Professional Documents
Culture Documents
Case no:
17-15217
Factual Background
Applicant Madhuri Trivedi is a citizen and national of India who entered the United
States in 2003 on an H4spouce nonimmigrant visa. Compl., Over the next few years,
she transitioned to an F student visa and then an H-1B highly skilled worker visa.. At all
times, her status remained that of a nonimmigrant authorized to remain in the United
States on a temporary basis. Ms. Trivedi sought to adjust her status to that of an alien
lawfully admitted for permanent residence in the United States (LPR), either through
her former employer, General Electric Healthcare (GE); who as a retaliation for not
invested 13 years in USA. After I was terminated from that position, through an
employment petition that she filed on her own behalf with Hardvard medical job offer as
a person of extra ordinary ability. On March 4, 2015, USCIS ultimately denied Ms.
Trivedis I-140 petition and again in May 2016 second I 140 was denied while district
RELIEF
I pray to the Court for the relief that Madhuri sought below
work authorization petitions.(all three were unlawfully and wrongfully denied.) make
me "whole."
Ms. Trivedi adds a request for advance parole as well . She can go to India and then
return to the United States. Also Back pay, lost wages and punitive damages related
One needs to be a fighter in order to be a woman in technology and also woman from
India. Despite all odds and mountains of challenges; I have contributed in the EB1/EB2
national interest waiver capacity. If given right environment, opportunity and support; a
person like me may get a NOBEL prize at some point (I spoke with Nobel prize
committee member in Europe in January 2017; emailed my lawsuit info. He said you
are still not WHITE and government is scoundrel). Currently I feel it is lawless and
For the violation of a constitutional right, require the defendant to repair past violations
of the law;to make whole again Madhuri whose rights have been violated. Court to
give special attention to questions of fairness and good faith. Relief I requested is
appropriate to prevent an illegal action, to put a stop to ongoing or repeated conduct that
violates my rights and continue causes injury, or to force a defendant to take action in
order to prevent harm..request both reward for money damages and relief in terms of
immigration documents approved. The defendant continued to act in bad form.
Legal Arguments
1. President Obama gave National technology award by to 20 people start up founder(
where I was one of the few founding member of engineering team)Dr. Jonathan
Rothberg.
1.1. Dr. Rothberg sold the sister company for 700 million to Thermo Fisher
scientific/Life Tech. I didnt made a penny though. But these facts prove that I
was EB1-extra ordinary ability person for which DHS illegally(TORT) denied
my petitions and not giving me work authorization. This is also violation of
human right and intentional. Within weeks of my GE termination ; Thermo
Fisher had a job for me but got stuck on H1 visa.
1.2. Given Dr. Rothberg award ; it is unconstitutional and illegal for DHS to keep
me in this situation. Ninth circuit must give me relief I requested.
I developed WORLDS first digital - biological equivalent -equivalent to PERSONAL
COMPUTER -an instrument for genome sequencing PCR (instrument price was $150,000
per unit) Raindance executives and other seniors have stated that my contribution was of
a major significance, leading /critical role to existence of organization
and entrepreneurial.
2. Below is an article I published := using Artificial intelligence for solar storms and it's
affects. I did this project in 2004. It shows my forward, critical, highly complex,
technical and subsequently business, legal impact, original thinking and contribution.
Given DHS, White House made laws ( Item 1.2, 1.3, 1.4 below)
2.1. My article is : Backpropogation Neural Network for Prediction of
possibility of Solar storms
Madhuri Trivedi https://www.linkedin.com/pulse/20141020222732-70561201-
prediction-of-possibility-of-ionospheric-storms-neural-network-backpropagation-
model?articleId=5930091444567027712#comments-
5930091444567027712&trk=prof-post
This was a masters of science -Artificial intelligence class project I did in 2004. But
deep learning and predictive analytics used widely. In US recent new regulation
require energy companies to have a measures/mitigation strategy against solar
storm related outage.
Ionospheric storms - solar storms are caused by particle emissions from the sun,
generally alpha and beta rays. Since these takes about 36 hours to reach the earth,
some warning is possible after large sunspots or solar flares and several different
noises generated due to these activities are noticed. Under normal quiet conditions,
there is a constant noise radiation from the sun, simply because it is a large body at a
very high temperature (over 6000 degree Celsius on the surface) The main sun
caused disturbances in the atmosphere are sudden ionospheric disturbances and
ionospheric storms.
Studies with earth-based radioheliographs and from satellites in orbit have provided a
large amount of data on solar flares and several noises, so that some short term
predictions are becoming possible.
The disturbances have been known to cause blackouts, power plant shutdowns,
corrosion in pipelines, disruptions in radio and television transmissions, malfunction
of geological survey equipment, satellite tracking problems, and other detrimental
effects. Being able to predict these occurrences helps prevent disasters.
In this example a neural network is designed and trained to predict the possibility of
ionospheric storm in future. It takes several different noises as inputs. If the presence
of noise and increase in solar sector boundaries and presence of solar flares are
beyond normal limit, then it is being considered in this example as presence of input.
Inputs are in the form of 0 and 1(absence and presence) of noises.
This program is for a simple neural network that performs supervised learning by
backpropagation.
2.2. Subsequently as per DHS website dated 2015-04-15 Solar Storm Mitigation
Fact Sheet https://www.dhs.gov/publication/solar-storm-mitigation-fact-sheet
Case 17-15217 Madhuri Trivedi vs. DHS Page 5 of 20
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2.3. White House directs accelerated response to solar flare grid threats
http://www.eenews.net/stories/1060044695 October 24, 2016
2.4. A massive solar storm could cost the US economy $40 billion per day
By Joel Hruska on January 23, 2017
https://www.extremetech.com/extreme/243255-massive-solar-storm-cost-us-
economy-40-billion-per-day
3. I have been suffering and will continue to suffer irreparable harm in the absence
of relief, resolution. please grant relief requested in this application.
4. Skidmore v. Swift & Co., 323 U.S. 134, 65 S.Ct. 161 for setting aside and reversing
agency decision. Force of law.
5. Act 8 U.S.C. 1152(a)(1)(A) forbids discrimination based on a person's race,
nationality, place of birth, or place of residence. My nationality, gender, race
and up to certain extent religion I have been treated differently.. It is extremely
difficult to be a woman in technology from Indian nationality , Asian women
and also religion ( my GE direct manager commented about me being Hindu-
though I have read Bible and read about most of other religions and am open
minded...all religions take us to same God- a creator.) But there is unconscious
and conscious BIAS exists towards my class. Also there is Whistleblower and
QUITAM retaliation.
6.
7. After I wrote about Kazarian memo used by USCIS in my lawsuit; in Nov. 2016/Jan
2017; DHS made so many changes in regulations that used Kazarian memo for
employment based visa petitions adjunctions; while terrorizing me.
8. For my healthcare start up..I was doing it for a cause and not for a money. What I
have been going through and My fathers loss;I must rethink about this.
9. Now given a new Trump administration ; they are also harassing and
terrorizing me.
Page 61 Q So in your opinion, the work I did for I did for security VNC server issues
on Surgery was good work, and it was good for GST given that I was a couple of months
old within the company, and it was -- I was bringing tons of issues, and it was too much
for them.I was expressing tons of concerns, and it was truth. It was not just -- It was
happening. Things were not working the way they were supposed to.
Q Good work for GST.
A Yes. Technically, I thought what you were doing -- a lot of what you were doing made
sense
Page 107 Q Do you have knowledge that there were design nonconformances,
means defects in Insite ExC in production?
A Yes.
Q Do you have any idea of how many of them?
A I don't recall. I know there were several hundred or more.
Q So it says 465.
A Okay.
Q So your -- I'm talking about -- I'm just consolidating everything in one sentence.
Your point was connectivity is better than defects in Insite ExC. At the least we
would
have connectivity?
A Right.
Page 168 Q At the time of Insite ExC release, when it was public facing, it failed a
security test or had the security concerns?
A Yes.
Page 170 Q Insite ExC in production had security issues. Is that correct?
A The user interface, which is a little bit different, yes, had some security
vulnerabilities found during Scabba testing. Our mitigation was several things: One
of them was to move the user interface inside GE.
Q And also some of them were not fixed. Some of the security were never --
A Right, because we could not fix them.
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11.3. Laws prohibit deceptive practices for use, benefits of medical device.
Failing to disclose material information concerning its usage, operation, maintenance not
as advertised, sold and mentioned in contract agreement; with intentional inducement
..failed to willfully disclose and actively concealed defects for upto ten years( last 5-7
years where hundreds of critical defects). Fraudulent Concealment by GE.
11.4. Given that fact that FDA banned OEC surgical device medical devices due
to
quality issues and Madhuri was assigned a project from Day 1 to integrate Insite(
defective product with security issues) on OEC. UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF UTAH Case No. 2:07CV00017 TC -GE entered consent
decree
withFDA(https://wayback.archiveit.org/7993/20170113091924/http://www.fda.gov/New
sEvents/Newsroom/PressAnnouncements/2007/ucm108828.htm )
11.5. Internal customer Missy Ryan testified even during arbitration hearing done
after 11 months on my termination that she is still having all kind of issues.
11.6. Northern District of California, Federal Trade Commission v. D-Link
Systems Corp. et al., Case 3:17cv39. This case has been assigned to my district case
Judge James Donato.
You could have the FTC say, you know, there's a lot of data suggesting that fire alarms
don't work, and we want to intervene now before the house burns down. There's nothing
wrong with that. thought the case read D-Link has had this practice of making
assurances, and it's bound back in time, but the kicker is and it's still happening today.
FTCs function is to prevent consumer harm, rather than merely respond to harm
that has already occurred.
THE COURT: I think maybe, you know, the harm is a consumer bought a good that
was misrepresented. You don't have to bring more than that. You don't have to show that
your
medical records were consequently lost. This is not what the case is about. The case is
about deceptive and unfair marketing of these products; isn't that right?
THE COURT: But isn't it -- I mean, it's unfair in that they were selling a good that did
not live up to the promises that were made. What about the allegations of unfairness
and deceptive conduct overlap.
THE COURT: Okay. I mean, just buying the product is harm, if it doesn't perform as
represented or if it exposes someone to unreasonable danger. I mean, you don't need
anything -- Twombly and Iqbal requires - fair notice under Rule 8. That's
all you need is fair notice..The Third Circuit just said Wyndham, you told
people that your data was safe, and it turns out your data wasn't safe.
11.7. Judge James Donato mentioned above transcript that in complaint
Twombly and Iqbal requires fair notice. This was for a motion to dismiss for failure to
state a claim and jurisdiction. In Madhuris complaint. I gave a fair notice. Despite
Judge Donato dismissed my claims without even considering any materials and
mentioned Bell Atlantic case in his order along with other things.. This he showed
double standard.
case. GE architect already testified as shown above that it was vulnerable. If Judge
Donato said all these things for possible harm, security, FTC, and D Link( remember D
Link does not spend billions in lobbying) that he could have applied that atleast 10% of
that standard what he was saying here to DHS; in my case and address my legal claims.
12. Computer Fraud and Abuse Act (CFAA) ( 18 U.S.C. 1030), the
CFAA are defined as "protected computers"; 18 U.S.C. 1030(e)(2) to mean a
computer: In practice, any ordinary computer has come under the jurisdiction of the
law, including cellphones, due to the inter-state nature of most internet
communication. 18 U.S.C. 1030(b): Conspiracy to violate 18 U.S.C. 1030(a) .
CFAA is both a criminal law and a statute.
13. Given GE was selling medical devices With Insite Exc to Department
of defense, Vetrans affairs VA hospitals . I have attached hereCentricity-GE medical
product uses Insite Exc medical device and Centricity was installed on 130 VA
hospitals. (Appendix Exhibit 4 atttached here ). CFAA applies to some level to GE.
14. Madhuri was engaged in a protected activity. There are retaliation
claims if "there is credible direct evidence that retaliation was a motive for the
challenged action,"
15. GE framed meThey outsource and off shore most/all of it software.they had no
intention to keep me on a payroll (cost of paying me). Also after my labor
certification was approved as a person of exceptional ability-EB2 ; by department of
labor. Next step was just a formality by GE where GE was required to submit all its
financial information and number of US employees etc. Several immigration
attorneys said that GE has cooked accounting books. GE does not want to submit
financial data. So GE framed you. PRETEXT.
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16. GE and DHS both have showed elements of unfairness, abuse as well.
16.1. DHS could have taken it seriously and can still take it seriously.
GE was/is putting large money in connecting devices such as healthcare, energy, jet
engines..with bad security... My job at GE as a lead engineer was around this ...
