Federal Complaint Against Governor Jerry Brown, Medical Board

'-" '--"
Billy Z. Earley P.A.

1 2144 Wembley Lane
2 Corona, California 92881
3
Telephone: 714-615-4956
Email: bze2101 @aol.com
ORIGINAL
Guven Uzun M.D. FILED
4 4712 Admirality Way, Suite 925 APR 0 2201a
5 Marina Del Rey, California 96259
CLERK , u.s. DISTR I.cr COURT
Telephone: 310-867-5556 EASTERN DISTRIC T OF CALIFOR NIA
6 Email: medicalexpertl @gmail.com ~------~~~-----
DEPU TY CU R~
7 Attorneys for Plaintiffs

8
In Propria Persona, pro se Litigants
10 UNITED STATES DISTRICT COURT

11 FOR THE EASTERN DISTRICT OF CALIFORNIA
12
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13
COMPLAINT
14 BILLY Z. EARLEY P.A.; I
GUVEN UZUN M.D., I 1. VIOLATION OF THE UNITED STATES
15 I CONSTITUTION (42 U.S.C. § 1983)
Plaintiffs, I 2. RACKETEERING INFLUENCE CORRUPT
16 V. I ORGANIZATION ACT (18 U.S.c. § 1964)
17 I 3. VIOLATION OF OATH OF OFFICE
EDMUND GERALD BROWN JR. , I PUBLIC OFFICIAL (5 U.S.c. § 7311)
18 Governor of California, in his Official I 4. VIOLATION OF FEDERAL CIVIL RIGHTS/
Capacity; and XAVIER BECERRA, I UNFAIR IMMIGRATION (8 U.S.c. § 1824B)
19 Attorney General of California, in his I 5. REQUEST FOR PROTECTIVE COURT
20 Official Capacity, and DOES 1 - 10 I ORDER PURSUANT TO (FRCP RULE 65)
I 6. DECLARATORY AND INJUNCTIVE
21 I RELIEF
Defendants, I
22 _ _ _ _ _ _ _ _ _ _ _ _ _ -' JURY TRIAL DEMANDED
23
24
Billy Z. Earley P.A. and Guven Uzun M.D. ("Plaintiffs" ), brings this civil action against
25
26 Edmund Gerald Brown Jr. , and Xavier Becerra ("Defendants"), in their official capacity
27 for declaratory and injunctive relief. Plaintiffs allege the following:
28
1
COMPLAIN T FOR DAMAGES
1. Plaintiffs are US citizens residing in the state of California and subject to
2 copious adverse effects promulgated by the actions of defendants. Plaintiffs seek to
3 invoke the federal power of this Court pursuant to Article III, Section 2, and Clause 1 of
4
the US Constitution. Plaintiffs are adverse parties who have genuine interest at stake in
5
6 this instant action and controversy. Muskrat v. United States, 219 U.S. 346 (1911).
7
2. Plaintiffs seek redress for improper state laws implemented and enacted by
8
9 defendants that violate the United States Constitution. In addition, defendants allegedly
10 violated federal law with respect to the Racketeering Influence Corrupt Organization
11
("RICO") statute and unlawful violation of Oath of Office, pursuant to 5 U.S.C. § 7311.
12
3. Plaintiffs assert a genuine cause of action even though monetary relief is not
13
14 pursued; in suits for declaratory and injunctive relief. Davis v. Passman, 442 U.S. 228,
15 239-40 n.18 (1879). Plaintiffs have a legally protected interest as citizens of the United
16
States and residing in the state of California. Plaintiffs also have a protected concrete
17
18 interest as healthcare providers and defendants ' actions have led to injury and avid harm.
19 4. Plaintiffs assert that redress is likely as opposed to merely speculative and

20
the injury will be redressed by a favorable jury trial decision. Lujan v. Defenders of
21
Wildlife, 504 U.S. 555, 560-61 (1992). The law in support of plaintiffs' standing in this
22
23 action provides its roots in article Ill' s case and controversy requirement. Summers v.
24
Earth Island Institute, 555 U.S. 448, 492-93 (2009). "It Is As Much The Duty Of
25
Government To Render Prompt Justice Against Itself, In Favor Of Citizens, As It Is To
26
27 Administer The Same, Between Private Individuals" ABRAHAM LINCOLN.
28
2
COMPLAIN T FOR DAMAG ES
PRELIMINARY STATEMENT
1
2
5. In this action, Plaintiffs are seeking several remedies to enforce federal laws
3
by preliminarily enforcement of the California Constitution and the Constitution of the
4
5 United States of America. Plaintiffs are seeking declaratory and injunctive relief against
6 defendants to stop further harm and correct ongoing federal and constitutional violations.
7
6. The defendants have purposely enacted laws that obstruct or otherwise
8
9
conflict with federally protected laws. Defendants have adopted policies and procedures
10 not consistent with the California Constitution, and in violation of the United States
11
Constitution, inter alia, Senate Bill 54, the sanctuary state law ratified in 2017.
12
7. The portrayal of Senate Bill 54 and years of improper pro-immigration laws
13
14 have led to a Constitutional crisis in the state of California, leading to the worst homeless
15 disaster seen in the US. The defendants are responsible for providing leadership and
16
vision for the State Attorney General ' s office and the California Constitution. By
17
18 adopting and promoting laws that clearly violate federally protected rights; defendants
19 have created a cause and effect condition where California state and federal government
20
officials are now also engaging in parallel Constitutional violations and malfeasance.
21
8. The defendants' transgressions have far-reaching implications, affecting
22
23 the core values of our republic; this affects judicial, law enforcement, administrative
24
laws, jobs and pay scales, healthcare displacement of jobs for American Doctors and
25
Nurses by foreigners and non-American citizens. In addition, unlawful immigration has
26
27 led to the over prosecution and persecution of professional nurses and doctors by design.
28
3
COMPLAINT FOR DAMAGES
9. The sovereign people of California have suffered great harm and Plaintiffs
1
2 are seeking equitable remedy against defendants for declaratory and injunctive relief.
3 Plaintiffs are appearing in propria persona ("pro se") in this instant action and we are
4
requesting the following relief from this Court, respectfully:
5
6 a. A Court Order to remove California Attorney General Xavier Becerra from
7 Office and a permanent injunction barring him from holding or running for
8
Public Office in the State of California, pursuant to 5 U.S.C. § 7311 ,
9
b. A Court Order to impanel the Grand Jury to investigate California Governor
10
11 Edmund Gerald Brown, a public official, for federal corruption charges and for
12
violation of the Racketeering Influence Corrupt Organization Act of 1970, and
13
Pursuant to Section 18 U.S.C. § 1964(c),
14
15 c. A temporary and permanent injunction enJommg the defendants from
16 exploiting the Sovereign people of California by assessing improper taxes,

17
fines , or payments to support illegal immigration that violates federal laws,
18
d. A temporary and permanent injunction against defendants and their agencies
19
20 for violation of the American First Policy, by over prosecution of American

21
heaIthcare providers in California in a scheme to hire non-American doctors
22
and nurses from foreign countries pursuant to 8 U.S. Code § 1324B , and
23
24 e. Plaintiffs seek Protective Order restraining the defendants and their agents from
25 threatening harm, injury, retaliation, and any further abuse against plaintiffs,
26
their families , employers, or their businesses, pursuant to FRCP Rule 65.
27
28
4
JURISDICTION AND VENUE
1
2 10. The Court has jurisdiction over this action under 28 U.S.C. §§ 1331 and
3 1345.
4
11. Venue is proper in this jurisdiction under 28 U.S.C. § 1391(b) because
5
6 Defendants reside within the Eastern District of California and because a substantial part
7 of the acts or omissions giving rise to this Complaint arose from events in this District.
8
12. The Court has the authority to provide the relief requested under the
9
Supremacy Clause, U.S. Const. art. VI, cl. 2, as well as 28 U.S.C. §§ 1651 , 2201 , and
10
11 2202, and its inherent equitable powers,

12
13. The Court has authority to impanel Grand Jury Pursuant to Penal Code
13
sections 893 , 904.6, 909 and 910. The Court has federal question jurisdiction and subject
14
15 matter pursuant to 18 U.S.C. § 1331 , 5 U.S.C. § 7311 , 18 U.S.C. §§ 1964(c), 42 U.S.c. §
16 1983,18 U.S.C.§ 1819, and Protective Orders pursuant to FRCP Rule 65(a),(b).
17
PARTIES
18
14. Plaintiff Billy Z. Earley, Physician Assistant, Healthcare Advocate. 2144
19
20 Wembley Lane. Corona, California 92881

21
15. Plaintiff Guven Uzun M.D., Medical Doctor. 4725 Admiralty Way. Suite
22
930. Marina Del Rey, California 96259.
23
24 16. Defendant Edmund Gerald Brown Jr. IS the Governor of the State of
25 California and is being sued in his official capacity.

