SUPERIOR COURT OF THE DISTRICT OF COLUMBIA Civil Division JOSEPH CRUSSIAH : 9701 Cottrell Terr, Silver Spring, MD 20903, Plaintiff, : v. : MEDSTAR HEALTH 10980 Grantchester Way, Columbia, MD 21044 JEFF JACOBSON, M.D. 4927 Auburn Ave Suite 200, Bethesda, MD 20814 17-0007694 SONALEE KULKARNI, M.D. 8505 Arlington Blvd, Suite 450 Fairfax,VA 22031 SHANNON MCMAHON 201 W. Preston St, Baltimore, MD 21201 GENERAL CONFERENCE OF SEVENTH- DAY ADVENTISTS 12501 Old Columbia Pike Silver Spring, MD 20904 i Defendants, COMPLAINT Preliminary Statement 1. A Jury Demand is requested. Damages exceed $1 million. Punitive Damages are sought. A federal court, in dismissing a federal claim, found concurrent jurisdiction for the state courts of The Washington DC Metro Area; The District, Maryland and Virginia. Substantial (Quinstransactions occurred, and will occur within The District, Defendants tortious conduct caused injury in multiple venues, including several in Wisconsin, Massachusetts and Texas. Defendants “state of mind” led them to cause injury in multiple venues, with the final goal being injuries in The District. With even greater specificity, injuries and harm at the Medstar campus on Irving Street in Northwest. Furthermore, the lead parties, Medstar and Jacobson are in every way, other than their choice of a paper business address, District parties. Specific award of damages are left to The Court. Defendants and other persons that they act in concert with for a common design, engage in malicious conduct. The method includes both acts and omissions; doing ongoing substantial injury and alteration of the status quo, ‘The method includes tortious interference with Plaintiffs attempts to obtain counsel. Defendants, already know and The Complaint reminds them, of what they must do, immediately. Reasonably, Defendants failure would cause Plaintiff to seek emergency preliminary injunctive relief, Reasonably, when it is that Defendants disengage from ongoing tortious conduct, Plaintiff would have counsel, and such coinsel would request to file an amended complaint, 2. The custom most relevant in the instant case, a case that claims intentional evil acts, is that in The U.S.; Whites, Caucasians do nearly all of the bizarre crimes, usually sex is involved. When Whites do rape, terrorism, etc; Whites in government and the media don't whitewash these events. This is because other racial groups commit these acts in much greater numbers. Rightly; the deeper examination and explanation for murders; goes to the African American household and community. Similarly, for terrorism; to Islam and their communities. 3. But when it comes to being sickos; rightly the focus should get deep into the private spaces of Whites. Freudian theories are often dismissed; but there is good reason that theyappear prominently in entry level psychology courses and within the practices of psychiatrists, Sigmund Freud worked with Whites, and not other races. Consequently, Freudian theories apply, exclusively, to Whites. Whites in positions of power, don't want scrutiny of Whites. To this end, Whites dismiss Freud and they whitewash all the bizarre things that Whites do. 4, The contemporaneous case of the Las Vegas mass shooting has all these Whites in power, examining for motive, They said he went to Dubai, so possibly a secret jihadi; but Dubai is not a terrorist state, and this was a cruise. Now, they are studying his brain under as microscope; and answers are not appearing. The lone theory that these Whites don't consider is a sexual motive. ‘That Paddock had a resentment towards happy young couples of his race. And he, perhaps, even obtained sexual gratification, 5. One way to term the nature of the intentional torts done against Plaintiff is non-consensual sexual hazing. This is how the courts in Italy called the case of the rape and murder of Meredith Kirchner, Italy has a substantially different legal system; this includes the role of judges. In that case, a very well-known one; at the center is Amanda Knox, a 20 year old White American woman, Knox was convicted and while serving her sentence. 6. The verdict was, wrongly overturned, with the appeals judges unwilling to consider, something equal to a murder-for-hire, where individuals not physically acting, share culpability. 7. Keeping the focus upon the original conviction; there was undisputed evidence that someone other than Knox had meticulously cleaned Knox's hair and the insides of her ears. She had great difficultly with maintaining a single consistent story. This included different versions of how her ears got so clean, Then her final version of why she wasn't concemed about blood on the bathroom floor; in a unsolicited letter she wrote that she has female roommates; she thoughtit was menstrual blood. Knox, knew specifies of the crime, which had been secret, She knew that the physical rape was done by a Black man. In a place where there are very few Blacks she swore out a set of false facts against an innocent Black man. Knox was in a very jovial and celebratory mood, including doing a cartwheel inside the police station, 8. There are so many similar well-known crimes where Whites, in positions of power, misrepresent a few facts and with that, the common link is eliminated. In the crime called the “Stanford rape”, was in no way a typical college sex assault. This was a stranger crime, and the young White man who is the perpetrator, dragged the unconscious victim from a bed, to behind a dumpster. There were such bizarre things like inserting dry leaves into her vagina. And how he got caught in the act was that he was fully clothed and thrusting on her unclothed body, while trying to record the actions. 