17. This is an Affirmative action matter. In general, Women in technology-
computer science etc are discriminated, retaliated. Most women in Tech leave. There
is a KNOWN problem. It is dominated by Males. (sometimes women can be worst
too but the discussion is how women in tech are treated etc.)
18. GE healthcare global services division(where I worked) CEO Mike
Swinfords father is a senior retired FBI veteran James Swinford. Mike came to my
arbitration hearing. He made millions in salary and had his own private jet.
19. FBI supervisor Clayton Wible in Milwaukee called me and said it is Quitam-civil
fraud and then I emailed David J Johnson special agent in charge- San Francisco about
criminal investigation/jail ;he replied in 20 minutes and assigned an agent. Soon after my
lawsuit in March 2016 he was promoted as assistant director to report to James Comey-
FBI director ..David left FBI in January ..I met him in lobby of FBI SF in Jaunary and he
was sorry .He had a conference call with James Comey so he couldnt meet he said.
Judge Donato dismissed my whistleblower and other claims without even looking at
material information..where DHS (Dept of homeland security???) Itself failed to take
any action..regardless of me reporting to them in writing since my GE termination .
Though I have sent emails to James Comey( from December 2016) copying David at
james.comey@ic.fbi.gov .
I worked as a Lead engineer for General Electric Healthcare. There were 200-600
defects (security, HIPPA/HITECH); where 100,000 medical devices communicate and
controlled. I was doing my job and I was punished. I was one month shy from getting
my greencard processing- I 140 . GE put me in a bad situation. GE was also doing
fraud against government & customers(QuiTam). FBI said that my matter is Quitam
matter .
GE was forcing me and they themselves wanted to release remote service product on
surgery and many more device on a Linux platform in a same way they were doing it
for 10 years on Windows platform. Windows and Linux are two different operating
systems and are like apples and oranges. I was able to hack it on a Linux platform and
GE was desperate to sell that product.
I believe and A very senior executive , fraud attorneys mentioned that GE people
should be in a jail. Linux and windows are different how can they do this.
Harvard medical school has offered a job in April 2014 ; thats when I filled my
I140 EB1 A petition and supported my immigration along with Philips HC
manager. Another Indian engineer who got her GC though EB1 wrote a really strong
letter supporting my EB1A peition I am in US for 13 years and have proved myself as
a person of extra ordinary ability..have contributed for US economy/US healthcare.
Immigration is knowingly not giving me work authorization.
Anyway, I have filled extra ordinary ability EB1 petition to get work authorization in
US...Immigration is dragging it. GE has done fraud, Andrew Beato fraud attorney in
Washington DC said GE's goal is to remove witness and they are using immigration as a
tool.. I also got my healthcare app- start up idea and it is unique patent able but in all this
mess I can't do much.
20. When I spoke with Charles Meyers FDA officer on Phone in February
2014(Exhibit
12 of my District court complaint ECF-1), he said he want to do a recall today but there
is some loophole. And I cried on phone with my immigration issues to him. Once they
knew about my immigration issue, they had no incentive to do anything.
20.1. FDA was required to a RECALL several healthcare filed expert said that
including Philips Healthcare product manager Hans Griesser (he supported my
immigration petition) . Even though it was public policy violations, security issues,
HIPPA, HITECH violations; it was covered up.
20.2. FDA FOIA team knew about my lawsuit, so in my FOIA response they
deleted lots of information and didnt disclose muchPlus said that given your
lawsuit, you wont get anything from us. FOIA (Ninth circuit case no: [1715217] ECF
No. 5) response has communication from Quitam division attorney at DOJ San
FranciscoPage 15 FOIA gave only email DOJ attorney sent to FDA and NOT what
FDA responded.
21. Ninth circuit March 4th 2017 ECF 17,18,19,20,21 ; have detailed GE issues,
deposition, arbitration, 600 defects on 100,000 medical devices for several years,
wrongful /illegal termination and loss of immigration and wages as a retaliation of not
participating in GEs fraud scheme and HAVE SUBMITTED NUMBER OF
EVIDENCES.
22. District judge rescheduled hearing twice and finally vacated hearing and that
ruling will be done based on paper filings as shown below. So he didnt even gave me a
hearing
23. Trial, Trial de novo, de novo judicial review
Kazarian memo used to adjudicate my immigration petition by USCIS is not a rule, as
Administrative Procedure Act rule making is not followed.. USCIS has not posted this on
a federal register for public comment and then implement itbut rather choose to force
this on applicants and adjuncate petitions arbitrarily. Page 6- 11 district court Joint case
management statement filed by Madhuri Trivedi ECF Dct No. 20
Skidmore judicial deference is more appropriate and De novo judicial review, trial de
novo for agency decisions. But it from legal point trial de novo review is proper.
Administrative procedure Act (including but not limited to under APA 702 ) under its
umbrella have jurisdiction to have a trial like proceedings for allegations of misconduct
24. EB1 Employment based Immigrant visa petitions . I filed it SECOND TIME in
November 2015 petition number LIN-16-022-50295 which was denied in May 2016
DHS started giving work authorization to spouses of h1B who suffered domestic violence;
while despite my (a)EB1, (b)EB2 back dated to 2009 if DHS would have considered
whistleblowing for which they added protection in 2016, (c) U visa pending; till date
havent given me work authorization. And during response to my emergency motion And
Gisela West water wrote that Appellant have not applied for new work authorization ECF 10 page 4
paragraph 86.
Harvard medical offered me job for their artificial protein/DNA development for Cancer
computer instrument for genome sequencing PCR used for drug discovery in 2009 at
even under EB2 employment based immigration visa category backdated to 2009 I am
eligible to get my immigration visa. DHS changed number of laws on their own for
employment based immigration since my GE/DHS dispute . In November 2016 also made
intentionally failed to do any action which is TORT ..Genome sequencing field as a whole
have been proven different and failed to deliver its promise Dr. Jonathan Rothberg was
awarded national medal by former president Obama..and Dr Rothberg sold one of the
within month of GE termination as shown below but was stuck on my H1B transfer as I
From: Bryan.Nguyen@lifetech.com
To: madhuritrivedi@hotmail.com
Hi Madhuri,
Our legal team is educating us on the transfer process. When did you leave GE exactly?
-Bryan
I , Madhuri also Contributed in major significance to Fortune 10/50 and successful start
ups including startups by noble laureates and other in enterprise security field
In January to February 2017- Pat hale- MIT and MIT Sloan school of management
director and I Madhuri sent emails to Peter Thiel( President Trump supporter and a
key person in his transition team). We confirmed that Peter Thiel has received these
emails.
few emails (copied emails to white house folks, DHS, FBI, some journalists, couple
Horowitz at DOJ etc.). Office of first lady Michelle Obama did inquiry to DHS but
DHS said they are waiting for judge Donato to rule. I also copied Rick Dearborn (at
that time he was a director for Senator Jeff Sessions) and now Mr. Dearborn is deputy
chief of staff at White House( I emailed Rick when he was announced to join WH &
CERTIFICATE OF SERVICE
I hereby certify that on this date, I caused a true and correct copy of this statement
delivered electronically to Gisela Westwater.
Respectfully submitted,
Madhuri Trivedi
1. Below is white house general counsel email ...Even though I told her that I
haved sued OIG at DHS, she kept referring to links below and contacting them..
2. Ombuds Judge Fren Smith Notice. She was upset with government and
mentioned that how can they do this to you
NOTICE UNDER NDCA LOCAL RULE 7-13
RE: CV16-CV-01122 JD
Whenever any motion or other matter has been under submission for more than 120 days, a
party, individually or jointly with another party, may file with the Court or may ask the Northern
District of California Ombudsperson to provide such notice to the Court a notice that the matter
remains under submission. If judicial action is not taken, subsequent notices may be filed at the
expiration of each 120-day period thereafter until a ruling is made.
PLEASE LET ME KNOW IF YOU WISH TO DISCUSS THIS MATTER FURTHER, AND I WILL
BE HAPPY TO PROVIDE YOUR STAFF WITH MY CONTACT INFORMATION.
RESPECTFULLY,
3. Below is portion of what I submitted to Senator Boxer. They did inquiry and sent
me denial notice received from USCIS. I have contacted senator Feinstein in
Nov. 2016 and senator Kamla Harris , congressman Ro Khanna nothing
happened from legislative branch side.
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Appendix Exhibit 1
a) The Plaintiff alleges that this Court has subject matter jurisdiction pursuant to 8
U.S.C. 1331, Federal question jurisdiction is a subject matter jurisdiction. and 5
U.S.C. 702 et seq.
Compl. at 3, ECF No. 1.
b) A case clearly arises under the Constitution for purposes of 1331 when the plaintiff
claims, that a government officer or employee i.e. DHS officials, acting in his or her
official capacity, injures the plaintiff by taking an action that violates a provision of
the Constitution or statute. The federal question jurisdiction of the district courts also
encompasses causes of action created by federal statutes, such as 42 U.S.C. 1983,
which explicitly authorizes a private remedy for acts that are taken under color of law
and violate rights secured by law. In such cases, federal law both creates the cause of
action, supplying the underlying substantive rules
(Substantive law refers to the body of rules that determine therights and obligations of
individuals and collective bodies. ) that govern defendants conduct, and authorizes
plaintiffs to enforce the rights created.
c) The Supreme Court created a private damages action against federal officials for
constitutional torts (civil rights violations), which are not covered by the FTCA.
Supreme Court recognized the availability of damages and injunctive relief for
constitutional violations committed by individual federal defendants acting under
color of federal law or authority. District courts have jurisdiction over Bivens actions
pursuant to 28 U.S.C. 1331 (federal question statute). In the immigration context,
FTCA and Bivens claims often are brought together. Bivens actions have a jury-trial
right.
I did mentioned intentional infliction of emotional distress, negligence (also Madhuri
alleged it in her lawsuit complaint as a claim and IIED is a Federal Tort claim) in my
administrative record submissions since 2013, in my I 140 petitions, Ombuds fillings
and OIG fillings. I didnt use word TORT/FTCA but it is implied and inferred. All
defendants knew it ,But the agency didnt care to look into it nor do any investigation.
As per plaintiff pleading Executive branch has been influenced by corporate GE and
government officials prefer to have corporate company on a side. Plaintiff believes that
exhaustion of Federal Tort Claims Act claims with administrative remedy with such
LAWLESS agency is NOT required. If Madhuri would have filled administrative
claim, DHS could have definitely done more harm in retaliation and even take
extreme steps to completely eliminate witness. Hence, District court (under such
extreme Hardship, complex and difficult circumstances) have Jurisdiction for my
FTCA and Bivens Claims.
d) PROHIBITION OF INTIMIDATION OR RETALIATION 8 U.S.C. 1324b(a)(5)
DHS has knowingly tried to cover up my report about GEs unfair employment
practice since 2013. And DHS have retaliated in violation of 8 U.S.C. 1324b(a)(5); even
though DHS has legal authority to investigation these charges, have a hearing, issue
order which requires such person or entity(i.e.GE) to cease and desist from such unfair
immigration-related employment practice. DHS and its officials have deliberately failed
to act upon it in any way. Hence have violated public office duty statutes, committed
obstruction of justice, perjury and witness tampering. 8 U.S.C. 1324b(a)(5) and 8 U.S.C.
1324b as a whole. 1324b clearly states when applicant complains about unfair
employment practices, even though Madhuri complained about all this.
5 U.S.C. 706(2)(a) (authorizing courts to strike down agency actions that are
"arbitrary, capricious [or] an abuse of discretion");
f) see also 5 U.S.C. 705 ("On such conditions as may be required and to the extent
necessary to prevent irreparable injury, the reviewing court ... may issue all necessary
and appropriate process to postpone the effective date of an agency action or to
preserve status or rights pending conclusion of the review proceedings.").
h) Plaintiff also bring claims under Supplemental jurisdiction for her claims 28 U.S.
Code 1367 (a)- Supplemental jurisdiction. Joinder of claims. Though Under 28 U.S.
Code 1367 (a) , state claims can be joined with federal claims as long as there is a
federal claim(in my case , even defendants have admitted undisputedly that there is a
federal question jurisdiction and under APA 702; supplemental jurisdiction have
evolved through common law, it is up to the court/judge to look into the light of
current circumstances in which case is presented.)
i) District court has jurisdiction for Trial like proceddings for Eb1 denial for following
reasons;
The criteria for Kazarian policy memo used in Evaluating /adjuncting EB1 petitions
are not written in the law or any regulation; hence is purely an administratively
created procedure and is described only in guidance for USCIS adjudicators -
specifically, Kazarian USCIS memoranda. As such, the decision to grant any
particular type of I 140 EB1 request is discretionary.
