Joseph Crussiah Crussiah Crussiah Paula Xinis U.S. Court Inova Medstar

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 1 of 21
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND
JOSEPH CRUSSIAH,
Plaintiff,
Civil Action No. PX-14-40 17
v.
INOVA I-IEALTH SYSTEM
Defendant.
MEMORANDUM IN SUPPORT OF PLAINTIFF .IOSEPH CRUSSIAII'S MOTION TO

RECONSIDER DENIAL OF SECOND AMENDED COMPLAINT, MOTION FOR
EMERGENCY PRELIMINARY IN.JUNCTIVE RELIEF AND MOTION FOR
AI'POINTMENT OF REPRESENTATION
Background and Skills of Involved Third Partv

Dr. Jeff Jacobson is credited with saving the life of White House Press Secretary James
Brady, while a neurosurgery resident. The news artieles say that even with the massive injuries
to the brain, the surgeries could wait. But the injuries caused hydrocephalus, cerebrospinal lluid
to accumulate in the brain. This, will, very soon crush some of most vital parts of the brain,
including those that control critical functions such as breathing. It takes a genius to get things,
just right; using drugs to remove lluid and managing all the physiological actions of the body.
But then; his career is of being crook, using his own MRJ machine to create false reports,
which allow for unnecessary back surgeries, costing more than $100,000 for half a days work.
Unlike other surgery mills, this surgeon docs a good job on the surgeries; but he deliberately
injures patients for a thrill. In an appealPannu
v. Jacobson, a malpractice case, his own experts
don't have an explanation for how he severed all the nerves for bowel, bladder and sexual
functions. He also has some strange play and buddy relationships with his own 3 daughters and
his doctors' office employccs.
His own daughtcrs have even worked for him. And recently, all 3
averaging age 30, live with Dr. Jacobson