9, Around the same time there is another well-known similar crime at Vanderbilt University. In that crime most of the offenders are Aftican American. ‘The two crimes are often linked because of the lengthy sentences in Tennessee and the virtual lack of punishment in California, With Vanderbilt crime, the lone White man involved was not spared a lengthy sentence. In Tennessee all the offenders got what they deserved; but the nature of the crime is misstated, 10. The story is presented as though the African Americans were the leaders and the White man some lackey, aiding and abetting and cheerleading. But it was the White man who brought to life, a very popular fantasy of White men. It starts with a horrible characterization of Black men; that they are out to rape White women, But the Black men cannot do this because the White man is protecting his girlfriend. The White man deliberately fails to protect his girlfriend, then hides and secretly watches the crimes against his girlfriend; for his own sexual gratification.11, The African American men can be said to be teammates of the football team; but the ‘White man had been there for two weeks, and had little connection. The White man came from California. He immediately made a girlfriend, He set her up; including taking her for drinks and poisoning her drink is some way. And he hadn't collaborated with his teammates, until taking her to them and inciting them to do the crimes that they did. Then, right away; he sent the images to his White friend back in California. 12, Hearing before the Senate Judiciary Committee, Prohibiting Obscene Animal videos in the wake of United States v, Stevens, written testimony of Kevin Volkan, professor of psychology (2010): “paraphilias are sexual disorders that involve recurrent and intense sexually arousing fantasies, urges or behaviors related to non-human objects, non-consenting persons or children, and the suffering and/or humiliation” Volkan goes on, with the topic of the crush-fetish of animals, to call the viewing of these acts to meet two contradicting fantasies in different viewers, The viewer can be a sexual sadist, and identifies with the woman torturing the animal, The viewer can also be a sexual masochist, and identifies with the animal being tortured. And all the while, physically, keeping their own hands clean, 13, Volkan discusses a “conditioning model”, of how over time with repetition an reinforcement even in an experimental setting normal subjects could be caused to be this way. “[White]Humans have the capacity to DEVELOP paraphilias in a wide variety of ways” 14, In discussing treatment “{they] do not seek treatment unless the paraphilia has resulted in legal consequences” with paraphilias, especially the more egregious types such as pedophilia said to have a high rate of relapse, even after treatment, 15. Dr. Park Dietz, a psychiatrist, is a well known expert associated with well known criminalcases. Dr, Dietz submitted a declaration on behalf of his client Gilberto Valle in the “Cannibal Cop” case. Reasonable minds can differ on this case where Valle was convicted and served more than 20 months before a reversal from a higher court. 16. “Research has demonstrated that many aspects of [WhiteJhuman sexual arousal, particularly those aroused by unconventional stimuli, do not use common sense to decide what is sexually arousing, they discover what nature and nurture has made arousing to them. All available scientific evidence is consistent with the hypothesis that itis partly a matter of chance association (conditioned learning)”. 17, Inthe DC Region, where there are nearly no murders that could be attributed to a White perpetrator; the few that exist, relate to non-consensual sexual hazing. In The District, there is the murder of Wone. It's hard to believe that he is strictly heterosexual and went to sleep in the home of three homosexual men, when his own home is nearby. Then because the three men Were successful in adjusting evidence, such that a guilt beyond reasonable doubt, could not be met, reasonably, they were not convicted. 18. There was a heterosexual couple, went to a nightspot in The District, met up with some of the man's friends, ‘The facts parallel the Italian case. Equality doesn't apply to sex hormones, ‘Testosterone and the way men are wired; men think about sex frequently and women are not, normal if they do. Prosecutors in Italy, translated said that: Amanda Knox is a nympho, a ho; and she was an exhibitionist of all this in front of her female roommates. Meredith Kirchner was not approving Knox's conduct. The combination of Knox's hyper-sexuality and rage from Kirchner's disapproving tone, caused Kirchner to want to rape and murder Kirchner, using a man as a) ;. In the Silver Spring/DC case, there is older email from the woman showing she has a proxy. privoracious sexual appetite, a nympho. At the DC wings and beer place, Buffalo