Case 1 18 Cv 02074 Rmi Document 1 Filed 04 05 18 Page 1 Of 27-Books Download

Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 1 of 27
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Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 2 of 27. 1 individual LEO LEER MD an individual , ALLAN WILKE MD an individual MIRIAM. 2 STEINBERG DO an individual AMANDA, JAMES NP an individual AMBER. 3 FLOWERS FNP an individual RACHEL, HATCHIMONJI FNP an individual ROBIN. 4 FRASER PA C an individual and DOES 1 , 100 inclusive . 5, Defendants , 6, 7, 8, 9,10,11,12,13,14,15,16,17.
18,19,20,21,22,23,24,25,26,27,28, Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 3 of 27. 1 Plaintiff Wahidullah Medical Corporation doing business as Redwood Urgent Care and. 2 Laboratory based on knowledge as to itself and its own acts and on information and belief as to. 3 all other matters files this Complaint against the above named Defendants and demanding trial. 4 by jury complains and alleges as follows , 5 I, JURISDICTION AND VENUE. 6, 7 1 The federal antitrust claims stated herein are filed and these proceedings are. 8 instituted against the above named Defendants under Section 4 of the Clayton Act 15 U S C 4 . 9 to recover treble the actual damages sustained by Plaintiff to its business and property by reason of. 10 the above named Defendants violations of Sections 1 and 2 of the Sherman Act 15 U S C 1 . 11 2 as hereinafter alleged Plaintiff also claims damages by reason of Defendants violations of the. 12 Lanham Act 15 U S C 1051 et seq This Court has original jurisdiction over Plaintiff s. 13 federal antitrust treble damage claims which arise under the Sherman Act and the Clayton Act as. 14 well as Plaintiff s damage claims arising under the Lanham Act Title 28 U S C 1331 . 15 1337 a This Court has supplemental jurisdiction pursuant to Title 28 United States Code Section. 16 1367 a over the related claims for violations of California statutory and common law alleged. 17 herein because those claims are so related to the federal claims that they form part of the same. 18 case or controversy under Article III of the United States Constitution . 19 2 Venue is proper in this District under Title 28 United States Code Section 1391 b . 20 because Plaintiff and all Defendants are residents of this District and a substantial part of the acts. 21 and circumstances giving rise to this action occurred in this District and all Defendants are subject. 22 to personal jurisdiction in this District , 23 3 The interstate trade and commerce involved with and affected by the alleged. 24 violations was carried on in part within this District and substantially all of the unlawful acts. 25 described herein were conceived performed or made effective within this District . 26 ,27 ,28 , COMPLAINT, 2 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 4 of 27.
1 II, THE PARTIES, 2, 3 A Plaintiff, 4 4 Plaintiff Wahidullah Medical Corp d b a Redwood Urgent Care and Laboratory. 5 referred to as Plaintiff Redwood or Redwood Lab a medical office providing patient. 6 care is a California corporation with its principal place of business at 2440 23rd Street Eureka . 7 California 95501 , 8 B St Joseph Health Defendants. 9 5 St Joseph Hospital of Eureka a California nonprofit corporation d b a St Joseph. 10 Health Humboldt County which is a 138 bed health care facility with its principal place of. 11 business at 2700 Dolbeer Street Eureka California 95501 is hereby made a Defendant herein . 12 6 Humboldt Medical Specialists Inc a California corporation d b a St Joseph Health. 13 Medical Group which is a multispecialty medical group providing patient care with its principal. 14 place of business at 2725 Myrtle Avenue Suite B Eureka California 95501 is hereby made a. 15 Defendant herein , 16 7 St Joseph Health Northern California LLC a California limited liability company . 17 which is an integrated health delivery network with its principal place of business at 3345. 18 Michelson Drive Suite 100 Irvine California 92612 is hereby made a Defendant herein . 19 8 St Joseph Health System a California nonprofit corporation with its principal. 20 place of business at 3345 Michelson Drive Suite 100 Irvine California 92612 is hereby made a. 21 Defendant herein It controls St Joseph Hospital of Eureka and is the sole corporate member of St . 22 Joseph Health Northern California LLC , 23 9 St Joseph Health a California nonprofit corporation which is a health care system . 24 with its principal place of business at 3345 Michelson Drive Suite 100 Irvine California 92612 is. 25 hereby made a Defendant herein , 26 10 St Joseph Heritage Healthcare a California nonprofit corporation which is the.
