Federal Complaint Against Governor Jerry Brown, Medical Board
Federal Complaint Against Governor Jerry Brown, Medical Board
Federal Complaint Against Governor Jerry Brown, Medical Board
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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~
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Billy Z. Earley P.A. and Guven Uzun M.D. ("Plaintiffs" ), brings this civil action against
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26 Edmund Gerald Brown Jr. , and Xavier Becerra ("Defendants"), in their official capacity
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COMPLAIN T FOR DAMAGES
1. Plaintiffs are US citizens residing in the state of California and subject to
3 invoke the federal power of this Court pursuant to Article III, Section 2, and Clause 1 of
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the US Constitution. Plaintiffs are adverse parties who have genuine interest at stake in
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6 this instant action and controversy. Muskrat v. United States, 219 U.S. 346 (1911).
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2. Plaintiffs seek redress for improper state laws implemented and enacted by
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9 defendants that violate the United States Constitution. In addition, defendants allegedly
10 violated federal law with respect to the Racketeering Influence Corrupt Organization
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("RICO") statute and unlawful violation of Oath of Office, pursuant to 5 U.S.C. § 7311.
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3. Plaintiffs assert a genuine cause of action even though monetary relief is not
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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
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States and residing in the state of California. Plaintiffs also have a protected concrete
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18 interest as healthcare providers and defendants ' actions have led to injury and avid harm.
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COMPLAIN T FOR DAMAG ES
PRELIMINARY STATEMENT
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5. In this action, Plaintiffs are seeking several remedies to enforce federal laws
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by preliminarily enforcement of the California Constitution and the Constitution of the
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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.
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6. The defendants have purposely enacted laws that obstruct or otherwise
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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
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Constitution, inter alia, Senate Bill 54, the sanctuary state law ratified in 2017.
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7. The portrayal of Senate Bill 54 and years of improper pro-immigration laws
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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
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vision for the State Attorney General ' s office and the California Constitution. By
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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
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officials are now also engaging in parallel Constitutional violations and malfeasance.
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8. The defendants' transgressions have far-reaching implications, affecting
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23 the core values of our republic; this affects judicial, law enforcement, administrative
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laws, jobs and pay scales, healthcare displacement of jobs for American Doctors and
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Nurses by foreigners and non-American citizens. In addition, unlawful immigration has
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27 led to the over prosecution and persecution of professional nurses and doctors by design.
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COMPLAINT FOR DAMAGES
9. The sovereign people of California have suffered great harm and Plaintiffs
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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
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requesting the following relief from this Court, respectfully:
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7 Office and a permanent injunction barring him from holding or running for
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Public Office in the State of California, pursuant to 5 U.S.C. § 7311 ,
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b. A Court Order to impanel the Grand Jury to investigate California Governor
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11 Edmund Gerald Brown, a public official, for federal corruption charges and for
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violation of the Racketeering Influence Corrupt Organization Act of 1970, and
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Pursuant to Section 18 U.S.C. § 1964(c),
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24 e. Plaintiffs seek Protective Order restraining the defendants and their agents from
25 threatening harm, injury, retaliation, and any further abuse against plaintiffs,
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their families , employers, or their businesses, pursuant to FRCP Rule 65.
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COMPLAIN T FOR DAMAGES
JURISDICTION AND VENUE
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2 10. The Court has jurisdiction over this action under 28 U.S.C. §§ 1331 and
3 1345.
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11. Venue is proper in this jurisdiction under 28 U.S.C. § 1391(b) because
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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.
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12. The Court has the authority to provide the relief requested under the
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Supremacy Clause, U.S. Const. art. VI, cl. 2, as well as 28 U.S.C. §§ 1651 , 2201 , and
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16 1983,18 U.S.C.§ 1819, and Protective Orders pursuant to FRCP Rule 65(a),(b).
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PARTIES
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14. Plaintiff Billy Z. Earley, Physician Assistant, Healthcare Advocate. 2144
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8 Nurses has reached endemic stages and proportions. The recovery system of International
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Medical Graduates and illegal migration of immigrants has placed California American
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healthcare workers in harm' s way. The defendant' s action has led to the construction of
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12 Medical Violence Excessive Force Abuse ("MVEFA"), harming the Medical Community:
13 a) Law Enforcement units raiding doctors and healthcare providers' offices
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and homes with guns drawn on family/patients to criminalize medicine,
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17 to tamper with charts, file frivolous lawsuits, coerce false statements, etc.,
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c) The forfeiture of doctors assets for the sole purpose of denying due process
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and blocking their ability to defend against complaints, even misconduct,
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21 d) Prosecutorial retaliation, threats, excessive punishment, loss of income,
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bullying, threatening jail, false reports, and daunting plea bargains, and
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e) The killing of doctors, massive suicides of patients and doctors, racism, and
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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),
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1369 and 1770(i). See Exhibit 1. Becerra mortified the California Constitution by
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cheering unsuitable immigration laws. He also engaged in serious misconduct that placed
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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
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involved Imran Awan, Hina Alvi Awan, Abid Awan, Jamal Awan and a family friend.