26
17. Defendant Xavier Becerra is Attorney General for the State of California
27
and is being sued in his official capacity.
28
5
MEDICAL VIOLENCE EXCESSIVE FORCE ABUSE
1
THE DEPARTMENT OF JUSTICE
2
3 18. Foremost, the advent of sanctuary laws and regulations in the state of
4 California has led to harmful deprivations of federally protected rights and abuse of
5
American people by enacting laws that clearly harm California's Sovereignty. The
6
7 painful infliction of violence against Physicians, Mid-Level Practitioners, and Registered
8 Nurses has reached endemic stages and proportions. The recovery system of International
9
Medical Graduates and illegal migration of immigrants has placed California American
10
healthcare workers in harm' s way. The defendant' s action has led to the construction of
11
12 Medical Violence Excessive Force Abuse ("MVEFA"), harming the Medical Community:
13 a) Law Enforcement units raiding doctors and healthcare providers' offices
14
and homes with guns drawn on family/patients to criminalize medicine,
15
16 b) The use of healthcare providers family/patients as confidential informants,
17 to tamper with charts, file frivolous lawsuits, coerce false statements, etc.,
18
c) The forfeiture of doctors assets for the sole purpose of denying due process
19
and blocking their ability to defend against complaints, even misconduct,
20
21 d) Prosecutorial retaliation, threats, excessive punishment, loss of income,
22
bullying, threatening jail, false reports, and daunting plea bargains, and
23
e) The killing of doctors, massive suicides of patients and doctors, racism, and
24
25 systemic discrimination against ethnic healthcare providers of color.
26 19. The carriage of MVEF A by defendants is a measured act against medical

27
providers; a similar scheme seen in the 60 Minute DEA investigative joint report.
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6
COMPLAINT FOR DAMAG ES
A. REQUEST FOR INJUNCTIVE RELIEF TO BAR
1
XAVIER BECERRA FROM HOLDING PUBLIC OFFICE
2
3 20. Defendant Xavier Becerra violated his oath of office and Executive Order
4
10450 - Security requirements for Government employment. In addition, the US
5
6
Constitution requires an oath of office pursuant to Art. 6, cl. 3, for appointed or elected
7 officials; Becerra did not file, in violation of Government Code Section 1360, 1363(a)( 1),
8
1369 and 1770(i). See Exhibit 1. Becerra mortified the California Constitution by
9
cheering unsuitable immigration laws. He also engaged in serious misconduct that placed
10
11 American Sovereignty in jeopardy by aiding and abetting with a Criminal Enterprise.
12 I. Awans ' Brothers IT Scandal

13
21. Xavier Becerra was identified as one of the main characters involved in the
14
15
Awan' s scandal which has been verified by Fox News, Politico, National Review, Luke
16 Rosiak of the Daily Caller, and Tom Fitton, President of Judicial Watch. The IT scandal
17
involved Imran Awan, Hina Alvi Awan, Abid Awan, Jamal Awan and a family friend.
18
19 22. Tom Fitton and Luke Rosiak provided testimony to the Freedom House
20 Commission Members, which included, Louie Gilbert, Jim Jordan, Steve King, Ron
21
DeSantis, and Representative Scott Perry. They stated that the scandal was extremely
22
23 significant in terms of National Security and referred to the Awan' s Tech Group as a
24 criminal enterprise who had access to 40 house members' emails and electronic data with
25
and without their knowledge. Imran was out of the country in Pakistan for several months
26
and they had access to House Members electronic records, during the entire fiasco.
27
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7
II. Xavier Becerra Unlawful Involvement
1
2 23. The Capitol Police contacted Xavier Becerra and alerted him of the pending
3 criminal investigation against the Awans. Becerra was responsible for hiring Imran Awan
4
and his wife Hina Alvi Awan. The actions of Xavier Becerra involved clear and
5
6 conscious criminal misconduct in violation of his oath of office and in violation of state
7 and federal constitutional laws. Becerra engaged in the following deliberate violations:
8
9
• Imran A wan was hired and paid by Xavier Becerra and he was paid four (4)
times the salary amount of an average IT Tech working for the Government.
10
11 • Hina Alvi Awan, in addition to her normal pay, was paid an additional
12 30,000.00 dollars by Xavier Becerra and she was given additional payments by
13 Becerra's personal office.
14
• Abid Imran was hired by Xavier Becerra with the knowledge that he had been
15 prosecuted for Driving Under the Influence of Alcohol, and he also had a
16 Public Drunk Intoxication on his record.
17
• The Capitol Police became aware that Xavier Becerra wanted or tried to wipe
18
his server clean, after finding out about the investigation into Imran.
19
20 • The Capitol Police requested that Xavier Becerra give them a copy of the image
21
server and Becerra gave an elaborate falsified copy of the images.
22 • The Capitol Police stated that Becerra hide massive violations committed by
23 Imran and his Tech Group by falsifying the images given to police.
24
• The Capitol Police stated that Xavier Becerra interfered with an active police
25
investigation, by providing the Capitol Police with deliberate false evidence.
26
27
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8
III. Violation of the U.S. Constitution
1
2 24. Xavier Becerra pledged his oath of office as the California Attorney General
3 to uphold the Constitution of the United States. On September 16, 2017 -

4
California lawmakers passed the "sanctuary state" bill to protect immigrants without
5
6 legal residency in the U.S., part of a broader push by defendants to ... The state attorney
7 general's office (Becerra) engaged in developing recommendations that limit immigration

8
agents' access to illegal aliens personal information. President Donald Trump and US
9
Attorney Jeff Sessions publicly urged defendant Governor Jerry Brown to veto the bill
10
11 calling it "unconscionable" which Brown signed with the recommendations of Becerra,

12
thus, creating the first sanctuary state in the Union for illegal immigrants. The California
13
Constitution is clear: Section 9(a), no one who advocates to overthrown the Constitution
14
15 may not hold any office or employment under this State.
16 IV. Oath of Office Unlawful Violation

17
25. Xavier Becerra has violated Federal laws regulating the oath of office by
18
government officials along with executive orders, which further defines the laws for
19
20 purposes of enforcement. 5 U.S.C. § 7311, which explicitly makes it a federal criminal

21
offense (and a violation of oath of office) for anyone employed in the United States
22
Government (including members of Congress) to "advocate the overthrow of our
23
24 constitutional form of government". Xavier Becerra is actively advocating overthrowing
25 our constitutional form of Government by participating and implicitly passing and

26
enforcing laws (sanctuary), which are not consistent with the United States Constitution.
27
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9
V. Violation of Provisional Orders
1
2 26. The definition of "advocate" is further specified in Executive Order 10450

3
which for the purposes of enforcement supplements 5 U.S.C. § 7311. One provision of
4
Executive Order 10450 specifies it is a violation of 5 U.S.C. § 7311 for any person taking
5
6 the oath of office to advocate "the alteration ... of the form of the government of the
7 United States by unconstitutional means." It can only be "altered" by constitutional

8
amendment. Therefore, any act taken by government officials who have taken the oath of
9
office prescribed by 5 U.S.C. § 3331 , which alters the form of government other by
10
11 amendment, is a criminal violation of the 5 U .S.C. § 7311. The adoption and passing of
12
unlawful sanctuary laws is an act to overthrow the US constitution by defendant Xavier
13
Becerra. The fourth federal law, 18 U.S.C. § 1918 provides penalties for violation of oath
14
15 office described in 5 U.S.C. § 7311 which include: (1) removal from office and; (2)
16 confinement or a fine. Defendant Becerra actions were egregious and willful, thus,
17
removal of office is appropriate.
18
19
B. REQUEST FOR COURT ORDER TO IMPANEL
THE GRAND JURY TO INVESTIGATE RICO ALLEGATIONS
20
21
27. Plaintiffs' alleges that Governor Edmund Gerald Brown authorized CVS
22
23 Health, a special interest lobbying group to access confidential secret government files
24 and records; in a scheme that permitted CVS Health to engage in unlawful business
25
competition and gain rapid market shares of the community clinics by utilizing Governor
26
27 Brown' s office as a racket, thus causing significant harm and injury.
28
10
28. Racketeering Influence Corrupt Organization ("RICO") Act for civil
1
2 remedies are set forth in 18 U.S.C. § 1964(a), (b) and (c). To obtain relief under Section
3
1964(c), a plaintiff must establish that a defendant committed a violation( s) of the RICO
4
statute, and that such RICO violation was the proximate cause of injury to the plaintiffs
5
6 business or property. Holmes v. Sec. Investor Prot. Corp., 503 U.S. 258, 268 (1992). By
7 allowing CVS to gain unfair access and use of Governor Brown's controlled regulatory
8
agencies for the purpose of illegal competition and gaining market shares, this constitutes
9
a proximate cause of injury, which led to the sacrilege of plaintiffs ' businesses and harm.
10
11 29. The statute for 18 U.S.C. § 1964 provides a remedy for relief. Plaintiffs seek
12
declaratory and injunctive relief in prayer and hope that the Federal Government bring its
13
own independent "RICO" lawsuit against defendant Governor Brown which is an
14
15 appropriate relief to punish and deter defendants from committing future violations.
16 30. The Supreme Court has repeatedly emphasized that courts are vested with
17
extensive equitable powers to fashion appropriate remedies to redress unlawful conduct.
18
Swann v. Charlotte-Mecklenburg Bd. of Educ. , 402 U.S. 1 (1971). Moreover, the
19
20 Supreme Court has pointedly ruled that where "the public interest is involved ... those
21
equitable powers assume an even broader and more flexible character than when only a
22
private controversy is at stake." Porter v. Warner Holding, Co., 328 U.S. 395, 398 (1946).
23
24 31. CVS endangered public safety and created a criminal enterprise by
25 controlling taxpaying government agencies, such as; the Drug Enforcement Agency
26
("DEA"), Federal Bureau of Investigations ("FBI"), Medical Boards and their
27
28
11
investigative details, consisting of DO] employees and Police personnel. The Washington
1
2 Post and 60 Minute reports, "The drug distributors triumph over the DEA", uncovered a
3 small glimpse of the drug cartel ' s control. The DEA was lobbied from 2009 to 2016,
4
leading to improper legislation passed to weaken the DEA' s ability to go after Big
5
6 Pharma and 53 of the DEA ' s top employees, switched sides after the deal was complete.
7 32. In addition, plaintiffs seek injunction because it is the quintessential