Billiards, she's trying to seduce his two friends, but certainly, her boyftiend is party to all her schemes, He wants to be with her, so he'll do whatever she wants. Prosecutors in Italy called the victim “poor Meredith” and here “poor Mr. Waugh”, ‘The victim Wone was an attorney and the victim Waugh, student at Georgetown Law School, a champion in mock trials; but these sexual predators have schemes to override every barrier, Waugh, at Buffalo Billiards had chastised the woman for her conduct, that of trying to seduce her boyfriend's friends. It was reasonable for Waugh, in a bar- hopping way to follow his friend to his home. The couple didn't waste any time. Within a few ‘minutes of arrival at the efficiency apartment, Waugh is in the bathroom sending out a text that the situation is so awkward that he should gnaw his hand, so that an ambulance will come to take him out, Several minutes later, Waugh had been stabbed to death, [t appears that the woman engaged in sex with Waugh, but Waugh's conduct throughout the night indicates that he had not consented to sex. The boyfriend, not being a sociopath, with Waugh nearly dead, appears to ‘want fo save him at that point. ‘Thus ruining the likely planned cover-up, for the two biomechanical engineers. Knox knowing that a Black man raped the victim, put the blame on another Black man. The best that these two perpetrators, could salvage was for the man to call it a crime of passion, that he killed after walking in on, the victim with his girlfriend, Then after learning that such a defense isn't available in Maryland, and he gets a lengthy sentence and his girlfriend abandoning him; he says she did it, but that he didn't see it. 19, When one hears the word “masochist”, there is an immediate association with “pacifist”, and the masochist is seen as being even less dangerous than a pacifist, But, as the crush-fetish. and child pornography shows, when a sexual masochist seeks tangible content to their fantasiesand substitute others in their place; the results are entirely sadistic, a word that is an antonym. 20. What would be collaborative sex crime between men and women that first made the news was that of a couple in Canada, with the woman being Karla Homolka, Homolka was a sexual ‘masochist, and she got into this type of relationship with a man. This included inciting him to beat her. But this wasn't enough and she wanted to vicariously enjoy the rape and murders of teenage girls, including that of her younger sister, by a man she called “the king”. Then for someone who is a masochist, Homolka did many aggressive sadistic acts. Homolka kidnapped these teenage girls, restrained and drugged them, sexually assaulted them, and killed them. 21. What African Americans allege in recent years is the concept of “White Privilege”. By hook or by crook, or some other way, Whites escape accountability, The allegation is made about the disparity between the sentencing of the Black and White college perpetrators. Most recently, an African American woman, one leading a seedy lifestyle identifying herself as a stripper; made public a video of a married White man, an assistant coach with a NFL team; snorting lines of cocaine. And she further alleged that what this White man really likes is to snort lines of cocaine off her naked body. ‘Then she asserted the same thing that this Complaint asserts, that Whites holding positions of power; always whitewash and conceal all the bizarre things that Whites do. Whites are on a sex- related rampage. There is the Hollywood and media sex crime stories, ‘There are the violent acts, where the sex in not visible; as with the Las Vegas shooter. The Texas church shooting shows more than an ax to grind and some anger problem. Some criminal states of mind can be ‘managed with a mental health approach. But this does not mean that these perpetrators are mentally ill. The killer posted an image of his weapon with the caption, “she's a bad bitch”, Hestrategically shot at the exits, then went inside and roamed and wherever he heard the sounds of children, he went over and slaughtered them. John Hinckley, in his letters to Jodie Foster, wanted to be together with her. But his final letter, the letter sont just before secking to assassinate The President did not express the delusional thought that by the assassination he could then impress Foster and be with her. It expressed the very rational statement that he knows that he will be arrested, and this would end all hope that they could be together. Everything got covered up under “mental iliness bs”. ‘There was the dentist who went to Zimbabwe, targeted Cecil The Lion, a popular tourist attraction, He deliberately, sadistically, wounded the lion, ‘watched it suffer for 40 hours, and only then finished the kill. ‘There is the two 12 year old girls in Wisconsin who took their friend into the woods and slaughtered her, but the victim survived. ‘Then the cause is said to be some bs about some fictional character “Slenderman”, not tha the perpetrators enjoyed doing the crime. Plaintiff's general situation is not unique. There is regular whitewashing and covering-up of sex related crimes done by Whites. Although at the allegation stage, the New York Daily News has a cover with “Perv Nation”, shows all these White men, a full range from liberal