27 California healthcare professional network of St Joseph Health with its principal place of. 28, COMPLAINT, 3 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 5 of 27. 1 business at 200 West Center Street Promenade Suite 800 Anaheim California 92805 is hereby. 2 made a Defendant herein , 3 11 Providence St Joseph Health Network a California nonprofit corporation which is. 4 the parent corporation of St Joseph Health with its principal place of business at 20555 Earl. 5 Street Torrance California 90503 is hereby made a Defendant herein . 6 12 Providence St Joseph Health a State of Washington nonprofit corporation with its. 7 principal place of business at 1801 Lind Avenue Southwest Renton Washington 98057 is hereby. 8 made a Defendant herein It is the ultimate parent corporation of each of the foregoing Defendants . 9 13 Each of Defendants named in Paragraphs 5 through 12 above are referred to. 10 collectively as St Joseph Health Defendants or St Joseph Health . 11 C Medical Professional Defendants, 12 14 John Aryunpur MD the Medical Director of the St Joseph Health Medical Group . 13 with his principal place of business at 2752 Harrison Avenue Eureka California 95501 is hereby. 14 made a Defendant herein , 15 15 Petra Kuhfahl MD of the St Joseph Health Medical Group with her principal. 16 place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 17 herein , 18 16 Bruce Kessler MD of the St Joseph Health Medical Group with his principal.
19 place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 20 herein , 21 17 Stuart Cataldo MD of the St Joseph Health Medical Group with his principal. 22 place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 23 herein , 24 18 Alexey Shereshevsky MD of the St Joseph Health Medical Group with his. 25 principal place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a. 26 Defendant herein ,27,28, COMPLAINT, 4 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 6 of 27. 1 19 Gregory Holst MD of the St Joseph Health Medical Group with his principal. 2 place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 3 herein , 4 20 Caroline Connor MD of the St Joseph Health Medical Group with her principal. 5 place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 6 herein , 7 21 Steven Korenstein MD of the St Joseph Health Medical Group with his principal.
8 place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 9 herein , 10 22 Leo Leer MD of the St Joseph Health Medical Group with his principal place of. 11 business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant herein . 12 23 Allan Wilke MD of the St Joseph Health Medical Group with his principal place. 13 of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 14 herein , 15 24 Miriam Steinberg DO of the St Joseph Health Medical Group with her principal. 16 place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 17 herein , 18 25 Amanda James NP of the St Joseph Health Medical Group with her principal. 19 place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 20 herein , 21 26 Amber Flowers FNP of the St Joseph Health Medical Group with her principal. 22 place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 23 herein , 24 27 Rachel Hatchimonji FNP of the St Joseph Health Medical Group with her.
25 principal place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a. 26 Defendant herein ,27,28, COMPLAINT, 5 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 7 of 27. 1 28 Robin Fraser PA C of the St Joseph Health Medical Group with her principal. 2 place of business at 2280 Harrison Avenue Eureka California 95501 is hereby made a Defendant. 3 herein , 4 29 Each of the Defendants named in Paragraphs 14 through 28 above are referred to. 5 as Medical Professional Defendants , 6 D Doe Defendants. 7 30 The true names and capacities of DOES 1 through 100 referred to as Doe. 8 Defendants are presently unknown to Plaintiff Plaintiff will seek leave from this Court to amend. 9 the Sixth and Seventh Claims for relief in this Complaint to identify Doe Defendants true names. 10 and capacities once such information has been ascertained Plaintiff alleges that Doe Defendants. 11 participated in St Joseph Health Defendants and Medical Professional Defendants misconduct . 12 as herein alleged and are therefore liable to Plaintiff for damages . 13 E Agency, 14 31 St Joseph Health Defendants Medical Professional Defendants and Doe. 15 Defendants are referred to as Defendants Plaintiff is informed and believes and thereon alleges. 16 that at all times mentioned herein each of Defendants was the agent of each of the remaining. 17 Defendants and that in doing the acts hereinafter set forth each of Defendants was acting within. 18 the course and scope of that agency with the knowledge and consent and or the ratification of each. 19 of the remaining Defendants ,20 F Co Conspirators.