8
equitable order designed "to prevent and restrain" violations of law under 18 U.S.C. §
9
1964(a). An injunction is a "coercive remedy" whereby the "defendant is enjoined by a
10
11 prohibitory injunction to refrain from doing specific acts; or he is commanded by a

12
mandatory injunction to carry out specified acts." DOBBS, Vol. One at 59; see also. id. at
13
223-277.
14
15 33. Plaintiffs' claims against defendant Brown for civil RICO, pursuant to 18
16 U.S.C. § 1964 entitlements are plausible and the statutory elements required are satisfied
17
pursuant to codes, which provides four elements: (1) conduct (2) of an enterprise (3)
18
through a pattern, and (4) of racketeering activity. In addition, each RICO claim must be
19
20 properly analyzed with respect to individual elements:

21
I. Conduct Analysis: Brown received a certified letter in November of 2015 ,
22
demanding for an investigation into one of his agencies MBC for corruption. A fact that
23
24 was declined by Brown and Becerra. The complaint revealed that MBC and DO]
25 investigators were identified tracking and monitoring a lawsuit filed by plaintiff Earley
26
against CVS. The suit outlined CVS unlawful conduct with respect to informing
27
28
12
thousands of Earley patients, and thousands of doctors in California, that they were under
1
2 criminal investigation by the DEA, FBI, Police, and other regulatory agencies governed
3 by defendants. Each CVS store in the state of California, by virtue of computer, fax, and
4
utilizing their phone systems; transmitted and shared these fraudulent statements with
5
6 their customers and they sent these statements to unsuspecting doctors in California.
7 Conduct that meets threshold for RICO pursuant to 18 U.S.C. § 1964(c).

8
II. Enterprise Analysis: Defendants association and control marks this element.
9
First, CVS lobbyers are members of Governor Brown' s inner circle. CVS is one of the
10
11 top contributor' s to Brown' s campaign. In addition, CVS is actively lobbying 35 percent

12
of California' s state legislators for special interest purposes. Governor Brown has control
13
over California government agencies and his connections with CVS are undisputed. The
14
15 Washington Post and 60 Minutes televised research of the drug distributors, led by CVS,
16 showed how DEA was ran by drug distributors, by virtue of controlling and lobbying the
17
top officials in these agencies. The DEA control and infiltration was not isolated to
18
Washington DC, as their strong-arm on the DEA ' s activities were felt nationwide. The
19
20 DEA was not the only government agency under the control of CVS and the drug
21
distributors; the MBC, FBI, Police, and their control involves both state and federal
22
judicial systems in part. Brown's association and his willing to authorize CVS control
23
24 over California' s Government regulatory agencies violated 18 U.S.C. § 1964.
25 III. Pattern Analysis: Governor Brown was warned about CVS having access to
26
confidential secret files of government agencies that he and Becerra was responsible for
27
28
13
regulating. The infiltration of the DEA shows a pattern of continuity that posed a
1
2 significant threat, leading to criminal violations. CVS made false statements to plaintiffs
3
and to customers all over the us. This is a significant finding with respect to "pattern"
4
and "continuity" thresholds. The criminal threat was identified when Governor Brown
5
6 had knowledge that they were violating California competition and anti-trust laws,
7 however, Brown and Becerra turned their heads the other way; giving their approval for
8
CVS to commit criminal misconduct against California patients and doctors abroad. As
9
evidenced by the Washington Post, this pattern was captured in 2009; and documented by
10
11 doctors and patients since in 2009, as well, a correlation that draws definitive ties. CVS
12
access to government resources for the DEA and other regulatory agencies to slander
l3
doctors and scare away their patients over a 10 year period meets the threshold for pattern
14
15 analysis. Recently, Anthony Mimms M.D. from Indiana Indianapolis was awarded a $1
16 million dollar jury award for the same tactics used against California citizens and
17
doctors!.
18
IV. Racketeering Analysis: This activity involves violation of federal laws. Mail and
19
20 wire fraud are federal crimes. The principle actions of Governor Brown authorizing
21
government access to CVS Health involved mail and wired fraud. The evidence shows
22
that CVS stores in California and nationwide, such as in the case of Anthony Mimms
23
24 M.D., used their faxes , phones, and internet systems to publish fraudulent statements to
25 each other and store these false statements within their internal computer systems. CVS
26
workforce, including pharmacy staff and legal representatives, would target unsuspecting
27
28
14
doctors and patients with this unlawful data that they were illegally acqumng from
1
2 defendants regulatory agencies, a similar pattern witnessed transpiring all over the United
3
States, from 2009 to 2016, as reported by 60 Minutes and Washington Post. CVS Health
4
is the number one employer of "Physician Assistants" and ''Nurse Practitioners" in the
5
6 US. An outcome accomplished with the help of defendants by authorizing the use of their
7 agencies to function as a criminal enterprise, a phrase refen"ed to by pain doctors as "The

8
Criminalization of Medicine." This is a predatory relationship between defendants and
9
CVS causing significant harm and injury to plaintiffs and thousands of innocent doctors
10
11 and patients nationwide. An act causing injury must be an act of racketeering, not just an
12
act in furtherance of a conspiracy. Beck v. Prupis, 529 U.S. 494, 120 S.Ct. 1608, 146
13
L.Ed.2d 561 (2000). Mail and wire fraud examples were given to defendants, demanding
14
15 for an investigation into corruption, which was flat-out declined. Plaintiffs believe
16 defendants ' act to decline to investigate was in furtherance of conspiracy. See Exhibit 2.
17
Cox v. Administrator United States Steel & Carnegie, 17 F.3d 1386, l397 (11 Cir.
18
1994) (holding that predicate acts are related if they have the similar purposes, results,
19
20 participants, victims, or methods of commission, or are otherwise interrelated by

21
distinguishing characteristics, and are not isolated events; and that a plaintiff who alleges
22
a RICO violation may demonstrate continuity over a period of time by proving a series of
23
24 related predicate acts that extend over a substantial period of time and threaten future
25 criminal conduct). Ihttps:llwww.theindianalawyer.com!articles/42428-indianapolis-