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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
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DeSantis, and Representative Scott Perry. They stated that the scandal was extremely
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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
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and without their knowledge. Imran was out of the country in Pakistan for several months
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and they had access to House Members electronic records, during the entire fiasco.
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COMPLAINT FOR DAMAGES
II. Xavier Becerra Unlawful Involvement
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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
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and his wife Hina Alvi Awan. The actions of Xavier Becerra involved clear and
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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:
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• 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.
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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.
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• 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.
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• The Capitol Police became aware that Xavier Becerra wanted or tried to wipe
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his server clean, after finding out about the investigation into Imran.
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20 • The Capitol Police requested that Xavier Becerra give them a copy of the image
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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.
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• The Capitol Police stated that Xavier Becerra interfered with an active police
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investigation, by providing the Capitol Police with deliberate false evidence.
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COMPLAINT FOR DAMAGES
III. Violation of the U.S. Constitution
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2 24. Xavier Becerra pledged his oath of office as the California Attorney General
6 legal residency in the U.S., part of a broader push by defendants to ... The state attorney
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COMPLAINT FOR DAMAGES
V. Violation of Provisional Orders
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6 the oath of office to advocate "the alteration ... of the form of the government of the
11 amendment, is a criminal violation of the 5 U .S.C. § 7311. The adoption and passing of
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unlawful sanctuary laws is an act to overthrow the US constitution by defendant Xavier
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Becerra. The fourth federal law, 18 U.S.C. § 1918 provides penalties for violation of oath
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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,
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removal of office is appropriate.
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B. REQUEST FOR COURT ORDER TO IMPANEL
THE GRAND JURY TO INVESTIGATE RICO ALLEGATIONS
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27. Plaintiffs' alleges that Governor Edmund Gerald Brown authorized CVS
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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
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competition and gain rapid market shares of the community clinics by utilizing Governor
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27 Brown' s office as a racket, thus causing significant harm and injury.
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COMPLAINT FOR DAMAGES
28. Racketeering Influence Corrupt Organization ("RICO") Act for civil
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2 remedies are set forth in 18 U.S.C. § 1964(a), (b) and (c). To obtain relief under Section
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1964(c), a plaintiff must establish that a defendant committed a violation( s) of the RICO
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statute, and that such RICO violation was the proximate cause of injury to the plaintiffs
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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
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agencies for the purpose of illegal competition and gaining market shares, this constitutes
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a proximate cause of injury, which led to the sacrilege of plaintiffs ' businesses and harm.
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11 29. The statute for 18 U.S.C. § 1964 provides a remedy for relief. Plaintiffs seek
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declaratory and injunctive relief in prayer and hope that the Federal Government bring its
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own independent "RICO" lawsuit against defendant Governor Brown which is an
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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
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extensive equitable powers to fashion appropriate remedies to redress unlawful conduct.
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Swann v. Charlotte-Mecklenburg Bd. of Educ. , 402 U.S. 1 (1971). Moreover, the
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20 Supreme Court has pointedly ruled that where "the public interest is involved ... those
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equitable powers assume an even broader and more flexible character than when only a
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private controversy is at stake." Porter v. Warner Holding, Co., 328 U.S. 395, 398 (1946).
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24 31. CVS endangered public safety and created a criminal enterprise by
25 controlling taxpaying government agencies, such as; the Drug Enforcement Agency
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("DEA"), Federal Bureau of Investigations ("FBI"), Medical Boards and their
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COMPLAINT FOR DAMAG ES
investigative details, consisting of DO] employees and Police personnel. The Washington
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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,
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leading to improper legislation passed to weaken the DEA' s ability to go after Big
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6 Pharma and 53 of the DEA ' s top employees, switched sides after the deal was complete.
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
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pursuant to codes, which provides four elements: (1) conduct (2) of an enterprise (3)
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through a pattern, and (4) of racketeering activity. In addition, each RICO claim must be
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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
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against CVS. The suit outlined CVS unlawful conduct with respect to informing
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COMPLAINT FOR DAMAG ES
thousands of Earley patients, and thousands of doctors in California, that they were under
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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
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utilizing their phone systems; transmitted and shared these fraudulent statements with
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6 their customers and they sent these statements to unsuspecting doctors in California.
