My name is Bharani and I am a neurologist who specialises in multiple sclerosis in the Boston area.

It takes a lot for a doctor to even contemplate suing the sitting Attorney General of a state.

Massachusetts Attorney General Maura Healey has hurt me a lot and she deliberately broke both state and Federal law to do so. She also terrified my elderly parents by an unprovoked ambush on my home by two of Maura’s investigators who came intent on immediately physically carrying away my computers and my patients’ “complete page-by-page” medical records.

Naturally I refused as doing so would have been totally unlawful.

Unlike Maura, I am not prepared to violate the law and my patients’ privacy rights.

As I wrote in the lawsuit complaint - “The degree of lawlessness at the level of the Massachusetts Attorney General that has been laid out with particularity in this complaint should not be tolerated.”

Maura broke the law to help her client in a private civil lawsuit, a James Paikos, who routinely violates the law himself at the Massachusetts Board of Registration in Medicine.

The case involves intentional violations of the federal Computer Fraud and Abuse Act and the Stored Communications Act.

You may read and download the complaint here -> DOWNLOAD CASE # 1:15-CV-13297-NMG

As the case proceeds please check back for fresh documents and updates. I shall post original documents here for everyone to follow along.

Thank you for reading about this case!

Best wishes,

Bharani Padmanabhan MD PhD

When Maura sent her thugs to my home and scared my elderly parents she sent them with the express intention of intimidating us and stealing my files unlawfully.

The woman officer who accompanied Investigator Chris Cecchini was there to provide muscle.

My mother described her as a prison guard. Maura and the rest at the Attorney General's Office have kept her identity hidden to this day.

Even though the AGO accepted service for her, she was not named or included in the AGO's Motion to enlarge time to answer.

I therefore filed a Motion for Entry of Default against this Jane Doe.

Download default entry jane doe FILED 2015_10_22_13_40_57

Maura Healey responds to my seeking Default against Jane Doe

Maura Healey and the other defendants filed a Response to my filing for Entry of Default against Jane Doe.

Which is interesting given they have refused to identify or represent Jane Doe.

There were severe problems in their Response as well.

DOWNLOAD Document 20

Motion for Sanctions against Maura Healey for Fraud on the Court

I tried to confer with Maura's Office about my Motion for Sanctions but received total silence in return.

Went ahead and filed the Motion for Sanctions against Maura Healey and others on November 6th, 2015.

As of this moment, November 13th, 2015, the total silence continues.

DOWNLOAD - Maura sanctions FILED

Maura Healey and her co-defendants were ordered by the Federal Court to file their Answer to my Complaint before the end of November 15th, 2015.

November 15th came and went so I went in to Court and filed a Motion for Entry of Default against them.

My Motion was time-stamped at 9:08 AM on the 16th of November, 2015.

DOWNLOAD Document 26

At 10:24AM Maura's lawyer, Mark Sutliff, filed a Motion to Dismiss my Complaint.

They did not however file an Answer to my Complaint.

DOWNLOAD Document 23

The reason my Motion has a higher Document number is because I am pro se and have to depend on the Court Clerk to scan my written documents and file them.

The Clerk electronically filed my 9:08AM Motion after 11AM while Maura's lawyer filed electronically himself at 10:24AM.

So his document is 23 and mine is 26. You can see the time-stamps on the documents.

The very next day the defendants also filed an Opposition to my Motion for Entry of Default claiming that they were perfectly correct in filing their Motion to Dismiss on the 16th.

DOWNLOAD Document 27

The next day I filed my Objection to their Opposition and Motion for Sanctions proving they deliberately lied to the Court in writing and asking that their Motion to Dismiss be thrown out for being too late plus them lying about it.

It's not as if they owned up to it, said sorry and asked for my assent prior to filing.

DOWNLOAD Document 28

That was on Thursday morning. There has been total silence from Maura's office since then.

We now have to see if the Judge will enforce the rules and the law on Attorney General Maura Healey and her co-defendants.

If he does then the case is over and I have won by default.

On November 30, 2015, I filed my Opposition to the deliberately fraudulent Motion to Dismiss filed by Maura Healey. Doucement 34

DOWNLOAD Document 34

I followed that up with a Motion for Sanctions and Affidavit against Maura Healey's lawyer, Assistant Attorney General Mark Sutliff, for filing her Motion to Dismiss without conferring with me beforehand as required. Document 35

DOWNLOAD Document 35

And then I filed a Motion to Seek Order that Defendants furnish a sworn Affidavit attesting to the veracity of each of their pleadings. Document 36

DOWNLOAD Document 36

Naturally I dutifully emailed Co-counsel Adam LaGrassa prior to filing each Motion. So far I have not heard back from anyone at Maura Healey's Office.

The Judge, Nathaniel Gorton, finally ruled, on one motion. He denied my motion for entry of default against Jane Doe, Document 29

DOWNLOAD Document 29

More importantly he threatened me with sanctions for "excessive, inflammatory and groundless" claims. He thought that would frighten me and stop me from pursuing Maura Healey's unlawful actions.

Maura Healey's office opposed my motion for them to file a sworn affidavit attesting to the veracity of everything they file in court. I of course filed a sworn affidavit with every motion I filed.

I further filed a Motion for Contempt against Maura Healey and her co-defendants - Document 44

DOWNLOAD Document 44

Then I filed a Judicial Notice with Judge Gorton. Document 47

DOWNLOAD Document 47

A whole month then went by.

So i filed a Motion to Expedite review. Document 49

DOWNLOAD Document 49

Within one hour of filing that, Judge Gorton tossed my case. Document 50

DOWNLOAD Document 50

He followed this rapidly by dismissing all my pending motions in a 2 page order without any explanations. Document 52

DOWNLOAD Document 52

Followed by a final order of dismissal. Document 53

DOWNLOAD Document 53

Once again Judge Gorton threatened me with sanctions for "inflammatory, groundless" language. He thought it would scare me away from seeking justice from the Courts.

Within 3 days I filed an 11-page Motion for Clarification. Document 55

DOWNLOAD Document 55

And a Notice of Appeal. Document 54.

DOWNLOAD Document 54

We will have to see if Judge Gorton will clarify his deliberately rudimentary and biased dismissal.

As expected, Judge Nathaniel Gorton has not responded to my Motion for Clarification.

On March 2, 2016, I went ahead and filed my APPEAL with the US 1st Circuit Court of Appeals.

DOWNLOAD Document 16-1159

  Maura Healey asked for and was granted time till June 17, 2016, to file her answer brief.

I fully expected Maura would NOT file an answer brief and would file a motion for summary affirmance instead. In fact I warned the Court of this in a motion - Download Document 55

On June 17, 2016, fully as I expected and warned the court, Maura filed a motion for summary disposition instead of an answer brief - Download Document 56

Maura also filed a motion to further extend time for her to file an answer brief! Download Document 57

I immediately filed an objection to this deliberate delay tactic and demanded my day in open court - Download Document 58

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