26
doctor-wins-defamation-judgment-against-cvs
27
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15
C. REQUEST FOR INJUNCTIVE RELIEF
1
COURT ORDER TO STOP IMPROPER STATE PAYMENTS
2
3
34. According to the Fair Federation of Immigration Reform, Californians bear
4
an enormous fiscal burden as a result of an illegal alien population estimated at almost 3
5
6 million residents. The annual expenditure of state and local tax dollars on services for that
7
population is $25.3 billion. That total amounts to a yearly burden of about $2,370 for a
8
household headed by a u.s. citizen3 . Plaintiffs ' seeks a court order to stop these outlays.
9
10 35. The defendants' actions have led to making California the largest state in the
11 union for homelessness, discrimination, and imprisonment of its people. Sanctuary laws
12
have led to significant harm to healthcare and other fiscal outlays resulting from the costs
13
14
of medical care ($4.0 billion), public assistance services ($800 million), administration of
15 justice functions ($4.4 billion), and general governmental services ($1.6 billion).
16
36. The most effective step a state can take to discourage the arrival of illegal
17
aliens is to utilize the E-Verify screening system designed to prevent employers from
18
19 hiring illegal workers; however, the defendants have deliberately passed laws to defeat
20 this method to control illegal immigration. By adopting measures designed to
21
accommodate the presence of illegal aliens. A.B. 54, the so-called Trust Act, this restricts
22
23 the cooperation between state and local law enforcement agencies with federal
24 immigration authorities. A more recent law, A.B. 60, gives illegal aliens ' access to
25
driver' s licenses, another act the cost Californians $64.7 million dollars yearly.
26
3https:llfairus.org/issue/publications-resources/fiscal-burden-illegal-immigration-
27
california-taxpayers
28
16
D. REQUEST FOR DECLARATORY I INJUNTIVE RELIEF
1
VIOLATION OF THE AMERICAN FIRST POLICY
2
3 37. The Medical Board of California is responsible for licensing doctors in the
4
state of California. However, a significant number of doctors employed in the state of
5
California are International Medical Graduates ("IMG"). According to the Bureau of
6
7 Labor Statistic, IMG' s represent 23% of the state practicing physicians in California.
8 38. The IMG do not require US citizenship to work in California. The only steps
9
required to work in the state of California is: (i) Certification by the Educational
10
11
Commission for Foreign Medical Graduates, (ii) Find a residency program, (iii) Apply for
12 post-graduate training authorization letter, and (iv) Apply for a physician license.
13
39. Defendants have created a hostile environment and excessive enforcement
14
against American physicians with the intent to hire and or acquire IMG ' s in the state of
15
16 California, thus, displacing American physicians with Non-American physicians, in
17 violation of the American First Policl. The state of California ranks 2 D in the nation,
18
with approximately 26,000 international physicians working in primary care facilities.
19
20 40. Gloomily, defendants have racially targeted American physicians of ethnic
21 color, Blacks, Muslims, and Mexican doctors; these statistics are well-documented by
22
research and California studies. The state's practice of over prosecuting ethnic American
23
doctors and replacing them with foreign non-American workers is wrong. Plaintiffs is
24
25 requesting the Court to intervene and grant an immediate injunction to stop this practice.
26 4https:llwww.upwardlyglobal.org/get-hired/california-professional-licensing-guidesl
27 california-physician-professional-licensing-guidel
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17
E. REQUEST FOR PROTECTIVE ORDER
1
HARASSMENT, THREATS, RETALIATION, HARM
2
3
41. Plaintiffs seek a Court Protective Order restraining defendants from
4
retaliating and causing added harm. Guven Uzun M.D. ("Uzun") was the subject of the
5
6 "BIGGEST" fraud in the history of California, committed by rogue DOJ employees.
7 42. Case #1 - Medical Violence Excessive Force Abuse involving DOJ

8
corruption against doctors: The former California Chief DOJ Attorney, Dorothy C. Kim,
9
10
now a State Judge for the Superior Court of California, developed a scheme to steal
11 millions and millions of dollars from unsuspecting doctors in the state of California;
12
using their position in the Government as a disguise. The scheme involved her brother
13
Beong Kim, who heads the fraud unit for the DOJ, her husband Jeffrey Rutherford, who
14
15 is a California attorney defending against FBI and DOJ litigation, and the MBC
16 enforcement team, which includes the DOJ and MBC dully sworn police officers.
17
43. Judge Hon. Mel Red Recana benched the case BC546690. Judge Dorothy C.
18
19 Kim got her husband Jeffrey Rutherford to befriend plaintiff Uzun. After establishing the
20 friendship , Judge Dorothy C. Kim and her brother, Beong Kim, working out of the Fraud
21
section for the DOJ, launched a "bogus" investigation into plaintiff Uzun for billing
22
fraud. A charge that DOJ dropped after 3 years of Mr. Rutherford sucking the money out
23
24 of the unsuspecting doctor Uzun. The record shows MBC had knowledge of the
25 "frivolous" investigation beforehand, as they visited Uzun' s clinic before the DOJ raid.
26
Judge Kim's husband, Jeffrey Rutherford, convinced Uzun to hire him, largely, because
27
28
18
of his experience defending FBI and DOJ complaints. Judge Kim' s husband, Mr.
1
2 Rutherford, then convinced Uzun to settle for a 8-year probation with MBC due to case
3 complexity; this was a sinister agreement that Judge Kim, her brother Beong, her husband
4
Rutherford, and the MBC investigative team had planned all along. Judge Kim' s husband
5
6 charged Uzun thousands of dollars over 3 years without disclosing that his wife and her
7 brother had arranged the unlawful investigation. Uzun license was taken by the MBC
8
after he became aware of their role in the DOJ scheme. [T]hey sent 20 masked federal
9
agents with high-power guns to Uzun' s home: Bashing on his doors, Pointing guns at his
10
11 wife and 4 small children, Threatening arrest, all while Uzun' s 6 month old child lied in
12
his crib crying alone for hours! Plaintiffs request for a Protective Order is appropriate.
13
44. Case #2 - Medical Violence Excessive Force Abuse involving homicides
14
15 and violence to plaintiffs: Plaintiff Earley reported David Chai, a Walgreens pharmacist,
16 for diversion of prescription painkillers, a fact that was proven by the California Board of
17
Pharmacy and he was fined a mere $1 ,000 dollars. Chai is believed to be a DEA
18
informant and he was steadily harassing Earley' s clinic and his staff. Earley sent David
19
20 Chai a cease and decease letter in 2014 and the following day; Earley' s family was taken
21
hostage by 3 masked individuals, carrying guns, claiming to work for the DEA and
22
Police. They pointed their guns to the head of Earley' s wife and two small children. One
23
24 of the suspects assaulted Earley' s 76 year old father with his gun, sending him to the
25 hospital for 2 weeks. The police who arrived at the scene informed Earley that his clinic
26
was under surveillance by Corona Police, for allegedly treating Black patients with
27
28
19
prescription pain medications. Plaintiff Earley sent for a FOIA request and learned that
2 the DEA, and several DEA agents, were investigating him and was staked-out at Earley' s
3 home multiple times. The masked individuals left plastic tie-downs in Earley' s home, the
4
same types used by the DEA to restrain suspects. Earley believes that filing several
5
6 lawsuits against CVS and identifying the l\1BC investigative team tracking these lawsuits
7 played a significant role. The police records clearly shows the individuals stated that they
8
were employed by the DEA and Police, the same agencies that 60 Minutes proved was a
9
CVS-DEA joint relationship, and plaintiffs proved that they (CVS) had a relationship
10
11 with the l\1BC and other government agencies. The DEA has 18,000 confidential
12
informants and they are mostly targeting community doctors and their families without
13
oversight. Request for a protective order is valid pursuant to Rule 65.
14
15 *NOTICE Congressman Stephen F. Lynch, 8th District, Massachusetts; DEA
16 Oversight Hearing on Confidential Informants, November 30, 2016, stated, opening

17
remarks, "We don't know too much about the DEA confidential informant program, but
18
in Boston, FBI informants "Killed" 19 people and DEA agents were in jail for murder
19
20 and other charges 6 ." The Defendants are involved in killing doctors and this must stop!
21
45. Case #3 - Medical Violence Excessive Force Abuse involving unknown
22
State actor(s) accessing private Mortgage Accounts: The defendants and/or their agents
23
24 have unlawfully accessed plaintiffs Mortgage Account with Mr. Cooper. Plaintiff was
25 qualified to receive Federal Mortgage Unemployment Assistance for 18 months, which

26
defendants ' agencies unlawfully interfered with funding. Mr. Cooper refused to receive
27
28
20
payments in October of 2017. According to Mr. Cooper' s representatives, they advIsed
1
2 the [State] that Mr. Cooper can accept federal funding. Mr. Cooper changed its name
3 from Nationstar, after they was found guilty of the Largest Mortgage Fraud Lender Suit
4
in the history of the US in 2016. The investigation was conducted by the DOJ Attorney
5
6 General ' s Office. Mr. Cooper has not provided the names of the "State" actor(s) who
7 have accessed and apparently diverted federal dollars from reaching the home of Earley
8
and perhaps other qualified families meeting the guidelines for federal assistance. The
9
defendants and their agencies are abusing their authority and power by interfering with
10
11 federally funded programs designed to help needy families in the state of California; by
12
accessing confidential Mortgage accounts of private citizens in this state with the intent to
13
harm, injure, and harass the families requiring the assistance. This Court should grant a
14
15 Protective Order and restrain defendants from further retaliation and misconduct against
16 plaintiffs for seeking the pursuit of justice and

17
46. Case #4 - Medical Violence Excessive Force Abuse involving the
18
MBCIDOJ team tied to multiple suspicious deaths: The Death of a prominent Black
19
20 American doctor, Anthony Jackson, and a MBC employee, in the wrong place at the
21
wrong time, Cassandra Hockensin, both deaths appears to be deliberate and intentional.
22
By virtue of a public written demand, Earley, on behalf of Black Doctors Matter, has
23
24 demanded an investigation into these suspicious deaths. Anthony Jackson ended-up dead
25 several days after he publicly stated that he was going to sue the defendant' s agency
26
MBC for racism and discrimination against doctors of ethnic colorS. Doctor Jackson met
27
28
21
with the National Medical Association (NMA), the Golden State Medical Association
2 (GSMA), the Black American Political Association Committee (BAPAC), Al Sharpton