21 32 Various persons firms partnerships and corporations currently unknown to. 22 Plaintiff participated as co conspirators with Defendants named in the First Second and Fourth. 23 Claims for Relief When Plaintiff learns the identity of any co conspirator it will seek leave of. 24 this Court to add such co conspirator as a Defendant herein . 25 III, RELEVANT MARKET,26, 27 33 The relevant market for the First Second and Third Claims for Relief is the market. 28 for out patient medical laboratory testing services in the relevant geographic market The term. COMPLAINT, 6 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 8 of 27. 1 out patient medical laboratory testing services as used in this Complaint excludes medical. 2 laboratory testing services for patients who are hospitalized and excludes medical laboratory. 3 testing services where specimen collection and specimen testing are not performed within the. 4 relevant geographic market , 5 34 The relevant geographic market is the City of Eureka situated in Humboldt County . 6 California Eureka is a distinct and defined geographic market with its own hospital service. 7 area HSA as defined in the DARTMOUTH ATLAS OF HEALTH CARE a recognized and. 8 authoritative source of information about healthcare in the United States . 9 35 Providing out patient medical laboratory testing services directly involves and. 10 affects interstate and foreign commerce The violations of the antitrust laws alleged hereafter in. 11 the First Second and Third Claims for Relief have had the effect of substantially lessening . 12 suppressing eliminating and interfering with competition in the business of providing out patient. 13 medical laboratory services in Eureka ,14 IV, NATURE OF THE CASE. 15, 16 36 Until 2017 healthcare consumers in Eureka California i e residents of Eureka .
17 and patients of medical providers located in Eureka who needed an out patient medical laboratory. 18 test such as a blood panel to determine cholesterol levels or a urinalysis to assess kidney function . 19 had no real choice for lab testing services The region s healthcare giant St Joseph Health which. 20 has been serially acquiring formerly independent healthcare providers throughout Humboldt. 21 County and beyond offered the only out patient medical laboratory testing services in Eureka . 22 37 To the extent that out patient medical laboratory testing services were available. 23 outside of Eureka they did not provide practical or reasonable alternatives to St Joseph Health s. 24 lab services Some eight miles north of Eureka on the other end of Arcata Bay the Mad River. 25 Community Hospital a small independent hospital with a five bed emergency room operates an. 26 out patient medical lab in the City of Arcata which constitutes a distinct and separate HSA from. 27 Eureka But Eureka healthcare consumers would not benefit by for example going to a doctor s. 28 appointment in Eureka travelling to the Arcata hospital for lab testing ordered by the doctor and. COMPLAINT, 7 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 9 of 27. 1 then returning to the doctor in Eureka to consult regarding the results Alternatively travelling. 2 some 18 miles to the south of Eureka to the Redwood Memorial Hospital in the City of Fortuna . 3 with an outpatient lab at its 35 bed facility would also yield no benefits The distance to Fortuna. 4 itself a distinct and separate HSA from Eureka and thus the patient s time and expense lost to. 5 travel would be even greater And in any event Redwood Memorial Hospital is part of St Joseph. 6 Health meaning there would be no competition between the commonly owned lab facilities in. 7 Eureka and Fortuna There were no other out patient medical laboratory testing services within 80. 8 miles of Eureka , 9 38 St Joseph Health profited from this lack of competition With no alternatives St . 10 Joseph Health s lab testing services became an entrenched monopoly Without having to compete. 11 on price and service a predictable result ensued prices increased and service quality declined . 12 This fit a familiar pattern for Eureka healthcare consumers In 2014 St Joseph Health closed what. 13 was Eureka s only urgent care facility forcing Eureka healthcare consumers with urgent but non . 14 life threatening conditions to seek prohibitively expensive care at St Joseph Health s emergency. 15 room simply because there was no other choice , 16 39 Sensing an opportunity to improve the choices available to Eureka healthcare. 17 consumers Dr Wahidullah Wahidullah opened Redwood Urgent Care in Eureka in 2014 . 18 providing a much needed alternative to the St Joseph Health emergency room By providing. 19 quality medical services at more affordable prices Redwood flourished It supported its own in . 20 house lab to provide testing services to its urgent care patients For Dr Wahidullah the natural. 21 next step was to invest in expanding and improving the in house lab so that it could be certified as. 22 a full service out patient medical laboratory and thereby bring the same competitive dynamic to. 23 out patient lab testing services in Eureka as he had done with urgent care . 24 40 In January 2017 Plaintiff s fully accredited out patient medical lab opened for. 25 business as Redwood Urgent Care and Laboratory allowing any patient to obtain medical lab. 26 testing services at its facility The community response was overwhelmingly positive with Eureka. 27 healthcare consumers finally enjoying price competition and in the process laying bare the extent. 28 to which St Joseph Health s lab services were overcharging its captive customer base . COMPLAINT, 8 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 10 of 27. 1 41 For instance some routine tests were nearly ten times more expensive at St Joseph. 2 Health s lab services compared to those same tests at Redwood Lab Using a cash paying patient. 3 i e one with no insurance coverage rate as a reference point a Vitamin D test at St Joseph. 4 Health s lab costs about 327 while that same test at Redwood Lab costs 36 For a. 5 Comprehensive Metabolic Panel at St Joseph Health s lab the charge to a cash paying patient is. 6 about 116 while the cost at Redwood Lab is about 13 And a Complete Blood Count test at St . 7 Joseph Health s lab costs a cash paying patient about 86 while at Redwood Lab the same patient. 8 would pay just 10 for the same test , 9 42 Independent doctors i e those not affiliated with St Joseph Health likewise felt.