Hollywood elite to a firebrand conservative public official, exposed for sex crimes, that could only have been hidden so long in a system where Whites protect other Whites, even Whites who are their rivals and enemies. And these protections are not limited to the powerful, they go to the lowest of the low. John Walsh reports that police deliberately botched the investigation into his son's murder, a crime done by a homeless type serial killer. ‘And in Utah, a homeless type is walking around town for months with a kidnapped girl, and nobody does anything. John Walsh reports that he had to use his own money, and hire a former police officer, working as a private detective, And these are the prevailing conditions thatPlaintiff lives under. That he has to do everything, on his own. IL Parties and Jurisdiction 23. More than a hundred parties, including The District of Columbia, The State of Maryland and its governor Lawrence Hogan, could be sued based upon the same nexus of facts. Defendants and the parties they act in concert with; effectuated a virtual dungeon, with actions including tortious interference with Plaintiffs ability to obtain counsel. Reasonably, preliminary injunctive relief or some equivalent, for the purpose of maintaining the status quo is required. Reasonably, when considering the ongoing harm suffered by the pro se Plaintiff; excluding all but the minimal parties needed to provide such relief, promotes justice and economy. 23. Plaintiff Joseph Crussiah is a resident of Maryland, residing about three miles from The District. In 2013, he needed a quick appointment with a cheap neurologist, and sclected Defendant Sonalee Kulkarni, MD, practicing at an office in Fairfax, Virginia. 24, Defendant Jeff Jacobson, MD is credited with saving the life of White House Press Secretary James Brady by using non-cutting means to reduce fluid in the brain. 25. There are opinions from This Court and DC Court of Appeals in a medical malpractice case, Pannu v. Jacobson. There, all acts and omissions occurred at Suburban Hospital in Bethesda, MD. The Courts found concurrent jurisdiction with Maryland, The rationale: that Dr. Jacobson is a District entity with one office in Maryland. All care that preceded and followed the surgery occurred in The District. The Court treated Suburban Hospital in Bethesda differently from the MRI facility in Bethesda owned by Dr. Jacobson, Suburban Hospital was found to be an independent Maryland entity, whereas; the MRI facility was found to be an auxiliary part of Dr. Jacobson's DC medical offices.26. Defendant Medstar Health, always was, and still is synonymous with Washington Hospital Center, the largest hospital in the Mid-Atlantic region. Medsta's corporate registration is in Howard County, MD, The DC Courts have rightly and consistently found that corporate registrations are essentially paper and not substance. And how true this concept is for Medstar, which primarily owns and operates hospitals, but has no such business in Howard County. 27. Medstar’s hospitals in Maryland are small and spread out. The region in Maryland that Medstar dominates is Southern Maryland, a region comprising ten percent of Maryland's population, On the other hand, in The District, Medstar commands something close to one hindred percent, By the numbers, Medstar commands sixty percent. 28. In practical terms though: Sibley is a tiny hospital. Providence has no advertising or public presence. No one knows it even exists. Howard is large and well known, and even among the African American residents; no one really wants to go there. Everyone wants to go to either Washington Hospital Center, George Washington or Georgetown; with GW being the sole non-Medstar entity, and Medstar still dominating by a ratio of six to one. 29. Ina Washington Business Journal article, Medstar says that places in Maryland, such as ‘Takoma Park is Medstar’s turf, With Washington Adventist Hospital set to relocate seven miles away; Plaintiff's region of Maryland will be even more of Medstar’s turf. Additionally, Prince Georges Hospital, another hospital close to The District is set to relocate, 30. Maryland and The District carry out their Medicaid obligations through Medicaid Managed Care. Maryland has a collaboration with Medstar to be its MCO in several parts of Maryland, “On paper” there is a choice of more than one of these MCOs, but, effectively, for Plaintiff's region, there is only one, Medstar. The primary care doctor could be a doctor in theSilver Spring-Hyattsville areas of Maryland, but every service beyond that is on the Washington Hospital Center campus. If an enrollee needs a cardiologist or a neurologist, they are referred to specialists at the doctors’ office buildings on that campus. Many of these specialists work, exclusively, with Medicaid patients. All surgeries and hospitalizations occur at The Washington Hospital Center. Rehab occurs at the Medstar Rehabilitation Hospital on that same campus. 31, Defendant General Conference of Seventhday Adventists, herein referred to as, “Adventist” is the head of the corporate structure of all things Adventist, primarily; churches and hospitals. The headquarters for this worldwide organization is in Silver Spring, MD. 32. Adventist is directly or indirectly involved in all transactions from the instant case. Adventist has acted in concert with the other Defendants. The entire group, those named as, defendants and others; have engaged in criminal conduct that is the subject of this civil case, ‘Those transactions have spanned Maryland, Virginia and The District. 