Several Amicus briefs have been filled about criticism of implementation of Kazarian
memo complaining that memo
Exercise abuse of discretion, inconsistency, amorphous- structureless, indeterminate .
After ninth circuit appeal court ruled though; USCIS is not taking common law, prior
court rulings and objective evaluation but it is merely subjective and depends on how
adjunction officer uses his/her discretion in evaluation analysis.
abuse and arbitrary decisions in EB1 /EB2 category by USCIS based on Kazarian
memo
including but not limited to Center for Immigration Services(CIS)-Ombuds as per
August 2015 (EXHIBIT 2 ) Stakeholders report that adjudications under this policy
memorandum have been inconsistent. The Office of the Citizenship and Immigration
Services Ombudsman makes these recommendations to improve predictability and
transparency in adjudications of extraordinary ability . The Ombudsman
recommends that USCIS:
https://www.dhs.gov/sites/default/files/publications/cisomb-
rec_extraordinaryability_petitions.pdf
The Administrative Procedure Act (APA) prescribes the process for agency rulemaking
and was written to bring regularity and predictability to the decisions made by executive
branch agencies.58 Generally, the APA ensures that the public has an opportunity to
provide input in how federal statutes are applied by the executive agencies charged with
their enforcement. The various rulemaking procedures set forth in the APA provide the
public with:
Stakeholders are concerned that the current I-140 policy memorandum allows for too
much subjectivity for adjudicative petitions. Stakeholders presented in amicus curiae
briefing to the USCIS Administrative Appeals Office (AAO) that the Kazarian decision
does not require USCIS to implement a two-part review and that application of the I-140
policy memorandum has not resulted in a clearer adjudicatory standard.
USCIS Immigration Service Officers lack guidance that clearly demonstrates the nature
and type of evidence that typically establishes whether an individual possesses
extraordinary ability, Like an exercise of discretion, a subjective consideration of facts
does not mean the decision can be arbitrary, inconsistent or dependent upon intangible or
imagined circumstances. how to apply subjectivity without leading to arbitrary or
inconsistent adjudications.
The I-140 policy memo contains numerous examples of what does not constitute proof of
extraordinary ability. However, it does not provide adjudicators with affirmative
examples of the type of evidence that satisfies the governing law; outstanding
professor/researcher status; and, exceptional ability. Although these categories are
too broad for USCIS to produce any type of exhaustive list of examples, solid training
materials containing approvable examples, from which adjudicators could extrapolate,
would significantly improve the quality adjudications. Affirmative examples could be
developed by expanding upon the brief descriptions of the various criteria used by USCIS.
CONCLUSION
Rulemaking would provide the forum for USCIS to receive stakeholder concerns and
formally respond.
>have been enough to fulfill the intent and other retaliatory requirement.
Plaintiff argue that the defendant's knowledge from Madhuri I 140 petition with
sequence and correlation of day/time that she is working with Quitam attorney and
have been in communication with FBI ;
>denying Madhuris I 140 petition, 765 petition for work authorization and NOT
give her in any way work authorization ; stating in denial letter to leave the
country (obstruction of justice, witness tampering, violation of 8 CFR 1324b(a)(5) )
>would as a result make her unavailable and unable to pursue Quitam case, and
also
current Ninth circuit lawsuit against DHS. And also prevent her from growing her
start up in healthcare field and/or work for Harvard medical school
>have been enough to fulfill the intent and other retaliatory requirement.
On December 2015, as shown in (EXHIBIT 1), Plaintiff Madhuri went to San Fracisco
USCIS
office (which defendant didnt admit, omitted and mislead court in their answer
paragraph 87). Upon called as a witness at the trial in this case to testify, the USCIS
officer would agree that Plaintiff Madhuri showed her all immigration documents
pertaining to her EB1-extra ordinary petitions; upon reviewing those, she stated that
Madhuri is a person of extra ordinary ability. She stated that , Madhuri is eligible
under EB1- I (USCIS officer)can see that but San Francisco office does not adjuncate
petitions hence she cant adjuncate. Madhuri persuaded to expedite petition process on
extreme hardship-financial, economic loss to a person/company and distress. That USCIS
officer stated that in to me ,you look fine , and she was willing to submit expedite
request only on humanitarian basis (and not extreme hardship) and hence she submitted
that.
None the less, MESSINA vs. U.S. CITIZENSHIP AND IMMIGRATION
SERVICE[3]underscores the basic administrative law tenet, which applies to every
regulatory agency, that an adjudicator may not only look to evidence which supports the
adverse decision but rather, must consider the entire record, make specific findings, and
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reach cogent conclusions concerning all relevant claims which have a bearing on the
outcome of the decision.
The Supreme Court instructed lower courts to reject an agency decision as arbitrary and
capricious if it either failed to consider a relevant factor or relied on an impermissible
factor.
Madhuri given that the complaint alleged conspiracy based on information and belief,
and
because it did support that allegation with sufficient subsidiary factual allegations.
Predictive and personalized medicine by using genome sequencing and stem cell
research; It allows physicians and healthcare professional to use genomic information
to predict diseases a person may get, prevent such diseases all together in advance by
personalized medicine or minimize the impact of that diseases and find cure for life
threatening disease. This would be first step towards whole new era of medicines, drug
discovery and emerging medial field. Find mutations and cure diseases like cancer.
Technological advances would make it possible to manage incurable and chronic
diseases; help patients, families, physician and healthcare providers to work closely
and have access to right information at right time and make smarter decision and
provide smart care. Making Technologies feasible, available and affordable would bring
new revolution in healthcare.
Motivation and passion are keys to make differencethis give me tons of energy to
work on such projects; to combine solutions that have not been brought together.
I am never tired of working, learning new things in healthcare. I have worked nights
and weekends with a drive to do an excellent work in improving health care for
families across America and across the world
$3.1 trillion U.S. health-care industry continue to adapt to new technologies, solutions
and a way to provide quality care to more people in cost-effective manner.
Page 51 of 63
In his 2015 State of the Union address, President Obama announced that he's launching
the Precision Medicine Initiative a bold new research effort to revolutionize how we
improve health and treat disease.
Until now, most medical treatments have been designed for the average patient. As a
result of this one-size-fits-all approach, treatments can be very successful for some
patients but not for others. Precision Medicine, on the other hand, is an innovative
approach that takes into account individual differences in peoples genes, environments,
and lifestyles. It gives medical professionals the resources they need to target the
specific treatments of the illnesses we encounter, further develops our scientific and
medical research, and keeps our families healthier.
I also called white house main line in April 2015 and spoke with volunteer about
my whole situation and she said she will notify Obama administration about this. As
per her instructions, I also wrote a letter online to Whitehouse requesting that I need
assistance with a federal agency DHS. In that letter also I mentioned personalized
medicine.
These email from FBI supervisor is of probative value; to assert cause of action and
claims I raised in my complaints.
Begin forwarded message:
From: "Wible, Clayton M. (MW) (FBI)" <Clayton.Wible@ic.fbi.gov>
Date: August 25, 2015 at 6:37:26 AM PDT
To: Madhuri Trivedi <mcis99@gmail.com>
Subject: RE: Please contact US att General Loretta Lynch
Madhuri,
Sincerely,
SSA Wible
Please help me and ask her for help... Apology for bugging you.. Thanks in
advance..
Given I have tried Article I, Aticle II branches to get justice with NO SUCCESS in this
lawless environment, now it rests on Article III branch. Though I havent gone into
All Writs Act, but would like to bring jurisdiction All Writs Act provide and judge can
issue WRIT to grant relief to plaintiff as she requested. We , as Humanity have many
serious problems to work on and find solutions.
When I reported security issues at GE product and whistleblowing activity; in my B1
visa
documents in October 2013, and that denial letter which was signed by Donald Nuefled in
April 2014 (EXHIBIT 4) even though being Department of Homeland Security official ,
Mr. Nuefled ignored to at least have an special counsel assigned as per 1324b ..nor did
any investigation and told me in a letter even though he knew that I had an arbitration
hearing next weekThis clearly is a crime. Essentially, the crime is where a person,
having a public duty entrusted to him, willfully neglects to carry out that
dutyReporting to public about security issues/defects in 100,000 medical devices and at
least doing investigation; is public duty of DHS officials. Donald
Nuefleds deliberate failure to perform a duty owed to the public, with serious potential or
actual consequences for the public. During my conversation with FDA official Charles
Meyer (Plaintiff complaint EXHIBIT 12) in February 2013, Mr. Meyers did
acknowledged that GE defects I reported are not acceptable by FDA and he wants to do
public release today but there is a loophole. Untill unless FDA finishes investigation , he
cant do public release. (GE general manager Josh Hanna knew that and told me that it
will take FDA years to come after us, we have screwed up, but by the time FDA will come
after us, Madhuri-you will be gone to India) In December 2015 , FDA is proposing new
rule in federal register about public release of emerging signal of defects and issues of
medical/pharma products and services. I am glad that FDA took it seriously after
numerous communications I had with them.
If the agency fails to consider the evidence and make the proper findings on all
relevant issues, the court will oblige and make findings which may not be palatable to
the agency.
Claim of liability under the Civil Rights Act if the intentional infliction of emotional
distress TORT was committed while the defendant was depriving the plaintiff of
federal rights under color of law, including but not limited to Equal protection clause
under US constitution, where similarly situated class of people would have not told to
leave the country and as a result prevent from pursuing arbitration and False claims
Act case, Immigration visa petitions.
The causal relationship for retaliation case, causing injury; The defendant ;be officials
such as the named defendants, to whom GE has influenced for the immigration denial
decision and GE withdrew my H1 even though I was undergoing mediation/arbitration
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(and Immigration officials knew about it, despite didnt take any action EXHIBIT 11
from plaintiff complaint). The Court views this as "successful retaliatory inducement
to put Madhuri in a situation in which Madhuri is currently". The required causal
connection is therefore between the retaliatory motive of one person(GE/USCIS ) and
the action of another (USCIS).
In Dr. Kazarians own words: I have lived in America and contributed to its
astrophysics research interests for so long, I cannot consider myself as anything other
than an American scientist. Beyond the implications for my immigration status, I am
frightened for the future of this country I love so much when I see the great pains its
government is taking to ensure that brilliant scientists who offer nothing but a benefit
to America are forced to leave. If the terrible USCIS policy bearing my name is not
reversed, it will be the final nail in the coffin for American innovation and economic
progress. - See more at: http://connect.wolfsdorf.com/?p=974
Virtually every member of the immigration bar is familiar with Dr. Kazarians plight
and the Wolfsdorf Immigration Law firms successful 9th Circuit petition for panel
rehearing on his denied extraordinary ability petition.
The Buletini holding has been followed for years and was subsequently echoed in
Muni v. INS, 891 F.Supp. 440 (N.D. Ill. 1995). The Muni Court confirmed USCIS
decisions cannot rest on an impermissible basis which is against the weight of the
evidence and deviate[s] from its own policies and precedents. Sadly, USCIS Interim
Memo and Policy Memorandum have ignored the clear findings of the Buletini and
Muni Courts, which clearly articulated the appropriate method of analysis for USCIS
adjudication of extraordinary ability, outstanding professor/researcher, and
exceptional ability immigrant visa petitions. The Kazarian decision does not support
the approach outlined in the Policy Memorandum; indeed, it explicitly condemns the
implementation of new regulatory and evidentiary requirements.
Defendants have exhibit 7 of plaintiff complaint . Where plaintiff submitted with
evidences i.e. credible evidences, true analysis stating why Madhuri meets three of ten
EB1 criteria and final merit determination (Though final merit determination along
with whole adjunction of EB1 process has been widely criticized as inconsistent,
abusive, subjective in nature to adjuctive officers personal experience and discretion),
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One report indicated that adjudicators have an average of twenty-three minutes to decide
an EB-1-1 case. AILA recently noted that these cases are often complicated and require
an in-depth understanding of an applicant's field of endeavor, the applicant's
qualifications, and the complicated legal standard. [87] Numerous commentators have
called for adjudicators to visit research facilities and national laboratories, as occurred
during the limited collaboration between the California Service Center, the California
Institute of Technology, and NAFSA (an association of international educators). USCISs
resource constraints make this prospect unlikely. An officer with a liberal arts degree and
twenty-three minutes to review a petition simply does not have time to familiarize
himself with a highly specialized field. the [USCIS] has effectively established itself as
an expert in areas where its expertise is most assuredly lacking.
