08-27-13 pre-complaint discovery
TRANSCRIPT
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, CENTER FOR COMPLEX CIVIL LITIGATION
MICHAEL RAMON OCHOA, GD-13-011757 Plaintiff, pro se, vs. PRE-COMPLAINT DISCOVERY DR. ARTHUR LEVINE, UNIVERSITY OF PITTSBURGH BOARD OF TRUSTEES, UPMC BOARD OF DIRECTORS, Defendants.
Filed by:
Michael Ramon Ochoa Plaintiff, pro se 58 West Portal Ave #218 San Francisco, CA 94127 (415) 373-2172 [email protected] #UPMCrecycles https://www.dropbox.com/ sh/yvt5jv2dim5fklq/AdENY _UOJt
COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, CENTER FOR COMPLEX CIVIL LITIGATION
MICHAEL RAMON OCHOA, No. GD-13-11757 Plaintiff, pro se, PRE-COMPLAINT DISCOVERY vs. DR. ARTHUR LEVINE, et al., Defendants.
τί με καλεῖς ὦφήμερε; ἀεροβατῶ καὶ περιφρονῶ τὸν ἥλιον. -Aristoph. Cl. 221
InstructionsDr. Levine,
All documents referenced herein should be regarded as if entered in their entirety, along with every document referenced within every reference herein.
All documents referenced herein can be downloaded at:
https://www.dropbox.com/sh/yvt5jv2dim5fklq/AdENY_UOJt
You were served with interrogatories by USPS certified priority mail at:
10-31-12 Doc 000 Trustee Interrogatories; 03-07-13 Trustees Cease and Desist.
The instructions and definitions given therein apply herein.
Please, review those instructions and definitions, then sign and date below.
I acknowledge that I read and understood the foregoing instructions and definitions prior to preparing my responses to these interrogatories.
_____________________________________Senior Vice Chancellor Arthur S. Levine
Pre-Complaint Discovery Pursuant to 231 Pa. Code Rules 4003.8, 4005 & 4009.11
1. Please, respond to 10-31-12 Doc 000 Trustee Interrogatories.
2. Also, provide complete billing information for all my patient care by UPMC.
3. At 10-23-12 Doc 000 Hearing Transcript pp.37-40, Dr. Erin Rubin, a.k.a. Erin Rubin Ochoa, described her botched attempts to use the Allegheny County Family Court to seize the hepatogenesis data contained on my laptop computer in order to destroy evidence of my primary authorship of the Prometheus Project.
4. At p.40, lines 7-12 of that account, she stated in direct examination that “I’ve worked in close conjunction with the chancellor’s lawyer...”
5. Please, identify “the chancellor” and “the chancellor’s lawyer.”
6. Please, review 05-26-09 Doc 400 Pl.B.25e 05-14-09 Letter George Michalopoulos to ERO.
7. Did “the chancellor” or “the chancellor’s lawyer” assist Dr. Rubin or Dr. Michalopoulos in preparing that letter?
8. Was Dr. Rubin given tenure after she submitted that letter as evidence to Judge Thomas E. Flaherty at the 06-09-09 trial?
9. Please, identify every person whose approval was required for her promotion.
10. What is Dr. Rubin’s current employment status within the University of Pittsburgh, UPMC, or any affiliate?
11. Are you aware of any other instance of a member of the faculty, clinical staff or UPMC contract worker being promoted, relocated, or employed out of state after having been accused of a serious crime directly involving patient care, domestic abuse or research fraud?
12. Are you aware of any other allegations of any member of the faculty or clinical staff using his or her medical license, research funding, or any University of Pittsburgh or UPMC facility, resource or credit card to attempt to murder their spouse?
13. What have you done to prevent a recurrence?
14. Were Dr. Autumn Marie Klein’s organs harvested by the Starzl Institute?
15. Who signed the pathology reports?
16. How many organs has the Starzl Institute harvested from suicide victims? murder victims? former WPIC patients? former Allegheny County Jail prisoners? family members, domestic partners or intimate relations of University of Pittsburgh or UPMC faculty or staff? indigent persons of color?
17. Who signed the pathology reports?
18. Where does Dr. Rubin now work? Where does she hold medical licenses?
19. Where are my innocent daughters?
20. Produce complete itineraries for any travel out of state or abroad by Jael and Esther Ochoa arranged by, paid for, or accompanied by Dr. Rubin in her capacity as a member of the University of Pittsburgh or UPMC.
21. Identify every individual with whom they travelled, stayed or met in Palermo, Sicily or the People’s Republic of China.
