Additional instructions for Interrogatories

I seek answers from Inova. With many questions, it may seem that Dr. SonaleeKulkarni should
be the person who provides the answers. But Inova has fully taken over my doctor-patient
relationship with Dr. Kulkarni. Inova took several actions, such that Dr. Kulkarni and I could
have no contact. A short, non-exhaustive list, includes: Dr. John Cochran, using Inova stationery
to give notice of termination of that doctor-patient relationship. Not only was the letter not
signed by Dr. Kulkarni, there is no attempt to convey to the patient that, the statements are a
reflection of the wishes of Dr. Kulkarni. The letter also notes a refund, which is fully the work
of Inova. This same letter is referenced in the large defamatory statement, which was lead
page of my medical records, which though Inova is its mere custodian; Dr. Kulkarni is the only
one authorized to write into it. Nearly a year later, Mr. Carey, representing Inova references this
same letter. Mr. Careys letter also, represents that Inova wants to tell me that; Inova, Dr.
Kulkarni, Dr. Cochran, other non-officers, VCU, VCUs non-officers, third parties [meaning
Capital Imaging of Bethesda and its agents]; are all united with Inova at the head. Inova, is
itself, a medical entity. Inova conducted meetings that included physicians, specialists at that;
and discussed my matter. Inova should be able to answer as though, Inova is a specialist.
Interrogatory 1:Mr. Careys demand letters, made bald conclusory statements: Give the specifics
of assertions of; defamatory statements, statements which are inappropriate and statements that
are actionable in law? Demonstrate the full claims, as though to meet the federal pleading
standards?
Interrogatory 2 : [The definition of patients for this matter will be those similarly situated to
Plaintiff. These are the patients whose relationship arises from an initial appointment and
contact with Inova; directly to the neurology practice or by referral from Inova primary care or
urgent care. This excludes patients whose initial contact with Inova was at a hospital] For every
12 month period, since, Inova commenced with its relationship with Dr. Kulkarni; State the
number of new patients taken on by Dr. Kulkarni? State the number of existing patients at the
end of the 12 month period for Dr. Kulkarni? Then for comparison, the lone non-management
neurologist, remaining is Dr. Eric Sklar. Answer these same questions for Dr. Sklar?
Interrogatory 3:Prior to seeing Dr. Kulkarni, I had drawn up a list of neurologists. With the
criteria being; low price, immediate availability of appointment, and a neurologist who is well
established. Inovas website for the neurology practice, was purposefully, deceptive. It listed all
the training and credentials for Dr. Kulkarni. The assumption by any patient is that there is a
corresponding work history. It was only after, Inova restricted my access to my doctor, Dr.
Kulkarni; that I looked into Dr. Kulkarnis curriculum vitae. Neurologists, especially, female
neurologists with much less training and credentials, easily get contracts with neurology
practices. But she, essentially worked odd jobs for many years and no one picked her up until
Inova, did so.

Why did Inova contract with Dr. Kulkarni, when none of the other neurologists would have
passed on her, for lack of training or credentials; and would have only passed on her for reasons
such as character and personality; qualities neurologists, like psychiatrists, have qualifications to
assess? What was the criteria applied by Inova, which was different from those other neurology
practices and Inovas neurologists were able to give Dr. Kulkarni a contract?
Interrogatory 4:It is true that I look back to the year 2013 and point fingers at Dr. Kulkarni for a
variety of misdeeds. But during the period that the events were occurring, there was a great deal
of goodwill which was built into this doctor-patient relationship, above and beyond, the standard
doctor-patient relationship. When I filed a complaint with The Board of Physicians in October,
2013; what I said was that Dr. Kulkarni was ignoring her patient and had abandoned her patient.
There was nothing about concealing injuries. Things like the deletion of the MRI test from the
records were not even noticed. Even after the very noticeable and overt injuries which occurred
with the Verapamil; I did not assert that the migraine diagnosis was a sham or that Dr. Kulkarnis
misdeeds were the cause of the injuries.
Is there any evidence, showing this statement to be false and if so what specific evidence?
Interrogatory 5: The MRI test report shows that Dr. Kulkarni is the referring physician. In a
recorded exchange from December, 2015, which is on YouTube, an agent for Capital Imaging is
heard telling me that my contact person for discussing the test or any injuries related to the test is
my referring physician. Inova, in many ways, including with official letters has converted my
contact to be Inova, and not Dr. Kulkarni. Furthermore, from the misdeeds which I accuse Dr.
Kulkarni of or Inova of, which Inova as at least acknowledged could have likely occurred, are
related to the actions of Capital Imaging and its technician, Papel. Placing whiteout on page
numbers by Inova and Dr. Kulkarni removing doctors notes from the records; relate to the MRI.
I have always and until very recently asserted that it was Dr. Kulkarnis prescription for
Verapamil which was the big problem, and yet; Inova and Dr. Kulkarni have not taken actions to
conceal these facts. Dr. Kulkarni prescribed one other drug and she sent me to a generalist for a
blood pressure drug. Both these drugs, Dr. Kulkarni, even stated he did not tolerate. The
history of my medical condition which brought me to seek treatment from Dr. Kulkarni was the
mistakes of other physicians. All this; Dr. Kulkarni does reflect in her notes. It is only the facts
regarding the MRI test, which Inova and Dr. Kulkarni; have worked to conceal. The
concealment includes great efforts to conceal that the MRI test ever even occurred. Inova has
used its official letter to not discuss the wrongs of Capital Imaging, but to shut off the debate by
asserting defamation by Plaintiff against third parties, which is Capital Imaging.
Please provide facts that contradict this statement? Furthermore, provide reasons for why Inova
should not answer for the actions of Capital Imaging, if any exist?

