SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION-CIVIL ACTIONS BRANCH

JOSEPH CRUSSIAH, *
*
Plaintiff, * Civil Case No. 2017 CA 007694 B
* Civil II, Calendar I
v. * The Honorable John M. Mott
* Next Event: Initial Scheduling Conference
MEDSTAR HEALTH, et al., * February 23, 2018
*
Defendants. *

PLAINTIFF'S APPLICATION FOR TEMPORARY RESTRAINING ORDER

Plaintiff Joseph Crussiah, Pursuant to Super. Ct. Civ. R. 65(b) apply for a temporary

restraining order. Defendants have not denied that this is a case of: life and something even

worse than death, and that Defendants ongoing tortious conduct includes greatly eroding the

status quo and interfering with and obstructing Plaintiff's rights, directed at his activities related

to This Case. Plaintiff, respectfully, requests This Court to immediately enjoin the harms being

done by Defendants Medstar Health, Jeff Jacobson, M.D., Sonalee Kulkarni, M.D., Shannon

McMahon and General Conference of Seventh-day Adventists. ORAL HEARING is requested,

and further requested to occur on February 23, 2018, the date of the next event.

Per Super. Ct. Civ. R. 12-I(a) Plaintiff has repeatedly asked Defendants to grant the relief

requested, including within other filings in the case file. But Defendants ignore and don't

comply, respond with even worse conduct.

A Proposed Order, follows the Memorandum of Points and Authorities that gives the specific

grounds for this application..

 Respectfully Submitted,
Dated February 22, 2018

Joseph R. Crussiah
Pro Se Plaintiff
9701 Cottrell Terrace
Silver Spring, MD 20903
240-475-7737

crussiah@yahoo.com
 3CERTIFICATE OF SERVICE

I hereby certify that on this, the 22nd day of February, 2018, a copy of the foregoing was mailed,
via U.S. Mail, additionally to be emailed to:

J. Jonathan Schraub and Michael T. Marr

Sands Anderson PC
1497 Chain Bridge Road, Suite 202
McLean, VA 22101
Counsel for Defendant Jeff Jacobson, M.D.

Jared Green
Goodell DeVries, Leech and Dann, LLP
One South St, 20th Floor
Baltimore, Md 21202
Counsel for Defendants Medstar Health and General Conference of Seventh-Day Adventists

Meghan K. Casey
OAG of Maryland
200 St. Paul Place 20th Floor
Baltimore, MD 21202
Counsel for Defendant Shannon McMahon

Kevin F.X. DeTurris

Blankingship & Keith P.C.
4020 University Drive, Suite 300
Fairfax, VA 22030
Counsel for Defendant Inova, Defendant

Respectfully submitted,

Joseph R. Crussiah
Pro Se Plaintiff
9701 Cottrell Terrace
Silver Spring, MD 20903
Montgomery County
240-475-7737
crussiah@yahoo.com
 SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION-CIVIL ACTIONS BRANCH

JOSEPH CRUSSIAH, *
*
Plaintiff, * Civil Case No. 2017 CA 007694 B
* Civil II, Calendar I
v. * The Honorable John M. Mott
* Next Event: Initial Scheduling Conference
MEDSTAR HEALTH, et al., * February 23, 2018
*
Defendants. *

TEMPORARY RESTRAINING ORDER

The Court has considered Plaintiff's February 21, 2018 Motion for Temporary Restraining

Order, Plaintiff's Memorandum of Points and Authorities in support thereof, any opposition

thereto, and the applicable law.

For the reasons set forth in Plaintiff's Memorandum of Points and Authorities, The Court

believes that Plaintiff is likely to succeed on the merits of one or more of his claims. This Court

finds that Defendants have not denied allegations, nor challenged Plaintiff's exhibits from The

Complaint and have not denied allegations from Plaintiff's Responses in Opposition to

Defendants' Motions to Dismiss, Defendants never filed reply briefs. The Court further believes

that Plaintiff will suffer an irreparable injury in the absence of a Temporary Restraining Order,

and that the harm to Plaintiff in the absence of a Temporary Restraining Order outweighs any

harm to Defendants by the injunctive relief requested. Finally, the public interest is tied to

Plaintiff's interests. The Public will suffer injuries, with the injuries most greatly suffered by The

District's Medicaid enrollees, in the absence of a Temporary Restraining Order.