33. The group is intent on committing future crime to Plaintiff, on the Medstar campus on Irving Street in Northwest. This court has jurisdiction upon the Maryland party, Adventist by several theories, including application of The District's Long Arm Statute. 34. Defendant Shannon McMahon is sued in her individual capacity. She served as a Maryland Government official, the head of the state's Medicaid operations ftom February, 2015 until July, 2017, All Defendants have been involved in all transactions. McMahon, likely was not involved in the transactions prior to February, 2015. McMahon is currently in private ‘employment in The District. Several factors, including her, essentially, lingering in town; suggest that she continues to be involved in the unlawful conduct. McMahon is sued in her individual capacity, alone, Even if McMahon is found to be a Maryland party; the District'sLong Arm Statue would apply. 35. Defendants are the “government-healthcare complex”. Doctors gave care and insurers were there as a check on spending. Then the large local hospital corporations, and local and state officials, wanting to loot, got into the game. They encourage and support the full range of crimes, not limited to money crimes; including; rape, murder, sex crimes on the cutting edge of perversion. When everyone is up to no good, there’s no one to speak out, 36. At Johns Hopkins, an OBGYN was said to have taken 1000's of images with a pen camera, He committed suicide by placing a bag over his head and pumping it with helium. This ‘means that these people know techniques that are not legitimate medical techniques. 37. For the crime said to be no more than voyeuristic images by one man; things don’t add up. Pen cameras, dangling on a chain are spy cameras, poor resolution Hopkins hired a Baltimore police chief, and soon, police closed the investigation. Police lied to reporters that a judge sealed the images. The FBI's scope was limited to determining if minors were vietims; finding no minors, In the medical setting, many women work there, and with a OBGYN clinie, it’s all ‘women. The images should be examined by an expert OBGYN. Could the conclusion show sex acts done by the male OBGYN and his female helpers to the victims? 38. There was “the death of David Rosenbaum”, and here Congress investigated based on DC Oversight. The “chain of errors” theory is not what occurred. There’s a huge report of the DC Inspector General, online. There’s also a very important 2 page addendum, which after Plaintiff started referring to it, DC Government has pulled it off their website. And there's very lazy news reporting. No one involved, ever thought that Mr. Rosenbaum was homeless. They figured he lived in that wealthy DC neighborhood. The 3 African American police officers, rightly, didn’tsuspect a crime, because the crooks, though evil, for striking the victim on the head with a pipe, were also dumb; they didn’t steal a very expensive watch and wedding band. The African American paramedic did a whole bunch of sloppy things, but no harm resulted. 39. The African American female doctor, the head of the ER and coming from a top medical school has some particulars, that fit the profile for having animus towards Jews. She is from ‘Chicago, having a “Nation of Islam” sounding name, Rosenbaum is a “rich Jew”. The doctor, sadistically; let the patient suffer and die from a rapidly progressing brain injury, with five nurses going along with it. The addendum shows that this doctor was in luck. A doctor who works under her, is also the top EMS official of DC, who showed no loyalty to the mayor who appointed him, and at the same time spared no lie, scheme and hoax to help his fellow doctor. 40. Plaintiff provides argument and evidence that he is entitled to relief for 9 Claims: Assault, Battery, False Imprisonment, Breach of Duty, Tortious Interference With Contract, and Prospective Advantage, Fraud, Violations of Maryland's Constitution, Conspiracy to Commit Assault and Battery, Aiding and Abetting Assault and Battery; all inter-dependent, and with the Complaint being lengthy, and likely being amended upon retaining counsel; the Claims are argued together. Paragraphs 1-40 are incorporated by reference; herein, 41. Defendants have stipulated to the allegations, but argue “What are you going to do about Ashort summary published on YouTube, “Joe Crussiah” channel: “Crime in progress. Early 2013: a large number of persons, men an women, from the giant local DC area healthcare entities; Johns Hopkins, Inova, Medstar, Adventist Healthcare, VCU, along with local govt. officials, including Montgomery County Police Chief J. Thomas Manger III; committed an extra-evil, extra-perverted sex crime, Not only do they, with use of video and by discussing with each other, eternally gratify themselves; but a major component of the arousal was to see me suffer greatly and die. Miraculously, I survived. What followed; as with how it was “effective slavery”, for African Americans for several years following Emancipation;