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Avoid Malignent Programs-Khattab VS Morehouse Schoolof Medicine
Khattab Vs Morehouse
07CV196-RWS.
Exhibit
Residency Advisory Committee
Judge Walker ERORS regarding Defendant RAC.
Defendant claimed that plaintiff was terminated by its RAC- Residency advisory committee , in May 2005(See EEOC Position statement page one .Judge Walker refused to let the Defendant Certify under Oath who are Those mysterious RAC committee members .
Myra E Rose admitted under oath that she appoint RAC members (Rose March Dep page 82.L 2-13), Therefore Rose is responsible for RAC actions , and identifying RAC members Amazingly she failed to identify them during her deposition( Rose 2nd Dep Page 81 ).
Judge Walker neglected the fact that the RAC head is Rose and that committee includes Rohr and flenaugh , they were the decision makers in 2005 and judge Walker wrongfully claimed that No RAC decision maker made comments about/against plaintiff. Judge Walker committed a clear eror (See page 22 L6-11),that judge statement contradict what the judge wrote in Page 9 Lines 4-6,L12-16Page 10L1-8).Judge Walker mayhave the legeal power to strike plaintiffs Motions and documents ,However I wonder if calling me Nigger, I will kill you , Salve and Mad White person in a black institution is appropriate by the said Committee members and have nothing to do with my race, nationality ,religion and color. WHY Judge Walker is refusing to identify the who are those RAC Members? and who attended RAC meetings that discussed plaintiffs issued and met plaintiff?
(Judge Waller Refusal is a clear Error and effort to protect Defendant ).,The United States Public will never be damaged by certifying under Oath who are All those mysterious RAC members. RAC Conspiracy /Negligence. The individuals involved in RAC conspiracy are Morehouse Dean Smith , GME Director(Booth), GME Chairman (ELKS) ,Medicine Director (Rose) and James W Reed and Eric Flenaugh. In March 2005 Morehouse started to raise False allegations that the Medicine department RAC had taken actions against the plaintiff on behalf of Morehouse , However until today defendant refused to identify /certify under oath who are those RAC members . (Attorney Ms Sara Doyle submitted a list of RAC members via e-mail in 2008 and refused to let any defendant agent (employee) certify it under oath. Issues related to RAC were discussed in Plaintiff response to defendant statements ,7,8,9,10,11,17,18,19,).“Defendant and Rose are responsible for violating Morehouse’s own policy by refusing to appoint a resident in the RAC per Morehouse’s written policy.” (See Plaintiffs response to Morehouse alleged statement of fact number 8-See Khattab 0042). Defendant is liable for its unknown RAC members illegal actions including ignoring Discrimination complaints , maintaining a hostile working environment , neglecting patient care &Abuse compliments and Finally encouraging Morehouse employees to keep abusing plaintiff .(Judge Walker issued an order to strike Plaintiffs evidence-Documents that clearly proves numerous complaining to the RAC ). During discovery defendant insisted that plaintiff knew all the RAC members as he met them in March 2005 , However it failed to identify
RAC members and refused to release its March ,May or Jun 2005 RAC meeting minutes . Defendant current Chief of Morehouse staff at Grady Hospital( Reed) testified under Oath and claimed that a record is kept on every RAC meeting ,and if plaintiff want a list (roster) of who attended meetings then Christie (Residency Manager)has it ( See Reed Deposition 1st part page 26 L 6-
25- Page 27 L 1-7.-Page 27 L 11-16. Page 29 L 15-16 ) (See document khattab 0298-See documents and facts mentioned in plaintiffs response to defendant alleged genuine fact statement 19). See Akomolafe deposition pages 10-11-She claimed that she is a member of the RAC and she can NOT recall meeting Plaintiff Akomolafe Depo Page 11 L 1-4, Page 10 L 4 ). Defendant and Rose are responsible for violating Morehouse own policy by refusing to appoint a resident in the RAC per Morehouse written policy.Rose claimed that she did NOT attend the RAC meetings with plaintiff (Rose Dep 2nd part Page 80 L8-12) and Rose could Not remember who are those RAC ,or who are the RAC who met plaintiff(Rose Dep Page 81 L2-17). In 2005 numerous Morehouse faculty members ignored plaintiffs numerous requests to know whether or Not they are members of the RAC and who are Those RAC members whom according to Rose they met with Dr Khattab. See Documents Khattab 0673/0674/0678-0780-0900-0898-. 0298-0637-1085-1086- On April 6,2005 Plaintiff requested that Morehouse GME Director Booth send him the names of RAC member(Khttab 1085). , Booth ignored Dr Khattab. (See inquires about alleged RAC member Khattab-0670-0634 dated April 6,2005 . On April 6,2005 plaintiff informed his MANAGER Christie
(I DO NOT even Know the list of RAC members, names?)khattab 1086.