Accordingly, this _______ day of _____________, 2018, it is hereby

ORDERED that Plaintiff's Application for a Temporary Restraining Order is GRANTED. It

is further

ORDERED that Defendant Medstar Health is temporarily prohibited from operating a

Managed Care Organization for The District of Columbia's Medicaid program. It is further

ORDERED that Defendant Medstar Health is temporarily prohibited from providing

services, within The District of Columbia, to enrollees of Maryland's Medicaid program. This

injunction does not prohibit emergency room encounters for enrollees of Maryland's Medicaid

program, for emergencies occurring, while visiting The District. It is further

ORDERED that Defendants Medstar Health, Jeff Jacobson, M.D., Sonalee Kulkarni, M.D.,

Shannon McMahon and General Conference of Seventh-day Adventists, remove, heal; all bodily

injuries placed upon Plaintiff Joseph Crussiah's body, including the progression of these injuries.

It is further

ORDERED that Defendants Medstar Health, Jeff Jacobson, M.D., Sonalee Kulkarni, M.D.,

Shannon McMahon and General Conference of Seventh-day Adventists, to obtain Plaintiff with

his Social Security Disability benefits. This is consists of approximately $120,000 in payments

in arrears, $1100 monthly, and Medicare coverage. In the alternative, Defendants must pay this

money to Plaintiff, and must pay premiums for health insurance equal to Medicare. It is further

ORDERED that Defendants Medstar Health, Jeff Jacobson, M.D., Sonalee Kulkarni, M.D.,

Shannon McMahon and General Conference of Seventh-day Adventists and others they act in

concert with, cease and desist from further abusive conduct and unlawful conduct.

This injunction shall remain in force until final disposition of the case.

_____________________________________
The Honorable John M. Mott
Associate Judge
Superior Court of The District of Columbia
5
COPIES TO:

Joseph Crussiah
J. Johnathan Schraub
Michael T. Marr
Jared Green
Meghan Casey
Kevin DeTurris
Via CaseFileXpress
 7 SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION-CIVIL ACTIONS BRANCH

JOSEPH CRUSSIAH, *
*
Plaintiff, * Civil Case No. 2017 CA 007694 B
* Civil II, Calendar I
v. * The Honorable John M. Mott
* Next Event: Initial Scheduling Conference
MEDSTAR HEALTH, et al., * February 23, 2018
*
Defendants. *

PLAINTIFF'S MOTION FOR EMERGENCY PRELIMINARY INJUNCTION

Plaintiff Joseph Crussiah, Pursuant to Super. Ct. Civ. R. 65(a) moves for a preliminary

injunction against Defendants Medstar Health, Jeff Jacobson, M.D., Sonalee Kulkarni, M.D.,

Shannon McMahon and General Conference of Seventh-day Adventists. ORAL HEARING is

requested, and further requested to occur on February 23, 2018, the date of the next event.

Defendants have not denied that this is a case of: life and something even worse than death,

and that Defendants tortious conduct includes interfering with and obstructing Plaintiff's rights

directed at his activities related to This Case. Per Super. Ct. Civ. R. 12-I(a) Plaintiff has

repeatedly asked Defendants to grant the relief requested, including within other filings in the

case file. But Defendants ignore and don't comply, respond with even worse conduct.

A Proposed Order, follows the Memorandum of Points and Authorities.

Respectfully Submitted,
Dated February 22, 2018

Joseph R. Crussiah
Pro Se Plaintiff
9701 Cottrell Terrace
Silver Spring, MD 20903
240-475-7737

crussiah@yahoo.com
 CERTIFICATE OF SERVICE

I hereby certify that on this, the 22nd day of February, 2018, a copy of the foregoing was mailed,
via U.S. Mail, additionally to be emailed to:

J. Jonathan Schraub and Michael T. Marr

Sands Anderson PC
1497 Chain Bridge Road, Suite 202
McLean, VA 22101
Counsel for Defendant Jeff Jacobson, M.D.

