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   1: I remain one of only 2 doctors to be given this Award by Cambridge’s nurses in 27 years  
   2: Neurology Chief Dr Tom Glick described my first written complaint about Cambridge’s      negligent fraudulent Brain MRI scan reports as a “smoking gun”  
   3: Just like in Tuskegee, patients with treatable diseases are being left untreated by Cambridge      Hospital. This document is well worth your time.  
 4: A Cambridge radiologist confessed in writing that he had never even eyeballed the scan      before issuing an official report.  
   5: Cambridge Radiology Chief Dr Carol Hulka responds to my Tuskegee alert with an email      asking the hospital’s progressive leadership to retaliate against me.  
 6: Cambridge’s Fair Hearing Plan, a binding contract.  
   7 The Medical Executive Committee consciously violated the US Constitution and the hospital’s Fair Hearing Plan and Bylaws by simply robosigning on the 9th of November 2010 the demand by Cambridge’s progressive leadership to throw me out. The entire meeting lasted a total of 29 minutes and I was one of three doctors discussed within that time. It was exactly like in Soviet times. I was summarily suspended for being an imminent danger to the public. Cambridge then let 48 hours go before actually informing me and throwing me out.  
   8: The termination letter from the 11th of November, 2010, 48 hours after the summary suspension.  
   9: Cambridge’s report to the Board in 2010.  
   10: The ad placed immediately after I was thrown out and before the Fair Hearing took place.  
   11: I was immediately removed from the hospital website.  
   12: Andy Fuqua's letter reporting the report from the Fair Hearing Panel which examined sworn evidence.  
   13: The MEC’s response to my exoneration by the Fair Hearing Panel. The MEC threatened to demand I be sent for a psychiatric evaluation if I did not leave town.  
   14: The Investigative Committee’s report, written without meeting me and with the exact same charts looked at by the Fair Hearing Panel. It was a blatant unsworn do-over. They called me on a Monday in July and asked me to come that Thursday and did not tell me what I was to discuss. The Report blatantly states that had I set foot in the room the progressive authors would have demanded that I be sent for a psychiatric evaluation. The Report also states explicitly that Dr David Bor wishes for me to be driven out of the practice of Medicine entirely.  
   15: The Greeley Report was paid for by Cambridge and again used the exact same charts and allegations. It was Cambridge’s second unsworn do-over. The Report states clearly that the CV of the author is attached. Cambridge removed the CV and has not turned it over to this day.  
   16: I dragged Cambridge to Middlesex Superior in August to make the simple demand from the Court that the Government must be required to follow it’s own laws. Cambridge told Judge Edward Leibensperger that my Fair Hearing Rights have yet to be triggered. Court Transcript and denial.  
   17: Cambridge fabricated a consciously false second Termination letter in November 2011 in order to claim the Fair Hearing never took place. After all, if it never took place how could I have been exonerated? This second fabricated letter was sent to Massachusetts and the Federal Government, which makes it a double felony.  
   18: Cambridge’s report to the Board in 2011 - very different from 2010 - and another felony.  
   19: My Jan 2013 letter to the Board’s Complaints Committee proving that the Board corruptly persecuted me on behalf of Cambridge using a report paid for by Cambridge.  
   20: The email from Board Investigator Paikos proving that he quoted an expert at the 2013 Hearing. Board Investigator Paikos has been trying ever since to hide this expert. The Board has refused to produce a cancelled cheque documenting that this “expert” was paid by the Board prior to that January 2013 Hearing.  
   21: The response to my letter from the Board’s Complaints Committee.  
   22: What the taxpayer-funded government’s Board claims is it’s minutes from that January 2013 Hearing. The Board claims there is no transcript.  
   23: The Board put me on ice till May 2014 hoping I would be broken in the interim. The Board also wanted to claim it based it’s actions on the Horowitz Report from April 2013 and not the still-anonymous expert from January 2013. My speech to the Complaints cmte in May 2014.  
   24: What the taxpayer-funded government’s Board claims is it’s minutes from that January 2013 Hearing. The Board claims there is no transcript.  
   25: The Horowitz report. The Board hired a Dr Steven Horowitz from MGH (Harvard) to simply paraphrase the Greeley Report and launder it into the Horowitz Report. The whole point was to hide the fact that the Board is still using the Greeley Report that Cambridge paid for. When Dr Horowitz found out that I was not going to sign some secret consent agreement and disappear, he refused to testify under oath in open court or even issue a sworn affidavit taking responsibility for “his” Report.
   26: The Board’s Statement of Allegations, which is identical to the Greeley Report and Cambridge’s second “Investigative Committee” Report and involves the same patient charts, with one exception. One patient has been randomly dropped, as I noted in my speech in May 2014. The patient wanted to come testify against the Board and is still miffed she was not allowed to as she is not on the Government’s list.  
   27: The transcript for the Pre-Hearing Conference at DALA in August 2014.  
   28: My certiorari petition to the Massachusetts Supreme Judicial Court.  
   29: The Board motion to dismiss the certiorari petition.  
   30: My opposition to the Board’s SJC motion to dismiss.  
   31: SJC Judge Margot Botsford’s denial of certiorari review.  
   32: The doctrine of unclean hands.  
   33: DALA Magistrate Bresler’s denial of my unclean hands motion.  
   Transcripts from the Board Trial at DALA in January 2015. Jan 12  
   Transcripts from the Board Trial at DALA in January 2015. Jan 13  
   Transcripts from the Board Trial at DALA in January 2015. Jan 14  
   Transcripts from the Board Trial at DALA in January 2015. Jan 15  
   Transcripts from the Board Trial at DALA in January 2015. Jan 16  
   Transcripts from the Board Trial at DALA in January 2015. Jan 29  
   Transcripts from the Board Trial at DALA in January 2015. March 6  
   Transcripts from the Board Trial at DALA in January 2015. March 9  
   35: Transcript of my cross examination of Dr Barry Levin.  
   36: My Norfolk Superior complaint.  
   37: Cambridge’s Motion to dismiss the Norfolk case. They state that I cannot claim any harm from Cambridge’s felonies.  
   38 My Opposition to Cambridge’s Motion to dismiss.  
   39: My Opposition to Cambridge’s Motion to impound and keep secret every single document and the Judge’s denial of Cambridge’s Motion to impound.  
   Judge Denies Motions to impound.  
   40: Attorney General Maura Healey’s Motion to enlarge time to answer. I had the Board staff served by a Sheriff at the Board. They never responded within the 20 days allowed. Also Attorney General Maura Healey’s Motion to strike service at the Board. She claimed I should have served the Board staff at their homes. As if Prisoners should serve their lawsuit on the Prison Warden at his home.  