Interrogatory 6:An official statement from Capital Imaging stated that: my pre-existing
conditions would not lead to any complications. Vein attempts would not lead to
complications There are only 2 possible complications. From this short list of possible
complications, only one the infiltration into the muscle could anyone attribute to medical
malpractice. Dr. Kulkarni, Inova, Capital Imaging, Plaintiff, other physicians and no other
person has ever stated that infiltration into the muscle occurred. The Court did not state that I
began to discuss with Dr. Kulkarni any injuries related to the MRI test. The Court stated that I
began to discuss the statements of, and the acting suspiciously of Papel. [But that without any
medical assessment] Dr. Kulkarni knew what Papel had done. The Court also stated that the
actions of Papel produced injuries. The injuries were not a bad knee or such; a non- exhaustive
listing of the injuries included the brain and the aorta. The injuries included a long period of
unconsciousness which was concealed by Papel and by Dr. Kulkarni. My current Primary Care
with MSFC Medicaid has attested that all my cardiovascular and neurological problems,
including a herniation of the brain, seen as a swelling on the upper portion of the forehead, have
the same underlying etiology [causation]. The root is attributed to the actions of the people at
the MRI facility.
When it is said that Dr. Kulkarni knows what the MRI tech did, is there any reason to exclude
things that other persons [the people] did, when the doings of the other persons are by analogy,
something like stealing cash out of the safe of a bank after a teller gave access to the vault?
Interrogatory 7: Then with a similar analogy, the teller may have access to the room, but not the
vault; itself. Then when the vault is broken into by the manner seen in the movies, that of
cracking the code, or by the manner which occurs in real life, that is of detonating small
quantities of explosives; these things are not within of the skillset of a bank teller.The MRI tech
is an imaging specialist, with little ability to alter the human body.
So when Dr. Kulkarni, a neurologist, knows; Would she not know that the process of causing
unconsciousness was done by inserting a needle into the ulnar artery by navigating through a
maze of structures in the dorsum of the hand; then to send water racing upstream and into the
brain with such force, that the ulnar artery has blown out; that an engorged pattern of collateral
venous circulation appeared on the upper chest because the normal draining veins were also
injured, when the water drained from the brain into the heart; that there are drugs such as antidiuretics which can increase the retention of water in the brain and then there are other drugs
such as Manitol which can cause the water to drain from the brain; and all this is the work of Dr.
Jeff Jacobson, the principal owner of Capital Imaging and neurosurgeon and trauma surgeon,
who has been featured in several news articles related to saving the life of White House Press
Secretary James Brady by non-cutting techniques that reduce the water in the brain?
Interrogatory 8: If this #7 is not what Dr. Kulkarni knows, then what is what Dr. Kulkarni
knows that produced severe injuries?