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
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top officials in these agencies. The DEA control and infiltration was not isolated to
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Washington DC, as their strong-arm on the DEA ' s activities were felt nationwide. The
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20 DEA was not the only government agency under the control of CVS and the drug
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distributors; the MBC, FBI, Police, and their control involves both state and federal
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judicial systems in part. Brown's association and his willing to authorize CVS control
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25 III. Pattern Analysis: Governor Brown was warned about CVS having access to
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confidential secret files of government agencies that he and Becerra was responsible for
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COMPLAINT FOR DAMAG ES
regulating. The infiltration of the DEA shows a pattern of continuity that posed a
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2 significant threat, leading to criminal violations. CVS made false statements to plaintiffs
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and to customers all over the us. This is a significant finding with respect to "pattern"
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and "continuity" thresholds. The criminal threat was identified when Governor Brown
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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
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CVS to commit criminal misconduct against California patients and doctors abroad. As
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evidenced by the Washington Post, this pattern was captured in 2009; and documented by
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11 doctors and patients since in 2009, as well, a correlation that draws definitive ties. CVS
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access to government resources for the DEA and other regulatory agencies to slander
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doctors and scare away their patients over a 10 year period meets the threshold for pattern
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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
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doctors!.
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IV. Racketeering Analysis: This activity involves violation of federal laws. Mail and
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20 wire fraud are federal crimes. The principle actions of Governor Brown authorizing
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government access to CVS Health involved mail and wired fraud. The evidence shows
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that CVS stores in California and nationwide, such as in the case of Anthony Mimms
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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
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workforce, including pharmacy staff and legal representatives, would target unsuspecting
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COMPLAINT FOR DAMAGES
doctors and patients with this unlawful data that they were illegally acqumng from
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2 defendants regulatory agencies, a similar pattern witnessed transpiring all over the United
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States, from 2009 to 2016, as reported by 60 Minutes and Washington Post. CVS Health
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is the number one employer of "Physician Assistants" and ''Nurse Practitioners" in the
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6 US. An outcome accomplished with the help of defendants by authorizing the use of their
11 and patients nationwide. An act causing injury must be an act of racketeering, not just an
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act in furtherance of a conspiracy. Beck v. Prupis, 529 U.S. 494, 120 S.Ct. 1608, 146
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L.Ed.2d 561 (2000). Mail and wire fraud examples were given to defendants, demanding
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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.
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Cox v. Administrator United States Steel & Carnegie, 17 F.3d 1386, l397 (11 Cir.
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1994) (holding that predicate acts are related if they have the similar purposes, results,
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24 related predicate acts that extend over a substantial period of time and threaten future
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COMPLAIN T FOR DAMAGES
C. REQUEST FOR INJUNCTIVE RELIEF
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COURT ORDER TO STOP IMPROPER STATE PAYMENTS
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34. According to the Fair Federation of Immigration Reform, Californians bear
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an enormous fiscal burden as a result of an illegal alien population estimated at almost 3
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6 million residents. The annual expenditure of state and local tax dollars on services for that
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population is $25.3 billion. That total amounts to a yearly burden of about $2,370 for a
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household headed by a u.s. citizen3 . Plaintiffs ' seeks a court order to stop these outlays.
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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
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have led to significant harm to healthcare and other fiscal outlays resulting from the costs
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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).
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36. The most effective step a state can take to discourage the arrival of illegal
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aliens is to utilize the E-Verify screening system designed to prevent employers from
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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
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accommodate the presence of illegal aliens. A.B. 54, the so-called Trust Act, this restricts
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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
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driver' s licenses, another act the cost Californians $64.7 million dollars yearly.
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3https:llfairus.org/issue/publications-resources/fiscal-burden-illegal-immigration-
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california-taxpayers
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COMPLAINT FOR DAMAG ES
D. REQUEST FOR DECLARATORY I INJUNTIVE RELIEF
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VIOLATION OF THE AMERICAN FIRST POLICY
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3 37. The Medical Board of California is responsible for licensing doctors in the
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state of California. However, a significant number of doctors employed in the state of
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California are International Medical Graduates ("IMG"). According to the Bureau of
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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
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required to work in the state of California is: (i) Certification by the Educational
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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.
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39. Defendants have created a hostile environment and excessive enforcement
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against American physicians with the intent to hire and or acquire IMG ' s in the state of
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17 violation of the American First Policl. The state of California ranks 2 D in the nation,
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with approximately 26,000 international physicians working in primary care facilities.
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21 color, Blacks, Muslims, and Mexican doctors; these statistics are well-documented by
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research and California studies. The state's practice of over prosecuting ethnic American
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doctors and replacing them with foreign non-American workers is wrong. Plaintiffs is
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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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COMPLAINT FOR DAMAGES
E. REQUEST FOR PROTECTIVE ORDER
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HARASSMENT, THREATS, RETALIATION, HARM
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41. Plaintiffs seek a Court Protective Order restraining defendants from
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retaliating and causing added harm. Guven Uzun M.D. ("Uzun") was the subject of the
5
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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;
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using their position in the Government as a disguise. The scheme involved her brother
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Beong Kim, who heads the fraud unit for the DOJ, her husband Jeffrey Rutherford, who
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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.