Jared Green
Goodell DeVries, Leech and Dann, LLP
One South St, 20th Floor
Baltimore, Md 21202
Counsel for Defendants Medstar Health and General Conference of Seventh-Day Adventists

Meghan K. Casey
OAG of Maryland
200 St. Paul Place 20th Floor
Baltimore, MD 21202
Counsel for Defendant Shannon McMahon

Kevin F.X. DeTurris

Blankingship & Keith P.C.
4020 University Drive, Suite 300
Fairfax, VA 22030
Counsel for Defendant Inova, Defendant

Respectfully submitted,

Joseph R. Crussiah
Pro Se Plaintiff
9701 Cottrell Terrace
Silver Spring, MD 20903
Montgomery County
240-475-7737
crussiah@yahoo.com
 SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION-CIVIL ACTIONS BRANCH

JOSEPH CRUSSIAH, *
*
Plaintiff, * Civil Case No. 2017 CA 007694 B
* Civil II, Calendar I
v. * The Honorable John M. Mott
* Next Event: Initial Scheduling Conference
MEDSTAR HEALTH, et al., * February 23, 2018
*
Defendants. *

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFF

JOSEPH CRUSSIAH'S APPLICATION FOR TEMPORARY RESTRAINING ORDER
AND MOTION FOR EMERGENCY PRELIMINARY INJUNCTION
This motion incorporates the entirety of Complaint and Plaintiff's Responses in Opposition to

Defendants' Motions to Dismiss. (the 4 briefs are identical). In those filings, Plaintiff, did both;

made substantial argument for injunctive relief, and the term is stated several times.

I. Defendants attack more than the status quo, they attack and harm the tools needed for
Plaintiff to prosecute This Case

The federal court in Maryland, three years ago, found: that Defendants and others they act in

concert with, engage in tortious interference to block Plaintiff's medical care and his access to

attorneys. Consequently, in addition to the irreparable harm of bodily injuries and other harm,

Defendants use the combination of; bodily injuries, depriving Plaintiff's access to money as with

Social Security Disability, and directly obstructing Plaintiff's efforts to seek assistance from third

parties, most importantly, attorneys.

One of the injuries being caused by Defendants is the diminished ability to speak. This

makes the need for representation, critical. Additionally, the process of finding and retaining

counsel requires that same ability to speak. Until January 28, 2018, supported by drinking large

quantities of fluids, Plaintiff was capable of participating in an hour long hearing. Since that
date, Plaintiff lost his voice; limited to whispering. Defendants refuse to repair this injury.

For some of the Defendants who present defenses, albeit with no support, of statute of

limitations and lack of personal jurisdiction,; they have new transactions everyday and several

are in The District. And they are very disturbed by Plaintiff sending an email to The Mayor's

Office. If there is no DC jurisdiction, why do they get disturbed.

Defendants malicious conduct and control over Plaintiff is so great that it includes by some

unlawful hacking means spying on Plaintiff's internet activity when he uses a tablet. In Plaintiff's

Responses to Defendants' Motions to Dismiss, Plaintiff showed convincing inference that when

he uses the Montgomery County libraries computer, Defendants are spying.

On February 13, 2018, Plaintiff filled out a form on the website of an attorney in The District.

Medstar which has been making crank calls to Plaintiff's mother, using spoofing, meaning

showing false numbers on caller-id, within two minutes made two calls. Defendants, like

stalkers, need to always have the sensation that they are dominating Plaintiff, so those crank calls

were made to taunt Plaintiff that they are spying on his private web browsing.

On February 15, 2018, at 10:19 a.m. Plaintiff emailed a letter to the office of The Mayor of

The District of Columbia. Then for all arguments of statute of limitations and that the case has

nothing to do with The District, seconds later at 10:20 a.m.; Medstar who is spying on Plaintiff's

web browsing and had it's sensations greatly disturbed, made a crank call to Plaintiff's phone, and

using a Medstar number.

II. The Legal Standard

The legal standard of This Court for granting This Motion is pursuant to Zirkle v. D.C. (2003)

and Wieck v. Sterenbuch (1976). The emphasis is on the irreparable harm prong of the 4 prong

test. The standard of This Court is that; if future tortious injuries can be compensated, and the

11
party made whole, then that is not irreparable. The emphasis of This Court is on bodily harm.