10 confident in receiving patient test results from Redwood Lab because it was staffed by the most . 11 qualified laboratory personnel in the area and because it utilized the most current electronic. 12 medical record technology , 13 43 Unfortunately St Joseph Health having already seen its lucrative emergency room. 14 business undercut by Redwood s urgent care facility decided to protect its lab testing business. 15 from fair competition by resorting to tortious and anticompetitive behavior designed to put. 16 Redwood Lab out of business and thereby leave consumers of out patient medical laboratory. 17 testing services in Eureka with no option but St Joseph Health . 18 44 Specifically Defendants have monopolized and or attempted to monopolize and or. 19 conspired to monopolize the market for out patient medical laboratory testing services in Eureka . 20 as well as engaging in a conspiracy to restrain trade organizing group boycott activities and. 21 committing other tortious and anticompetitive conduct all to the financial and competitive harm to. 22 Redwood Lab as well as to consumers of out patient medical laboratory testing services in Eureka . 23 45 Defendants have also harmed competition in the relevant market as defined herein. 24 by among other things preventing patient lab test results from Redwood Lab from being. 25 electronically transmitted to medical practices acquired by St Joseph Health despite such medical. 26 practices having the technological capacity to receive such electronic medical records Medical . 27 Professional Defendants have also falsely informed patients that they are required to use St Joseph. 28 Health s lab facilities when in fact patients are free to use the medical lab of their own choosing . COMPLAINT, 9 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 11 of 27. 1 46 In doing so and as alleged below St Joseph Health Defendants Medical . 2 Professional Defendants Doe Defendants and their co conspirators and accomplices have violated. 3 a number of federal and state laws including Sections 1 and 2 of the Sherman Antitrust Act 15. 4 U S C 1 2 the Lanham Act 15 U S C 1051 the California Unfair Competition Law Cal . 5 Bus Prof Code 17200 et seq and other state laws . 6 V, FACTUAL ALLEGATIONS, 7, 8 47 Redwood Lab provides out patient medical laboratory testing services in Eureka It. 9 collects specimens and performs specimen testing at its facility in Eureka Redwood Lab is. 10 licensed by the State of California certified by the U S Centers for Medicare and Medicaid. 11 Services and accredited by COLA the national clinical laboratory accreditor Its facility is. 12 located in downtown Eureka among a cluster of several other medical service providers and is. 13 situated approximately one block away from St Joseph Hospital of Eureka and approximately one. 14 block away from the medical offices of the St Joseph Health Medical Group making it. 15 conveniently accessible from any of the medical service providers in Eureka . 16 48 Redwood Lab endeavors to provide its patients with superior service competitive. 17 pricing and the latest electronic medical record technology To that end Redwood Lab utilizes the. 18 industry leading laboratory technology software LabDAQ to enable the electronic recording . 19 analysis and transmission of medical lab test results . 20 49 Furthermore to facilitate the seamless electronic transmission of lab tests ordered. 21 by a medical provider and then to securely transmit the results of those tests back to the medical. 22 provider Redwood Lab is connected to the North Coast Health Improvement and Information. 23 Network NCHIIN NCHIIN is the non profit health information exchange for Humboldt. 24 County acting as an intermediary to facilitate the secure electronic exchange of patient. 25 information among local medical providers Thus for example a doctor s office may. 26 electronically send an order for a patient s lab tests to NCHIIN which lab test order will then be. 27 accessible to the medical lab that is also connected to NCHIIN When the lab tests are complete . 