Through
and Through An 'nova Operation
The scheme only works because, Dr. John Cochran of lnova has compromised Dr. Sonalee
Kulkarni's doctor patient relationship contract with Plaintiff
Plaintiff is going to sufTer severe
neurological injuries at Capital Imaging. Dr. Kulkarni is a neurologist and his only physician.
Dr. Kulkarni has already agreed to cover-up, in exchange for professional favors. The career
failure, Dr. Kulkarni; seeks status and she will also cheerfully take the resulting financial gains.
Inova took the third involved with criminal offenses under it's protection. A letter from
Inova's counsel, Mr. Carey; Plaintiff is threatened with defamation suits, even on behal f of the
third parties. The VCU Virginia College of Medicine connection also is stated. (Exhibit 3)
Personal assault and Thrill crimes financed with public assets
Dr. Cochran and Inova are authorized to either appoint or recommend candidates for a
prestigious position at VCU Virginia College of Medicine, Fairf[1Xcampus. This is a state
institution and heavily federally, funded. The scheme was made possible by public funds.
The Main Event, Fehruarv
15,2013
The MRI test was flawless. Mr. Papel, the techinician lied that thc injection failed and this
allowed him to do another injection. But this one took about 10 minutes and not seconds. Dr.
Jacobson would have had to train Papelto navigate through the complex structures and rcach
deep inside the back of the hand and insert the nccdlc. With the catheter and cxtension tubc
established and PlaintifTsealed inside the MRI tube; Dr. Jacobson would takcover.
It's all about hydrocephalus, which translatcd into English means, watcr in the brain. A good
lesson can be found at ("Cerebral edema and its management medlnd") The textbooks say that
it's not the same water that one drinks; its cerebrospinal fluid, as was the case with Mr. Brady.
But for Plaintiff, Dr. Jacobson deliberately put actual water into his brain, via the artery in the
hand. Objective testing shows that the artery was blown out; that much force.
The large quantity of water overwhelms the drainage system in the brain. It also damages the
smallest blood vessels, such that the water pokes small holes into the walls of these vessels and
fills up spaces, which normally are free of fluids. One of the first signs Plaintiff noticed
following the event was small swellings beneath both eyes. When people get the "bags" under
the eyes it is said to be the result of capillary damage. For those bags, the problem originates
around the eyes. For Plaintif1: the problem originated deep inside the brain and it would have
damaged all the other blood vessels inside the brain, with the area around the eyes, the only
observable region.
The brain is entirely composed of fluids. The 3 fluids arc blood, cerebrospinal fluid
[transmits neuro signals and several other functions] and the brain matter; itself: Thc MonroKcllic Doctrine is that, there is an overall pressure exerted by the 3 fluids, whieh the body seeks
to keep, statie. When either of the other 2 fluids, or when a fourth component is added, perhaps
a tumor; causing the overall pressure to increase; the body compensates by reducing the pressure
of the blood component.
With this, blood flow into the brain is reduced. The brain bccomcs
uneonscious and yet the rest of the body is not afTected. For Plaintiff, it was the f(llllth
component, that of; the water that was sent into the brain. This would permit for several minutes
of unconsciousness, as the fluid slowly drains out of the brain. The technique can be repeated.
Dr. Jacobson would have his hands full; he most likely could not cngage in sexual contact.
No men, likely, had any scxual contact.
All of Dr. Jacobson's subordinates and partners are
already involved is the variety of fraudulent schemes, so when one says "receptionist", she it not
the true typical receptionist. The ones who would engage in sex acts are Michelle Miller, the
receptionist, and a thus far, unidentified woman, both about age 30. Dr. Jacobson is only at his
Bethesda office on Fridays and he likely brings along only a single assistant. She may even be
one of his daughters.
The women were not coerced or paid and eagerly participated. That unidentified woman
came down to the MRI office to "check out" Plaintiff. It was len for these women to give Dr.
Jacobson the go ahead. And all these details and appearances mattered because there was a
vicwin~ ~allcry, comprised of Dr. Cochran, other physicians from Inova, very likely including
the other management level neurologist, Dr. Lewis Eberly. The audience did not come to see
consensual sex; which may have been the case if Plaintiff was not made unconscious.
They also
did not want to see sex acts with someone in a ncarly lifeless state or visibly sick.
The concepts are "level of consciousness" "coma scale" and "stimuli".
Dr. Jacobson put
Plaintiff into a semi-conscious state, in which he would be sleeping, but would awaken with
stimuli such as slapping in certain sensitive regions, such as around the ears. The sex act would
occur, with PlaintifTtrying to resist not because hc is resisting a sex act but because he wants to
sleep and be len alone. This would have occurred several times. Although, rendering
unconscious, has made the offense, aggravated; that is meaningless to the audience. They came
to see a violent sex assault.
PlaintifT had treatment relationships with two physicians prior to being enrolled into
Medicaid. The first one was Dr. Aroor Rao, a cardiologist.
With Dr. Rao, Inova's conspiracy
was already in place, even prior to PlaintiWs appointment.
Plaintiffasked
Dr. Rao to tell hini
what has produced the small swellings underneath the eyes. The swellings look somewhat
different from the usual "bags", which are sometimes attributed to inadequate sleep. It's likely
he was trying to say, inadequate sleep; but he said something else, because of the facts he had in
his mind. Dr. Rao replied "that's beeause you are waking up all the time".
The first physician with MSFC and Medicaid was Dr. Anjana Dhar. There was no prestanding conspiracy.
Within a minute, Dr. Dhar, discerned all the facts. When PlaintifT
mentioned the injection; Dr. Dhar genuinely had a look of shock on her face. But then she
decided to seek out a conspiracy. Dr. Dhar made a commcnt that Plaintiff should have taken
someone with him, whcn he went for the MRI test. Dr. Dhar's briefs restated this comment and
did not deny that Dr. Dhar had made it. Thc MRI room is a special cnvironment and if at all
someonc came with Plaintiff; they would be in the waiting room. Even is the tcchnician had
done some unlawful things; that person would not have scen. However; if unauthorized persons
wcre going in and out of the room, perhaps Plaintiff's body even taken out ofthc MRI room for
the sex acts; all that; thc accompanying person would notice.
MSFC, then assigncd Dr. Anthony Macarthy, who said "you shouldn't say too much". Dr.
Macarthy scnt Plaintiff to Dr. Luc Oke, a cardiologist, a defendants from the related case.
There was no pre-standing conspiracy that involved Dr. Oke. The medical evidence alone,
coupled with a local physician's knowledge of1ocal factors. This would include such detailed
things as knowing about the conduct of other physicians and in the case of Dr. Oke; he has a
practice of going and meeting with other doctors and their stafr. The staff at Dr. Mac3l1hy's
officc refer to Dr. Oke as "Mr. Luc".
Dr. Oke said that he does not want to finish the visit. He wants 2 weeks to obtain medical
records Irom the PCP, Dr. Macarthy (something that should take, minutes) and then, resume the
visit, 2 weeks later. Dr. Okc wcnt shopping for deals from thc offendcrs.
Dr. Oke is familiar with Dr. Jacobson's neurology office and MRJ office staff. PlaintilThas
nevcr said anything about any sex offenses to his medical providers. His statcments have becn
limited to the mcdical facts. Dr. Oke became so titillated, that he made some joking comments
that were directed to both his subordinatc and to Plaintiff. From the perspcctive of the
subordinate, these indirect comments fall within the ambit of sexual harassment.
respond to the comments.
told Plaintiff"Don't
She did not
Dr. Oke, winking and smiling and mainly looking at his subordinatc,
do anything over the 2 weeks to make yourself, pass-out".
Perhaps, to
suggest to his assistant, why can't you be like those other assistants.
Even though all sorts of horrihle things were occurring, such as; the brain swelling; it
could have been done with minimal permanent
injury, after all; Dr . .Jacobson is an expert.
l'laintill~ who was agc 42, would likely not have noticed any problems until, he were in his 60's.
At that time; conditions, such as; dementia, and other major problems, would be very, likely.
All the individuals who participated
with tbe sex crime; were fully on-board for Dr .
Jacobson, to: after the sex acts had concludcd;