3
Action Network Group, and local reporters including the Wave Newspaper and the MBC
4
public information officer Cassandra Hockensin, who also mysteriously ended-up dead
5
6 months after she witnessed the death and mockery of doctor Anthony Jackson. Anthony
7 Jackson M.D. died only days after he brought these huge organizations together to sue the
8
MBC. Doctor Jackson' s name was placed in a research done from 1993 to 2013 , a
9
research that he publicly stated was bogus, and his name ended-up inside of this research
10
11 report as an acknowledgment; to mock his death. We believe that former CBS news
12
reporter, Cassandra Hockensin, was going to release evidence that defendant' s agencies
13
were engaged in criminal misconduct. Cassandra witnessed everything; (i) she saw the
14
15 huge meeting gathered by doctor Jackson, (ii) she heard and was aware the 1993 to 2013
16 study was a sham, (iii) she heard the group cry out racism and discrimination done by the
17
MBCIDOJ, (iv) she was aware of the sudden death of doctor Jackson, and (v) Cassandra
18
Hockensin became aware that the MBC published the 1993 to 2013 report in January of
19
20 2017, knowing it was bogus and she saw Anthony Jackson name acknowledged in the
21
report. The evidence shows doctors and employees seeking to speak out against
22
defendants illegal operations are silenced to death, literately. Plaintiffs have firm beliefs
23
24 that defendants are engaged in organized crime and this should invoke FRCP Rule 65.
25 5http://doctorsofcourage.orglprominent-black-doctor-ends-up-dead-after-accusing-the-
26 medical-board-of-discrimination!
6Youtube Video Rep. Stephen Lynch comments.
27
https://www.youtube.com/watch?v=HNeybrXvJvA
28
22
FIRST CAUSE OF ACTION
1
Violation of the United States Constitution - All Defendants
2
3 47. Plaintiffs hereby incorporate and reallege each and every allegation
4
contained in paragraphs 1 through 46 as fully stated herein.
5
6 48. Enforcement of immigration law is up to Congress, not the States, and State
7 law provisions that conflict with Congress's system of immigration enforcement are
8
invalid under the Supremacy Clause. Arizona v. United States, 567 U.S. 387 (2012).
9
49. Defendants, with full knowledge of their actions adopted AB 60, AB 450,
10
11 and SB 54, which prohibits private employers in California from voluntarily cooperating
12
with federal officials who seek to inform them of illegal aliens, which harm plaintiffs.
13
50. Defendants adopted unconstitutional law shown to cause injury and harm to
14
15 American people in the state of California. Such as the endemic homeless crisis,
16 imprisonment, discrimination of American Ethnic people of color, unfair immigration 8

17
U.S. Code § 1324-B, and forced to pay $2,875.00 dollars for each household yearly to
18
cover the astronomical debt and cost of supporting unlawful sanctuary laws.
19
20 51. American healthcare providers are subject to over-prosecution and targeted

21
by defendants with enforcement misconduct to increase foreign healthcare workers.
22
52. Plaintiffs seek injunctive and declaratory relief to invalidate the burden
23
24 positioned on the people of California from making involuntary payments, such as; fines,
25 collections, taxes, or any other unlawful practice to collect funding for illegal aliens
26
pursuant to 48 U.S.C. § 1983, or any relief the Court deems appropriate.
27
28
23
SECOUND CAUSE OF ACTION
Racketeering Influence Corrupt Organization - Edmund Brown
2
4
5
6
54. Pursuant to Article 5 Executive Order, Section 1, which provides in part;
7 "The supreme executive power of California State is vested in the Governor and he shall
8
see that the law is faithfully executed," defendant Brown failed to uphold his vowes.
9
55. Defendant Edmund Brown used his office as a gateway for allegedly
10
11 allowing CVS to gain access to confidential and secret investigative records of the DEA,
12 FBI, MBC, DOJ, and policing agencies in California. In addition, CVS employees and
13
upper management sent letters, pharmacy documents to doctors, and verbal warnings to
14
15 customers in California and across the United States; stating that they were under
16 government regulatory investigation; knowledge that is privy only to defendants.

17
56. The Washington Post research took a tinny glimpse into how the drug
18
distributors gained access and control of the DEA, through controlling their executives
19
20 and team leaders, a process that has been duplicated in other government regulatory
21 agencies, such as MBC, FBI, DOJ, and police agencies in numerous states in the US.
22
57. Governor Brown conspired with CVS by giving access to confidential
23
24 government files and allowing them to use unfair competition using Brown' s agencies to
25 point-out doctors, over prosecute them, run their patients away, leading to CVS
26
controlling the community clinic market shares, a scheme that violates 18 U.S.C. §
27
1964c. Plaintiffs request the Court to impanel a federal Grand Jury for RICO violations.
28
24
THIRD CAUSE OF ACTION
1
Violation Oath of Office Xavier Becerra
2
4
5
59. Xavier Becerra has not discharged his duties as the Attorney General of
6
7 California in good faith and he has not upheld the California Constitution, explicitly, by
8 adopting legislation and executive orders that violate the United States Constitution.
9
60. Xavier Becerra was identified by members of Congress and media outlet
10
11
news representatives; the gist of this meeting detailed Becerra' s participation with the
12 A wan' s scandal and that he had provided the Washington police with false evidence, and
13
he was accused of interfering with a criminal investigation.
14
61. Government Code 1770, subdivision (i), clearly states an office becomes
15
16 vacant on the happening of any of the following events before the expiration of the term,
17 "If his or her refusal or neglect to file his or her required oath or bond within the time
18
prescribed." Becerra consciously broke his vows, moreover, pledging his allegiance to the
19
20 illegal immigration. Becerra swore to uphold federal laws and he violated his oath and
21 promise to the people of California, in further violation of 5 U.S.C. § 7311.

22
62. The top cop must set standards for the people who look up to them. Xavier
23
Becerra showed all of California' s enforcement bodies the contrary; he was eager to
24
25 violate federal laws. Plaintiffs' seeks injunctive relief barring defendant Xavier Becerra
26 from holding any public office in the State of California due to extreme dishonesty,
27
aiding and abetting in a criminal enterprise pursuant to 5 U.S.C § 7311,18 U.S.C. § 1918.
28
25
FOURTH CAUSE OF ACTION
Federal Civil Rights Violations Both Defendants
2
4
5
6
64. The defendants ' unlawful immigration laws were intended to violate the
7 Civil Rights Act of 1964, and US labor laws in the United States, that outlaws
8
discrimination based on race, color, religion, sex or national origin.
9
65. The enactment of Senate Bill 54, Assembly Bill 103, and Assembly Bill
10
11 450, are discriminatory provisions against American citizens residing in the State of
12 California by virtue of encouraging illegal immigration, encouraging foreign non-

13
citizens, such as IMG's to hold US jobs, and making it a crime to report illegal
14
15
immigrants to federal agencies. This affects religious and national origin class members.
16 66. The Sanctuary immigration and illegal immigration violates 18 U.S. Code
17
242, which provides in part: "Whoever, under color of any law, statute, ordinance,
18
regulation, or custom, willfully subjects any person in any State, Territory,
19
20 Commonwealth, Possession, or District to the deprivation of any rights, privileges .... "
21 It is well settled that a "person" subject to liability can be an individual sued in an

22
individual capacity (see Devereaux v. Abbey, 263 F.3d 1070, 1074 (9th Cir.2001).
23
24
67. The sanctuary law provisions intrude on the privileges of American people
25 in the state of California, by virtue of not allowing people the right to report federal
26
crimes and charging them money if they exercise their rights to report federal violations.
27
These actions congruently violates constitutional rights pursuant to 42 U.S.C. § 1983.
28
26
PRA YER FOR RELIEF
2 WHEREFORE, Plaintiffs respectfully requests the following relief:

3
1. That this Court enter a judgment for injunctive relief barring California Attorney
4
General Xavier Becerra for holding public office, for violating the California Constitution
5
6 section 1360, Executing Order 10450, Oath of Office, and 5 U.S.C. § 7311;
7 2. That this Court enter a judgment to impanel a federal Grand Jury against Governor
8
Edmund Gerald Brown for violation of the RlCO Act of 1970, pursuant to 18 U.S.C. §
9
1964(c);
10
11 3. That this Court enter a judgment for injunctive and declaratory relief declaring SB 54,
12 AB 103, AB 450, in violation of federal laws for involuntary taxes, fines, and payments
13
in support of sanctuary laws that violate federal constitution and protective rights;
14
15 4. That this Court issues a preliminary and permanent injunction prohibit defendants from
16 unfair immigration, in violation of the American First Policy, 8 U.S. Code § 1324B;
17
5. The this Court issue a protective order to pursuant to FRCP Rule 65 ~ or any appropriate
18
order to restrain defendants from harming plaintiffs and their families; and
19
20 6. That this Court award any other relief it deems just and proper.
21
DATED: March 28, 2018
22
Respectfully, submitted by
23
24
25
26
27 opria Persona
28
27
C OMPLAINT FOR D AMA GES
~ ., ::-. ~ ~~ .... (\! -:'II ~w ~ ,: ·.j ·:Hr ·; ~~ ':I:::-~c
of ~ I: ~!c~ .: ~ r C~:kp"...")
"I;:"CQr;"1QQ,
u'- • 1__ O
OATH
for the Office oL ____ _Assemb 1 v "'! e mb e_r':..-.-_ _ __ _ _ __
I, ______~~~_ie r ___~_~_~.:!"!"_~ ________________________ , do solemnly swear
(or affirm) that I will support and defend the Constitution

of the United States and the Constitution of the State of
California against all enemies, foreign and domestic; that I
~'ill bear true faith and allegiance to the Constitution of the
United States and the Constitution of California; that I take

this obligation freely , without any rnental resen;ation or pur-
pose of et:asi.on; and that I will well and faithfully discharge
the duties u.pon which I am about to enter.
(; (( 2
!
---~ -
" I
I
•
X'AVIER BEc-E~P_Ri,\
-----------------
I
I
/
Subscribed and sworn to before me,
this3~~ ___day of ---g-~-~-~~~~~------

A. D. 19 ___~_?__ /~
ROBERT K. P ~ GLIA
J~STICE , THIRD APPS LLAT2 DISTRICT
2.8
MAR ! ~i 20i8
Oa~: ______~______________
~
~LA. Secr.nary of Sta!.e
;fit~i ______________N_o_ta_r_y_p_'-l_b_li_C._P_O_B_O_X_9_~_.2_~_~_;_n_~_:_:r_a_:_~_~_~t_:~_~_:_79_ ~_i~_7Ts;_a_i_o~
\ larch 2()_ 20 IS
2 1-P \\·cmbk\ !.ane

Cnrnn<l_ Ca lifornia L)2SS I
])car I)i l h- / . I~~\rk\:

-
I hLlnh. you fllr cOlllaeting the ~ eerctary o( Slate \\ith your request (or copies of the oallS
llr oj'fiee on lik \\ith this onicc '-or. Sk\·C Kim. XC\ \ icr Ikccrra, and t\ lic ia I)oom cr.
Pleasc fi nd cne losce! copies 0 f the oaths for .\a \icr Ikcerra.
Y(lU \\ill rceci \ccl a rc runJ ofS1 2. 00 \\ilhin si.\ to eight \\eeks_
\\"c \\Crl' ull~lbk 10 l()e<lL.~ an oath or onicc 011 ["or SIC\·C Kim _and : \Iici ~l 130omcr.
Pkasc Ilotc, railll re tll locatc nn (lalh nf otli cc It)r a ll indi\·iduu! does not ind ica te thut till'
indiyidual is rcquired \l) li k an uuth or orli ce purSll< nl 10 (io\·erl1I11cnt Cock seCli(lI1 1:163
or that the inJi\·idual is in yio lation or the la\\ ror t~\illlre to lile. There is no statutory or
regulatory authority prescribing the liling proccss or penalties 'or '~\ilurc to Ille an oath 01-
officc \\ilh Ihe Sec rc t<1r: or Stale pursuant to (Joycrn mcn t Code section 1363. Therefore
tlk' Secret:\n 0'- State docs not issuc certi li cates oj" no record ror oa th s 01" oi"licc.
\ ill-:ereh _
:\Olan Pub_ic Seclion

nusincss Programs Di\·ision
.ito
\ \ '. \ \\ ;-t I, \,:.1 ;!l l"

L 'i I ( - ! I) ~ . : - ,I ) ~ ;
30
9/2/2017 RE: DEA Papers etc .. .
From: Maxwell. Paul E. <PauI.E.Maxwell@usdoj.gov>

To: Billy Earley <bze2 101@aol.com>
Subject: RE: DEA Papers etc...
Date: Wed , Mar 8, 20 176:23 am
I have received the documents. Per our discussion yesterday, there is very little I can do to address the issues you have
with CVS or any other pharmacy. I will coordinate your information with our Diversion Section to insure they are aware
that some pharmacies could be providing law enforcement information to patients and others.
Regards
Paul
Paul E. Maxwell Jr.

Senior Inspector
Office of Professional Resonsibility (OPR)
Headquarters Team-B
Desk: (202) 353-1642
Cell: (305) 796-9803
From: Billy Earley [ mailto:bze2101@aol.com ]

Sent: Tuesday, March 07, 2017 7:16 PM
To: Maxwell, Paul E.
Subject: DEA Papers etc ...
Hello Mr. Maxwell,
I was looking and I am having some difficulties locating the stack of papers with all the CVS actions.
I found another one, but they are all from 2012 and 2013 , as you will see, my attorney was send in g them letters telling
them to stop it.
I sent you a few cases with the case number, these are from 2015,
I attached a copy of the SB "first page" this is the authority they say they have to tell people in court that their doctors are
under dea investigation and they are working with the dea. I don't believe it because they are involved in too much crime to
be partnered-up with ou r government. Lobbying , for sure. but partners, that should not be the case .
The DEA should ask all these doctors that they are investigating about the pharmacies. They are using you guys to scare
doctors and provide reports that lead to these unwarranted investigations.
Regards ,
Billy Earley
714-615-4956
ps,
They sent me a total of approxim ately 10 documents that I was under dea investigation , but this was told to thousands of
people and I do have affidavit, video, and other testimony that shows what they are doin g to the people who take pain
medications.
https:llmail.aol.com/webmail-std/en-us/PrinIMessage 1/2
3l
January 18,2013
john Christiansen, Store Manager

Gyen Cao , Phannacy Manager
CVS
11 0 1 Hidden Valley Parhvay
1\orco, CA 92860
Re: CVS R'( ~ 1002654: Prescriber is Physician :\' Assiszanf Billy Earley
Dear \ ,lr. Christia.l1sen and Ms. Cao:
I represent Dr. Billy Earley and First Choice Clinica Familiar of Corona. It has come to
my client 's attention that a prescription refill request submitted for his patients was
recently denied by your store, for the above-reference Rx =t o I am \.\Titing to request that
yo u provide infoll11ation in response .
The rejection fOITIl given to Mr. Earley ' s patient references (in typewrinen/computer-
printed letters) that ~'fr. Earley is "under DEA investigation: ' I know of no such
investigation, nor does Mr. Earley. If your information is inaccurate and you continue to
disseminate it, this of course could be iegally actionabie. though ~ir. Earley simply
prefers that the maner be rectified by you immediately.
I request that you promptly reply to me in VvTiting. along with any suppo rting
doc.umentation, as to ,yhether you haw knowledge or infonnation of any DEA
investigation underway concerning \r11'. Earley. arid the basis of that !'nowledge or
:nfonnation.
Please mail yourreplyandtherequestedinfonnationtomyoffice.Tha.1.lk ) ou for your

attention to this matter.
Most sincerely,
STEVE MEISTER
Anorney at Law
32.
REQU EST FOR A REFIll OR NEW PRESC RI PTION
AUTO - FAX ELECTRONICA LLY TRAN SMmED : 01 -11 - 2013 22 :20
PRESC RlB ER;
Nam e : BI LL. Y EARLEY From: CVS /pharm acy
Store :¢ 97 18
Address : UND ER DEA I NV ES'IG.A,T!O N ~; I ,Ad dress : l1Cl HI~D E N VALL EY PARK'v,/AY
CORONA; CA 92882 NORCO , CA 928 6 0
Phone: 951-520 - 1003 pr.or. e : 951 - 734 -41 81

Fax: 951 - 520-1872
Fax: 95 1-734 -4846
Or ig, Prescriber:
Patien t exp ect s t o pick-up prescription at: 01 -16-2013 a t 13 :00

FOR PATIENT:
Nam e :
008 :
Acdress:
79
Pho ne:
FOR ORIG!NAL PRESC iJUPTION : \
C'JS Rx# 1002654 Dat e Last Fil led: 12-19- 20:1\2
"
1<l ed ica tion: PROAI R HFA 90 MCG I NHALER r; jz ,: ' ~ :.-

Qty , Prescr ibed : 8,5 Gi'-l Eight a nd Fiv e Ti2!it h( s) ,, -",
~ '-- ......'
:V
\,..
'~
V \~
~' \ '" /;;~
/'" .
,,"'-'.,- -
Presc ri bed Ref iil s: 3 \ ~~ ' / '
Dat e vVritter. : 06 - 27 -2012 ; / /
S IG : INHALE 1 SPRAY EVERY 4 HOURS AS N::::DED FOR S HORTNE SS O F ,'
BREATH .I
Pharmacy Comments :
PR ESCIUBER ACTION REQUIRED:

"
"\ /
>.: -s:-~ t ime plus additio na l refill s
~ ------~
:, til Not Au thori zed " \
Presc riber Comments :