28 the results can be sent back securely through NCHIIN and then become available to the patient s. COMPLAINT, 10 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 12 of 27. 1 doctor all without the delay and dangerous potential for medical errors caused by having the. 2 doctor s office manually input test results to a patient s electronic chart from a paper record . 3 50 St Joseph Health is the dominant healthcare provider in Humboldt County St . 4 Joseph Health operates the 138 bed St Joseph Hospital of Eureka the sole hospital in the Eureka. 5 HSA as well as the Redwood Memorial Hospital a 35 bed facility in Fortuna California the sole. 6 hospital in the Fortuna HSA St Joseph Health has acquired several local medical practices in. 7 recent years including for example Humboldt Medical Specialists After acquiring these. 8 previously independent medical practices St Joseph Health re brands the practice under the St . 9 Joseph Health Medical Group banner The St Joseph Health Medical Group is connected to. 10 NCHIIN , 11 51 St Joseph Health provides out patient medical laboratory testing services in Eureka .
12 It collects specimens and performs specimen testing at its facilities in Eureka St Joseph Health. 13 operates a facility located within the St Joseph Hospital of Eureka and a facility located within the. 14 medical offices housing the St Joseph Health Medical Group The St Joseph Health lab facilities. 15 are connected to NCHIIN , 16 52 St Joseph Health Defendants Medical Professional Defendants Doe Defendants . 17 and their co conspirators and accomplices have engaged in a concerted effort to eliminate. 18 Redwood Lab as a competitor because Plaintiff generally charges consumers of out patient medical. 19 laboratory testing services in Eureka less than St Joseph Health does for the same services . 20 Plaintiff also provides better quality of service to healthcare consumers in Eureka than St Joseph. 21 Health , 22 53 Defendants crusade against Redwood Lab is designed to remove the choice that. 23 Eureka healthcare consumers have when it comes to out patient medical laboratory testing. 24 services so that St Joseph Health can continue to charge more for its out patient medical. 25 laboratory testing services than it could by honestly competing with Redwood Lab . 26 ,27 ,28 , COMPLAINT, 11 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 13 of 27. 1 A Defendants Illegal Tortious and Anti Competitive Scheme. 2 54 For at least the past year Defendants have been organizing and plotting ways to. 3 remove the choice that Eureka healthcare consumers have when it comes to selecting out patient. 4 medical lab services , 5 i St Joseph Health Unilaterally Blocks Test Results from Redwood Lab. 6 55 For example Defendants unilaterally block receipt by the St Joseph Health Medical. 7 Group of electronic medical lab test results performed at Redwood Lab and transmitted through. 8 NCHIIN Defendants have accomplished this by intentionally configuring their own computer. 9 networks so as not to accept through NCHIIN an electronic medical lab test result generated by. 10 Redwood Lab and only Redwood Lab Thus a medical lab test result generated by Redwood. 11 Lab will successfully transmit from Redwood Labs computer network to the NCHIIN computer. 12 network but when that record is thereafter transmitted to Defendants computer network . 13 Defendants computer network responds with the equivalent of a telephone busy signal thus. 14 denying receipt of the record There is no technological reason for this blocking Instead . 15 Defendants are seeking to degrade Redwood Lab as a competitor in the marketplace in hopes of. 16 eliminating it altogether The NCHIIN system is designed to facilitate transmission of electronic. 17 medical records among separate medical providers for the benefit of the patient Defendants . 18 refusal to accept Redwood Lab results electronically places the economic self interest of. 19 Defendants ahead of patient care , 20 56 Redwood Lab is unaware of any medical provider other than St Joseph Health.