And This Court makes no distinction between a broken bone that can be mended and some other

injury such as setting an individual on fire, which leaves permanent injury. This Court in

Coppinger v. Johnson (2015) issued an injunction to stop second-hand marijuana smoke. The

emphasis on bodily injuries, future battery, and assaultive conduct is seen in statutes that allow

individuals, by way of petition, to seek The Court's help, without ever filing suit.

III. Allegations supported by evidence and not denied by Defendants

A. Five years ago, physicians, hospital officials and others related to healthcare in a

hundred mile region around The District, and at least one public official, J. Thomas Manger III

the police chief of Montgomery County; commenced with a scheme.

1. During a harmless MRI test, used a needle to access an artery, sent water into the

brain, caused medical status similar to that seen with; David Rosenbaum, the well-

known District incident, and seen with the young man returned from North Korea.

Next to hold Plaintiff for years and subject him to sex assault and torture.

2. The first hour was at the MRI facility. Then because Plaintiff was not employed and

not insured, with such a incapacitating condition, he would be taken care of, by

Medicaid, free safety net public healthcare. Plaintiff, a resident of Maryland, in the

shadow of the giant Medstar Washington Hospital Center, he would be assigned to the

Medstar Medicaid MCO and his care would be at the Medstar campus on Irving

Street, where there is a long-term rehab facility, in addition to the hospital. It would

not be unreasonable to consider Plaintiff to be a District resident when being held in

The District, permanently. Medstar operates a Medicaid MCO for Maryland and The

District, and no other state. Additionally operates the two programs, together. All

12
combined; the target of this crime could have been a District resident and could have been a

resident of Maryland near the border; and no one else.

3. It's a common feature of these elaborate, bizarre sex crimes, for the originators to

add more offenders to the group. Getting further gratification, vicariously. And in the

instant scheme, they want to pile on the abuse on a single victim. The primary act is

patterned after the crush-fetish, a dominatrix type act. Likely, at the MRI facility,

sexual contact came from two women. Plaintiff saw them at the facility, and he saw

that their face and hair were made-up, professionally. And, likely, video is used as a

marketing scheme to grow the crime. Growing the number or women would grow the

number of men. Medstar, which has no business outside DC and Maryland, relocated

the administrative positions of the Medicaid MCO to Wisconsin. A network of home-

based offices and other tiny offices, with ads listed as “mommy jobs”. This means

home-based, and it also means that men don't even find the listing. The leader signing

the checks, with money stolen from the Medicaid program in the CEO of Medstar

Kenneth Samet. The operational head is Carol Attia, a Vice President at Medstar, a

real life Nurse Ratched, who gets her name from marrying a psychiatrist at a

psychiatric facility. Samet made Attia, an enforcer, to crush all the little nurses at the

hospitals. Then she was moved to head the Medicaid operations, and dominate all the

women who work in those administrative jobs. Attia, whose expertise is in recruiting

women she can control, recruited White women from remote areas of Wisconsin,

literally The Great White North, for the express purpose of indoctrinating them into

this sexual scheme.

B. The perpetrators were unsuccessful in producing the permanent injury, while at the

13
MRI facility. They created injuries, that over time, as soon as the the same evening produce the

final results. But those calamitous ends didn't come. Plaintiff experienced little problems, and

the great internal injuries could have been treated and managed. The perpetrators had many

opportunities to do what surgeons do all the time. When they do malpractice, perhaps with a

heart surgery, they tell the patient some excuse other than what really occurred, do a new surgery

and make it right. I didn’t need something as extreme as surgery; just needed simple medical

care; being given the right meds and being kept away from things that make the problem worse.

C. But, they were bound and determined to get the horrible ends. Medstar's Samet and Attia

are clearly the leaders. Without them, the crime would have fizzled out long ago.

1. Kulkarni, deliberately, gave a false diagnosis, and treated with meds that would

exacerbate the injuries. When the offenders found out that Plaintiff was still largely okay; from

Virginia, Kulkarni called in a prescription to a pharmacy in Maryland, and lied that it was a refill;

when it was an entirely new drug, for which a patient normally has to seen by his doctor. Months

later, Plaintiff' had to get the common local anesthetic for dental care, a root canal, in DC.

Kulkarni said okay. Primarily owed to the drug she gave and secondarily from the dental

anesthetic; those stalled out injuries got greatly kick-started. Resulting were progressively

worsening impairment, disability, pain and suffering and a degree of disfigurement.