catastrophic
usc his sldlls to deliberately
produce
iujuries, in the form of a severe stroke. The stroke would be said to be a mere
coincidencc to the MRI test. The, prior relatively minor injuries could be said to be
manifestations of the stroke. The risk of Plaintiff developing problems alier decades and tracing
causation back to these offenders would be erased. Plaintiff would be a "vegctable" and die
soon; end of story.
But, it was more than even an effort to further hal'm their victim, in order to; evade justice.
Dr. Jacobson actually enjoys causing people to suffer as evidenced in Pannu v. ,Jacobson.
Following the conclusion of the sex acts; Dr. Jacobson, worked diligently to greatly increase the
water into the brain and may have included an anti-diuretic drug, which prevent loss of fluids.
What occurred is that the heart and aorta were injured, along with the appearance of signs such
as swellings beneath the eyes and the collateral circulation on the chest, and perhaps impending
kidney failure. All these things could not bc said to be related to a stroke. FurthemlOre;
something other than a strokc may have produced death, without the stroke ever appearing.
Prior to being enrolled into Medicaid; the second physician, with whom Plaintiff established
a treatment relationship is Dr. Jeffrey Dormu, a cardiologist, but in the subspecialty of
"vascular".
Dr. Dormu went shopping for conspiracies, but in the presencc of Plaintiff he had
"loose lips". It was Dr. Dormu who gave the critical evidencc of the blown out ulnar artery and
also that the veins in the arms were fine. [Papel's pretext for additional injection was that there
was a problem with the veins]. Dr. Donnu, even easily agreed with Plaintiff that if a vein failed
on the left arm, Papel would simply have to tryon the right arm. And then, Dr. Dormu
concluded with "You're smart, you can figure it out".
But Dr. Donnu, steadfastly, concealed other parts of the evidence; that showing the evil acts
done following completion of the sex acts.
Dr. Dormu's technician, "Alex W" had \\Titlen up a full report showing that there is injury to
the major veins that return blood from the brain, to the heart. There is a large pattern of
collateral circulation. This is something of a bypass, that the body does on its own. Dr. Dormu,
erased out, this evidence using a program such as "Photoshop".
Dr. Dormu gave Plainti ITmorc
than 20 pages of things from Plainti!rs
tile, many things of no value. It was only that particular
report which is speckled with spots. Thc craser tool, docs this
Dr. Jacobson is a bigshot at Suburban IIospital, 5 blocks away and he could easily control
facts. Plaintiff has only physician, a neurologist, a specialist in strokes. This is Dr. Sonalee
Kulkarni. But Dr. Kulkarni had already been bought off; primarily with professional favors
from Dr. John Cochran of Inova. None of this would have occurred had Plainti!rs own
physician, Dr. Kulkarni not betrayed; him, and the ethics of her profession.
And ultimately, the effort to cause immediate catastrophic injuries, depended on fooling the
Bethesda-Chevy Chase Rescue Squad, which sits next door to Capital Imaging. This is
something of an elite group, with missions to foreign disaster zones and even a physician or two
among their ranks. Then because all those, unexplainable signs were appearing, Dr. Jacobson;
stopped. Not only had large scale injury already been inflicted; Dr. Jacobson produccd cven
morc latcnt injurics, such that; although Plaintiff would walk out of thcrc;
timebomb"
or "poison pill" would matcrializc
at any momcnt.
Someone else forged an interpretation and signed off as "Elcctrically

Board Certified Radiologist"
"ticking
signed by Jolm Athas,
Irs common knowledge that thc word is "electronically".
Plaintiff
thought for a long time that Mr. Papel, who docs not have good English skills, did this.
But the error is too grcat and this was not thc work of Mr. Pape!. The forged report was the
work of Dr. Jacobson, using dictation software. Dr. Jacobson is a surgeon and it is surgeons,
who always write by voice, because their hands are not frcc. The physicians' version of this
sotlware recognizes medical words. The word "electrically" is frequently uscd, most Ii'equently
with ECG; but "electronically" is a computer term and not part of the medical lexicon. Dr. Athas
would have some password that when given to a computer by typing, or by voice would imprint
his template signature. But when Dr. Jacobson did it, he had to say it all out.
"Clinical history" should be compared against Dr. Kulkarni's doctor's notes January 24,
2013. Virtually, nothing matches. The MRI report states "Rule out pituitary abnormality".
Dr.
Kulkarni's large narrative says nothing about pituitary. Furthernlore, there are specific mandates
from insurers, to not use the term "rule out". Then under "technique", it says that the test was
performed according to standard pituitary protocol. 1'Iaintif1; anonymously, contacted Ms.
Miller by email and she confirmed that the script must specifically state pituitary protocol. The
script did not say that. Furthermore the images show that the test which was performed is the
standard MRI test. When the pituitary protocol is done, many of the images are to be focused on
the pituitary region. All the images show the full brain.
Imaging test for pituitary abnonnalities is the last step of a long process. It is only used when
a tumor is suspected. For pituitary abnon11alities, testing begins with a standard blood and urine
test, with the blood test checking thyroid function, as well. Then there are all sorts of blood tests,
urine test and saliva tests, which require testing at different times of the day and such.
This MRI report notes a clinical history of problems around the region of the eye and yet
there it has not reported on the condition of the optic chiasm and optic nerve, both of which are
to be reported on a pituitary protocol test.
The report is a hydrocephalus evaluation report. "No pituitary mass identified. The
pituitary stalk is in the midline. The cavernous sinuses are unremarkable bilaterally".
region that swells and crushes downward.
This is the
"The ventricles, sulci, and cisterns arc within nornlallimits.