21 Medical Group connected to NCHIIN that has blocked receipt of electronic medical test results. 22 from Redwood Lab , 23 57 Because of Defendants unilateral blocking of the electronic test results Redwood. 24 Lab is required to print out test results and then transmit those paper test results to St Joseph. 25 Health Medical Group by fax because that is the only way clinicians with the St Joseph Health. 26 Medical Group will agree to receive such results This arrangement thwarts the purposes of. 27 electronic medical records which provide speed accuracy and overall improvements to patient. 28 care while reducing the risk of life threatening medical errors Furthermore because Defendants. COMPLAINT, 12 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 14 of 27. 1 will transmit test results conducted at their own lab facilities electronically the unilateral blocking. 2 of Redwood Lab s electronic test results creates an artificial burden on users of out patient medical. 3 lab testing services who prefer to use Redwood Lab . 4 ii St Joseph Health Interferes with Redwood Lab s Clients and Defames. Redwood Lab, 5, 6 58 During the past year Defendants have only escalated their anti competitive tactics . 7 waging a campaign of disinformation designed to eliminate the choice that Eureka healthcare. 8 consumers have in selecting a provider of out patient medical lab services . 9 59 For instance when a patient of one of the clinicians of St Joseph Health Medical. 10 Group comes to Redwood Lab the patient s lab test order will not be accessible to Redwood Lab. 11 through NCHIIN due solely to Defendants unilateral blocking When a Redwood Lab staff. 12 member contacts the patient s doctor s office to request a fax version of the order the doctor s. 13 office will typically insist that the patient walk to the doctor s office to obtain a paper lab order . 14 presumably to be walked back over by the patient to Redwood Lab . 15 60 When the patient arrives at the St Joseph Health Medical Group doctor s office to. 16 obtain the paper lab order the patient is typically told that he or she went to the wrong lab and. 17 that the patient must go to the right lab which the patient is told is St Joseph Health s lab . 18 This is false and misleading and is designed to deprive Plaintiff of the opportunity to provide. 19 outpatient medical lab testing services to the patient and to further Defendants scheme to boycott. 20 Plaintiff and require that St Joseph Health clinicians send their patients to St Joseph Health lab. 21 facilities More specifically during the 12 months preceding the filing of this Complaint . 22 a John Aryunpur MD the Medical Director of the St Joseph Health Medical Group. 23 in Eureka has advised patients that Redwood Lab is the wrong lab for the patient. 24 to use for outpatient medical lab testing and that the patient needs to use St Joseph. 25 Health s lab , 26 b Petra Kuhfahl MD practicing with the St Joseph Health Medical Group in Eureka . 27 has advised patients that Redwood Lab is the wrong lab for the patient to use for. 28, COMPLAINT, 13 , Case 1 18 cv 02074 RMI Document 1 Filed 04 05 18 Page 15 of 27.
1 outpatient medical lab testing and that the patient needs to use St Joseph Health s. 2 lab , 3 c Bruce Kessler MD practicing with the St Joseph Health Medical Group in Eureka . 4 has advised patients that Redwood Lab is the wrong lab for the patient to use for. 5 outpatient medical lab testing and that the patient needs to use St Joseph Health s. 6 lab , 7 d Stuart Cataldo MD practicing with the St Joseph Health Medical Group in. 8 Eureka has advised patients that Redwood Lab is the wrong lab for the patient to. 9 use for outpatient medical lab testing and that the patient needs to use St Joseph. 10 Health s lab , 11 e Alexey Shereshevsky MD practicing with the St Joseph Health Medical Group in. 12 Eureka has advised patients that Redwood Lab is the wrong lab for the patient to. 13 use for outpatient medical lab testing and that the patient needs to use St Joseph. 14 Health s lab , 15 f Gregory Holst MD practicing with the St Joseph Health Medical Group in Eureka . 16 has advised patients that Redwood Lab is the wrong lab for the patient to use for. 17 outpatient medical lab testing and that the patient needs to use St Joseph Health s. 18 lab , 19 g Caroline Connor MD practicing with the St Joseph Health Medical Group in.
20 Eureka has advised patients that Redwood Lab is the wrong lab for the patient to. 21 use for outpatient medical lab testing and that the patient needs to use St Joseph. 22 Health s lab , 23 h Steven Korenstein MD practicing with the St Joseph Health Medical Group in. 24 Eureka has advised patients that Redwood Lab is the wrong lab for the patient to. 25 use for outpatient medical lab testing and that the patient needs to use St Joseph. 26 Health s lab , 27 i Leo Leer MD practicing with the St Joseph Health Medical Group in Eureka has. 28 advised patients that Redwood Lab is the wrong lab for the patient to use for.


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