2. Being in between the dungeons of the MRI facility and Medstar's campus, the acts

and omissions of Defendants and others in their group is the same as the Jim Crow

Era. “Effective slavery” was things like; if you don’t complain about the landfill

being put into your neighborhood, don’t try to move into the White neighborhood, sit

back and enjoy the carcinogens and diminished property value; government and the

14

private persons such as The Klan that they acted in concert with; will not bother you. There was
unwarranted law enforcement action against Blacks; simultaneously; no action for even major

crimes done to Blacks by Whites. The offenders, by criminal means, blocked everything;

doctors, lawyers, state jobs, Social Security disability.

3. All variety of bizarre things done to tide over the offenders' psyche, to keep the fire

lit, during the holding pattern of being between the two dungeons. Many stated in

The Complaint. The one with massive evidence is a taunting email campaign. They

spend millions, commit billions to hide the crime from Plaintiff; but also spend a

million to reveal their crime to Plaintiff with their email campaign. They fly to

different states paying money for mailboxes that give addresses, paying money for

more than 1700 web domain registrations including premiums for domains already

owned. Then renting email marketing software, then designing 30 emails per day,

with 30 minutes of work per email; all with multiple violations of federal anti-spam

laws. The Complaint titled these exhibts“cryptically obscene emails”. They bought

even more domain names, including that of “encryptionhogwash.com” What they say

is that their emails are not cryptic, but out in the open. Additionally, Defendants don't

disagree that the emails are obscene. They don't call that allegation, hogwash.

4. Defendants and others have thus far used or committed a Billion Dollars; stolen from

healthcare and public funds. The leader is Medstar. There is an ongoing controversy where The

District did not renew Medstar's contract to be a MCO for the Medicaid program. The District

found that Medstar is denying nearly all pharmacy claims. This means that Medstar pockets this

money. The District found that Medstar had a large number of hospitalizations. This means that

Medstar, which owns the hospitals; pockets

15

that money. An active case in This Court Case Number 2017 CA 8488 P(MPA). The shooting of
the Congressman brought attention to WHC. USA Today reports that he suffered repeated life

threatening infections. That employees wear biohazard suits for simply walking around.

Consumer Reports calls WHC “out of control” for infections and safety. HHS gives Medstar the

lowest safety rating. The Leapfrog report shows that Medstar's Georgetown Hospital maintained

a “B” rating during the past 3 years; but WHC fell from “C” to “D”. Medstar has been forcing

retirements upon it's top surgeons, and layoffs of other employees. And it was in the news in

2016 because of massive hacking against it's computers, which came about consequent to

Medstar gutting it's budget for cyber-security. There is a whistleblower case in federal court,

alleging billing Medicare for unneeded hospitalizations; and WHC is the lone hospital defendant,

denied it's motion to dismiss.

IV. A flurry of additional tortious conduct since instituting This Suit

1. It is well established that Defendants have a campaign of leveraging and bribing, breaking

firewalls and unlawfully accessing info. Plaintiff uses Montgomery County libraries

computers for some activities related to this matter; they unlawfully monitor his computer

use. The day before filing the DC civil case, Plaintiff downloaded and printed the civil

cover sheet and summonses. So they knew that he would be going to DC Superior Court.

Nothing had worked to get the ex-con neighbor to stop unlawful hunting, which is not

hunting at all but crimes related to crush-fetish. What stopped it for months was

identifying on YouTube that Tom Manger is doing those crimes, using the ex-con. On the

morning of 11/16/2017; the activities of the ex-con resume, and they were much more

aggressive than in the past. He was shooting for several hours. This is

16

even during all the morning school vehicular and foot traffic. In the past, he would shoot from a

second floor window, across the street, at the base of a tree, right at the street. But this time he
was shooting well beyond and within a couple of feet of the house.

2. Then after filing the case; the crank calls to Plaintiff's mother that averaged one per day,

became 9 per day. The new email domains began to be used. In the Complaint, it shows a

bizarre harassing phone call campaign, aimed at Plaintiff's mother, who is 72 and Plaintiff

is 47; that they act out as though he is a toddler and his mother is in her 20's. Like the

brain surgeon in California getting women to have sex with their own young children.