Christie ignored Plaintiffs e-mails and requests. In 2005 All the following defendant employees failed to identify the RAC members (1)GME chairman -ELKS,(2) GME Director Booth
,(3)Medicine Director(Rose) (4) Residency Manager (Christie) 5-Morehouse Chief operating officer(Pruitt) ,and finally (6) Flenaugh(Associate Residency director) In an effort to identify alleged RAC members Plaintiff kept sending e-mails in 2005 to confirm that HE DID NOT met or know RAC members ,Never knew know who are all those RAC members
(See Khattab 1105 (e-mail to Dr Igho-Pemu)she informed Rose and I do not know the appropriate response.
/Khattab 1102 From Pricillaia Igho-Pemu to Rose (Is there a process in place for dealing with such enquires) Myra Rose forwarded the matter to Marlin Pruitt(FYI) .Khattab 1103 .See also Notice to Igho-Pemu and Oderinde about an alleged RAC. Christie (Defendant Residency Manager) identified RAC members . ( Christie Page 10 L21-23 Page 11 L 1-5 ) . she also provided a document about the alleged RAC members . Christie document was FALSE .The evidence about falsifying the said RAC document came during Akomolafe deposition , Akomolafe claimed under Oath that she is a member of defendant 2004/2005 RAC ( Akomolafe Dep page 10 L 2-9). Akomolafe name is not included either in the list provided by attorney Sara Doyle or the list provided by the residency manager Christie during her deposition (See Christie dep Page 10 L21-23 Page 11 L 1-5 ). All Plaintiffs concerns regarding Patient care , safety issues ,unlawful practice ,and Dr Khattab work evaluation had never been discussed with a real RAC members , See Khattab 1086(Letter to unknown RAC members to be forwarded by Yolanda Christie-). According to Morehouse Due process policy the plaintiff has the right to physically meet the RAC members and appeal their decisions to GME/Dean as the RAC decision is NOT final (Khattab 0045-0055). In 2005 Defendant Manager Christi informed plaintiff in writing that RAC decision is Final and that his advisor Dr James Reed will advocate the plaintiff during RAC meeting (see Document khttab 300 ). The defendant retaliated against plaintiff by letting someone who wants to Fire Dr Khttab (James Reed) represent him during RAC meetings (khattab 300) Further defendant retaliated by denying plaintiffs right to appeal to Morehouse Dean Smith , Indeed defendant actions should be considered Non legitimate simply by using common sense as defendant should have identified its RAC members under Oath. In Spring 2005 Dr Khttab Filed numerous compliments via e-mail (See documents Khattab 0637-0638-1050-1086 ) , Defendant and its employees Reed and Rose ignored all plaintiffs complaints/e-mails. Rose & Reed retaliated against plaintiff because he Filed numerous complaints via e-mails about neglecting ACGME/Morehouse policy regarding resident evaluations (See Khattab 0325),Further Dr Reed retaliated against plaintiff because Dr Khattab started contacting lawyers in March 2005 and officially assigned an attorney in April 2005 to deal with Morehouse,(See Attorney Elkhalil Invoice1199). Rose took negative actions against plaintiffs in Spring 2005 and claimed that an RAC decided those actions based on Rose opinion about plaintiffs patient care although she never worked with