An abuse of discretion is a failure to take into proper consideration the facts and law
relating to a particular matter. Positive use of discretion would have resolved this
disputes....If Obama admin is trying to keep illegals here.try to send me back and
remove me from USA is also abuse of discretion by DHS. It also shows how desperately
DHS people want to harass me under GEs influence. (JUST so to set up an
example/send a message for all current /future GE employee that if you speak up as a
whistleblower /fraud/security/qualityyou will be put in a situation like Madhuri and
also clearly sending a message that not a single government body will be on a side of
JUSTICE ; rather on corporate GE side.)
Joint case management statement ECF 20, page 22 line 5: while the defendant was
depriving the plaintiff of federal rights under color of law, including but not limited to
Equal protection clause under US constitution, where similarly situated class of people
would have not told to leave the country and as a result prevent from pursuing
arbitration and False claims Act case, Immigration visa petitions. The Fifth
Amendments Equal Protection Clause directs that all persons similarly situated should
be treated alike
Plaintiff did mention punitive damages in her complaint pleadings. And that was for
individual capacity based claims.
2) Court generally allows amendment; while this is also clarification and to resolve
ambiguity. Supreme court of United States in Foman v. Davis 371 U.S. 178 (1962) Rule
15(a) declares that leave to amend "shall be freely given when justice so requires"; this
mandate is to be heeded. See generally, 3 Moore, Federal Practice (2d ed. 1948), 15.08,
15.10. If the underlying facts or circumstances relied upon by a plaintiff may be a proper
subject of relief, he ought to be afforded an opportunity to test his claim on the merits. In
the absence of any apparent or declared reason -- such as undue delay, bad faith or
dilatory motive on the part of the movant, repeated failure to cure deficiencies by
amendments previously allowed, undue prejudice to the opposing party by virtue of
allowance of the amendment, futility of amendment, etc. -- the leave sought should, as the
rules require, be "freely given."
Defendants could not demonstrate bad faith or dilatory motive on Plaintiffs part. To the
contrary, Plaintiffs seek to amend /clarify these claims to more thoroughly frame the
relevant constitutional issues before this Court.
Defendants will not be prejudiced by Plaintiffs amended complaint. The liberal concepts
of notice pleading is to make the defendant aware of the facts. Harrison, 174 F.3d at 253
(emphasis added) (quoting Hanson v. Hoffman, 628 F.2d 42, 53 (D.C. Cir. 1980)).
Accordingly, a plaintiff is not bound by the legal theories originally alleged unless a
defendant is prejudiced on the merits.
3) Thus adding/clarifying Bivens claim does not substantially change the legal theory at
this early stage of litigation.
4) The court must construe the complaint in favor of the plaintiff and grant plaintiff the
benefit
of all inferences derived from the facts. Schuler v. United States, 617 F.2d 605, 608 (D.C.
Cir. 1979).
5) 28 U.S.S. 1391(b) Biven venue personal injury actions.. 5th Amendment Equal
Protection Clause: and due process cause to have a hearing.
Providing a remedy under Bivens: Serves to deter future constitutional violations by
holding federal officers accountable for unlawful actions
Claim for damages arises directly under Constitution without explicit statutory cause of
action (implied constitutional cause of action)
Money damages for constitutional tort committed by defendant acting under color of
federal law/authority
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Federal officer acting under color of federal law/authority violated that right;
6) Below email is from attorney David Nelson at from Boies, Schiller & Flexner LLP.
David looked in to my voluminous GE documents and stated that Madhuri has SEC
security Exchange commission claim . Because of my immigration situation (partly
due to GEs Godzilla influence )that SEC right also hasnt been exercised.
From: David Nelson <dnelson@bsfllp.com>
Date: Mon, Jun 23, 2014 at 9:21 AM
Subject: RE: should I send my deposition ?
To: Madhuri Trivedi <mcis99@gmail.com>
Cc: Aaron Marcus <amarcus@bsfllp.com>
Madhuri, today is hectic and I have some meetings tomorrow. Is Wednesday possible for
you at some point? Dave
David Nelson
BOIES, SCHILLER & FLEXNER LLP
401 East Las Olas Blvd. Suite 1200
Fort Lauderdale, FL 33301
(Ph) 954.356.0011
(Direct) 954.377.4233
(Cell) 954.213.8810
7) Biven claims against individually named defendants. Under fifth and fourteen
amendments of constitution . Right to have a hearing. Donald Neufeld (defendant
)signed a denial letter in April 2013 (Exhibit 4 of ECF 4 Plaintiff Joint case
management statement) knowingly a week before my arbitration hearing and
threatened that Madhuri Must leave the country immediately. Madhuri had a Due
process constitutional right to have administrative hearing and court proceeding for
her immigration matter in immigration content along with exercising 8CFR 1324 b
unfair employment practice . Donald prevented Madhuri from exercising such
constitutional rights .
The Requirements of Due Process.Although due process tolerates variances in
procedure "appropriate to the nature of the case," it is nonetheless possible to identify
its core goals and requirements. First, "[p]rocedural due process rules are meant to
protect persons not from the deprivation, but from the mistaken or unjustified
deprivation of life, liberty, or property." Thus, the required elements of due process are
those that "minimize substantively unfair or mistaken deprivations" by enabling
persons to contest the basis upon which a State proposes to deprive them of protected
interests. The core of these requirements is notice and a hearing before an impartial
tribunal. Due process may also require an opportunity for confrontation and cross-
examination, and for discovery; that a decision be made based on the record,
Defendants have admitted in all of their court fillings that Madhuri s right related to her
ex employer GE for HIPPA violations, Patient safety act, civil rights , 8CFR 1324b , False
claims act. Despite Have knowingly and intentionally deprived Madhuri from exercising
those rights.
hearing , equal protection right clause under constitution ) Constitution also prohibits
retaliation to whistleblower (including but not limited to for both False claims act and
8CFR 1324b)when whistleblower reports disparate treatment under gender,
nationality, race , discrimination again in Immigration context.
If USCIS since May 2015 is giving unrestricted work authorization to spouses of H1B
visa whose green card is pending (total up to 80,000 work authorization to be given in
first year only); NOT giving Madhuri immigration work authorization violated Equal
protection clause , also Madhuri is NOT Married so she has been treated differently .
2.1. Though this applies to government employees under WPA ..using this common law
product Insite Exc was dangerous and illegal I put my own job and immigration
in line NOT realisign then that I will end up dealing with 500 pounds of corrupt/Lawless
government and GE. Madhuri talked to supervisor , team lead , executives at GE..but
since they were knowingly releasing it for several years ..they retaliated Later I
reported to FBI, DHS ,talked to FBI agents
Investigation found that was a measurement error. We can now see our performance is
gradually getting worse as new devices are added, which matches the reports we are
getting from users.
***************
****** ******
=************************
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EXHIBIT 3
August 9, 2013
GE Health Services
3114 Nmih Grandview Blvd.
Waukesha, WI 53188
I represent Ms. Madhuri Trivedi regarding the above-captioned matter. Ms. Trivedi has been an
outstanding employee in the GST division since November 2011, and was unfairly terminated in
June 2013. Despite getting consistent high marks for her work product and expertise, and
despite the fact that many of her reviews have praised her work, she was terminated based on one
or two managers deciding that they did not want to work with her.
Permit me to get right to the point: what Ms. Trivedi wants is her job back with GE, and to be
moved to a different division. Despite the fact that I think Ms. Trivedi should pursue several
claims against GE for unfair termination of employment and being forced to work in a hostile
environment, she wants to put this behind her, waive all rights regarding the unfair termination in
exchange for GE giving her a similar job in a different division, plus immediate continuation of
the green card process which was abruptly stopped when she was terminated.
Here is a brief summary of the issues that I think Ms. Trivedi would be able to successfully make
both in the comiroom and the media if this case is not immediately settled:
Orange Health
Simple ways to take control of your health
OrangeHealth
a peer to peer platform-usable & secure for
health management & engagement; DRIVEN
By artificial intelligence.
(phase 1) interested in healthy living, manage chronic condition.
The company aims to provide support, advise, expertise through
peer to peer interactions; users can be anonymous.
By driving accountability, purpose and context through
communities and measurement/analytics though fitness/health data
integrated(phase 2).
Prevention is better than cure by managing chronic condition such
as a hyper tension future stroke and disability can be prevented. US
cost saving $200B global double US number.
chronic disease is the leading cause of death and disability
Confidential 2
worldwide.
Confidential 1
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Market Need
While working as lead engineer, I build Chronic condition
management portal in rapid app development. We were team of
two. Blue cross blue shield, Molina, Emblem were delighted when
product was demo and it generated multi million revenue in first
year.
Peer to peer engagement is a holy grail for consumerization of
HC. Patients now turn to other patients online for health
information and advice in a phenomenon known as peer-to-peer
healthcare.
The mHealth market is poised to grow to $41 billion by 2020 and
experts credit the expected growth to chronic disease
management .
As per World Health Organization, China, India ,USA are among the top
three countries with a high number of diabetic.
Confidential 4
Confidential 2
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Team
Madhuri Trivedi Founder, CEO MS PGDBA
Extensive experience in product & software development in multiple industries-
healthcare industry, health insurance, medical device integration, Life science,
Security; working in Fortune 50 corporations as well as start-up, entrepreneur
companies. Lead software engineer for General Electric, Senior Engineer
MedAssurant, Software engineer for United Technologies,
MIT Sloan school of management
MS computer information science Cleveland state university
Medical director Dr. Jody Ellen , MD, MBA finance
Board Member
Pat Hale MIT Sloan school of management
Advisors
Robert F Hogan Founder, CTO Softshadow Security
Confidential 5
Product Roadmap
Phase 1 User Portal -mobile app
login for people interested :Target areas :in healthcare/wellness
for i.e. healthy living , Chronic conditions .Ability to be
anonymous user.
Based on the profile they create regarding their interest(s).
Community and peer to peer interaction that fosters accountability;
leading people to stick to their self management goals for healthy
living, condition management.
Leverage Power of tribe- Most people have tribe/group but are
not engaged with purpose.
Bridge the gap between data from tracking device and social
alone..
Provide context and purpose ; drive accountability
Tribe level- group goals, measurement, incentives-celebration
and rewards. Built trust and support network.
Confidential 6
Confidential 3
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Product features
Coupons and
membership
Anonymous login Join Tribe Set End results discounts
Deep Machine
Set actions plan Measure Learning Support
Analytics
Refer to health
resources Find fittest
Celebrate
website, material member in tribe
Seek advise/ask
questions Community
Chat bot discussions
Confidential 7
Product features
Watch risks/factors
Manage
Junk food high
sugar, insulin
resistance
Hypertension
unhealthy diet
tobacco use
etc
Confidential 8
Confidential 4
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Architecture
Cloud
Mobile App Json Web service Backend
Hybrid
Cassandra
Analytics
Confidential 9
10
Confidential 5
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11
12
Confidential 6
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Product Roadmap
Milestone 1-250k or less six months
functioning app People can share, support each other with
such/similar condition/interest, volunteer to provide
support/service/share their experience and expertise, seek
information.
Free login (to create market and engage customers)
in future Offer advanced service features with premium login
Sales & marketing /business
Integration and partnership with
Health plans and services
o Private/public health insurance companies and plans/hospitals.
o Physician and specialist network
Get their input and feedback at early stage i.e. pilot customers to
drive requirements.
o They also want to have social voice.
Confidential 13
Competition
Market currently is fragmented. People use website(s)/app for few
features here and there.
There is need for people to stay connected and stay informed; get
support , share, seek advise.
Need to get common, simple theme based product(s).
Currently Viverae offers service staying motivated and other
wellness. But it is like facebook group, not much offerings and
features are not that appealing, usability & design needs work. Not
much activities in public app. Seems passive. App has limited
features in public level app.
Confidential 14
Confidential 7
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Funding
Confidential 15
Pricing
Pricing
Confidential 16
Confidential 8
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Pricing
ROI 14%
Confidential 17
Confidential 9
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EXHIBIT 5
This letter is regarding employment of Madhuri Trivedi at Wyss Institute, Harvard University.
Madhuri will be eligible for a full time job that may be an existing or new position. Her job
title/job role would be Lead Software Engineer or the equivalent in a software engineering
role/capacity Her responsibilities may include the development of publicly available software for
calculating the 3D and functional sites of protein interactions and complexes from genomic
information. Madhuri would be expected to oversee version control of code development, turn
research code into pipelines for use by internal researchers as well as collaborators, and
develop publicly available software in the research area of identifying evolutionary constraints
from sequences; will also work with the researchers as the project manager for collaborations
with other faculty on structure determination of membrane proteins and complexes. This
position is Salary Grade 057 has a range of starting salary of $60,200 to $102,200. Our
software development group is located at the Center for Life Science Boston Bldg., 5th Floor, 3
Blackfan Circle, Boston, MA 02115.
