FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
`NYSCEF DOC. NO. 83
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`INDEX NO. 516861/2019
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`RECEIVED NYSCEF: 05/14/2020
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`Index No. 516861/2019
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`AFFIDAVIT IN SUPPORT
`OF EMERGENCY
`ORDER TO
`SHOW CAUSE FOR
`EMAIL PRODUCTION
`
`SUPREME COURT OF THE STATE OF NEW YORK
`KINGS COUNTY, Par 64
`------------------------------------------------X
`WALID KHASS, MD
`Plaintiff,
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`
`
`-Against-
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`NEW YORK- PRESBYTERIAN
`BROOKLYN METHODIST HOSPITAL,
`DOCTOR PRAMOD NARULA, MD.
`DOCTOR BRANDE BROWN, MD,
`SAINT GEORGE’S SCHOOL OF MEDICINE,
`DOCTOR RICHARD LIEBOWITZ, MD,
`DOCTOR STEPHEN WEITZMAN, MD,
`DOCTOR TODD SIMON, MD,
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`
`Defendants.
`-------------------------------------------------X
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`WALID KHASS, MD, being duly sworn, affirms under the penalties of perjury, the following:
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`1. I am Walid Khass, MD, a resident of Brooklyn in Kings County who was born at Defendant
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`Hospital and am a recent graduate of Medical School at Saint George’s University School of
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`Medicine on June 14, 2019, having enrolled in January 2015. My schooling at Saint George’s
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`University School of Medicine commenced in Grenada from January 2015 until December
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`2016, after which I continued my clinical rotations in 3 ethnically diverse Hospitals in New
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`York City from May 2017 to June 2019. I paid tuition to attend the school using United
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`States Federal Loans approximating $450,000.00 and graduated on June 14, 2019 and
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`received my medical degree and diploma, which is a pre-requisite for commencement of a
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`medical residency in an accredited hospital.
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`2. In the 2019 Main Residency Match, I matched to the Pediatrics Program at New York
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`Presbyterian Brooklyn Methodist Hospital for a July 1, 2019 start date. On April 19, 2019,
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`the Pediatrics program requested an NRMP waiver out of its match commitment with me due
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`FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
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`INDEX NO. 516861/2019
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`RECEIVED NYSCEF: 05/14/2020
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`to “applicant ineligibility”. On May 30, 2019, the waiver request was denied by the NRMP.
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`On June 6, 2019, the Program requested reconsideration of the waiver decision, and on July
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`1, 2019 the decision to deny the waiver was upheld by the NRMP. On July 9, 2019, the
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`Program informed the NRMP that it would not accept me into training. Section 3.6 of the
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`Match Participation Agreement for Applicants and Programs (“MPA”) states that the NRMP,
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`in its sole discretion, may grant or deny a waiver request. If a waiver is not granted to the
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`Program by the NRMP, the Program will be expected to offer the position to the applicant. If
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`the program does not offer the position, the NRMP will initiate an investigation to determine
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`whether the program or applicant has violated the terms of the MPA, the NRMP will follow
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`the procedures set forth in Section 8.0 of the MPA. In addition, Section 5.1 of the MPA states
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`the listing of an applicant by a program on its certified rank order list or of a program by an
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`applicant on the applicant's certified rank order list establishes a binding commitment to
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`offer or to accept an appointment if a match results and to start training in good faith (i.e.,
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`with the intent to complete the program) on the date specified in the appointment
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`contract. Absent a waiver from the NRMP, failure to honor this commitment by either party
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`shall be a breech of the MPA and may result in penalties to the breeching program or
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`applicant, as described in Section 8.0.
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`3. The Hospital has been listed in the NRMP R3 System as a Match Violator Pending Action
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`due to breeching the 2019 Main Residency Match Participation Agreement with me in not
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`allowing me to start my Pediatric Residency on July 1st, 2019.
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`4. On February 13th, 2020, Honor Judge Kathy King “ORDERED, that the application for
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`Mandamus is hereby granted to the extent of compelling the Pediatric Residency Program at
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`New York Presbyterian Brooklyn Methodist Hospital to admit Petitioner, Walid Khass, MD,
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`into the July 2020 Pediatric Residency class forthwith”
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`5. I’m writing this affidavit in support of an Order for the Defendant Hospital and named
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`Defendant Doctors to send me the prerequisite extensive materials, multiple paperwork and
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`required emails that were sent out to the rest of the July 2020 Pediatric Residency Class that I
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`FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
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`have not yet received in order to start Pediatric Residency on July 1st 2020. These prerequisite
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`procedures and requirements must be completed in a sequential stepwise matter in order to
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`start residency on July 1st 2020.