is detected.
No abnormal white matter lesion
There is no evidence of intracranial mass, hemorrhage or acute infarction. No
hydrocephalus present".
" No hydroccphalus
prcsclIt" is the conclusioll.
When all these other things are normal, it
means that no hydrocephalus is present. Impression: "No evidence of a pituitary mass. The
suprasellar structures are unremarkable. No intracranial abnormality identified"
Ventricles, cisterns, cavernous sinuses; all some of the suprsellar structures, the drainage sites.
When PlaintifTmade his first return visit to Dr. Kulkarni, she was in a physical state of panic
throughout the visit. She was pacing, shuddering and made the sound of fear with her mouth.
This came only after Plaintiff began to talk about the strange behavior of the MRI technician.
Papel is nervous because he is something like the getaway driver, in it for the money, but afraid
to get caught. Papcl, likely told the co-conspirators that he was very cool and so Dr. Kulkarni,
another of the getaway drivers; also has an immense fear of getting caught.
Prior to the MRI test Ms. Miller told I'laintiffthat she could not find her receipt book. The
plan very likely was that after a stroke was produced, to say that Plaintiff was in the building, but
not in the MRI room. The experts who did all this, have the expectation that catastrophic injuries
are imminent.
When Plaintiff returned to Dr. Kulkarni, her nurse LaToya Tates could not find
the MRI report, but Dr. Kulkarni could fit either in some hidden compartment of the computer.
Epic software is the top of the line software. The test results should have appeared with the other
test result and fiJrthermore, it would have been logged-in is being completed.
But the test has
always shown as being outstanding.