The Wyss Institute is a rapidly growing organization with many R&D projects that require
programing and related skills. Madhuris experience qualifies her for the following duties and
she will be performing such duties when hired (it may vary based on the project she is working
on):
Lead software design and development /product development for products and systems. Work
on full product development life cycle of requirement gathering, requirement analysis, high level
design, development, testing. Interact with teams to promote consistency and maximize
synergies across software platforms. Work with interdisciplinary teams including robotics,
manufacturing, and instrumentation. Collect and document feedback, and identify necessary
metrics to measure and optimize various system parameters against functional requirements.
Documentation, human interface design, contribute in the preparation of demonstration
prototypes, internal reports, patent applications and presentations.
The mission of the Wyss Institute for Biologically Inspired Engineering at Harvard University is
to transform human healthcare and the environment by emulating the way nature builds.
Developed as an alliance between Harvard and other premier academic and clinical partner
institutions, Institute faculty and staff collaborate in high-risk, fundamental research and science-
driven technology development. A major focus of the Institute is to translate the technologies
developed by its faculty and staff into commercial products and therapies through collaborations
with clinical investigators and establishment of corporate alliances.
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I strongly urge that Madhuri Trivedi be granted this petition as soon as possible.
Sincerely,
Robert Cunningham
Tel: 617-432-1761
Cell: 617-750-1889
robert.cunningham@wyss.harvard.edu
www.wyss.harvard.edu
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EXHIBIT 6
She has solid academic experience and a strong track record in her industrial career. She has shown
tenacity, zealousness and business acumen. Madhuri possesses diverse experience, skills combination
that makes her a unique technical asset.
She has progressively grown in her career, have taken more progressive responsibilities. She is effective
at dealing with business /engineering problems and she has shown leadership ability to overcome such
tough problems and deliver results/solutions and values.
She is a dedicated, self-starter software engineer with experience working in multiple industries;
combined in software development and engineering area in designing, developing products and services
in cross functional environment; along with excellent problem solving, business acumen and
organizational skills.
She has participated and contributed in leading capacity in high-risk projects that lead to
transformative breakthroughs, innovation, commercialization/application of new technologies to
deliver significant values to stake holders, customers and users, generate significant revenues.
Projects were in the areas of providing healthcare service and improving access at affordable cost to
large patient populations, up-time, serving and availability of medical devices, security of commercial,
industrial establishment and enterprise security, wireless remote monitoring solutions for energy
transformers, jet engines, water systems, dashboards for locomotive (rail engine) service/repair data.
As the Vice President of Business Development at Raindance Technologies Inc., I saw Madhuri
make significant /original contributions at the intersection of computer science, healthcare,
biology, chemistry, mechanical engineering, electrical engineering, and product development.
At Raindance, Madhuris interaction involved working with Vice president of Engineering, Marketing
executive, Product manager, scientists.
She imbibes and demonstrated Expertise with advanced technology ; unique multi-disciplinary
combination of skills/background.
She played a critical role /leading role in the genome selection system instrumentation product
development. At Raindance, this product enabled the translation of cutting edge micro droplet
based sequencing nano technology into commercialization/commercial product. Madhuris work
also involved using latest and emerging Microsoft technologies/platforms, integration, writing end to end
software requirements/specification and end to end product validation. Raindance was a start up with 20
plus people when she joined. Software team consisted 2-3 engineers. Developing genome sequencing
product; a complex system from scratch whose sales price was $150,000; this is implied that she was on
a leading and critical role as in a small start-ups contribution matters NOT title. Her contribution was
original and of major significance. Madhuris contribution /role was critical/leading in order for product
delivery and product development; hence success and existence of Raindance as a company. SW
engineers are responsible for whole software and hence product development.
She has worked in a leading role in designing and developing chronic care solutions portal using service
oriented architecture; latest Microsoft technologies. This chronic care portal generated very large amount
of revenue for company and was used for serving patients by leading health insurance companies in US.
As described by the Centers for Disease Control, chronic disease is the leading cause of death and
disability in the United States. It accounts for 70% of all deaths in the U.S., which is 1.7 million each year.
Data from the World Health Organization show that chronic disease is also the major cause of premature
death around the world even in places where infectious disease are rampant.
(http://cmcd.sph.umich.edu/what-is-chronic-disease.html ). Developing products, solutions and
services so more people can have access to care, family to manage disease and bring down healthcare
costs.
Madhuri Trivedi Alien #A206599531 Recommendation letter Robert Cunningham Page 2 of 3
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Madhuri intends to continue to contribute in innovative work projects. She has consistently delivered
results that generated millions of revenue and delivered values to stake holders.
Madhuris extensive experience and world class expertise in healthcare, health informatics, medical
devices, healthcare IT, remote service, security products and services makes her highly valuable
engineer. The variety of her experience sets her apart from many of her professional peers.
At Wyss Institute, she is qualified to play an essential role of leading software design and development
/product development for products and systems for healthcare and medical systems that include full
product development life cycle of requirement gathering, requirement analysis, high level design,
development, testing. Working with interdisciplinary teams including robotics, manufacturing, and
instrumentation she is able to collect and document feedback, and identify necessary metrics to measure
and optimize various system parameters against functional requirements. Her expertise in inter-
disciplinary area, development of healthcare systems and her extra-ordinary expertise make her valuable
to a multidisciplinary organization like the Wyss Institute at Harvard University.
She has extensive experience working in start-up, entrepreneur companies as well as mid to large
corporations in important and growing technology areas in the US such as bioinformatics, genomics, and
genomics instruments, and personalized medicine development. Allowing Madhuri to continue work in US
and in these fields would contribute to improving US healthcare systems and reducing healthcare costs.
Approving of this petition would allow her to continue work in leading engineering role in this area.
I strongly recommend Madhuri Trivedi, for her petition for a person of extra-ordinary ability,
and I suggest that Madhuri Trivedi be granted this petition of person of extra ordinary ability as soon as
possible.
Sincerely,
Robert Cunningham
USCIS
Madhuri is a highly regarded engineer, with outstanding ability, in the field of computer
science, at the cross section of Healthcare, Genomics, Instrumentation and Computer
Security as reflected in her collaboration with industry leaders and subject matter experts
including Nobel laureates.
Madhuri Trivedi, a citizen of India, received her Bachelors in Electronics and
Communications engineering with Distinction. In the state of Gujarat, India, approximately
50,000 candidates compete for a few hundred admissions and Madhuri was one of them.
Ms. Trivedi graduated with distinction and received funding from the government for her
education. She has continued to add to her academic laurels with Post Graduate Diploma in
Business Administration in First Class from Sardar Patel University India and an
advanced degree in computer information science - GPA 3.73.from Cleveland State
University, Ohio. Her educational achievement is remarkable considering that even in the
United States participation of women in STEM (Science Technology, Engineering and
mathematics) lags in student enrollment as well as in the workforce.
She was further sponsored by her employer United Technologies for executive level
education for preparing Technocrats at Massachusetts Institute of Technology in the field of
systems design and management; United Technologies, a multinational conglomerate and a
government contractor, handpicked few extra ordinary candidates every year out of
thousands of employees worldwide for this fully funded program. At MIT Madhuri
stood out with a GPA 4.0. Thus, Madhuri stands out with her strong, multidisciplinary
academic background;
I have been an adviser to Ms. Trivedi on her start up Orange Health. Ms. Trivedi is
developing a mobile app for chronic disease self-management that is a peer to peer, peer to
expert platform. Chronic diseases such as cardio vascular disease, diabetes, hyper tension,
high cholesterol and pain are not entirely curable but by managing chronic condition, future
stroke and disability, vision loss and limb amputation etc. can be prevented. Chronic
disease is the leading cause of death and disability worldwide, and also a huge economic
cost to governments, tax payers and individuals. Ms. Trivedis mobile app aims to address
these problems and provide solutions.
As a chronic pain sufferer myself, I know how valuable an app where I can use self-
management, crowd sourced mobile platform and exchange with communities would be
immensely valuable. In the United States, there are 116 million chronic pain sufferers; it is
undertreated and the annual cost of chronic pain is as high as $635 billion a year, which is
more than the yearly costs for cancer, heart disease, and diabetes, say health economists
from Johns Hopkins University. (
http://www.apta.org/PTinMotion/NewsNow/?blogid=10737418615&id=10737427933 ) .
Today there is only one physician for every 25,000 patients who is a specialist.
Crowd community sourced self-management tool such as Ms. Trivedi is developing
fill a critical need where there is a gap between patient care and patient needs. In
absence of expert/specialist doctor for chronic pain management; primary care
physicians provide mainly prescription based pain relief. Wide use of pain killers
has created its own problem of addiction to pain killers like Morphine and
OxyContin and associated social and economic cost of these medicines. See New
Yorker story.
http://www.newyorker.com/magazine/2014/05/05/prescription-for-disaster
Crowd sourced self-management apps like Ms. Trivedis startup have been shown to bring a
significant improvement in patient self-care; increasing wellbeing and even some return to
productive work life, in many other disciplines. I live in near Stanford University with a
leading Pain Care Clinic that provides me such self-management tools and interventions. It
is a pity that such care is is not available to population at large in Th United States except
where research hospitals are located. Ms. Trivedis start up intends to solve this BIG
problem.
I have spent several hours in technical and professional assessment of Ms. Trivedi. She is a
full stack developer, a skill rare and necessary for a successful startup where initial product
has to be built by the founder herself without any outside help and the founder must be able
to design and code everything from the user experience on the mobile phone to the server
backend where user management, knowledge management, analytics and privacy and
security is implemented. An article explaining the distinct and outstanding value in an
engineer being full stack in the early days of a startup is enclosed below.
http://www.laurencegellert.com/2012/08/what-is-a-full-stack-developer/
Ms. Trivedi is amply qualified both academically and professionally to build such products.
She has worked on medical equipments technology at top medical equipment company GE
Healthcare where she enabled medical machines to be serviced remotely thus increasing
availability of equipment (I have no exact figure, it could be 7%)for patient services.
Similarly, she has worked at another top technology company in defense, medical,
aerospace, security fields. One of the key indicators of Madhuris extraordinary
contributions in the field of computer science/product development is her work for United
Technologies, a Fortune 50 Company and an organization of distinguished reputation At
UTC- global security group; she led and developed a cutting edge wireless security system
in 2007. This product is now finding use in Internet of Things/home automation. But in
2007 streaming live video from embedded panel to mobile phone was highly
advanced in terms of computer science. Madhuri owned this streaming video on
mobile and successfully developed this unique technology. Madhuri also developed a
Remote Service Application to access, monitor and communicate with remote devices that
solution that enabled UTC to save more than $1 million per year in service costs and tens of
millions since it was deployed; in service operations and provide enhanced value to their
customers.
Her remarkable career has continued with her employment with the startup Raindance in
2008,
Founded by Harvard scientists and Nobel laureates such as Jean-Marie
Lehn (Chemistry, 1987), Sir Aaron Klug (Chemistry, 2002), and Dr. Richard
Roberts (Physiology or Medicine, 1993) as well as Sir Gregory Winter.
At another leading cybersecurity company BeyondTrust that was acquired by Symark for
$20 million and eventually by Veritas Capital, Madhuri lead development of automation test
framework which even impressed company customers and partners.At Medassurant, (
health informatics company;to support the assessment and coordination of care among members
who have complex needs associated with diabetes, heart disease, asthma, coronary artery disease
(CAD), or chronic obstructive pulmonary disease (COPD) ; solution called CCSAdvantage), she
worked in a leading role in designing and developing chronic care solutions portal thin
client/ web based portal using service oriented architecture. This chronic care portal
generated large amount of revenue for the company and was used for serving patients by
leading health insurance companies in the US, such as Emblem Health, Blue Cross Blue
Shield and Molina Healthcare. As described by the Centers for Disease Control, chronic
disease is the leading cause of death and disability in the United States. It accounts for 70%
of all deaths in the U.S., which is 1.7 million each year. Data from the World Health
Organization shows that chronic disease is also the major cause of premature death around
the world even in places where infectious disease are rampant.
(http://cmcd.sph.umich.edu/what-is-chronic-disease.html ). Thus, her contribution to
developing products, solutions and services so more people can have access to care, to
manage disease and bring down healthcare costs is not only in human interest but also in
national economic interest. She also has experience in designing of Electronic Medical
Records a key cornerstone of the new Healthcare legislation for the State of Indiana-
Department of Disability and Rehabilitation.