I
II P r-=5~: : DEr' 5 \i2~e 1: ~:- ! r. teG J : __ ____ _ ___ _ _____ ____ Presc":ber"s CEA F . __ _ _ _ _ __ _
I
. -r '_ .oJ
· -aiS ,i l :-:..€\.- ~ ',' : -- _ ,sr-v ~, . •
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! ~ resc;",: be -: 5 S i 9 '1 3:~re : _ _ _ _ _ _ __ _ _____ __ ___ _ J~ t€ : ______ ._ .... __ __ _ _ .__
I M ,c sa"' ~ ·\ s --- .-'\'".!y . _.,~"'\t

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e, ~, '::. te,J
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-'No ;:;'u . r '
I
! -:-:~e . nfor~at!c :-' (onc.a i:-: eo:l : ~ th IS eJect:-ofiiC message ~s 'Nell as a~ :' atta;: M~ : ij::S to : n:s i7i es~a ge 2 r2 !"! ce;"iced for : l"',e
I exc lus.v e Jse of ~;, e :nte r ceo ;"ec!cient ar:c :r.c y COr;c.9 1f1 C'~ ~~ ic e r:t! a ; :>~ ; .- :v!ieg ed : ~fG:n;3~;c n . '! f YO L 3re :let the :n t e::ded
! :E(ic le nt, ~j Ease destroy an :~Dies of th is f'T".ESS2ce 2S '.I;e i ~s :!:S at:'3c h -er~ ts 311d 3c vise ~he s2::ce r :imec! ;ate !'I .
! - ----~~~--~
!I FOR cv § use ONLY : SRXl 290000000005462(
R EQU EST FOR A R EFI LL OR N E'N PRESC R I P TION
Attachment H
33
c S/pharmat
'-.--I
II Ii 1IIIIIIIIIIw" ~ I~ III III II I II
I
REQUEST FOR A REFILL OR NEW PRESCRIPTION

AUTO-FAX ELECTRONI CALLY TRAN StvnTIED: 01-04-2013 12:06
PRESCRIBER:
Name: BILLY EARLEY From: CVS I pharmacy
Store :F. 9728
Address: UNDER DEA INVESTIGA.!ION! ! ! ! Address : 1322 VI . 6TH ST.
CORONA, CA 92882 CORO NA, CA 92882
Pho ne: 951-520-1003 Phone: 951-371 - 904 7

Fax : 951-520 -1 872 Fax: 951-817-8629
Orig. Presc ribe;-:
Patient expects t o pick-up prescription at: 01 -09 -2013 at 13:05

FOR PATIENT:
Name:
003:
Address : "- - - - - - - -- -- - - -
CORONA, CA 92882
Phone : 951-281 - 9244

fOR ORIGI NAL PRESCRIPTIO N:
CV S Rx :.i: 532172 Date La st Fi iled : 12-11-2012
""l ed icat ion: BD I NSULIN SYR ~ . 3 rvlL 3 1GX5 ; 16"
Qty . Prescribed: 100.0 EA One Hundred
Prescribed Refill s: 2
Date Writte n: 04-26 -2012
SIG: USE SEGUN LO INDICADO
Pharmacy Comments :
PRESCRIBER ACTION REQUIRED:

/ 1'/
~thorized th is t ime plus ~ additiona l refil 's
o Not Authori zed
Prescriber Comments:
i- n'2 infc ... mat;o~ ~~nt.:;"'2 .ite;--:oe::

e XC lUSiv e USE or t r. e
:;e~ in. .i s e! ec~lo n ;: :IlE5sage c.s ·...."ei: .~5 c;'. y 3t~a c r: m.e"'i:s .~~ ~h ls :Ti~ssag~.. are lr. :ended ~o r .the
i:
iec;p'e n:
a -: may ~or:ta ' r. :or.: · GE:n~ : c : or pr:v 'lege::J 1nicrma:lOt1.
.
~r yeti are I~ot tne ln te r1G ec
;""e:: ipier\:, p iecse ces~ro y a:j CO::l ieS of th is rt:essage 2S . ... ~ : j 25 i;:s c:tc: h-r: e~:s a rc ad V Ise ;::1 E sendei irnT!€c:arely .
"
FOR CVS USE ONLY: SRXl 290000000005387
REQUEST fOR. A REFILL OR NEW PRESCRIPTION
3i
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:,~,,: <,; ,-: c'-:::;<" ' '-,' ", ',: . '. .." _< -' • ,~, .0 0: .< "'q=._ ,j:~C
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i! Patient 1 Pharmacy Statement

!
~
- ,I
G
1/
;1iI+~G~a7b~ri~e~
1 ----------------'I ~\~Y~~~--~-'e-e-n-s--------Tl~v~(ru
-~ gr-c-e-
n -s;~P~b-ann
-l--aC~i~st-~-~-ffi~e~d~,'~'NU
I
~.--~!!
~ ill I: CVS (J
Los .-'\n~eles, CA
. : Earley is under investigation" Ii
I : CVS: Pharmacist 5':.ated, "We ca..nnot H
- :, ' 1' I and will not fill prescriptions from this il
II doctor, You have to find a different Ii
" II ractitioner." I:
G I! +
' ~ =D-rum
--)-'-----------------+~W~'~~~-gr
--ee-n-. ~-
,,~P~ru~kri~'d~g-e~IF=hann~~_a~c~i~=7Nf~an-7-a-~-'t-at~e~d-:7."~Nrr
~,~E~ar~1-
e)-/~
:i! Ave" Norco, CA ! i doesn't have a license . 'I}...'e cannot fill r.
., III . I
this prescription," Supervisor I!
BIll ' i Pharmacist Nguyen said, "\V~ can-t 1\
i~!~~~________________~~~______~~__-+'~B~.l~l=-ill~i~ s!~T~h~i~s~gu
~Y~i~s.n:'+.t7e~v~en~li~c~ens
~e~d~~:-f::I'
? li!1 Ronald ~ Wal-greens,6 St.,
ti1
, Phannacist stated," Biliy Earley isn't Ii
'.- I' I, I1 Corona' CA licensed. His prescriptions have been I'
- v Ij I I' red-flagged, and the DEA is I,I
:;. : _:! I ! inVestigating him, Y.)Ll should not go :1
,
I'
,
i to him a11ymore. These are fake .
1.2 ,i
·1
! prescriptions, and we will call ~he !i
13 I:
I i police on you!" Ii
I
:4 ;; Ellen i CYS, 64": St, Corona, Pharmacist Truong stated that his boss I
:11 II CA · whom he identified as "Princess" ,:;
:l5
ill
Ii , instructed him to tell her, "We can no I
11 longer flll prescriptions by Billy !i
16
:1 Earley because he is under DEA
, - investigation_
,
18
ill Nicosa
"
.,
: CYS, 6 . St_, Corona, : Pharmacist stated, "We cannot fill this I
: 9 ;' ; CA I prescription from Billy Earley's :
· office. They are u..l'lder investigation ,:
2 ~
I:
i ; by the DEA." II
~-
22
I~ J=es i CVS, 6Tii St" Corona,
1 CA
IPharmacist stated that Billy Earley's
· clinic is a «pill mill."
II
'i
23
I Melody : CVS, Ontario Ave., , CVS: Phannacist stated. "We cannot '
: Corona, CA ' fi 11 your prescription because
.
2~
III : Wal-greeus, 6 th St., IEarley is under investigation.'"
I
Billy 11,
:I!I ' . Corona, CA ! Wal-greens: Pha..""Itlac1st state{j, "We 'I ,