This pattern occurs with great frequency and consistency.
One could argue that there is no
fraud because I'laintiffhas the knowledge that he completed the MRI test. But then the question
10
arising, why does Inova an its agents go through lengths to do this. The answer is simple. The
expect the catastrophic injuries or death; and as the saying goes, dead men don't talk.
Although the criminal offenses were done by several agents of Inova, using Inova's assets;
its possible that the executive level did not have knowledge. But this changed; when Plaintiff
sent a large letter to Dr. Kulkanri in July, 2013. From that point onwards; the executive was
fully involved. The medical records for March 26, 2013 that were given, was only produced
much later. Therc is a series of actions which with the participation of the executive level. But
was no cover-up or even being accessories aftcr the fact. The actions from Inova were that of
joining with thc last componcnt of the criminal offenses. That of seeing to it that the catastrophic
injuries do materializc.
The following is directly from thc Complaint: Group asscmbled by Dr. Cochran continues to
meet:
79. In mid-Novembcr 2013, Plaintifftclcphoned
Alfa Neurology and askcd to
speak with Dr. Kulkarni. A nurse answercd and infornlcd the patient that "Dr. Kulkarni is in a
meeting with somc doctors and some other people that I don't know". The formation of this
group is morejustilied
at this timc, since a complaint was already filed with the state physicians'
board, however the Plaintiff was still a paticnt. Normally, such a group is asscmblcd, alicr
commcncemcnt of litigation and thc doctor-paticnt relationship has tcnninated.
Thc nursc,
rcpeatedly, wcnt to thc conference room and asked for someonc to speak with the paticnt.
Finally, Mr. Lewis, thc practice managcr spoke to the patient. Mr. Lewis, initially, said that Dr.
Kulkarni was with a paticnt; however, aftcr the paticnt revealed that he was aware of the panel,
Mr. Lewis, admittcd its existcnce.
80. During the Icngthy convcrsation, thc Plaintiff requested that thc practice rcfund thc fccs.
Thc point was that Medicarc would not pay for substandard care. Mr. Lcwis responded that this
11
very action is somcthing that the assembled group is considering, as one of their options. The
usc of the word, "options" provides an insight into the mindset of the assembled group. The
group believes that compliance with laws and compliance with the AMA Code of Ethics, are
merely, "options".
81. Subsequent to this conversation, Dr. Cochran mailed a letter (Exhibit 6) to the patient,
signed by Dr. Cochran and not co-signed by Dr. Kulkarni. Dr. Cochran's points were that: (I)
the practice is terminating Dr. Kulkarni's relationship with the patient because sometimes, the
doctor-patient relationship does not work well (2) Dr. Cochran would provide "neurological
care" for a period of30 days, ending on December 22,2013 (3) the practice will provide records
for continuity of care. A "records request form" was enclosed.
82. Plaintiff telephoned the records clerk. This records clerk told the patient that for the
reasons that his records were short and that the Christmas holiday was approaching, she would
waive the fee and would issues the copies, instantly. The clerk advised the patient that he could
either mail the form to the office or visit the office. Subsequently, Plaintiff mailed the form to
the practice. Allowed 15 days for the release of medical records. No records arrivcd.
Patient visited the practice for the sole pumose of obtaining his records
83. December 17,2013 at 2:00 p.m., presents a newly completed form to the employee at the
front desk, Charlene Seegers. Ms. Seegers was the last employee that the patient spokc with as
hc was departing the office following his September 13,2013 appointment.
At that timc, Ms.
Scegers told the patient in the presence of other employees at the front desk "That's what I like
about him, he is always smiling" and added supporting comments.
Large defamatory statement in patient records
12
84. Ms. Seegers, first, accessed the patient account. Next, as she was about to print, she
noticed a large defamatory statement on the first page of the mcdical records. This is the first
page of the medical records that would be; sent to another physician, scen by emergency room
staff at Inova hospitals. Purpose is to prejudice other physicians, in an cfTort to conceal
misconduct.
Ms. Secgcrs begins to read the statcment, aloud; "This patient has becn dismissed
from the practice becausc". Ms. Seegers continues to read thc balance, silently. Hcr facial
expressions are of shock and disbelief
It takes 5 minutes to complcte reading.
Hydrocephalus comcs with some warning signs. The top sign is poor gait. This is because
the crushing effect, first touchcs the connections from the brain that control walking. Plaintiff s
gait was okay and he had never complained about it. When the group assembled the March 26
records at a later date; it shows that a trick was used to report not only that gait was normal but
also to give the imprcssion that Plaintiff was "crying wolf' about this problem; such that when it
really does appear; it will not get treated in time. The records stated that the patient continucs to
report problems with his gait. But looking back at the only prior records; thcrc is not statemcnt
about the paticnt reporting any gait issues.
In thc September records, it makes a vague refercnce to a condition called "autonomic
dysfunction".
So for hypochondriacs and such, doctors use such a serious sounding tern] to go
along with the hypochondriac.
So an "autonomic dysfunction" spccialist, does some strangc
placebo like tcsting and such. When a doctor sees this tcrm on thc records; it mcans
hypochondriac or some psychosomatic symptoms.
But with hydroccphalus, somc of the other
warning signs includc real problcms with the autonomic system. But here, this is not called
"autonomic dysfunction", and if does not take some spccialist with that title. It is mcrcly one of
the many injurics that all neurologists deal with.
13
When a patient reaches an "autonomic dysfunction", it means that they have already gone
through extensive evaluations by cardiologists and other specialists; and these other specialists
found no problems. So when PlaintilT would report these signs, his doctors would thing he was
"crying wolf'.
Then that defamatory statement which The Court stated left Ms. Seegers with a look of
astonishment would be something similar to Dr. Oke's joke, inspired by titillation. Dr. Oke had
not yet conspired with thc offcndcrs, but all evil minds think alike, and the plan clearly was to
say that PlaintilT cngagcd in some consensual sexual adventurism and got hurt in thc process.
That hc allowed someone to make him unconscious in this way; pcrhaps PlaintifT gets enjoyment
from vicwing the tapc at a later timc. Whcn not only was Plaintiff the victim; it secms probablc
that the offcnders do in fact have recordings and frequently view it. lnova admittcd thc existcncc
of a defamatory statement, without disclosing its contcnts. Inova stated that only Ms. Seegers
had sccn it. The most plausible plan is that, Inova kcpt that statement on file, internally, so
Ms.Seegers saw it; but Inova would only send it to subsequent physicians after the catastrophic
injuries occurrcd. And at that time; Plaintiff would bc mentally and physically incapacitated,
with no memory, no ability to communicate and such.
Inova is not trying to "get one over" on Joseph Crussiah, the person who wrote this brief:
lnova is trying to "get one over" on Joseph Crussiah, the vegetable or Joseph Crussiah "thc
retard". Then on the same afternoon, Inova with connections to Fairfax County Govemmcnt had
a substantial police presence, 3 oflicers, where there was no probable cause. And if the response
was fear of a potential threat from Plaintiff, then why, did the oflicers by I'laintilTand go into the
back, where either the lnova of1icial Carol Jones or the of1icers used '\vhitcout", in order to
14
conceal page numbers. The computcr was spitting out thc order for the MRI test and to withhold
those pages. The only one who would get fooled is the future Joseph Crussiah, the vegetable.
There was a mutual connection between Plaintiff and [nova, Adventist Healthcare and
Washington Adventist I [ospital. Inova has been quietly, running the heart program at the
hospital and that's the only substantial part of the hospital. The very same cardiologists who