The emails include “Readyforanyandall.com” “ultrapreparedforlife.com” signaling that

they are not giving up on their crimes, and will even create new schemes. Five days in a

row, there was an email sent; as before an innocent image is sent for the sake of a

perverted meaning. A young couple is shown with a toddler son, who is reaching up

hugging his mother and kissing her. An email with the image of a father and 6 year old

daughter in a very cramped tent. Other emails have domain names of: “noshamfam.com”

“parenthoodnavigation.com” “familiarfamilies.com”. One of the older ones

“Childproofassuagements.com”. “Coverwhatyoucherish.com” What they mean is that

parents cherish their children, so they should perhaps lie on top of them. The email is

titled “The best travel advice for traveling with kids from a seriously cool mom”. There

is a link that goes nowhere, an article saying “Turn your bedroom into a luxury hotel with

this five-star bedding. Sleep like you're on vacation every night”. Perhaps, on vacation

parents and children share the same room, so practice at home. Then a link to a legitimate

news story “Father and daughter share last flight together as pilots”; but in these perverts'

mind they think incest.

17

3. More from their riddle website: Riddle me this? I am useless when together but useful

when I am broken apart. What am I? An egg. What they mean is that I'm useless to
 them, when healthy; but when my brain is broken; then I am useful to them. Another one

“32 white horses on a red hill. First chomping, then stomping, then standing still”. This is

a large number of White women, close to 32, doing the crush-fetish. There is a riddle

where the answer comes up “chocolate”. These White perpetrators persist in using this

sexual innuendo referring to Black men; even with the case sitting in a venue with a large

African American population and a local government, including The Mayor of that race.

These perverts admit that they are sick. They have a new domain name that starts with

“vr6k”. This is like reading vanity plates v r sixk. Some of these emails are from some

fake company named “Otter Travel”. At the bottom of these messages, it says “Sea otters

hold each others hands as they sleep to keep from drifting away from each other”.

This means that they are all going to stick together for their common design crime. And

they admit their conspiracy. That each one fully shares in the conduct of all.

4. Plaintiff served the civil case papers using certified mail; a method the court says has

worked well. Some very strange things occurred with the delivery process, and with the

return of the confirmation. It does appear that they bribed the mail man, likely multiple

Postal employees. At the same time, taunting that they did this. Some fake thing called

“Factbee” is sent in an email. The fact they teach is “The Postmaster General of the

United States is the second highest paid government official after the President”.

5. In January, Plaintiff used the library computer to print a listing of the domain addresses,

that Defendants registered. There are websites that list all domain names registered to the

same registrant. Plaintiff found that even after the case was filed, these even more names

18

were registered; including “hemlockharpoon.com” and “enormouscuteel.com”. The way things

have been, is that, whenever Plaintiff appears to be advancing, they do something to strike back.
And do so in some absurd ways. They throw away public money, and they harm people not

connected to Plaintiff, because they want the sensation that their sadistic crime is vibrant. Until

2013, Plaintiff's neighborhood was quiet with zero police activity. Within a couple of days, in

January, 2018, Manger's police conducted a huge operation to arrest someone within eyesight of

Plaintiff's house. Then Plaintiff looked back retrospectively to 2014, where Manger's police were

arresting a man who for months walks for exercise in the neighborhood.

6. The dehydration caused by the brain injury, gets worse and worse. In late January, 2018,

a flu came on. The dry lungs were causing great difficulty in breathing and non-stop

coughing, very loud noises with breathing, and could not sleep. 2/3/2018, Plaintiff went

went to the assigned Medicaid doctor, Dr. Macarthy. Reading the emails shows that

Defendants sent a barrage of 7 emails during those few minutes. An email that they

would repeat many more times in the days to follow has the title “Oil up”, and shows the

image of fresh motor oil pouring out. Then writing “keep your engine running quiet”.

This is a mocking reference to Plaintiff's injuries, that Defendants caused.

7. This doctor gave antibiotics, and with the first dose, the flu was knocked out. Plaintiff

asked for treatment for the dehydration to end the problem with the dry lungs. This

doctor did not provide this treatment. Instead, as Defendants often did, he treated

ignoring the underlying injuries. He gave an asthma inhaler with a Beta-agonist drug, a

drug that acts on the blood vessels. This does nothing for dryness in the lungs. It did

great harm because of my existing injuries. There was great tightness in the lungs and

19

throat, and Plaintiff lost his voice. He stopped using it, and those new problems went away with

the exception of the lost voice. This is what Defendants enjoy.