plaintiff inside any Georgia Hospital . Rose alleaged documents about Jan, Feb and March 2005 RAC actions are simply a personal opinion and conclusory allegations which should never be accepted as a genuine fact ( Conclusory allegations based on subjective beliefs are insufficient to create a genuine issue of material fact. See Leigh v. Warner Bros., Inc., 212 F.3d 1210, 1217 (11th Cir. 2000); Ramsey v. Leath, 706 F.2d 1166, 1170 (11th Cir. 1983). Rose is a person who can easily provide false allegation ,for example See Document (khattab 0751 ). Rose informed the CSBME on behalf of Morehouse that ((the EEOC decided that plaintiff complaint is unwarranted )) See document Khattab 0751 We found that the EEOC determined that Dr Khattab charge was unwarranted .). (CSBME is Georgia medical Board) See Khattab 0750- 0752- Rose described plaintiffs behavior as (erratic) and she indicated that he is manipulating her faculty members and want to make complaints so he can extend his visa/immigration status inside the USA . Rose personal opinion about Dr Khattab behavior contradict her faculty members opinion (See Legitimate Work Section and attached documents about Professionalism and behavior -See positive opinion documents 0851, 0370,0270,0272,0273 ,0271..etc). Rose claimed that plaintiff is manipulating her faculty members as she is not ready to accept her own faculty members positive opinion about plaintiff When Morehouse decided to terminate Dr Khattab employment ,its employees did Not review Plaintiff documents including the positive/ superior work
evaluations which were available to Morehouse . Reed who advocated/represented the plaintiff in alleged RAC meeting admitted under oath that he did not review specific doctors evaluation and recommendation ( Reed 1st part deposition-March/08 Page 42 L 20-25-Page43 L1-21)
07CV196-RWS.
Exhibit
Residency Advisory Committee
Judge Walker ERORS regarding Defendant RAC.
Defendant claimed that plaintiff was terminated by its RAC- Residency advisory committee , in May 2005(See EEOC Position statement page one .Judge Walker refused to let the Defendant Certify under Oath who are Those mysterious RAC committee members .
Myra E Rose admitted under oath that she appoint RAC members (Rose March Dep page 82.L 2-13), Therefore Rose is responsible for RAC actions , and identifying RAC members Amazingly she failed to identify them during her deposition( Rose 2nd Dep Page 81 ).
Judge Walker neglected the fact that the RAC head is Rose and that committee includes Rohr and flenaugh , they were the decision makers in 2005 and judge Walker wrongfully claimed that No RAC decision maker made comments about/against plaintiff. Judge Walker committed a clear eror (See page 22 L6-11),that judge statement contradict what the judge wrote in Page 9 Lines 4-6,L12-16Page 10L1-8).Judge Walker mayhave the legeal power to strike plaintiffs Motions and documents ,However I wonder if calling me Nigger, I will kill you , Salve and Mad White person in a black institution is appropriate by the said Committee members and have nothing to do with my race, nationality ,religion and color. WHY Judge Walker is refusing to identify the who are those RAC Members? and who attended RAC meetings that discussed plaintiffs issued and met plaintiff?