would have been part of that "death panel" at Inova, also work at Plaintiffs local hospital. The
hospital is owned by his church organization.
Although Plaintiff is not type who seek hclp from
a pastor; he only did so seeking a referral to an ethical cardiologist.
A sermon was already
prepared in advance that sought to discourage Plaintiff from seeking answers and seeking
medical eare. The church with sits next door to the hospital has made a conscious effort to hide
what it did. The church no longer puts the archived full church service online. Even the
sennons, themselves are podcasts, audio only, furthermore their edited to make them short. And
now all the things Plaintiff pointed out are no longer online. The pastor has even edited in some
new words. No longer is the pastor saying that cardiovascular problems come from anxiety. The
inference of guilt is clear. These are all people with carrying out Dr. Jacobson's scheme.
The first cardiologist, PlaintifT saw, Dr. Aroor Rao put a very odd comment into the records
that Plaintiff did not understand the motive. It says that his patient reported drinking 20 plus
cups of water daily, right next ofa statement about Plaintiff exercising 7 days a week, which is
also something Plaintiff has never done. There is new story about a hiker who drank large
quantities of water and hiked a great distance. What happens is that hydrocephalus results; not
fiOln the water directly accumulating but because thc water and the perspiration depletes the
body of sodium, and this causes thc brain to retain water.
15
Additional facts rcgarding Inova's co-offcndcl's
Plaintiff already noted that Mr. Papel was acting very nervously, including; asking Plaintiffifhe
knew what is going on. But then, at the time that Plaintiffwou!d
fully regain consciousness, Mr.
Papel!ooked fearful; very concerned for Plaintiffs well being. Pape! has all these problems,
because he did what he did for the money. His odd behavior does not come from some torment
of conscious; that he is doing great harm. His odd behavior is that of someone, perhaps similar
to one who acts as a lookout for a crime. lie does not have the confidence possessed by the ones
who are hands-on doing the crime. He fears, getting caught. During the staging process to get
PlaintilTrendered unconscious; Mr. Pape! is most fearful ofPlaintitr
himsclfeatehing
on to what
he is doing. But then after, they get away with everything; Mr. Papcl no longer fears Plainti ff;
what he fears is that should catastrophic injuries materialize; the paramedics or some other
medical professional would catch on.
This theory holds even with others, involved. Michelle Miller is the only "hands-on" offender
that PlaintilThas ever interacted with. It was only more than a year later, that Plaintifflooked
at
the data recording evidence from the MRl, contained on a CD and found that the full process had
taken more than double of the normal time. That's when l'laintiffbegan
having doubts about
Ms. Miller. Even ifit had been that Mr. Pape! did everything and Ms. Miller who sits outside the
door of the MRI room, decided to turn a blind eye; One would expect that she would be at least a
little nervous. But she was not because she had the confidence.
Papel, really was not part of the group; he had no confidence in Dr. Jacobson. Dr. Jacobson
asked Papcl to do a "neuroeheck" before PlaintifTleft the MRI room. This includes asking how
many fingers arc seen, answering in complete sentences and ability to walk straight. Papel was
fearful because he feared problems.
16
I'laintifTwaited 15 minutes for Mr.I'apelto
create and bring the CD to him. Plaintiff was in the
waiting room and Ms. Miller acted perfectly, normal. But there were odd things that she did.
Before the test; Plaintiff had paid with cash. Ms. Miller said that she could not find her receipt
book. And looking back, that would have been a lie. Depending of the outcome; there may even
have been a plan to deny that testing ever commenced; perhaps to say that Plaintiff took ill as
soon as he entered the building.
At the conclusion as Plaintiff waited in the waiting room, Miller; for an office with no work,
had 2 strange phone calls. The I" call, she is purportedly talking to an old woman, who is asking
all sorts of questions about the MRlmachine.
that she is annoyed.
Miller gives short answers, with a voice to show
Miller is also making hand motions and face gestures to Plaintiff to show
that she is annoyed by the call, and hoping this person ends the call. But Miller is a professional
customer service worker and she is mocking a customer in fi.ont of another customer.
Obviously; this is Dr. Jacobson on the phone and having Miller report the post-op
observations; some more neuro checks. The only thing that stood out at the moment was that the
purported weird caller asked about the color of the MRlmachine.
Plaintiff does not remember
whether the reply was black or white. Miller also answered some. question about, how large?
When Miller got off the phone, PlaintifTasked about that strange question and she said that
the old woman asked if the MRlmachine
is blue. This would have been Dr. Jacobson asking
about the color of Plaintiffs pupils or the cornea. Millcr had "eyes" associated with MRJ
machine, and blue came to her mind. Who knew that blue is the favorite color of old women; let
alone that a patient enquired about the color of medical equipment.
In the second call, this occurred aller Papel handed the CD; purportedly, it was Miller's
husband or boyfriend on thc phone, that type of phone call. This also would have been Dr.
17
Jacobson, now, gathering observations of Plaintiff walking to the elevator and operating it.
Plaintiff approached her window to ask if about when the interpretation would be completed.
Miller, thinking that Plaintiff could hear the person on the other end, got very loud with the
person, in an effort to muzzle the voice. And to send a hint to Dr. Jacobson that Plaintiff was
standing right there; she enquired of her purported husband; "where are you calling from it
sounds like you are under the pool or somcthing".
These are the kind of things people said when
cell phones first came into use; but by 2013 everyone knows about bad cell phone connections.
Ms. Miller continued to act as the eyes of Dr. Jacobson, apparently, rcporting as Plaintiff walked
and operated the elevator.
Nearly 3 years later in Decembcr, 2015, PlaintilTlawfully recorded a phone call with Ms.
Miller Irom Capital Imaging. Plaintiff; inadvertently, stepped away from the phone and Ms.
Miller; immediately told Plaintiff that he has a bad connection.
She's not really confounded by
telephony. This was not recorded. After committing all these crimes they are maybe trying to
have some more legitimate business and there is another receptionist. Ms. Miller is, now, more
of the office manager. Something that was not rccorded is that when Plaintiff started speaking to
"Stephanie", who likely is only involved in the legitimate side of operations, Ms. Miller
physically snatched thc phone out of Stephan ie's hands.
As the recorded portion begins; Ms. Miller who being a sociopath was able to act perfectly
normal, not only on the day of the incident, but also is subsequent interactions, at a time in which
Plaintiff did not think that there was any great problem; now whcn the real questions come; she
is not really a good liar. She starts off a couple of words with a bland legal statement like, tone.
But then, cven though part of the same sentcnce, she switches to a differcnt typc of spcech. Shc
may have bccn trying lor the "I don't know what you arc talking about" answer. But, instead,
18
she said, "Oh whatever do you mean!!", and a tone, that ofa child getting caught with his hands
in the cookie jar and still denying the accusation. And Plaintiff had only started off the call. He
had only said the he had a MRI test there a few years ago.
Miller switches to that legalese tone. She repeatedly tells to file; malpractice action and
complaints to the physicians' board, against all of them. The one thing that medical providers
don't admit to is malpractice, but here, to get out of jail, they seck to say it is all about
malpractice.
Ms. Miller's contact with Plaintiff was to be limited to giving a form to fill out,
accepting payment and giving a receipt, Plaintiff did not suffer any injuries from any of those
actions. I'laintiffasked,
if Dr. Jacobson was the physician, [who under Medicare rules, that
apply to even non-Medicare patients], is supposed to be somewhere in the building in case of