22. How many organs has ISMETT harvested from suicide victims? murder victims? former patients? former prisoners? family members, domestic partners or intimate relations of faculty or staff? indigent persons of color?
23. Who signed the pathology reports?
24. What was your gross compensation from the University of Pittsburgh, UPMC or any affiliate from 2006 to present?
25. How was your compensation related to clinical procedure volume or research awards?
26. Identify all past and present members of the University of Pittsburgh Board of Trustees as well as members of the Board of Directors of UPMC from 2006 to present.
27. Identify which of those Board members currently hold, or have ever held public office in Pennsylvania.
28. Please review 01-16-13 Doc 407 Motion for Reconsideration and Relief Exhibit C 01-10-13 Dr. Ravi Chandra Deposition, which was also served to you at 03-07-13 Trustees Cease and Desist.
29. Qua physician, do you object to any of Dr. Chandra’s assertions?
30. Can you determine whether any of the medical care described therein fell outside of acceptable standards?
31. Please, review 06-03-09 Doc 154 D.Ex.4.1.9 01-31-08 Dean Thompson Letter.
32. Given what you know now, do you still agree with Dr. Thompson?
33. Please, provide employment and contact information for Drs. Thomas Starzl, John Fung, Amadeo Marcos, Liise Kayler, Kasum Tom, Julie Fuchs, Parmjeet Randhawa, Tong Wu, Marida Minervini, Michael Nalesnik, Joon seok Song, Pallavi B. Limaye, Mukesh Sah, Pierre Azzam, Samuel Westmoreland, Duane Spiker, Marc Oster and Susan Silver.
______________________________________Michael Ramon OchoaPlaintiff, pro se58 West Portal Ave #218San Francisco, CA 94127(415) [email protected]#UPMCrecycleshttps://www.dropbox.com/sh/yvt5jv2dim5fklq/AdENY_UOJt
COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, CENTER FOR COMPLEX CIVIL LITIGATION
MICHAEL RAMON OCHOA, No. GD-13-11757 Plaintiff, pro se, PRE-COMPLAINT DISCOVERY vs. DR. ARTHUR LEVINE, et al., Defendants.
Verification
I, pro se Plaintiff Michael Ochoa, verify that the statements made in the
foregoing Pre-Complaint Discovery are true and correct to the best of my knowledge,
information and belief. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
______________________________________Michael Ramon OchoaPlaintiff, pro se58 West Portal Ave #218San Francisco, CA 94127(415) [email protected]#UPMCrecycleshttps://www.dropbox.com/sh/yvt5jv2dim5fklq/AdENY_UOJt
COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, CENTER FOR COMPLEX CIVIL LITIGATION
MICHAEL RAMON OCHOA, No. GD-13-11757 Plaintiff, pro se, PRE-COMPLAINT DISCOVERY vs. DR. ARTHUR LEVINE, et al., Defendants.
Notice of Presentation
University of Pittsburgh Office of General Counsel1710 Cathedral of LearningPittsburgh, PA 15260
UPMC Legal/Risk Management Office3600 Forbes Avenue, Suite 503Pittsburgh, PA 15213
Please, be advised that the within Pre-Complaint Discovery was presented via
USPS priority mail on or before August 29, 2013.
______________________________________Michael Ramon OchoaPlaintiff, pro se58 West Portal Ave #218San Francisco, CA 94127(415) [email protected]#UPMCrecycleshttps://www.dropbox.com/sh/yvt5jv2dim5fklq/AdENY_UOJt
COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, CENTER FOR COMPLEX CIVIL LITIGATION
MICHAEL RAMON OCHOA, No. GD-13-11757 Plaintiff, pro se, PRE-COMPLAINT DISCOVERY vs. DR. ARTHUR LEVINE, et al., Defendants.
Certificate of Service
The undersigned hereby certifies that a true and correct copy of the foregoing
Pre-Complaint Discovery was served upon all other parties at the addresses
below via USPS priority mail on or before August 29, 2013.
University of Pittsburgh Office of General Counsel1710 Cathedral of LearningPittsburgh, PA 15260
UPMC Legal/Risk Management Office3600 Forbes Avenue, Suite 503Pittsburgh, PA 15213
______________________________________Michael Ramon OchoaPlaintiff, pro se58 West Portal Ave #218San Francisco, CA 94127(415) [email protected]#UPMCrecycleshttps://www.dropbox.com/sh/yvt5jv2dim5fklq/AdENY_UOJt