She imbibes and has demonstrated Expertise with advanced technology; unique multi-
disciplinary combination of skills/background.
and applications for medical devices and applications, security related to medical
devices
software and engineering practices, Failure Mode Effect analysis(FMEA),Change
acceleration process (CAP) model, Agile Scrum master , agile methodologies, US
regulatory and compliance requirements such as HIPPA, HITECH, and FDA related.
Customer services such as providing support to internal lab scientists (biologist,
chemists) for bio-tech instruments and applications., Customer service to internal
users such as field engineers and online engineers who install and service medical
devices.
Projects were in the areas of providing healthcare service and improving access at
affordable cost to large patient populations, up-time, serving and availability of
medical devices, security of commercial, industrial establishment and enterprise
security,
I have reviewed her qualification and I have written this letter based on my experience,
analysis and expertise as an independent reviewer.
In view of the forgoing record, Madhuri has proved to be an alien of extraordinary ability in
the field her field of endeavor, with a level of knowledge and skill that is possessed by very
few individuals. Madhuri has continuously distinguished herself for her contribution in
developing innovative products/services. This is evidenced by her employment record.
Madhuris exceptional engineering/scientific capabilities are obvious. She has made
outstanding contributions to the field of computer science /Information science, healthcare
informatics, computer security and medical technology.
Based on this stellar record, her future potential to deliver similar product breakthroughs to
contribute to healthcare patient management and cost reduction, I strongly recommend her
for extra ordinary ability in various fields of national economic importance to the United
States.
Sincerely,
EXHIBIT 8
From: Pat Hale
Date: Wednesday, January 20, 2016 at 1:38 PM
To: <NCSC@uscis.dhs.gov>, <mark.hazuda@uscis.dhs.gov>,
<thomas.pearl@uscis.dhs.gov>, <Donald.W.Neufeld@uscis.dhs.gov>,
<leon.rodriguez@uscis.dhs.gov>, <jeh.johnson@dhs.gov>
Subject: Fwd: USCIS NSC (JJP 59811) RE: USCIS NSC (JJP 59810) RE: USCIS NSC
(JJP 59786) RE: (JJP 59767) RE: Your recent inquiry (receipt #LINXXXXX50295)
I am confident, based on experience with Miss Trivedi, that she will make
a fine employee for her company and an enthusiastic and loyal US
Citizen. Her skills and background make her a solid candidate, and her
motivation is unmatched.
Receipt number:
LIN1602250295
__________________________
Pat Hale
Executive
Director, SDM Fellows Program
Senior Lecturer, Engineering Systems Division
Massachusetts Institute of Technology
EXHIBIT 79
I 140 :I have provided Documentation under following regulatory areas:
RDT 1000 is used for DNA sequencing. It requires less DNA sample, has fast
turnaround, Comprehensive genomic coverage, increased accuracy, simple workflow.
It is used by scientists and researchers at pharmaceutical companies, educational
research and research institutes for Genome-Wide Association Studies, medical
genetics, cancer research, somatic mutation analysis, epigenetics.
7. Corroborating Support letter from Philips Healthcare product manager Hans Griesser for
Immigration petition,
5. I worked at BeyondTrust and my big boss Eric Voskuil was a REAL Top Gun Fighter
pilot. He is a legend, technology genius. Likes attracts like. I was at his company
because of having extra ordinary abilities like him.
10.3. Raindance scientific advisory board including three Nobel Prize winners:
Jean-Marie Lehn (Chemistry, 1987),
Sir Aaron Klug (Chemistry, 2002), and
Dr. Richard Roberts (Physiology or Medicine, 1993) as well as
Sir Gregory Winter joint head of the British Division of Protein and Nucleic Acids
Chemistry at the Medical Research Council's Laboratory of Molecular Biology in
Cambridge.
11. Leading role performance at Organization of having a distinguished reputation : Lead
Engineer at GE Fortune 10 company
12. Leading role performance at Organization of having a distinguished reputation :
BeyondTrust was acquired by Symark software in September 2009 for a little over $
20 million.
13. Genome Sequencing instrument RDT 1000 product Madhuri developed from scratch in a
year. This product was sold at $150,000 per unit. It was companys first commercial product.
This product generated significant revenues and company first raised $6 million funding in
2009. Since 2009 to till date has raised more than $100 million. My role was critical, and
of significant importance to the outcome organizations activities/existence.
14. Articulation: Leading capacity title was Lead software engineer, senior software engineer,
software engineer. Software is very critical for any product development. And software
engineers are responsible for whole software and hence product development. Thats why
Madhuri Trivedi Analysis Index document Exhibit 7 Page 3 of 9
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software engineers are very well sought and in demand. I have worked with Chief
Technology officers, CEOs, VP engineering, Marketing executives; because as software
engineer TITLE itself brings technical responsibilities and leadership. A Small startup like
Raindance; where WHOLE company size is 30 people. There are not many layers,
hierarchy and hence software engineer TITLE /role itself was leading in terms of
contribution. Lead TECHNICAL aspect product development and not managing people.
nd
14.1. At Raindance, I was 2 software engineer when I joined. Later we were a small team of
TOTAL 2-3.5 software engineers. As in press release ..Jun 2, 2008..
Raindance employs about 35 workers : Link for press release (
http://www.bizjournals.com/boston/blog/mass-high-tech/2008/06/kelly-taps-out-coo-role-
at-raindance.html )
14.2. Critical means for these projects Madhuris role, responsibility is critical in order for
product delivery and product development.
18. Worked in a leading role at MedAssurant company in designing and developing chronic
care solutions portal thin client/ web based portal using service oriented architecture; latest
Microsoft technologies. This chronic care portal generated large amount of revenue for
company and was used for serving patients by leading health insurance companies in
US; such as Emblem Health, Blue Cross Blue Shield, Molina Healthcare.
20. Mark sheets for MIT, Cleveland state university for Masters in computer science, Indian
degrees.
21. Deposition of GE architect Bill Barbiuax taken by me ,
Madhuri Trivedi Analysis Index document Exhibit 7 Page 4 of 9
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Comparable evidence
a) Commercial success in such as commercialization of technologies, generation of
multimillion revenues, working/delivering results on high risk projects.
1. Resume,
2. personal statements,
3. Harvard Medical school executive Robert Cunninghams support letter and his employment
offer,
4. Support letter from Philips Healthcare product manager Hans Griesser for Immigration
petition,
5. Immigration support letter by Co-founder Vandana Upadhyay
6. Orange Health business document,
7. I worked at BeyondTrust and my big boss Eric Voskuil was a REAL Top Gun Fighter
pilot. He is a legend, technology genius. Likes attracts like. I was at his company
because of having extra ordinary abilities like him.
8. At Raindance ; in leading role /orginal major significance contribution ----designed and
developed instrument that was the Professional Laboratory System to be the chemical
equivalent of a personal computer.
This instrument development required unique, multi-disciplinary skills, and
entrepreneurship. It also lead to wide range commercialization of nano technology,
raised hundreds of millions in funding and went to IPO; public company from a
garage.
9. Genome Sequencing instrument RDT 1000 product Madhuri developed from scratch in a
year. This product was sold at $150,000 per unit. It was companys first commercial
product. This product generated significant revenues and company first raised $6
million funding in 2009. Since 2009 to till date has raised more than $100 million. My
role was critical, and of significant importance to the outcome organizations
activities/existence.
10. Worked in a leading role at MedAssurant company in designing and developing chronic
care solutions portal thin client/ web based portal using service oriented architecture; latest
Microsoft technologies. This chronic care portal generated large amount of revenue for
company and was used for serving patients by leading health insurance companies in
US; such as Emblem Health, Blue Cross Blue Shield, Molina Healthcare.
16. Mark sheets for MIT, Cleveland state university for Masters in computer science, Indian
degrees
Masters in computer information science- GPA 3.73 - Cleveland State University, Ohio
Graduate certificate in systems engineering/systems design and management from
Massachusetts institute of technology, GPA 4.0(I have not completed this course yet).
Bachelors in Electronics and communications engineering with Distinction-India,
Post graduate diploma in business administration with First class India,
17.2. I have business acumen and organizational skills. Have advanced expertise in
multiple advanced technologies including but not limited to:
full software development life cycle, usability, integration, service oriented architecture
(SOA) including Microsoft based SOA technologies, user interface design, robotics
interface development, lean six sigma, various product development methodologies,
instrumentation development, systems architecture, product development,
security products and services, remote service application for security devices such as
DVRs, security cameras, fire panels ,
remote service technologies and applications for medical devices and applications,
security related to medical devices,
software and engineering practices
Failure Mode Effect analysis(FMEA)
Change acceleration process (CAP) model certification
Agile Scrum master certification , agile methodologies
US regulatory and compliance requirements such as HIPPA, HITECH, and FDA related.
Customer services such as providing support to internal lab scientists (biologist,
chemists) for bio-tech instruments and applications.
Customer service to internal users such as field engineers and online engineers who
install and service medical devices.
Projects were in the areas of providing healthcare service and improving access at affordable
cost to large patient populations, up-time, serving and availability of medical devices, security
of commercial, industrial establishment and enterprise security,
At GE, Wireless remote monitoring solution for energy transformers, jet engines, water
systems, dashboards for locomotive(rail engine) service/repair data.(Exhibit 7)
CERTIFICATION OF COPIES
I have submitted Copies of actual web based screen prints, documents, exhibits, emails,
images, screen prints. These are exact photocopies of unaltered original documents and are
original.
Signature
__________________________________
Name: Madhuri Trivedi
Note:
In the analysis documents have referred to screen shots, images, documents, emails. For
examples, products I developed, technology commercialized.. These are actual web based
screen prints, images, documents and emails; I am submitting. These information didnt exist
not could be obtained unless I would have worked on it/developed it myself; my work
EXHIBIT 10
Date: 7/25/2015
Apart from information in this document, please refer to my Analysis Index document (7 pages
total) , resume, supplement letter, Orange Health business document,
immigration support letters; for overall case analysis.
I write this letter as personnel statement for my immigration petition EB1 A person of extra-ordinary
ability.
I had a humble, modest and nice upbringing in India. Both of my parents worked in academia. My parents
and grandparents instilled values such as hard working, honesty, being modest, humble and being best
and excellent at anything I do; and become a good human being.
I have had grown progressively in my career. I have risen to the very top of the field and have consistently
contributed and have continuously improved myself; have played leading/critical role(s) for organizations
having a distinguished reputation and contributed significantly with extra-ordinary ability. Such activities
require special and unique combination of skills and expertise.
I have participated and contributed in leading capacity in high-risk projects that lead to transformative
breakthroughs, innovation, commercialization/application of new technologies to deliver significant values
to stake holders, customers and users, generate significant revenues.
Pursuing broad field of knowledge and experience carries special appeal; it is lots of fun because there
are always new challenges and ample stimulation, opportunities to learn and improve; contribute and gain
valuable experience. While growing up in India, it gave me real life view of need for healthcare products
and services.
Contributed and participated in leading capacity, have consistently Built products and services/
delivered results that generated multi millions of revenues;
Commercialization of new technologies/products, deliver values to stake holders, customers and users,
allowed new industry partnerships, was original and of major significant, critical to outcome of
organization (s) I worked for...
Chief Technology Officer, CEO, founder of OraneHealth and Lead engineer with 9 years experience in
managing complex software design projects, architecting and developing products and services in cross
functional environment; Hands-on design and development expertise in various technologies, full
software development life cycle.program management, agile methodologies, Excellent problem solving,
communication skill, and organizational skills & systems architecture skills combined with business
background, unique combination of talent, expertise, skills,Systems Engineering, Collaborate and co-
ordinate with cross functional team/management at various levels to build products/software architectures
that deliver business solutions.
I have blend of technology and business- makes me a technocrat; gives me depth and breadth in
my area of endeavor; I have ability to connect dots. Several distinguished experts/executives
consider my work, profile important.
Sets me apart in my field from others as one of the small percent who have risen to the very top of
the field.
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Note: I have used larger fonts to separate header in this letter. Articulations start with word
Articulation: . Have used green underline or pink underline.
I want to continue work in genomics/personalized medicine/bioinformatics and follow my passion for it.
Predictive and personalized medicine by using genome sequencing and stem cell research; It
allows physicians and healthcare professional to use genomic information to predict diseases a person
may get, prevent such diseases all together in advance by personalized medicine or minimize the impact
of that diseases and find cure for life threatening disease. This would be first step towards whole new era
of medicines, drug discovery and emerging medial field. Find mutations and cure diseases like cancer.
Technological advances would make it possible to manage incurable and chronic diseases; help patients,
families, physician and healthcare providers to work closely and have access to right information at right
time and make smarter decision and provide smart care. Making Technologies feasible, available and
affordable would bring new revolution in healthcare.