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`6. Time remains of the essence in this case, as the July 2020 Pediatric Residency Program of
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`Defendant Hospital that Honor Judge King ordered me to enter actually begins its
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`prerequisite required employment enrollment in April, including signing the 3 Year
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`Categorical Pediatric Residency contract and signing up for a New York State Medical
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`License and insurance, and completing required Hospital online modules and applications for
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`Hospital security clearances and other ministerial matters, starting on April 1st, 2020.
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`Introductory emails were also supposed to be sent out to all the new residents in March,
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`which I have never received. These pre-employment emails contain required enrollment
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`procedures and applications that are all required to be completed prior to the start of
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`Residency on July 1st 2020. Defendant Hospital sends out these materials in April as all the
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`previously stated takes quite a time to be completed before attending Orientation on June
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`2020 and starting Residency on July 1st 2020.
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`7. Based off all of the following Emails from 2019 and important dates that were taken from
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`2019’s Pediatric Residency timeline (as I was supposed to start in July 1st 2019), I have not
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`received anything from the Hospital since Honor Judge King made her Mandamus order on
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`February 13th 2020 and we are nearing the end of May 2020 and I have not received any of
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`the introductory emails in March 2020 or the required paperwork in April 2020 including
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`signing of the contract. My attorney has constantly, since March 2020, both by email and on
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`phone calls with the Defendant Hospitals attorneys, conveyed the importance of receiving
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`these materials, which the Hospital has completely ignored signifying their intent to
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`unlawfully disobey Judge Kings order of Mandamus.
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`8. On March 18, 2019, subsequent to the Match last year, I had received an introductory email
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`sent by the Program Coordinator for the Pediatric Residency, Ms. Yolanda Grajales, stating
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`“Dear Interns: I want to welcome all of you that matched with us at New York Presbyterian
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`FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
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`RECEIVED NYSCEF: 05/14/2020
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`Brooklyn Methodist Hospital. I look forward to meeting all of you and getting to know you
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`better. If you have any concerns or questions, please feel free to call me and let me know how
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`I can help you transition into our program without any difficulties. I know some of you are
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`concerned about the housing in the area. Unfortunately, housing at NYPBMH is very
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`limited. On or about April 1, 2019, you will be receiving instructions on how to register into
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`our program through a website that we use. The person sending you these instructions will be
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`Sophia Small Warner. With these instructions, you will also receive information on how to
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`access housing. Again, since housing is limited, please check on the Internet for additional
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`housing accommodations. If you are not sure about applying for hospital housing, I suggest
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`you apply anyway. If you change your mind later, it will be too late. It's best to be on the list
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`and if you don't want it, it will go to the next person on the list, but if you don't apply you will
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`be the last person on the list. Hope to hear from you soon. Those of you, who have not
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`responded to me regarding your new residency position, please do so. I want to make sure
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`you are starting with us in July and all is well”. I still haven’t received the email of April 1st
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`that was to be sent by the Hospital and Ms. Sophia Small Warner, which was supposed to
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`provide me with “receiving instructions on how to register into our program through a
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`website that we use”.
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`9. On March 19, 2019, subsequent to the Match, I had received an email sent by DOCTOR
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`BRANDE BROWN, the Hospital’s Associate Program Director for the Pediatric Residency
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`Program, stating, “Congratulations, and welcome to the New York Presbyterian Brooklyn
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`Methodist pediatric family. We are so excited that you will be joining our team!! Soon (April
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`1) you will receive an email from our GMEC [General Medical Education Center] office
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`regarding further useful information on your placement as well as instructions for how to
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`upload required paperwork. . In addition, the chief and I will also be sending you useful
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`information here and there regarding the program and what to expect. Attached you will find
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`the upcoming classes contact information. It is also a good idea to start a group email or
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`whatsapp thread in case you need to reach out to each other. If you have any questions at all,
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`please do not hesitate to email or call either myself, the chief, or our program coordinator
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`Yolanda Grajales (also cc'd on this email.) We look forward to seeing each and every one of
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`you again soon!”” I still haven’t received the email of April 1st that was to be sent by the
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`Hospital and DOCTOR BROWN, which was supposed to provide me with “useful
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`information on my placement as well as instructions for how to upload required paperwork”.
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`I have not been provided with this years upcoming classes contact information or been
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`included in an incoming Pediatric Residency group email or Whatsapp messaging thread.