some rare allergy or such. She said she had to look it up because there arc 5 physicians, upstairs.
l'laintiffreminded
her that, he was talking about February 15,2013 and she hung up. Dr.
Jacobson was the only physician at that building for many years. It was only after his criminal
offenses against me that he sold the Bethesda neurology practice to Johns Hopkins Health
System and the other physicians also came onboard. Dr. Jacobson was also named the director
of neurosurgery at Hopkins o\\11ed Suburban Hospital. This weasel appears to be sheltering
under the protection of this giant healthcare entity.
Plaintiff told Ms. Miller that his Medicaid doctors need his full medical history and, that the
report Capital Imaging released about therc being no complications, could just not be true. Ms.
Miller, without hesitation, yelled out "You walked out of our office".
Ms. Miller was very loud and aggressive until this point of the discussion. She, literally,
meant: that Plaintiff should be for'tunate that he walked out of their' office
because they were trying to kill or severely incapacitate.
19
Because of her sudden
silence, Plaintiff first said "I'm sorry!" (with the meaning of I don't understand, could you
please repeat, as in excuse me!). She remained silent and then Plaintiff asked "I walked out of
where"? It sounds like the cat got her tongue and one can actually hear her fOffiling the escape.
She has a very extended, "Did you---------"
and then adds in, "say something when you walked
out or our office". Adding in the phrase at the end, did not answer the question of; I walked out
of where. And it sounds like she is a contestant in a game show where one may have to add a
phrase upon one that has been given.
Plaintiff replied that he contacted their office about a month following the incident. She quickly
conceded; and it was Ms. Miller in the early part of this same discussion who said that several
emails wcre reccived. In no way did she mean, did Plaintiff rcgister a complaint. She meant
that: Plaintiff left, alive, and not incapacitated.
Ms. Miller was very loud and assertive during the phone calls, but at the point that she slipped
with this statement about walking out she became very subdued, then she again became loud and
assertive. When told that Plaintiff reported all of their actions to the police and prosecutor, her
demeanor again became subdued; very solily uttering, okay, several times.
Ms. Miller tells Plaintiff the procedure to get medical records and when he tell her that he
already has that document and asked her to verify if it is the one that says "electrically signed".
She replied by saying that she cannot speak to him until he is ready to have a "rational adult
conversation".
When Plaintiff asked a second time about "electrically
signed'", she hung up.
'Vhv can't Plaintiff not get the common finding that there is no acute distress
Physicians always note on records the comment "no sign of acute distress". There are even
hospitalized patients with severe conditions who get this statement. And all patients at an
outpatient doctors' office get this designation; but Plaintiffs doctors omit this statement. This is
20
because Plaintiffs body is essentially operating on some sort of back-up system. But the doctors
don't think that it is permancnt.
Conclusion
In light of the foregoing but additionally, in light of (1) Plaintiffs large volumes of evidence
in both of his case records, including; letters from a physician and a veterinarian who use words
like justice and revoking license, nothing to do with malpractice.
Additionally, threc out of four
of Dr. Kulkarni's neurology practice colleagues resigned as part of a mass resignation (2) the
virtual absence of any evidence submitted by any of the defendants (3) the acceptance of
Plaintiffs conclusions in the public eye, on YouTube, individuals such as Dr. John Cochran of
[nova, who once called it defamation for accusing Inova of malpractice, now fully accepts the
label of "sex offender" (4) the defendants in both cases, who are medical providers, with all their
Iilings, have not even attempted to discuss the medical fact. Plaintiff Joseph Crussiah,
respectfully requests that The Court grants his Motion to Reconsider denial of Second Amended
Complaint; Motion For Emergency Preliminary Injunctive Relief and Motion For Appointment
of Representation.
Respectfully Submitted,
Dated June 23. 20 I6
~;({J~
Joseph R. Crussiah
Pro Se Plaintiff
970 I Cottrell Terrace
Silver Spring, MD 20903
Montgomery County
240-475-7737
crussiah@yahoo.com
21