Motivation and passion are keys to make differencethis give me tons of energy to work on such
projects; to combine solutions that have not been brought together.
I am never tired of working, learning new things in healthcare. I have worked nights and weekends with a
drive to do an excellent work in improving health care for families across America and across the world
$3.1 trillion U.S. health-care industry continue to adapt to new technologies, solutions and a way to
provide quality care to more people in cost-effective manner.
US is a pretty great place to be. - For entrepreneurship/new ideas and new opportunities. I would
bring my background in technology, economics and management to the healthcare position.
I have contributed, I want to contribute and I will contribute. I want to do something and US is a place to
be for new ideas, opportunities. I would continue work in this healthcare area and contribute to improve
US healthcare and healthcare as overall, address healthcare cost issue and availability and access of
healthcare products, services, solutions to more people.
My extensive experience and world class expertise in healthcare, health informatics, medical devices,
healthcare IT, remote service, security products and services makes me highly valuable engineer. The
variety of her experience sets me apart from many of my professional peers.
I have extensive experience working in start-up, entrepreneur companies as well as mid to large
corporations in important and growing technology areas in the US such as bioinformatics, genomics, and
genomics instruments, and personalized medicine development. Allowing me to continue work in US and
in these fields would contribute to improving US healthcare systems and reducing healthcare costs.
I intend to continue to contribute in innovative work projects. I have consistently delivered results that
generated millions of revenue and delivered values to stake holders.
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1. Comparable Evidence
b. I have business acumen and organizational skills. Have advanced expertise in multiple advanced
technologies including but not limited to:
Entrepreneurship, business development, strategy, Business plan and business modelling,
competitive analysis, go to market strategy, Product development, pricing, technology stack, pitching
and return on investment.
full software development life cycle, usability, integration, service oriented architecture (SOA)
including Microsoft based SOA technologies, user interface design, robotics interface development,
lean six sigma, various product development methodologies, instrumentation development, systems
architecture, product development,
security products and services, remote service application for security devices such as DVRs,
security cameras, fire panels ,
remote service technologies and applications for medical devices and applications, security related to
medical devices,
software and engineering practices
Failure Mode Effect analysis(FMEA)
Change acceleration process (CAP) model
Agile Scrum master , agile methodologies
US regulatory and compliance requirements such as HIPPA, HITECH, and FDA related.
Customer services such as providing support to internal lab scientists (biologist, chemists) for bio-
tech instruments and applications.
Customer service to internal users such as field engineers and online engineers who install and
service medical devices.
Projects were in the areas of providing healthcare service and improving access at affordable cost to
large patient populations, up-time, serving and availability of medical devices, security of commercial,
industrial establishment and enterprise security,
At GE, Wireless remote monitoring solution for energy transformers, jet engines, water systems,
dashboards for locomotive(rail engine) service/repair data.(Exhibit 7)
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a. United Technologies (UTC) .UTC is a diversified company that provides a broad range of high-
technology products and services to the global aerospace and building systems industries, climate,
control, fire and security product and services.
( http://www.utc.com/About+UTC )
b. Raindance Technologies founder Dr. Jonathan Rothberg who is an American scientist and
entrepreneur. ( http://en.wikipedia.org/wiki/Jonathan_M._Rothberg )
c. RainDance Technologies has been selected as a 2008 World Economic Forum Technology
Pioneer. (Exhibit 3) (http://www.weforum.org/content/pages/list-technology-pioneers-2008)
Technology Pioneers are companies that have been identified as developing and applying highly
transformational and innovative technologies in the areas of energy, biotechnology and health, and
information technology. To be selected as a Technology Pioneer, a company must be involved
in the development of life-changing technology innovation and have the potential for long-
term impact on business and society. In addition, it must demonstrate visionary leadership, show
all the signs of being a long-standing market leader and its technology must be proven.
d. Raindance scientific advisory board including three Nobel Prize winners: (Exhibit 3)
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Articulation: It establishes EB1 eligibility under this criteria; that the foreign national Madhuri's
contributions in the field set her significantly above others in her field.
Articulation: Leading capacity title was Lead software engineer, senior software engineer, software
engineer. Software is very critical for any product development. And software engineers are responsible
for whole software and hence product development. Thats why software engineers are very well sought
and in demand. I have worked with Chief Technology officers, CEOs, VP engineering, Marketing
executives; because as software engineer TITLE itself brings technical responsibilities and leadership. A
Small startup like Raindance; where WHOLE company size is 30 people. There are not many layers,
hierarchy and hence software engineer TITLE /role itself was leading in terms of contribution. Lead
TECHNICAL aspect product development and not managing people.
nd
At Raindance, I was 2 software engineer when I joined. Later we were a small team of TOTAL 2-3.5
software engineers. As in press release ..Jun 2, 2008.. Raindance employs about 35
workers : Link for press release ( http://www.bizjournals.com/boston/blog/mass-high-
tech/2008/06/kelly-taps-out-coo-role-at-raindance.html )
Critical means for these projects Madhuris role, responsibility is critical in order for product delivery and
product development.
It establishes EB1 eligibility as the foreign national Madhuri has performed in leading roles in
productions/projects; and that the productions/projects were successful.
Exhibit 1
1. Proposed Employment letter- Wyss Institute Harvard Medical School
2. Recommendation letters from Robert Cunningham
Exhibit 2
nd
At Raindance, I was 2 software engineer when I joined. Later we were a small team of TOTAL 2-3.5
software engineers. As in press release ..Jun 2, 2008.. Raindance employs about 35
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workers : ( http://www.bizjournals.com/boston/blog/mass-high-tech/2008/06/kelly-taps-out-coo-
role-at-raindance.html )
I lead development of end to end workflow and user interface development, testing and test development
along with other responsibilities, . Given company size of 35 and software team size of 2-3.5; software
engineer title and my role itself was leading and my contribution was critical to organization.
RDT 1000
Raindance Technologies
1.
Technology Pioneer World Economic Forum - 2008
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Roche
o Scripps Translational Science Institute (STSI)
Articulation:
RDT1000 product I developed (in a small team of 2-3 software engineers); became a huge
success. Customers/partners for this product were worlds TOP FIVE pharma companies/research
institutes as shown below. Product development was my original contribution of major
significance and widely accepted all across industry. Generated revenues and commercialization
of product.
Sanofi S.A. is a multinational pharmaceutical company headquartered in Paris, France, as of 2014 the
world's fifth-largest by prescription sales. Sanofi engages in the research and development,
manufacturing and marketing of pharmaceutical drugs
www.sanofi.com
[1]
Roche's revenues during fiscal year 2013 were CHF 46.78 billion (about $51.3 billion). Roche is the
fifth-largest pharma company worldwide. www.roche.com
Broad institute MIT, The 2014 report from Thomson Reuters' ScienceWatch entitled "The World's Most
Influential Scientific Minds" recognized that 12 out of the 17 "hottest" researchers in science belonged to
genomics, and 4 out of top 5 were affiliated with the Broad Institute. https://www.broadinstitute.org/
----------------------------------------------------------------------------------------------------------------
Played a critical/ leading role in the genome selection system instrumentation product
development RDT 1000 (Exhibit 2 ).
At Raindance Technologies, the product RDT 1000 enabled the translation of cutting edge micro droplet
based sequencing nano technology into commercialization/commercial product.
Made significant contributions at the intersection of computer science, healthcare, biology, chemistry,
mechanical engineering, electrical engineering, and product development.
This translation of nano technology into commercial product also enabled new partnership and
collaborations; new corporate alliances with companies and educational institutes. Such as (Exhibit 3)
Exhibit 4
Raindance Founder Dr. Jonathan Rothbergs next start-up company (RDT sister company) Device
Brings $1,000 Genome Within Reach.
Exhibit 5
Work Products- at MedAssurant >> Chronic Disease Care Solution Portal
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leading health insurance companies Blue cross blue shield and Molina. Team consisted of me of two
people in terms of software.
This was my original major contribution. As shown in screenshot of application below which I
developed all by myself from scratch. (one man army in terms of writing software)
Worked in a leading role at MedAssurant developed above portal. This solution was part of
CCSAdvantage care management solutions. At MedAssurant; to support the assessment and
coordination of care among members who have complex needs associated with diabetes, heart
disease, asthma, coronary artery disease (CAD), or chronic obstructive pulmonary disease (COPD) ;
solution called CCSAdvantage. Inovalon uses advanced data management and analytics to identify
gaps in care and quality, as well as determining the most effective and efficient ways to resolve them.
Linking this insight with Inovalon's integrated call centers and in-market resources, SmartCare
provides for an unparalleled level of patient-specific matching between needs and targeted
intervention one focused upon the member and coordinated with the provider. (Exhibit 5 , 6)
Blue Cross Blue Shield, Molina Healthcare to select Chronic Disease Care Solution Portal
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This product I developed is part of the emerging field of Internet of Things where GE, IBM, Cisco
and Intel estimate several trillion dollars of new economic value will be created.
Work Products
GE Transportation Application (I Madhuri developed below product shown in screenshot)
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GE Aviation Application
Articulation: At another leading cybersecurity company BeyondTrust that was acquired by Symark for
$20 million and eventually by Veritas Capital by $310 million, Madhuri developed and lead development
of automation test framework. Her resume caught eyes of investors. Earlier more than half of products at
BeyondTrust were acquired by Microsoft.
Robert Hogan manager at Beyondtrust mentioned to me/team in 2009 that Symark executives looked
at your (Madhuris) profile and liked it. It helped to convince investors to sell this company for
$20 million
http://www.bloomberg.com/news/articles/2014-09-02/veritas-capital-agrees-to-acquire-beyondtrust-
for-310-million
http://venturebeat.com/2009/09/14/symark-acquires-beyondtrust-in-run-up-to-ipo/
Symark Software, maker of security applications that only allow network access to IT professionals, has
acquired a smaller rival,BeyondTrust, for a little over $20 million. Following the merger, the company will
operate under the BeyondTrust name, hoping that the boost in customers and revenue will carry it to a
lucrative public offering next year.
Agoura Hills, Calif.-based Symark is owned by Insight Venture Partners. The deal will also give the
company a Windows-version of its technology. Before, it only offered security solutions for Linux and
Unix.
Microsoft buys DesktopStandard
Microsoft acquired the entire company and product line with one exception. DesktopStandard CEO John
Moyer hung on to Policy Maker Application Security. In fact, Moyer is using the product as the basis of a
spinoff, BeyondTrust, also based in Portsmouth.
The mission of BeyondTrust is "to make the Windows platform the most secure platform out there," Moyer
said in an interview Monday.
According to Moyer, "There is too much trust out there.," meaning that users must often be given admin
privileges in order to run certain applications, forcing IT to "trust" those users. The result is that these
same users are often overrun by spyware and malware.
BeyondTrusts Privilege Manager is one answer. The tool "elevates the app rather than elevating the user
so the app can run," Moyer said. An application that ordinarily needs admin privileges can be elevated to
have those privileges, but "nothing else does," Moyer explained.
The trick is to use an extension to Group Policy that can set permissions for applications.
BeyondTrust has some 20 employees, including many from DesktopStandard. "Microsoft is picking up a
number of tech folks, but didnt have a lock on all of them," Moyer
said.___________________________________________________________________
1. Articulation: I worked for Entrepreneur Company like Beyondtrust whose founder sold company to
Microsoft. And when I was there in 2009; Symartk acquired Beyondtrust. I led automated test software
platform development there. We were very small team of few engineers; my role/contribution was
leading/critical. I also integrated component of product that was part of Microsoft operating system.
Microsoft already had several patents on this piece and I developed a solution which would allow us to
integrate the software without infringing Microsoft patent.
In 2014 Beyondtrust is acquired by Symantec.
BeyondTrusts customers range from 8 of the worlds 10 largest banks and 8 of the worlds 10 largest
aerospace and defense firms, to 7 of the 10 largest U.S. pharmaceutical companies, and other
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Articulation: What I meant in terms of commercial success as I am not an artist so Box office sales
does not apply to me. But what I meant was commercialization of technology and/or product.
At Raindance, their nano technology was sitting in the lab, not applicable to commercial use when I
joined in 2008. Raindance. In My leading, critical role as a software engineer where I made
original/significant contribution for Genome Sequencing instrument RDT 1000 product
development.
This instrument enabled commercialization of technology. Several senior scientists including Jason
Warner ( Jasons linkedin profile : http://www.linkedin.com/pub/jason-warner/9/703/666 ) at Raindance
appreciated in 2009 that Madhuri, your software/product engineering work is very significant, scientific
and led to success of this product development, you should be proud of what you do.. All work you did is
original, unique and of great value.