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43. Judge Hon. Mel Red Recana benched the case BC546690. Judge Dorothy C.
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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
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section for the DOJ, launched a "bogus" investigation into plaintiff Uzun for billing
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fraud. A charge that DOJ dropped after 3 years of Mr. Rutherford sucking the money out
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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.
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Judge Kim's husband, Jeffrey Rutherford, convinced Uzun to hire him, largely, because
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COMPLAINT FOR DAMAGES
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
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Rutherford, and the MBC investigative team had planned all along. Judge Kim' s husband
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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
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after he became aware of their role in the DOJ scheme. [T]hey sent 20 masked federal
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agents with high-power guns to Uzun' s home: Bashing on his doors, Pointing guns at his
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11 wife and 4 small children, Threatening arrest, all while Uzun' s 6 month old child lied in
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his crib crying alone for hours! Plaintiffs request for a Protective Order is appropriate.
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44. Case #2 - Medical Violence Excessive Force Abuse involving homicides
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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
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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
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20 Chai a cease and decease letter in 2014 and the following day; Earley' s family was taken
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hostage by 3 masked individuals, carrying guns, claiming to work for the DEA and
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Police. They pointed their guns to the head of Earley' s wife and two small children. One
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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
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was under surveillance by Corona Police, for allegedly treating Black patients with
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COMPLAINT FOR DAMAG ES
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.
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20 and other charges 6 ." The Defendants are involved in killing doctors and this must stop!
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45. Case #3 - Medical Violence Excessive Force Abuse involving unknown
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State actor(s) accessing private Mortgage Accounts: The defendants and/or their agents
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24 have unlawfully accessed plaintiffs Mortgage Account with Mr. Cooper. Plaintiff was
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COMPLAINT FOR DAMAG ES
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
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
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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
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COMPLAINT FOR DAMAGES
with the National Medical Association (NMA), the Golden State Medical Association
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
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Hockensin became aware that the MBC published the 1993 to 2013 report in January of
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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
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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.
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https://www.youtube.com/watch?v=HNeybrXvJvA
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COMPLAINT FOR DAMAGES
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.
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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,
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
COMPLAINT FOR DAMAGES
SECOUND CAUSE OF ACTION
Racketeering Influence Corrupt Organization - Edmund Brown
2
3 53. Plaintiffs hereby incorporate and reallege each and every allegation
4
contained in paragraphs 1 through 52 as fully stated herein.
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
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
COMPLAINT FOR DAMAGES
THIRD CAUSE OF ACTION
1
Violation Oath of Office Xavier Becerra
2
3 58. Plaintiffs hereby incorporate and reallege each and every allegation
4
contained in paragraphs 1 through 57 as fully stated herein.
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
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
COMPLAINT FOR DAMAGES
FOURTH CAUSE OF ACTION
Federal Civil Rights Violations Both Defendants
2
3 63. Plaintiffs hereby incorporate and reallege each and every allegation
4
contained in paragraphs 1 through 62 as fully stated herein.
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
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 .... "
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
COMPLAINT FOR DAMAG ES
PRA YER FOR RELIEF
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
(; (( 2
!
---~ -
" I
I
•
X'AVIER BEc-E~P_Ri,\
-----------------
I
I
/
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
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 _
30
9/2/2017 RE: DEA Papers etc .. .
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
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
Re: CVS R'( ~ 1002654: Prescriber is Physician :\' Assiszanf Billy Earley
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.
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
Pho ne:
FOR ORIG!NAL PRESC iJUPTION : \
C'JS Rx# 1002654 Dat e Last Fil led: 12-19- 20:1\2
"
I
. -r '_ .oJ
· -aiS ,i l :-:..€\.- ~ ',' : -- _ ,sr-v ~, . •
_ : ~ i · ", ....... : ; -
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i :)PS ~ / ':-ia : Code C)(!1-C C [\iL. '{ )
Attachment H
33
c S/pharmat
'-.--I
II Ii 1IIIIIIIIIIw" ~ I~ III III II I II
I
Pharmacy Comments :
Prescriber Comments:
"
FOR CVS USE ONLY: SRXl 290000000005387
REQUEST fOR. A REFILL OR NEW PRESCRIPTION
3i
,dl,~
,
:,~,,: <,; ,-: c'-:::;<" ' '-,' ", ',: . '. .." _< -' • ,~, .0 0: .< "'q=._ ,j:~C
,
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;1iI+~G~a7b~ri~e~
1 ----------------'I ~\~Y~~~--~-'e-e-n-s--------Tl~v~(ru
-~ gr-c-e-
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-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"!
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.
COMPLAINT
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
'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
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