(Judge Waller Refusal is a clear Error and effort to protect Defendant ).,The United States Public will never be damaged by certifying under Oath who are All those mysterious RAC members. RAC Conspiracy /Negligence. The individuals involved in RAC conspiracy are Morehouse Dean Smith , GME Director(Booth), GME Chairman (ELKS) ,Medicine Director (Rose) and James W Reed and Eric Flenaugh. In March 2005 Morehouse started to raise False allegations that the Medicine department RAC had taken actions against the plaintiff on behalf of Morehouse , However until today defendant refused to identify /certify under oath who are those RAC members . (Attorney Ms Sara Doyle submitted a list of RAC members via e-mail in 2008 and refused to let any defendant agent (employee) certify it under oath. Issues related to RAC were discussed in Plaintiff response to defendant statements ,7,8,9,10,11,17,18,19,).“Defendant and Rose are responsible for violating Morehouse’s own policy by refusing to appoint a resident in the RAC per Morehouse’s written policy.” (See Plaintiffs response to Morehouse alleged statement of fact number 8-See Khattab 0042). Defendant is liable for its unknown RAC members illegal actions including ignoring Discrimination complaints , maintaining a hostile working environment , neglecting patient care &Abuse compliments and Finally encouraging Morehouse employees to keep abusing plaintiff .(Judge Walker issued an order to strike Plaintiffs evidence-Documents that clearly proves numerous complaining to the RAC ). During discovery defendant insisted that plaintiff knew all the RAC members as he met them in March 2005 , However it failed to identify
RAC members and refused to release its March ,May or Jun 2005 RAC meeting minutes . Defendant current Chief of Morehouse staff at Grady Hospital( Reed) testified under Oath and claimed that a record is kept on every RAC meeting ,and if plaintiff want a list (roster) of who attended meetings then Christie (Residency Manager)has it ( See Reed Deposition 1st part page 26 L 6-
25- Page 27 L 1-7.-Page 27 L 11-16. Page 29 L 15-16 ) (See document khattab 0298-See documents and facts mentioned in plaintiffs response to defendant alleged genuine fact statement 19). See Akomolafe deposition pages 10-11-She claimed that she is a member of the RAC and she can NOT recall meeting Plaintiff Akomolafe Depo Page 11 L 1-4, Page 10 L 4 ). Defendant and Rose are responsible for violating Morehouse own policy by refusing to appoint a resident in the RAC per Morehouse written policy.Rose claimed that she did NOT attend the RAC meetings with plaintiff (Rose Dep 2nd part Page 80 L8-12) and Rose could Not remember who are those RAC ,or who are the RAC who met plaintiff(Rose Dep Page 81 L2-17). In 2005 numerous Morehouse faculty members ignored plaintiffs numerous requests to know whether or Not they are members of the RAC and who are Those RAC members whom according to Rose they met with Dr Khattab. See Documents Khattab 0673/0674/0678-0780-0900-0898-. 0298-0637-1085-1086- On April 6,2005 Plaintiff requested that Morehouse GME Director Booth send him the names of RAC member(Khttab 1085). , Booth ignored Dr Khattab. (See inquires about alleged RAC member Khattab-0670-0634 dated April 6,2005 . On April 6,2005 plaintiff informed his MANAGER Christie
(I DO NOT even Know the list of RAC members, names?)khattab 1086.
Christie ignored Plaintiffs e-mails and requests. In 2005 All the following defendant employees failed to identify the RAC members (1)GME chairman -ELKS,(2) GME Director Booth
,(3)Medicine Director(Rose) (4) Residency Manager (Christie) 5-Morehouse Chief operating officer(Pruitt) ,and finally (6) Flenaugh(Associate Residency director) In an effort to identify alleged RAC members Plaintiff kept sending e-mails in 2005 to confirm that HE DID NOT met or know RAC members ,Never knew know who are all those RAC members
(See Khattab 1105 (e-mail to Dr Igho-Pemu)she informed Rose and I do not know the appropriate response.