   41: My Opposition to Attorney General Maura Healey’s Motion to strike service.  
   42 Norfolk judge denies the enlargement of time for the Board staff to answer. Also Norfolk judge denies Attorney General Maura Healey’s Motion to strike service.  
   43: Massachusetts’ progressive Attorney General Maura Healey states in writing that Board Investigator James Paikos has “absolute immunity” even if he violated the Constitution or took bribes from a hospital.  
   44: Hearing scheduled on Cambridge’s Motion to Dismiss.  
   45: The Norfolk Superior case has been 'removed' to the Federal US District Court. It is now a Federal lawsuit!  
   46: I filed a Motion to hold James Paikos and his associates in Default as they deliberately ignored the Norfolk Judge's order to submit an answer before February 26, 2015. Mr Paikos is a lawyer and knows the law much better than I do.  
   47: I filed a Motion to hold the Greeley Company in Default as it ignored the deadline to file an answer.  
   48: Massachusetts Attorney General filed a Motion to Dismiss even though she knows James Paikos is in Default for 2 months already.  
   49: In an astounding move that reeks of corruption, Judge Young scheduled a Hearing on Maura Healey's Motion in favour of James Paikos BEFORE he scheduled a Hearing on my Motion to Default even though I filed my Motion first.  
   50: US Attorney Carmen Ortiz has filed a motion to dismiss on behalf of Dr Kassler and his supervisor claiming they enjoy Sovereign Immunity. Dr Kassler is the Medical Director of the Boston Medicare Office and is ultimately responsible for why Medicare never investigated my complaint about Cambridge Hospital. Turns out he is part of the Board for Dr Lucian Leape's LeapFrog Group and has published papers suddenly with Dr Leape's friends. US Attorney Carmen Ortiz clearly has no problem with that.  
   51: Federal Judge William Young issued his first decision in my lawsuit today. Judge Young denied my motion for entry of default against James Paikos even though James Paikos had flouted the order of the Norfolk Superior Judge and had not answered his summons for 2 whole months. By law the motion should not have been denied. Naturally I shall oppose this lawlessness to the fullest extent of the law.  
   52: I filed a Motion asking Judge Young to issue a written reason for denying a routine Motion for Default given that James Paikos had flouted a Court deadline not once but twice  
   53: Judge William Young instantly denied without explanation my request to explain his denial without explanation.  
   54: Judge William Young also denied my motion for default against the Greeley Company who ignored the summons and complaint for 2 months. Essentially the Judge is bending over backwards to save some private company.  
   55: I filed my opposition to Carmen Ortiz's motion to dismiss stating that she cannot claim lack of Federal jurisdiction after she herself threw my case from Norfolk into Federal Court  
   56: I filed my opposition to Maura Healey's motion to dismiss clearly stating that absolute immunity does not apply to criminals. This happens to be true even in progressive states!  
   57: All of a sudden Maura Healey sent two investigators to my home to demand immediate access to my patient charts and my computer files. She demanded complete page-by-page records for 16 of my patients and stated that she has information that I have committed Medicaid Fraud! The list of 16 patients was created by snooping through the Massachusetts Prescription Monitoring Program Database which collects and stores every prescription filled by everyone in Massachusetts, something totally personal and private. It is explicitly illegal to use this database to investigate Medicaid Fraud. And especially when Maura knows I have not billed Medicaid since being thrown out of Cambridge Hospital.  
   58: I refused to violate my patients' privacy just to make Maura Healey happy.  
   59: The Valley Patriot newspaper reported this sudden ambush at my home. Maura Healey fully intended to make off with all my computer files!  
   60: I filed an Amended Complaint including Federal charges.  
   61: Cambridge filed it's amended Motion to Dismiss.  
   62: All of a sudden Cambridge Hospital moved the Court to block a patient from filing a legal affidavit in his own name. The patient had filed the affidavit back in early May and the Federal Government had had no problems with it. Cambridge Hospital suddenly realised the terrible implications of his affidavit and the associated email from Dr Rachel Nardin being fully public.  
   63: The affidavit from the patient that Cambridge Hospital unilaterally redacted. Note it contains no medical information, only his name on a legal document that he willingly signed  
   64: Naturally I opposed this unilateral censorship of a patient's use of his own name in a legal document. A patient has the complete right to use his/her name or medical records in any way. Hospitals are bound by HIPAA. Patients are not!  
   65: The email from Dr Rachel Nardin that she sent through the public internet in conscious violation of my patient's privacy rights as well as three strong Federal laws. Cambridge Hospital moved to redact my patient's affidavit only after it realised the massive implications of this crime, FOUR YEARS after I brought it to their attention. This email also proves that Dr Rachel Nardin is the only one ever who diagnosed this confirmed MS patient with a stroke and exposed him to death from bleeding inside his brain.  
   66: The Board of Registration in Medicine submitted it's closing Brief as if the Hearing never occurred and Dr Barry Levin was not proved to have lied under oath. When you read the Brief you will note The Board is as vicious towards Patient I as it was to her in person at the Hearing. Note that the Patient was there because the Board alleged my care of her health was substandard, something she herself came in to deny.  
   67: My closing Brief to DALA Magistrate Bresler proving that by law this blatantly corrupt travesty should go no further and should be tossed.  
   68: An independent good governance expert and advocate analysed the actions of the Massachusetts Board of Registration in Medicine against me and found it to be unlawful and an expensive example of waste fraud and abuse.  
   69: - NEW UPDATES FOR MARCH 2016 -  
   70: DALA Hearing Officer Kenneth Bresler issued a decision stating clearly that the Board had not proved any "substandard" care.  
   71: The Board objected severely and said it could ignore the decision completely. The Board then sat silently for 5 months.  
   72: After I pointedly informed Board Counsel that the Board was still deliberately blocking me from earning a living, Board Counsel Debra Stoller scheduled my case for a meeting of the full Board for the first time on January 7, 2016. In that same letter she said I would not be allowed to speak to the Board members. And that she would not forward my letter to them.  
   73: Stoller followed that letter with another postponing the meeting to January 21, 2016, claiming lack of quorum  
   74: On January 7, 2016, in the evening, the Boston Globe reported on that day's Board meeting and documented that the full Board had been in attendance. Counsel Stoller had lied to me and delayed my case further.  
   75 The Valley Patriot reported on the January 21, 2016 Board meeting, with video.  