Joseph Crussiah Crussiah Crussiah Paula Xinis U.S. Court Inova Medstar

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Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 1 of 21

IN THE UNITED STATES DISTRICT COURT

Civil Action No. PX-14-40 17

MEMORANDUM IN SUPPORT OF PLAINTIFF .IOSEPH CRUSSIAII'S MOTION TO

Background and Skills of Involved Third Partv

v. Jacobson, a malpractice case, his own experts

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 2 of 21

averaging age 30, live with Dr. Jacobson

and Through An 'nova Operation

Plaintiff is going to sufTer severe

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 3 of 21

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 4 of 21

All of Dr. Jacobson's subordinates and partners are

Dr. Jacobson put

With Dr. Rao, Inova's conspiracy

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 5 of 21

was already in place, even prior to PlaintiWs appointment.

Dr. Rao to tell hini

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 6 of 21

She did not

do anything over the 2 weeks to make yourself, pass-out".

injury, after all; Dr . .Jacobson is an expert.

with tbe sex crime; were fully on-board for Dr .

Jacobson, to: after the sex acts had concludcd;

usc his sldlls to deliberately

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 7 of 21

Dr. Dormu gave Plainti ITmorc

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 8 of 21

than 20 pages of things from Plainti!rs

tile, many things of no value. It was only that particular

or "poison pill" would matcrializc

Someone else forged an interpretation and signed off as "Elcctrically

signed by Jolm Athas,

Irs common knowledge that thc word is "electronically".

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 9 of 21

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 10 of 21

"The ventricles, sulci, and cisterns arc within nornlallimits.

No abnormal white matter lesion

There is no evidence of intracranial mass, hemorrhage or acute infarction. No

prcsclIt" is the conclusioll.

When all these other things are normal, it

But the test has

always shown as being outstanding.

One could argue that there is no

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 11 of 21

79. In mid-Novembcr 2013, Plaintifftclcphoned

Alfa Neurology and askcd to

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 12 of 21

At that timc, Ms.

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 13 of 21

It takes 5 minutes to complcte reading.

along with the hypochondriac.

So an "autonomic dysfunction" spccialist, does some strangc

But with hydroccphalus, somc of the other

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 14 of 21

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 15 of 21

Although Plaintiff is not type who seek hclp from

a pastor; he only did so seeking a referral to an ethical cardiologist.

A sermon was already

Case 8:14-cv-04017-PX Document 35-1 Filed 06/24/16 Page 16 of 21

Additional facts rcgarding Inova's co-offcndcl's

fully regain consciousness, Mr.

having doubts about