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`10. On March 22, 2019, I had received an email sent by the Program Coordinator for the
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`Pediatric Residency, Ms. Yolanda Grajales, stating “Dear Residents: Dr. Hoang will be
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`administering the NRP (Neonatal Resuscitation Program) session with you on June 24th,
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`2019. I will mail books out to you in advance. You will have to pay for the cost of the
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`course on the Internet, but save your receipt and give it to me so that I can reimburse you.
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`Also when you complete the course, please make sure you print out the certificate verifying
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`you took and passed the course. You MUST bring it with you on the day of the session
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`(June 24) so that you can participate in this session. Please read the following message:
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`Future NYP BMH Pediatric Residents, Welcome! My name is Dan Thanh Hoang; I am one
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`of the neonatal attendings. Before you matriculate here in July, you will need to be certified
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`as a provider of the Neonatal Resuscitation Program (NRP). This requires that you read the
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`entire NRP manual, which will be sent to you by the residency program coordinator, Yolanda
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`Grajales. Please make sure you give Yolanda a current mailing address for this reason. We
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`will mail out the books the last week of April. You will then need to register with the
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`organization that administers the program, called Healthstream. The link to the instructions
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`is https://www.aap.org/en-us/Documents/nrp_provider_howto.pdf You have to complete and
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`pass the first part of the examination online. After the exam, you need to complete the survey
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`in order to to be cleared for Part II, which is a live skills demonstration and simulation that
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`we will proctor on June 24 in the hospital. Thank you, and we are excited to meet you” I still
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`haven’t received this very important email since it is a requirement for Pediatric Residency
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`FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
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`specifically to be certified in Neonatal Resuscitation before Residency begins so that we have
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`the expertise and knowledge necessary to resuscitate newborns who are suffering from
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`respiratory distress. I still haven’t received any email from the Program Coordinator, Ms.
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`Yolanda Grajales, asking for my mailing address so she can send me the required books. I
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`would need to receive the book, read the book, register with the organization Healthstream
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`and then complete the first part of the examination online so that I would be cleared for Part 2
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`“which is a live skills demonstration and simulation that we will proctor on June 24 in the
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`hospital.”
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`11. The other emails contain the Following Important Dates of receiving more important required
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`paperwork and was based off of the 2019 Pediatric Residency Incoming Class WhatsApp
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`Group Chat that I was part of. But I had not received any of the materials that my fellow
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`interns received last year because the Defendant Hospital had made a premature decision on
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`my residency position which was evident from me not receiving the first email on April 1st
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`2019 from the Defendant Hospital which was prior to my Medical Schools Disciplinary
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`Hearing on April 3rd, 2019 and the Defendant Hospitals NRMP Waiver Request which was
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`on April 19, 2019. Clearly, the Defendant Medical School colluded with the Defendant
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`Hospital as the Defendant Hospital had become unresponsive to my emails and phone calls
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`and made an arbitrary and unfair decision to stop responding to me or send me any of the
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`required emails or paperwork before the Defendant Medical School took any action.
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`12. An “Email on April 2nd 2019 from “New Innovations with
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`login
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`information”
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`(support@new-innov.com) was sent to all the incoming Pediatric Residents which I have yet
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`to receive. This login information is essential to receiving access to the Hospital Residency
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`Management System.
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`13. An “Email on April 2nd 2019 about “Initiating the checklist” from Ms. Sophie Small-Warner
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`from the Hospital with Checklists that include, multiple checklists, checklist on New York
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`Presbyterian Brooklyn Methodist Hospital Onboarding, and most importantly a Checklist on
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`the 2019-2020 Contract Checklist. I have yet to receive this email, which provides key
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`FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
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`information about Residency onboarding and gathering the necessary paperwork for signing
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`of the Pediatric Residency 3 year Categorical contract.
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`14. An “Email on April 3rd 2019 from Program Coordinator Ms. Yolanda Grajales which stated,
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`“The Staff ID badge office is in 501 6th street (not 506) and it is opened Monday to Friday
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`9AM to 1PM (not 4PM). The Employee Health appointment should be scheduled late May-
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`early June since they need blood results and physical within 60 days of start. We want to
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`schedule BLS (Basic Life Support) for new residents as a group in June (weekend of 22-23)
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`either Saturday or Sunday. The Pediatrics Orientation will be that last week in June when the
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`new residents have the NRP (Neonatal Resuscitation Program) Session and Hospital
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`Orientation. There won’t be any orientation activities scheduled before the last week in June.”