J
I
2 5 1:1
;:1 : cannot fill prescriptions from Billy II
2€ !:I , Earley,"
L
2 -: !!
28 II
Ii
i"!
II
IiII 17
EARLEY vs. CVS/C AREMARK a nd WALGREENS SECO;'llD AME!'IDED COMPLAINT
I', I
EXHU.!& T A
26
35
-iL: =.: .-''_.-. _" ,-,.:,.: . ~.-_ ...
r--'" ~ .- ~
:~... .-, .--." .'".;_: '...' -- - _..;:-' ':,.';'' , , '--",~
.~ ' . '
~ :. -.'; ~ :),:,-:.: . -.::J:~
- ~~ . ~ ". ~ , ~~ ,'-
, ~
II !
, ________________________~____~__________~~~~__~~____~____~~~-;
Il ~ "
1 !,!I Michael : CVS, 6U1 St., Corona, i CVS: Female oharr.r.acist stated, "'We
: CA I
can't tll1. Bill Earley's prescriptions, I'
2 11.,
3 11'\
I! Corona~ CA
th
VIal-greens, 6 Si., I He' s supposed to be in jail! "
i
'!;
Wal-greens: Pharmacist stated, "Billy I!
.,;
1
;1
'1 ! IEarley is red-flagged. We can't fill his I:
1 I ! ~~~~~ L
5 -·a- - - - - - - - --l-l-C-·"-'-S,- 6.....61",--S-t.-,C~or-on'a, : Pha..rm~cist ~tate.d, "Billy Earley ,~s
11l!II--N-fan I:
:, CA : under IDvesugatlOn by the DEA. . Ii,
s 'I
I:' Mark
i
i \Val-greens, Main St., ~ Pharmacist state-d, "Billy Earley is II
ill I Hesperia, CA I
under investigation." U
i'
~! ~
II
l
8
9 Il!1Myron ; W z.l-greens, Perris Female pharmacist stated, '<I cannot 'i
! : Bl /d., Perris, CA fill Billy Earley's prescriptions I
lC Ii I' ' because he is under DEA
I jnvestigation."
!i
Ii
I ~
~
W
:' 1 II! Ronald ! Wal-greens, W, Pico I Male phannacist stated, "I cen't filJ
:. 2 iii i B ivd., Los Angeles, I Bi lly Earley's prescriptions because I;
'I : CA ! he is not licensed. You should not be t,
:3 'I· IL -----.....L...--..----'L..E:::.:.:::~==--_ _
.~ 1 going to him." -----f
:. 4 il I
1.' 1'
15
I! ~ The patientS' iast narnes are witn:-.eld in (he Compleinl :0 pro!ecr their pr;\'~y, but willl>e m&dc confljcntial:y availab l.: 10 :he .
16
1",
I'
!i defenda.'lts in disco·..el')'.
1
.
1
~ j
le ,I'
Ii
-~ ~~ I!
fI
2C i,
I
2:
22 I;
23 IL
24 i;
25 I,
j;
-t:; ; ,
L. ~ i,
~/ -, f·
II
I
28 . '
il
1
il
III;---~~~~:;-::;::;-:-_;;_;:;_;;~-;-;-----;-;:;-77;"";~
l8~_:::;_;:;:=_:::~_:_:_:_:::-=~~~_=--i
EARLEY Ys. C VSiCA RE MARK and WALGREENS SECON D A,M ENDED CO:vIPLAINT
I; EXHB RT A
27
Case 3:15-cv-00370-, . ~P Document 1 Filed 06/19/15 Pa~c: 1 of 14 PagelD# 1
FtLED
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICID.o10ND DMSION
2D15 JUN I <1 P ~ 23
REDOUANE GOULMAMINE, M.D.
and
MIDLOTHIAN REHABILITATION
ASSOCIATES, PLLC d/b/ a The Petersburg
Spine Center
Plaintiffs,
v.
CVS PHARMACY, INC.

Service: CT Corporation System
Registered Agent
4701 Cox Road, Suite 285
Glen Allen, VA 23060
Defendant.
COMPLAINT
Plaintiffs Redouane Goulmamine, M.D. and Midlothian Rehabilitation Associates,
PLLC d/b/ a The Petersburg Spine Center (the "Spine Center"), by counsel, state as follows
as their Complaint against defendant CVS Ph8J.""1Ilacy, Inc. ("CVS" or the "Company").
NATURE OF AcTION
1. This is an action for defamation, insulting words, and tortious interference
'with contract and business expectancy. Over the last several months, CVS, by and through
employees at no less than nine of its Vrrginia pharmacies, has reckless1y and repeatedly
defamed Dr. Goulmamine and his business, the Spine Center. Among other things, CVS
employees have falsely told Dr. Goulmamine'g patients that: (i) he lost his license to
practice medicine; (ii) his license was "revoked"; (iii) he is under investigation by the DEA
and/ or the FDA; (iii) he is "being investigated" and is "under review" for writing too many
Doctors For Equal Rights For Mental and Physical Pain
DEAR MRo TRUMP PLEASE STOP CRIMES

AGAINST HUMANITY AND THE WAR
AGAINST PAIN DOCTORS-
Crimes against humanity have been committed by my govemment to promote "the war on pain
doctors" .
Strategies reminiscent of the Nazi Germany ,
• Cerebra genocide ,
• Financial strangulation,
• Terror ,
• Intimidation,
• False accusations,
• Undercover agents and assets feigning as patients
• Defamation
have been used to implement an irrational military solution to complex problems of
chronic pain and psychiatric disabilities of some hundred million Americans.
Deceptive propaganda - grass misrepresentations of CDC data and greatly exaggerated
dangers from specific subgroups to our national security or welfare- has been utilized
consistently and effectively to persecute pain doctors.
As a student of Hippocrates I ask you my president to do the right thing.
Alen J Salerian MD
38

Federal Complaint Against Governor Jerry Brown, Medical Board

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Federal Complaint Against Governor Jerry Brown, Medical Board

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'-" '--"

Billy Z. Earley P.A.

7 Attorneys for Plaintiffs

10 UNITED STATES DISTRICT COURT

27 for declaratory and injunctive relief. Plaintiffs allege the following:

2 copious adverse effects promulgated by the actions of defendants. Plaintiffs seek to

19 4. Plaintiffs assert that redress is likely as opposed to merely speculative and

6 a. A Court Order to remove California Attorney General Xavier Becerra from

15 c. A temporary and permanent injunction enJommg the defendants from

16 exploiting the Sovereign people of California by assessing improper taxes,

20 for violation of the American First Policy, by over prosecution of American

11 2202, and its inherent equitable powers,

15 matter pursuant to 18 U.S.C. § 1331 , 5 U.S.C. § 7311 , 18 U.S.C. §§ 1964(c), 42 U.S.c. §

20 Wembley Lane. Corona, California 92881

25 California and is being sued in his official capacity.

7 painful infliction of violence against Physicians, Mid-Level Practitioners, and Registered

16 b) The use of healthcare providers family/patients as confidential informants,

25 systemic discrimination against ethnic healthcare providers of color.

26 19. The carriage of MVEF A by defendants is a measured act against medical

11 American Sovereignty in jeopardy by aiding and abetting with a Criminal Enterprise.

12 I. Awans ' Brothers IT Scandal

3 to uphold the Constitution of the United States. On September 16, 2017 -

7 general's office (Becerra) engaged in developing recommendations that limit immigration

11 calling it "unconscionable" which Brown signed with the recommendations of Becerra,

15 may not hold any office or employment under this State.

16 IV. Oath of Office Unlawful Violation

20 purposes of enforcement. 5 U.S.C. § 7311, which explicitly makes it a federal criminal

24 constitutional form of government". Xavier Becerra is actively advocating overthrowing

25 our constitutional form of Government by participating and implicitly passing and

2 26. The definition of "advocate" is further specified in Executive Order 10450

7 United States by unconstitutional means." It can only be "altered" by constitutional

7 32. In addition, plaintiffs seek injunction because it is the quintessential

11 prohibitory injunction to refrain from doing specific acts; or he is commanded by a

20 properly analyzed with respect to individual elements:

7 Conduct that meets threshold for RICO pursuant to 18 U.S.C. § 1964(c).

11 top contributor' s to Brown' s campaign. In addition, CVS is actively lobbying 35 percent

24 over California' s Government regulatory agencies violated 18 U.S.C. § 1964.

7 agencies to function as a criminal enterprise, a phrase refen"ed to by pain doctors as "The

20 participants, victims, or methods of commission, or are otherwise interrelated by

25 criminal conduct). Ihttps:llwww.theindianalawyer.com!articles/42428-indianapolis-

16 California, thus, displacing American physicians with Non-American physicians, in

20 40. Gloomily, defendants have racially targeted American physicians of ethnic

6 "BIGGEST" fraud in the history of California, committed by rogue DOJ employees.

7 42. Case #1 - Medical Violence Excessive Force Abuse involving DOJ

15 *NOTICE Congressman Stephen F. Lynch, 8th District, Massachusetts; DEA

16 Oversight Hearing on Confidential Informants, November 30, 2016, stated, opening

25 qualified to receive Federal Mortgage Unemployment Assistance for 18 months, which

16 plaintiffs for seeking the pursuit of justice and

2 (GSMA), the Black American Political Association Committee (BAPAC), Al Sharpton

16 imprisonment, discrimination of American Ethnic people of color, unfair immigration 8

20 51. American healthcare providers are subject to over-prosecution and targeted

16 government regulatory investigation; knowledge that is privy only to defendants.

21 promise to the people of California, in further violation of 5 U.S.C. § 7311.

12 California by virtue of encouraging illegal immigration, encouraging foreign non-

21 It is well settled that a "person" subject to liability can be an individual sued in an

2 WHEREFORE, Plaintiffs respectfully requests the following relief:

for the Office oL ____ _Assemb 1 v "'! e mb e_r':..-.-_ _ __ _ _ __

I, ______~~~_ie r ___~_~_~.:!"!"_~ ________________________ , do solemnly swear

(or affirm) that I will support and defend the Constitution

United States and the Constitution of California; that I take

Subscribed and sworn to before me,

this3~~ ___day of ---g-~-~-~~~~~------

2 1-P \\·cmbk\ !.ane

! ~ resc;",: be -: 5 S i 9 '1 3:~re : _ _ _ _ _ _ __ _ _ _ _ J~ t€ : ______ ._ .... _ _ .__