enhancement of other body parts. In similar fashion, but to a lesser extent, SA and BA have had additional filler injections.Whatever someone claims to have found on SE’s and SA’s lips and/or faces was not in an} way related to Abby's injection of Juvederm, an FDA approved product, one sold to her by her mentor, Dr Ayalp. The reactions that the three women may have experienced were normal and were explained and covered in the consent forms. The later, so called, “MRI findings” by the Plaintiffs’ dermatologists and plastic surgeons are nothing but unsubstantiated nonsense; none of these women had a needle biopsy performed nor was any other type of lab analysis performed, and their “expert” witness was essentially unmasked as a charlatan who had admitted that he was never a medical director of anything. The presence of silicone was not confirmed by am; medical practitioner. More importantly, a medical report accompanying the MRI scan ffs confirming the presence of silicone has never been introduced by any of the Plai because it apparently doesn’t exist. According to SE, one of their doctors had stated that he had successfully removed silicone from people's lips, yet SE apparently chose not to have it done by him. Moreover, as of several months ago, none of the three women displayed any visible signs of any permanent damage to their faces and or lips. So, it’s no wonder that, in their depositions, they admitted as such and cannot offer any scientific proof that Abby damaged them. (It is important to note that, in Dearborn, there reportedly is a whole cottage industry of women operating out of their respective basements, who are injecting filler in friends and neighbors; only God knows where some of this stuff comes from.) Itis also patently clear that, Abby's clients find her competent and professional. Since 2004, no other complaint has ever been filed against her. Abby has demonstrated good moral character and has not committed an act of gross negligence or demonstrated incompetenceAbby had erroneously believed that, having been trained by Dr Ayalp and, after purchasing, FDA approved product from him (as opposed to numerous “on line” product offerings), she was in compliance with the law. Abby stipulated to a finding that she violated Section 602 of the Occupational Code-practicing medicine without direct, “on premises” supervision. She paid a $2,000 fine to the State of Michigan and was placed on six months probation which has been completed From a factual and legal standpoint, Plaintiffs’ case amounts to nothing more than an attempted shakedown by SE, a vindictive and angry person, leading her mother and aunt in a vendetta against a working girl who had made an honest mistake. I sincerely believe that the case will soon be dismissed against my client for the reasons stated above. January 8, 2020 Henry N. Sandweiss, Esq. Attomey for Abir (“Abby”) Ayyad