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Eric Lenaough MD A Dirctor Morehouse Medicine
I have A question
If you have an official workers compensation medical document indicating that you should not work for more than specific limited time and your program Director refused to obey it, what would you do ,especially if he hates you ,and he is acting like a Director.
If this guy sent an e-mail to your faculty member informing them that he is manipulating the resident ,what would you do ,SUE HIM or what ??
IF he contacted your new program and asked them over the phone not to take you what would you do ,bring him to court or what??
REad this by the way what do you think about it
In The UNITED STATES DISTRICT COURT
For the NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION 2211 Richard B. Russell Federal Building
and United States Courthouse
75 Spring Street, S.W.
Atlanta, GA 30303-3309 Khaldoun Khattab Vs The Morehouse School of Medicine . Civil action 07-CV-196 -RWS-LTW.
Honorable Judge Richard W Story MOTION to Compel Deposition Testimony Of Eric Flenough MD COMES NOW the plaintiff khaldoun khattab and files this motion to move the court to issue a subpoena to the defendant to compel deposition testimony of The defendant employee Eric Flenough MD and shows the court as follows -1-
Upon information and belief Eric Flenough MD participated in Plaintiff Bond hearing in an effort to deport the plaintiff and avoid being deposed under oath. -2- Morehouse School of Medicine through its legal councilor refused to schedule a deposition date for Eric Flenough MD who participated in the Plaintiff Bond hearing which took place without allowing the plaintiff himself to attend it in a clear violation of law and in an effort to deport the plaintiff or at least let him suffer at the Atlanta Detention center as long as possible by prohibiting him from knowing or even responding to Morehouse employee(S) and immigration allegation. -3-
The District judge has the power and authority to refuse to compel deposition testimony of Eric Flenough MD who participated in terminating the plaintiff employment and sending confidential negative information in an effort to prevent the plaintiff from transfer to work outside Georgia ,regardless for the reputation and purpose of justice Plaintiff respectfully request that a subpoenas be issued as soon as possible.
-4-
The Plaintiff addressed issues related to Eric Flenough MD previously in one of his Amendments ,and still have a lot of documents to be submitted regarding the previously mentioned individual . -5-
Eric Flenogh MD is the person who refused to release the identity of a Morehouse School of Medicine faculty member whom the Plaintiff filed a grievance against her or him . -6-
Eric Flenogh MD is the person who recommended in writing that (Dr khattab receive SOME REASSURANCE THAT his concern was addressed). -7 Eric Flenough is the person who refused to ensure compliance with the Workers compensation physicians order ,Furthermore he is the person who denied receiving letters and documents related to the plaintiff workers compensation and medical status in May& Jun 2005 . -8
Upon information and belief and or per the available documents Eric Flenough is the person who recommended that Morehouse employee(S) DECIVE the Plaintiff and weather they can create a security problem for him in 2005. -9- As Long as the defendant is refusing to settle this case or to schedule a deposition testimony for Eric Flenough MD any denial to compel deposition of the previously mentioned person has to be addressed with the District judge or the court of appeal . -10-
For the purpose of justice written and verbal discovery should be compelled in this case ,and hopefully the defendant which claimed that it has powerful Connection nationwide might one day care about Ethics or justice and understand it only represent its self and Not any community in the United states. Respectfully submitted this 23rd day of July 2007. Plaintiff
If you have an official workers compensation medical document indicating that you should not work for more than specific limited time and your program Director refused to obey it, what would you do ,especially if he hates you ,and he is acting like a Director.
If this guy sent an e-mail to your faculty member informing them that he is manipulating the resident ,what would you do ,SUE HIM or what ??
IF he contacted your new program and asked them over the phone not to take you what would you do ,bring him to court or what??
REad this by the way what do you think about it
In The UNITED STATES DISTRICT COURT
For the NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION 2211 Richard B. Russell Federal Building
and United States Courthouse
75 Spring Street, S.W.
Atlanta, GA 30303-3309 Khaldoun Khattab Vs The Morehouse School of Medicine . Civil action 07-CV-196 -RWS-LTW.
Honorable Judge Richard W Story MOTION to Compel Deposition Testimony Of Eric Flenough MD COMES NOW the plaintiff khaldoun khattab and files this motion to move the court to issue a subpoena to the defendant to compel deposition testimony of The defendant employee Eric Flenough MD and shows the court as follows -1-
Upon information and belief Eric Flenough MD participated in Plaintiff Bond hearing in an effort to deport the plaintiff and avoid being deposed under oath. -2- Morehouse School of Medicine through its legal councilor refused to schedule a deposition date for Eric Flenough MD who participated in the Plaintiff Bond hearing which took place without allowing the plaintiff himself to attend it in a clear violation of law and in an effort to deport the plaintiff or at least let him suffer at the Atlanta Detention center as long as possible by prohibiting him from knowing or even responding to Morehouse employee(S) and immigration allegation. -3-
The District judge has the power and authority to refuse to compel deposition testimony of Eric Flenough MD who participated in terminating the plaintiff employment and sending confidential negative information in an effort to prevent the plaintiff from transfer to work outside Georgia ,regardless for the reputation and purpose of justice Plaintiff respectfully request that a subpoenas be issued as soon as possible.
-4-
The Plaintiff addressed issues related to Eric Flenough MD previously in one of his Amendments ,and still have a lot of documents to be submitted regarding the previously mentioned individual . -5-
Eric Flenogh MD is the person who refused to release the identity of a Morehouse School of Medicine faculty member whom the Plaintiff filed a grievance against her or him . -6-
Eric Flenogh MD is the person who recommended in writing that (Dr khattab receive SOME REASSURANCE THAT his concern was addressed). -7 Eric Flenough is the person who refused to ensure compliance with the Workers compensation physicians order ,Furthermore he is the person who denied receiving letters and documents related to the plaintiff workers compensation and medical status in May& Jun 2005 . -8
Upon information and belief and or per the available documents Eric Flenough is the person who recommended that Morehouse employee(S) DECIVE the Plaintiff and weather they can create a security problem for him in 2005. -9- As Long as the defendant is refusing to settle this case or to schedule a deposition testimony for Eric Flenough MD any denial to compel deposition of the previously mentioned person has to be addressed with the District judge or the court of appeal . -10-
For the purpose of justice written and verbal discovery should be compelled in this case ,and hopefully the defendant which claimed that it has powerful Connection nationwide might one day care about Ethics or justice and understand it only represent its self and Not any community in the United states. Respectfully submitted this 23rd day of July 2007. Plaintiff