/Khattab 1102 From Pricillaia Igho-Pemu to Rose (Is there a process in place for dealing with such enquires) Myra Rose forwarded the matter to Marlin Pruitt(FYI) .Khattab 1103 .See also Notice to Igho-Pemu and Oderinde about an alleged RAC. Christie (Defendant Residency Manager) identified RAC members . ( Christie Page 10 L21-23 Page 11 L 1-5 ) . she also provided a document about the alleged RAC members . Christie document was FALSE .The evidence about falsifying the said RAC document came during Akomolafe deposition , Akomolafe claimed under Oath that she is a member of defendant 2004/2005 RAC ( Akomolafe Dep page 10 L 2-9). Akomolafe name is not included either in the list provided by attorney Sara Doyle or the list provided by the residency manager Christie during her deposition (See Christie dep Page 10 L21-23 Page 11 L 1-5 ). All Plaintiffs concerns regarding Patient care , safety issues ,unlawful practice ,and Dr Khattab work evaluation had never been discussed with a real RAC members , See Khattab 1086(Letter to unknown RAC members to be forwarded by Yolanda Christie-). According to Morehouse Due process policy the plaintiff has the right to physically meet the RAC members and appeal their decisions to GME/Dean as the RAC decision is NOT final (Khattab 0045-0055). In 2005 Defendant Manager Christi informed plaintiff in writing that RAC decision is Final and that his advisor Dr James Reed will advocate the plaintiff during RAC meeting (see Document khttab 300 ). The defendant retaliated against plaintiff by letting someone who wants to Fire Dr Khttab (James Reed) represent him during RAC meetings (khattab 300) Further defendant retaliated by denying plaintiffs right to appeal to Morehouse Dean Smith , Indeed defendant actions should be considered Non legitimate simply by using common sense as defendant should have identified its RAC members under Oath. In Spring 2005 Dr Khttab Filed numerous compliments via e-mail (See documents Khattab 0637-0638-1050-1086 ) , Defendant and its employees Reed and Rose ignored all plaintiffs complaints/e-mails. Rose & Reed retaliated against plaintiff because he Filed numerous complaints via e-mails about neglecting ACGME/Morehouse policy regarding resident evaluations (See Khattab 0325),Further Dr Reed retaliated against plaintiff because Dr Khattab started contacting lawyers in March 2005 and officially assigned an attorney in April 2005 to deal with Morehouse,(See Attorney Elkhalil Invoice1199). Rose took negative actions against plaintiffs in Spring 2005 and claimed that an RAC decided those actions based on Rose opinion about plaintiffs patient care although she never worked with plaintiff inside any Georgia Hospital . Rose alleaged documents about Jan, Feb and March 2005 RAC actions are simply a personal opinion and conclusory allegations which should never be accepted as a genuine fact ( Conclusory allegations based on subjective beliefs are insufficient to create a genuine issue of material fact. See Leigh v. Warner Bros., Inc., 212 F.3d 1210, 1217 (11th Cir. 2000); Ramsey v. Leath, 706 F.2d 1166, 1170 (11th Cir. 1983). Rose is a person who can easily provide false allegation ,for example See Document (khattab 0751 ). Rose informed the CSBME on behalf of Morehouse that ((the EEOC decided that plaintiff complaint is unwarranted )) See document Khattab 0751 We found that the EEOC determined that Dr Khattab charge was unwarranted .). (CSBME is Georgia medical Board) See Khattab 0750- 0752- Rose described plaintiffs behavior as (erratic) and she indicated that he is manipulating her faculty members and want to make complaints so he can extend his visa/immigration status inside the USA . Rose personal opinion about Dr Khattab behavior contradict her faculty members opinion (See Legitimate Work Section and attached documents about Professionalism and behavior -See positive opinion documents 0851, 0370,0270,0272,0273 ,0271..etc). Rose claimed that plaintiff is manipulating her faculty members as she is not ready to accept her own faculty members positive opinion about plaintiff When Morehouse decided to terminate Dr Khattab employment ,its employees did Not review Plaintiff documents including the positive/ superior work
evaluations which were available to Morehouse . Reed who advocated/represented the plaintiff in alleged RAC meeting admitted under oath that he did not review specific doctors evaluation and recommendation ( Reed 1st part deposition-March/08 Page 42 L 20-25-Page43 L1-21)
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