V. Plaintiff has at least 1 claim that is likely to succeed on it's merits

 Plaintiff filed responses to Defendants Motions to Dismiss. Not a single Defendant filed a

reply. Plaintiff's brief quoted directly from The Complaint to show that: there is jurisdiction for

This Court for all Defendants, several theories to defeat statute of limitations challenges, and that

full claims with all elements were stated. Plaintiff' showed some claims more strongly than

others. The tortious interference claim was supported by the federal court in Maryland. The

battery is ongoing by the broken egg that Defendants created. Defendants had inherent duties to

heal, with doctor-patient type relationships and there is a duty to save, arising out of having

caused the injuries. There is the assault claim, with no completed battery. This is Plaintiff's

reasonable apprehension by combining Defendants' threatening emails, actions to block medical

care, and the existence of the cracked egg Defendants created. And it is the stand-alone active

assault claim that most necessitates immediate action from This Court, to shut off the crime.

VI. Relief Requested

A. That Defendant Medstar Health is prohibited from operating a Managed Care

Organization for The District of Columbia's Medicaid program.

B. Tthat Defendant Medstar Health is prohibited from providing services, within The

District of Columbia, to enrollees of Maryland's Medicaid program. This injunction does not

prohibit emergency room encounters for enrollees of Maryland's Medicaid program, for

emergencies occurring, while visiting The District. C. That Defendants Medstar Health, Jeff

Jacobson, M.D., Sonalee Kulkarni, M.D., Shannon McMahon and General Conference of

Seventh-day Adventists, remove, heal; all bodily injuries placed upon Plaintiff Joseph Crussiah's

20

body, including the progression of these injuries.

C. That Defendants Medstar Health, Jeff Jacobson, M.D., Sonalee Kulkarni, M.D., Shannon

McMahon and General Conference of Seventh-day Adventists, to obtain Plaintiff with his Social
Security Disability benefits. This is consists of approximately $120,000 in payments in arrears,

$1100 monthly, and Medicare coverage. In the alternative, Defendants must pay this money to

Plaintiff, and must pay premiums for health insurance equal to Medicare. It is further

D. That Defendants Medstar Health, Jeff Jacobson, M.D., Sonalee Kulkarni, M.D., Shannon

McMahon and General Conference of Seventh-day Adventists and others they act in concert

with, cease and desist from further abusive conduct and unlawful conduct.

VII. Defendants suffer no harm

The relief request is less harsher than orders issued to individuals, compelling to pay child

support, move out of the house, give up Second Amendment Rights. And no harsher than

disciplinary actions by medical boards. Jacobson, for instance, in 2005, had been ordered to

immediately stop operating his MRI facility. Defendants have committed horrible crimes, and

because the conduct includes government officials and additionally Defendants and government

officials are friends, they have evaded punishment. All the Injunction seeks is for is to restraint

the factors that allow Defendants to keep pursuing further crime. When: the cracked egg is

healed, Plaintiff has his basic money from Social Security, Plaintiff gets Medicare with Social

Security Disability where he can go far away from Defendants for medical care, Medstar doesn't

control The District's Medicaid funds and Maryland doesn't send money to Medstar in The

District, the crime with fizzle.

VIII. Public Interest is same and aligned with Plaintiff

Ending a massive crime, no crimes against The Public, good medical care and good

21

stewardship of public and healthcare resources.

IX. Conclusion

During the first week of January, Plaintiff was in a discussion with The Clerk of The Court's
staffer about Defendants disrupting certified mail and denying Plaintiff a simple return receipt.