Interrogatory 9: When Dr. Kulkarni knows that an extended period of unconsciousness was
deliberately produced, does she know of a motive other than that which a reasonable person,
suspects, which is to commit sexual assault?
Interrogatory 10: With the recorded call with Capital Imaging, Michelle Miller of Capital
Imaging, who is an office worker with no medical training and not working under the license of a
physician, suggests that I should proceed with the usual process, related to breaching the
standard of care; that of medical boards and malpractice suits, against Ms. Miller. But it was Ms.
Miller, herself, who had been the spokesperson for Capital Imaging and with a statement which
would limit medical malpractice to Papel, the technician, and for infiltration into muscle. The
statement went on to say that such an event did not occur. Now Ms. Miller is talking about my
large scale and severe injuries and saying that there is probable cause to say that she is
responsible. But Ms. Miller does not want to use the term probable cause and criminal
prosecution.
Does Ms. Miller have skill to produce these injuries?
Interrogatory 11: For #10, if the answer is yes, does Ms. Miller or anyone with the skill, have
any standing to be shielded by a medical malpractice process, when Papels, state radiographers
license does not permit him to involve any other person, in his work?
Interrogatory 12: Has Inova had any communication with any agent of Capital Imaging,
commencing January 15, 2013; regardless of whether the communication concerned Joseph
Crussiah.?
Interrogatory 13: Has any agent of Capital Imaging been physically on Inova property,
commencing January 15, 2013?
Interrogatory 14: Has any agent of Inova been physically on premises controlled by Capital
Imaging or any entity controlled by Dr. Jeff Jacobson?
Interrogatory 15: For #12, #13 and #14, for yes replies, what are the specifics; time, place,
purpose?
Interrogatory 16: The interpretation for the MRI test is not authentic, in that recorded phone call
with Ms. Miller, she hung-up when asked about the authenticity of the report. Dr. Kulkarni
referred to this MRI report in her March 26, 2013 doctors notes. But this report was not
accessible to Latoya Tates, a nurse at the neurology practice. This report was not logged in as
being received. Where did Dr. Kulkarni find the report?
Interrogatory 17: How and when did the report referenced in #16 arrive and appear on Inovas
premises?

Interrogatory 18: Dr. Kulkarnis doctors notes from March 26, 2013; states that the purpose of
the visit was to discuss test results. Why was Plaintiff billed for an extended office visit and not
for the minimal visit?
Interrogatory 19: The March 26, 2013, doctors notes state that Plaintiff continues to report
problems with gait. Please show the notation from any previous visits indicating that Plaintiff
had complained in the past about gait?
Interrogatory 20: The MRI report, reports on a Pituitary Protocol. Is there any evidence that Dr.
Kulkarni ordered such a protocol or that the word pituitary even appears anywhere in the notes?
Interrogatory 21: For #20, if the reply is yes; please provide the evidence and also show all the
blood and urine tests which are standard practice as the initial studies?
Interrogatory 22: When injuries are produced by a surgeon, who hijacked a simple MRI test
process and a patient notices the injuries; would reason dictate the approach which Plaintiff
followed, which is to make the assumption that the injuries were produced by the MRI
technician, who was the only person that he saw while he was conscious?
Interrogatory 23: Even if a surgeon has produced injuries in a non-medical setting and with a
person not participating in any medical process, perhaps his wife; is not the initial action for the
wife to go her doctor [ethics and state boards of physicians dont permit treatment by her
husband]?
Interrogatory 24: So whether the hypothetical in #23 or perhaps something like Shaken Baby
Syndrome or for Plaintiffs matter; can the analysis, justice process and treatment move forward
and be successful, when the treating physician is deliberately providing poor care, as to conceal
the misdeeds?
Interrogatory 25: Is there at least one case, where, Inovas doctors have suspected Shaken Baby
Syndrome and have gotten police to file charges against the parents?
Interrogatory 26: Is there at least one case, where Inova sued a contract nurse and the firm she
worked for, because Inova had to spend about $150,000 defending her actions?
Interrogatory 27: When a patient is injured in a medical setting and his treating doctors, are on
the take from those who harmed him; does he have any course of action, other than paying more
than $100,000 to a medical malpractice attorney and have the experts, the attorney has on
retainer to develop the case?
Interrogatory 28: Plaintiff recently filed a group of motions, which he later, withdrew. Does
Inova dispute the allegations that that Capital Imaging and Inova; put statements in records and
did all the somewhat comical things they did, including the whiteout stunt because the
expectation is that Joseph Crussiah will either die or end up alive but in some virtually, dead

state; and these were all the schemes to explain to persons, other than Joseph Crussiah, that
Joseph Crussiah never went for a MRI test and what happened is that Joseph Crussiah, should be
put in the running for a Darwin Award because he got together with some people not known to
his medical providers and engaged in some bizarre sex acts, for which he did to himself or
consented to have done to him some homemade medical interventions in furtherance of the
bizarre sex-play?
Interrogatory 29: Was Dr. Eric Sklar at Capital Imaging on February 15, 2015?
Interrogatory 30: During the March 26, 2013 office visit, why was the office door left open?
Interrogatory 31: combining #29 and #30, why did Dr. Sklar peer into the room for several
minutes and observe Plaintiff?
Interrogatory 32: Provide any other theory [my theory is that the plan was for me, to not walk
out of the office] for Ms. Miller on the recorded phone call, saying that I walked out of our
office and then trying so hard to change its meaning?
Interrogatory 33: Plaintiff stated in his abandoned motions that Ms. Miller was making
observations and reporting to Dr. Jacobson. Did she mean that my voice sounds like I am talking
from under the pool?