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`I have yet to receive this email as it provides essential information on how to receive a Staff
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`Identification Card and schedule an Employee Health appointment. It also provides important
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`information about when BLS (Basic Life Support) training will be conducted as a group with
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`all the other incoming Pediatric Residents and when the Pediatric and Hospital Orientation
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`will take place.
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`15. An “Email on April 4th 2019 from Certiphi about “Background Investigation Form”. I have
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`yet to receive this email, as it is a requirement for all new residents regardless of what
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`specialty they enter for residency that they complete a Background Check before
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`commencing their respective residencies on July 1st. This Background check is a requirement
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`for Hospitals so that they can have assurance that their new residents are cleared to start
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`residency on July 1st.
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`16. An “April 6th 2019 Contract Available on New Innovations.” I have yet to receive this
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`very important email from the Defendant Hospital as it contains the 3 Year Pediatric
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`Residency Categorical Employment Contract that I am supposed to review and sign. This
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`contract includes everything from residency salary, medical benefits, and insurance to terms
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`of appointment, resident responsibilities, hospital responsibilities, duty hours, financial
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`support and benefits, reappointment, grievance procedures, and other miscellaneous things.
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`FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
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`The contract is supposed to be signed by myself, the Program Director, which is Defendant
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`Dr. Pramod Narula and the Chief Academic Officer/Designated Institutional Official (D.I.O),
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`which is Defendant Dr. Todd Simon who also coincidentally and conveniently holds a faculty
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`appointment at Defendant Medical School.
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`17. An “April 6th 2019 more Checklists were made available including the Final Transcript
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`Upload, Letters of Recommendation Upload, Drug Enforcement Agency Number, New York
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`State Infection Control, Death Certificate Training, Mandatory Prescriber Education, and
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`New York Presbyterian Brooklyn Methodist Hospital Corporate Compliance Module Links”.
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`I have yet to receive any of those checklists, training, education or links. I must provide the
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`required documents to be able to be cleared to start residency on July 1st. Also an application
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`has to be filled with the Drug Enforcement Agency (DEA) for a DEA number, which is
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`required to prescribe medications under the supervision of an attending physician while in
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`residency. Mandatory Prescriber Education refers to Prescribers licensed in New York to treat
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`humans and who have a DEA registration number to prescribe controlled substances under a
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`facility registration number, must complete at least 3 hours of coursework or training in pain
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`management, palliative care, and addiction. Practitioners must notify the Department of
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`Health that they have completed the educational requirements by submitting an attestation
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`online. New York State Law requires that all Health Care Providers including physicians,
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`medical residents and medical students receive training on infection control and barrier
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`precautions every four years. Death Certificate Training must be provided to all new
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`incoming residents in the unfortunate event of being able to correctly fill out a Death
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`Certificate. There is also New York Presbyterian Brooklyn Methodist Hospital Corporate
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`Compliance Modules that need to be done prior to starting residency on July 1st. I have yet to
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`receive any of the above very important information regarding registering for a DEA
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`Number, Mandatory Prescriber Education, New York State Infection Control, Death
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`Certificate Training and Hospital Corporate Compliance Modules, which needs to all be
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`completed prior to starting residency on July 1st and will equally take a substantial amount of
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`FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
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`time to complete which is why these are all released to the incoming Pediatric Class in April
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`so that they can be completed in time to start residency July 1st.
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`18. An April 6th 2019 Scope of Pain Prescriber Training at https://www.scopeofpain.org/ was
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`supposed to be emailed to me, which I have yet to receive. SCOPE of Pain is a series of
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`continuing Medical Education activities designed to help you safely and effectively manage
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`patients with acute and/or chronic pain, when appropriate, with opioid analgesics. In order to
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`fulfill educational requirements for the State of New York, after completing this core activity,
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`you must also take an additional module called “Managing Pain and Opioid Use: An
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`educational Program on Compliance with New York State Prescribing Laws.” The Hospital
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`has yet to send me this required training to be completed prior to the start of residency, which
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`is July 1st.
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`19. An April 15th 2019 NPI (National Provider Identifier) Application was sent out which I have
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`yet to receive which is very important for Health Care Providers. The National Provider
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`Identifier (NPI) is a Health Insurance Portability and Accountability Act (HIPAA)
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`Administrative Standard. An NPI is a unique identification number for covered health care
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`providers, created to improve the efficiency and effectiveness of electronic transmission of
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`health information. This is very important to physicians and residents who will work with
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`health information, which I have yet to receive and need to receive prior to starting residency
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`on July 1st.