4.1. RainDance commercialized part of this technology in 2009 with the release of
the RDT-1000 platform; where my role was critical/leading/major significant
original contribution.
( http://innovation.cancer.gov/about/outputs/tech/raindance.asp ).
"This milestone represents the first commercialized application of our exciting RainStormTM
microdroplet-based technology platform," said Chris McNary, President and Chief Executive Officer of
RainDance Technologies.
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RainDance's initial application will focus on the targeted sequencing of the human genome " one of
the fastest-growing segments of the $1 billion DNA sequencing market. This application will enable
the high-resolution analysis of genetic variation between individuals and populations at a level unmatched
by current methodology.
RainDance was founded in 2004 by scientists from Harvard University; the Medical Research Centre in
Cambridge, England and the ESPCI in Paris. ( http://www.massbio.org/news/member_news/37-
raindance_technologies_announces_commercial/industry_news_detail )
4.3. Objective evidence: My role was critical, and of significant importance to the
outcome organizations activities/existence.
Raindance funding info from garage to millions. I was part of founding team. ONLY
rockstars can deliver in such high demand environment.
Articulation: I worked at RDT from Feb 2008 to Feb 2009, developed RDT 1000; companys first
commercial product from scratch. This product generated significant revenues and company first
raised $6 million funding in 2009. Since 2009 to till date has raised more than $100 million. My role
was critical, and of significant importance to the outcome organizations activities/existence.
Source: https://angel.co/raindance-technologies
$6,000,000
Series D Jan 25, 2011
$37,500,000
Mohr Davidow Ventures
VC Firm Menlo Park
Acadia Woods Partners
VC Firm Greenwich
$20,000,000
Mohr Davidow Ventures
VC Firm Menlo Park
Acadia Woods Partners VC Firm Greenwich
$35,000,000
Capital Royalty
$16,500,000
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http://www.forbes.com/sites/matthewherper/2010/12/30/the-next-100-billion-technology-business/
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Hans mentioned in his letter as below. Hans wrote after reviewing my resume and it is his
independent expert review.
.
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About Hans.
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In that role, he was responsible for developing and implementing the Studios technology strategies in
areas diverse as film making, marketing, and distribution. Prior to that, Brandeau held the post of senior
vice president of technology for Pixar and Disney Animation Studios. He joined Pixar in 1996 as the
Studios director of technology. After five successful years, during which he was promoted to vice
president, he left the studio to broaden his expertise within other areas of technology. He returned to
Pixar in 2004 and was promoted to senior vice president in 2006. In that role, Brandeau was responsible
for providing, maintaining, and continually adapting the systems and technology used in creating
computer animated feature films that allowed Pixar to continually be on the cutting edge of filmmaking.
Among his other career milestones, Brandeau served as chief information officer for the biotechnology
startup company, Perlegen Sciences. His resume also includes a variety of senior level positions in
Silicon Valley, including director of Operations at NeXT. Brandeau is co-authoring a book, Collective
Genius: The Art and Practice of Leading Innovation, to be published by Harvard Press.
Brandeau earned BS and MS degrees in electrical engineering from MIT. After serving in the US Air
Force, he continued his education at The Fuqua School of Business, Duke University, where he received
an MBA.
Brandeau's early career working for Steve Jobs at NeXT Computer set the stage for opportunities to
apply both his engineering knowledge and business training, and his passion for fostering creativity and
innovation in companies. He joined Pixar when it was a relatively small company, and led the effort to
develop strong teams and cutting-edge technology to establish Pixar as an entertainment
powerhouse. http://finance.yahoo.com/news/former-pixar-disney-technology-operations-225551219.html
Hi Madhuri,
Your question is too broad. What type of role do you want to play, where do you want to live,
startup/large company etc.
-gtb
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Dear Greg,I came across your information in MIT alumni website.I have extensive experience working in
multiple industries(Healthcare,Life science, remote service, engg. training) from for products and services
from concept to delivery.
I have attached my resume for your consideration. Please let me know should you require any additional
information.
I am interested in being part of team/opportunities that you know of. Can we have quick chat. Thanks for
your time.. I look forward to hear from you soon.
Sincerely,
Madhuri
6.2. Megan Smith, United States Chief Technology Officer, Former Vice
President. Google x
Articulation: Megan Smith as kind of my mentor and she is MIT alum.
Madhuri,
+ Noelle who might be able to brainstorm with you about ideas. Are you going to the Grace Hopper
Conference? Many tech companies
will be there recruiting...
-- Megan
I don't think I'm the right solution here -- but I can help with ideas... but don't depend on me alone. I think
the question is, can the GE people help re-instate you somehow for the 7 months you need... also, an
immigration lawyer would be helpful to talk with -- sounds like the first one was unhelpful so try someone
else.. will read what you sent.
-- Megan
Dear Megan,
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Email:
On Thu, Sep 25, 2014 at 2:32 PM, Schroeter, Michael J <michael.j.schroeter@lmco.com> wrote:
Hello Madhuri,
My name is Mike Schroeter, and I am a member of the software engineer team working on flight
simulations at Lockheed Martin. I have received your
resume for consideration to join us in a software engineering position in support of our flight simulator
programs. Would you be available to discuss this
possibility in a short phone call in the next day or so? Please let me know when a convenient time would
be. I expect this initial phone call to last only
about 10-20 minutes. I am available most days between noon and 8:00 Eastern Time.
Thanks, and I look forward to hearing from you.
Job Description: http://search.lockheedmartinjobs.com/ShowJob/Id/6785/Software-Engineer-Stf/
Sincerely, Mike Schroeter Lockheed Martin Corporation
Articulation : My uncle Tushar Bhatt; He was a family friend and my mentor. As shown below now
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Prime Minister of India Mr. Narendra Modi ( Mr. Modi was Chief Minister of Gujarat when my uncle
passed away in 2012 ) .
Being close to Tushar Bhatt I developed deep interest in business, economics and ways on how to apply
technology for growth.
http://timesofindia.indiatimes.com/city/ahmedabad/Former-TOI-editor-Tushar-Bhatt-passes-
away/articleshow/12475100.cms
AHMEDABAD: Veteran journalist and former editor of The Times of India, Tushar Bhatt, 71, passed
away on Friday. He is survived by his mother, wife, a son and a daughter.
Chief minister Narendra Modi has condoled the demise of the veteran journalist. "Bhatt had a deep
understanding of Gujarat's growth and its problems. In his passing away, Gujarat has lost an expert
journalist", message from the CM said.
Family members said that Bhatt's funeral will be held on Saturday. During his 50-year-long stint as a
journalist, Bhatt was associated with The Hindu, The Economic Times (Editor), and The Times Of India
(Resident Editor) among others. "Sketches in the sand' and `Reti ma Rekhachitro' are the collections of
his articles published in the column `Random Notes'. tnn
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-----Original Message-----
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http://www.reuters.com/article/2014/10/22/us-cybersecurity-medicaldevices-insight-
idUSKCN0IB0DQ20141022
(Reuters) - U.S. government probes medical devices for possible cyber flaws
The U.S. Department of Homeland Security is investigating about two dozen cases of suspected
cybersecurity flaws in medical devices and hospital equipment that officials fear could be exploited by
hackers, a senior official at the agency told Reuters.
A DHS review does not imply the government thinks a company has done anything wrong - it means the
agency is looking into a suspected vulnerability to try to help rectify it.
These people said they do not know of any instances of hackers attacking patients through these
devices, so the cyber threat should not be overstated. Still, the agency is concerned that malicious actors
may try to gain control of the devices remotely and create problems, such as instructing an infusion pump
to overdose a patient with drugs, or forcing a heart implant to deliver a deadly jolt of electricity, the
sources said.
The senior DHS official said the agency is working with manufacturers to identify and
repair software coding bugs and other vulnerabilities that hackers can potentially use to expose
confidential data or attack hospital equipment. He declined to name the companies.
Articulation: So I (Madhuri)did see the end. What I assessed in terms of security while at GE from
2011 to 2013; government officials are looking into that seriously.
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I am security savvy. My grandpa (he was not my real grandpa but he knew my family since before I was
born and he considered me as his daughter. His name was Retd. Lt. Col. C.C. Bakshi. He worked in
British army/Indian Army, was an Infantry & Intelligence Officer and he was a deputy director of Joint
Cypher Bureau. I am passionate about information security because of him mainly) He passed away in
2008 at the age of 94.
Which Fortune 500 Boards of Directors are Taking Cyber Security Seriously?
http://bizblog.blackberry.com/2014/10/taking-cyber-security-
seriously/?utm_medium=social&utm_source=LINKEDIN_COMPANY:BlackBerry&utm_campaign=Enterpr
ise&linkId=9948719
Though these calls for action, coming from multiple sources, suggest an insufficient awareness of
business-crippling threats at an organizations highest levels, available evidence tells a more complicated
story:
General Electric, somewhat surprisingly, given that it is not a major player in the financial services
industry, issued a warning to shareholders in documents dating back to 2010.
Articulation: While at GE I worked with tenacity and applied my experience and skills to bring up
security concerns. And now in 2014, GE took it seriously.
http://www.welivesecurity.com/2014/10/24/hacker-heart-attack-medical/?CMP=spc-linkedin-health-blog-
hacker&utm_source=linkedin.com&utm_medium=post&utm_campaign=esetna&utm_content=health
Articulation: While at GE from 2011-2013; I worked with tenacity to take security of medical
device seriously. In 2013/2014 everyone is taking about security..
10. MedAssurant Job offer / Leading role job Title, duties and responsibility.
Articulation : When a company makes an offer for a leading role especially Fortune 10 company like GE;
a person MUST possess Leading role capacity and MUST be qualified to do so. Then ONLY a person
gets an offer.
Medassurant was not willing to sponsor my green card. And Philips Healthcare wanted to hire me. I have
whole day onsite interview at Philips in Maryland (Medassurant was also in Maryland). Medassurant
manager found out about Philips and later I moved to State of Indiana..Dept. of disability and
rehabilitation (DDRS). My extended family person was a fighter pilot in India. Due to faulty MIG accident
he became paraplegic /disabled and government helped him for vocational/rehabilitation. He died after
sometime of this accident. But I strongly wanted to work for DDRS because it was for greater good.
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..
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..
..
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11. GE Job offer / Leading role job Title, duties and responsibility.
Articulation : When a company makes an offer for a leading role especially Fortune 10 company like GE;
a person MUST possess Leading role capacity and MUST be qualified to do so. Then ONLY a person
gets an offer. GE has been known in press for Tax Heaven and finance issue. After PERM certified, next
step was to file I140; several immigration attorney said that GE does not want to show their finances to
government. SO they framed you and didnt file I 140. Also because they were doing a fraud they got rid
of me as to remove a witness and retaliate. GE has outsourced everything to India and China; keeping
me on a payroll is FACTOR of COST. They prefer cheap labor.
GE Healthcare
October 11, 2011
Dear Madhuri:
Congratulations! We are pleased to offer you the position of Software Engineer, Global Services
Technology located in Waukesha, Wisconsin. This position is in the Lead Professional Band
and your starting gross annual salary is $90,000.00 to be paid bi-weekly.
We are excited to have you join the GE Healthcare Team! If you have any questions, please
contact me at 262-
524-5152 or your Human Resources Manager, Mike Truman at 262-853-6054.
Sincerely,
David Mehring
Global Engineering Manager Platforms
Cc: Mike Truman
1433058
13. On December 2012, General Electric Healthcare (GE) filed PERM labor certification
under EB2 person with exceptional ability-advanced degree. ETA Case number: A
12333 17601 which was approved in May 2013. GE Healthcare has not filled I -140
after PERM ETA Case number: A 12333 17601 was certified. GE didnt file I 140.
At GE Healthcare, I came across and reported quality issues, and security vulnerabilities including where
80,000 plus medical devices communicate with remote service software application and lots of patient
data is handled. There were 600 (defects/design non conformances)-2000 quality issues in production.
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15. Articulation: We developed cutting edge wireless security system ..This technology
was patented as know. My name is not on the team but manager and systems
engineers name is there. I joined UTC just after graduating from Cleveland state
and having a fresh divorce.
I have deep technical expertise and business acumen. People have given feedback/comment that you
are future Sloan executive. I attended MIT Sloan School of management so.
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Note: This form must be signed by the attorney or unrepresented litigant and attached to the end of
the brief.
This brief complies with the length limits permitted by Ninth Circuit Rule 28-1.1. The brief is 5409
words or pages, excluding the portions exempted by Fed. R. App. P. 32(f), if applicable. The brief's
type size and type face comply with Fed. R. App. P. 32(a)(5) and (6).