Click here to watch the video

 
   76: The videos are also at:   

A: Click here to watch Video 1

B:  Click here to watch Video 2

C:  Click here to watch Video 3

 
   77: After that meeting the Board did not issue a final opinion. Instead it asked DALA Hearing Officer Bresler to write that the Board DID prove "substandard" care, the opposite of what he wrote  
   78: On March 2, 2016, DALA Hearing Officer expressed his willingness to do that, though the 180-day deadline to change the decision expired on February 3, 2016.  
   79 On March 10, 2016, DALA Hearing Officer Bresler further declared that was writing an opposite decision to suit the Board.  
   80: The state's Regulations are explicit. After 180 days the DALA Hearing Officer's decision becomes the FINAL Agency decision. The Board cannot have more bites at the apple.

See --> http://www.mass.gov/bb/regs/801001.html

3: Failure to Issue Final Decision. If the Agency fails to issue a final decision within 180 days of the filing or re-filing of the tentative decision, the initial decision shall become the final decision of the Agency, not subject to further Agency review.

 
   81: I filed a complaint with the Massachusetts Supreme Judicial Court for a declaration that the case was over at the Board and no more agency action is lawful  
   82: The Board filed a motion to dismiss claiming that the 180-day clock has not even begun!  
   83A: I filed a strong opposition but Judge Spina instantly dismissed my case without even oral argument.  
   83B: Second part of file 83A  
   84: I immediately appealed to the full bench and filed an Appellate Brief immediately.  
   85: The Board then filed a motion to strike the brief claiming I had not freshly added page numbers in the appendix and that they should be given 30 more days after I re-file a brief to file theirs.  
   86: I filed a robust opposition to the Board's motion to strike and demanded that they file their brief within the deadline.  
   87: The deadline came and went without the Board filing their red Brief.  
   88: Instead the Board filed a motion for an extra month to file their Brief.  
     
     
     
     
     






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