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`20. An April 15th 2019 E-Vital NYC Health Department Application was sent out and I have yet
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`to receive. E-Vital is New York City’s new electronic reporting system for birth and death
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`records. E-Vital will replace the Electronic Vitals Events Registration System (EVERS) and
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`NYCMED (the log-in health care providers use to access many NYC Health Department
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`online applications). The new system will allow users to electronically submit birth and death
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`registrations with the NYC Health Department’s Bureau of Vital Statistics. This is very
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`important, as this needs to be completed prior to the start of residency on July 1st to be able to
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`report births and deaths to the NYC Health Departments during residency.
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`FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
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`RECEIVED NYSCEF: 05/14/2020
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`21. On April 24th 2019 an email about Health Commerce System (HCS) Account Registration
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`was sent out which I have yet to receive. The Health Commerce System is a secure online
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`communications system operated by the New York State Department of Health. It supports
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`the exchange of routine and emergency statewide health information by local health
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`departments and health facilities, providers and practitioners. Through this system,
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`practitioners now order official prescription pads, subscribe to public health alerts through the
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`Health Alert Network, and access registries along with other health information exchange
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`applications that focus on preparedness, planning, communications, response and recovery.
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`22. On May 2nd 2019 an email from the Pediatric Residency Associate Program Director
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`(Defendant Dr. Brande Brown) about completing the Citi Program Online Modules (CITI
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`Health Information Privacy and Security (HIPS) for Clinical Investigators Course), which I
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`have yet to receive. These modules need to be completed as a requirement prior to the start
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`of residency on July 1st so that the incoming residents are educated and well informed at the
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`start of training.
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`23. Prior to May 3rd 2019 must visit Pediatric Residency Program Coordinator, Ms. Yolanda
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`Grajales, to show her my Diploma and Social Security for her to make copies for the program
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`to have record of.
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`24. On May 6th 2019 residents received Hospital Emails ID@nyp.org which made them part of
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`the New York Presbyterian system which I have yet to receive.
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`25. On May 16th 2019 email from Pediatric Chief to all new residents displaying each residents
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`specific schedules for residency, which I have yet to receive.
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`26. On June 24th 2019 NRP (Neonatal Resuscitation Program) Session and Hospital Orientation.
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`27. On July 1st 2019, all new Pediatric Residents started their residencies except me, as I was not
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`included in any Pediatric Residency orientation or hospital activities despite the Defendant
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`Hospital being denied of the NRMP Waiver Request and Request for Reconsideration they
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`submitted to the NRMP. I was aware from the Hospital’s group “WhatsApp” chat that my
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`FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
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`RECEIVED NYSCEF: 05/14/2020
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`fellow new Residents had received their schedules, identifications, books, hospital logins,
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`orientation materials, and many other items that were listed above that I had never received.
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`28. On July 1st 2020, all new Pediatric Residents start their residencies this year.
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`29. These important dates above which are crucial to commencing Pediatric Residency at New
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`York Presbyterian Brooklyn Methodist Hospital are the same every year but because of the
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`Corona Virus Pandemic, some hospitals have sped up their new residents required procedures
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`to enable them to begin their residencies early. Some Medical Schools have allowed their
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`Senior Medical students to graduate early to start their residencies early to help fight against
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`the COVID-19 Pandemic. Columbia University Vagelos College of Physicians and Surgeons,
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`which is affiliated with New York Presbyterian, has graduated its Medical Students early on
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`April 15th, 2020 instead of May 20th, 2020 to begin their residencies at several New York
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`Presbyterian Hospitals throughout New York City. So some graduates have already started
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`their respective medical residencies. I have already graduated in June 2019 so I am not
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`awaiting graduation from my Medical School.
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`30. I seek an Order from the Court directing Defendants NEW YORK PRESBYTERIAN
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`BROOKLYN METHODIST HOSPITAL to specifically perform the Honor Judge King
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`Mandamus Order to immediately allow me to begin my Pediatric Residency on July 1st 2020,
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`and further Order Defendant to send me the required prerequisite emails including the 3 year
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`Categorical Pediatric Residency Contract, required online certifications and modules, and
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`state medical licensing application and everything else stated above that I have to do in order
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`to start residency on time on July 1st 2020.
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`FILED: KINGS COUNTY CLERK 05/14/2020 05:13 PM
`NYSCEF DOC. NO. 83
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`INDEX NO. 516861/2019
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`RECEIVED NYSCEF: 05/14/2020
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`___________/S/__
`________
`WALID KHASS,
`MD
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`Dated: May 14, 2020
`New York, NY
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`Sworn to before me this ___day of May 2020
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`______________________
`NOTARY PUBLIC
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