So there is a very good witness that Plaintiff had not lost his voice. Then at the last week of the

same month, Plaintiff lost his voice, something that could have been prevented by seeking

immediate relief when the case was filed in November. But those same injuries that caused the

loss of voice, also limited Plaintiff's output to filing The Complaint, and nothing more. Again

taking on Defendants statute of limitations and jurisdiction defenses. This impairment occurred

in 2018, and Plaintiff is going to have to speak during the hearing and even with the clerk's

office, all in The District. All the while, Plaintiff a Maryland Medicaid beneficiary has a right to

get all these injuries treated, and the designated treatment site is two miles from this court on

Irving Street, and Defendants block this, such that Plaintiff's condition gets so bad, and then

they'll take him to that site, not for treatment though, but as their emails say, “useful only when

broken” and to do all those sadistic acts promised in those emails. In light of the foregoing,

Plaintiff Joseph Crussiah, respectfully requests This Court to Grant either the TRO or Preliminary

Injunction or some alternative the brings about an end to all vestiges of this crime.

Respectfully Submitted,

Dated February, 22, 2018

Joseph R. Crussiah
Pro Se Plaintiff
9701 Cottrell Terrace
Silver Spring, MD 20903
240-475-7737

crussiah@yahoo.com

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 SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION-CIVIL ACTIONS BRANCH

JOSEPH CRUSSIAH, *
*
Plaintiff, * Civil Case No. 2017 CA 007694 B
* Civil II, Calendar I
v. * The Honorable John M. Mott
* Next Event: Initial Scheduling Conference
MEDSTAR HEALTH, et al., * February 23, 2018
*
Defendants. *

ORDER ON PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION

The Court has considered Plaintiff's February 21, 2018 Motion for Preliminary Injunction,

Plaintiff's Memorandum of Points and Authorities in support thereof, any opposition thereto, and

the applicable law.

For the reasons set forth in Plaintiff's Memorandum of Points and Authorities, The Court

believes that Plaintiff is likely to succeed on the merits of one or more of his claims. This Court

finds that Defendants have not denied allegations, nor challenged Plaintiff's exhibits from The

Complaint and have not denied allegations from Plaintiff's Responses in Opposition to

Defendants' Motions to Dismiss, Defendants never filed reply briefs. The Court further believes

that Plaintiff will suffer an irreparable injury in the absence of a Preliminary Injunction, and that

the harm to Plaintiff in the absence of a Preliminary Injunction outweighs any harm to

Defendants by the injunctive relief requested. Finally, the public interest is tied to Plaintiff's

interests. The Public will suffer injuries, with the injuries most greatly suffered by The District's

Medicaid enrollees, in the absence of a Preliminary Injuction.

Accordingly, this _______ day of _____________, 2018, it is hereby

ORDERED that Plaintiff's Motion for a Preliminary Injunction is GRANTED. It is further

 ORDERED that Defendant Medstar Health is prohibited from operating a Managed Care

Organization for The District of Columbia's Medicaid program. It is further

ORDERED that Defendant Medstar Health is prohibited from providing services, within The

District of Columbia, to enrollees of Maryland's Medicaid program. This injunction does not

prohibit emergency room encounters for enrollees of Maryland's Medicaid program, for

emergencies occurring, while visiting The District. It is further

ORDERED that Defendants Medstar Health, Jeff Jacobson, M.D., Sonalee Kulkarni, M.D.,

Shannon McMahon and General Conference of Seventh-day Adventists, remove, heal; all bodily

injuries placed upon Plaintiff Joseph Crussiah's body, including the progression of these injuries.

It is further

ORDERED that Defendants Medstar Health, Jeff Jacobson, M.D., Sonalee Kulkarni, M.D.,

Shannon McMahon and General Conference of Seventh-day Adventists, to obtain Plaintiff with

his Social Security Disability benefits. This is consists of approximately $120,000 in payments

in arrears, $1100 monthly, and Medicare coverage. In the alternative, Defendants must pay this

money to Plaintiff, and must pay premiums for health insurance equal to Medicare. It is further

ORDERED that Defendants Medstar Health, Jeff Jacobson, M.D., Sonalee Kulkarni, M.D.,

Shannon McMahon and General Conference of Seventh-day Adventists and others they act in

concert with, cease and desist from further abusive conduct and unlawful conduct.

This injunction shall remain in force until final disposition of the case.

_____________________________________
The Honorable John M. Mott
Associate Judge
Superior Court of The District of Columbia

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COPIES TO:

Joseph Crussiah
J. Johnathan Schraub
Michael T. Marr
Jared Green
Meghan Casey
Kevin DeTurris
Via CaseFileXpress

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