D.O.G.E -> Notice of Malpractice Lawsuit Against the University of Kentucky Psychiatric Department

[CIABrad.eth]

[Bradley Tyler Burns / Central Intelligence Agency Legal Department VSOP]
[401 Courthouse Square]
[Alexandria, Virginia, USA]
[ciabradleyburns@gmail.com]
[702.773.4529]

[03/10/2025]

Clerk of the Court
[Eastern District Of Alexandria Virginia]
[401 Courthouse Square]
[Alexandria, Virginia, USA]

RE: Notice of Malpractice Lawsuit Against the University of Kentucky Psychiatric Department

Plaintiffs:

1. [Bradley Tyler Burns]
2. [Gary Smith III, if any]

Defendant:
University of Kentucky, Department of Psychiatry
[245 Fountain Ct, Lexington, KY 40509]

Case No.: [121-po-588]

COMPLAINT FOR MALPRACTICE AND MEDICARE FRAUD

INTRODUCTION

1. This is a civil action for medical malpractice and fraud against the University of Kentucky's Psychiatric Department. Plaintiffs allege that the University engaged in grossly negligent practices resulting in severe harm, including the wrongful diagnosis of patients and dual-booking that defrauded Medicare, leading to the loss of lives and countless emotional and financial damages.

PARTIES

2. Plaintiff [Bradley Tyler Burns/ Chief Prosecutor CIA] is a resident of [Clark, Las Vegas, Nevada] and has standing to sue in this jurisdiction.
3. [Gary Smith III, Austin, Texas]
4. Defendant, the University of Kentucky, Department of Psychiatry, is located at [245 Fountain Ct, Lexington, KY 40509] and is responsible for psychiatric treatment and care provided to its patients.

JURISDICTION AND VENUE

5. Jurisdiction is proper in this Court as the conduct giving rise to this action occurred within this jurisdiction, and the parties reside or are deemed residents within this jurisdiction.
6. Venue is appropriate as all relevant transactions, actions, and occurrences giving rise to this Complaint took place within the jurisdiction of this Court.

FACTUAL ALLEGATIONS

7. Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth herein.
8. Plaintiffs allege that the University of Kentucky Psychiatric Department misdiagnosed patients with severe psychiatric disorders without appropriate clinical evaluations.
9. Numerous complaints from both patients and families noted inconsistencies in diagnoses, leading to improper treatments, therapeutic mismanagement, and exacerbation of existing conditions.
10. Furthermore, the Department was found engaging in dual-booking practices—scheduling multiple patients for appointments at the same time—resulting in a failure to provide adequate care and attention to vulnerable individuals.
11. Evidence indicates that a number of patients died as a direct result of the misdiagnoses and subsequent lack of appropriate treatment.
12. Investigations into the Psychiatric Department also revealed fraudulent billing practices, filing claims to Medicare for services not rendered and artificially inflating treatment costs. As a result, this fraud has resulted in millions of dollars in wrongful payments to the University.
13. The actions of the Defendant created additional emotional turmoil for the families and contributed to the loss of lives that could have otherwise been prevented.

COUNT I: MEDICAL MALPRACTICE

14. Plaintiffs restate and incorporate all preceding paragraphs.
15. The Defendant had a duty to provide care that meets accepted standards in psychiatric treatment.
16. Breaching this duty, the Defendant misdiagnosed patients and failed to conduct adequate evaluations, which constitutes gross negligence.
17. As a direct result of this negligence, Plaintiffs have suffered severe emotional, psychological, and financial harm, including the loss of loved ones.

COUNT II: FRAUD

18. Plaintiffs restate and incorporate all preceding paragraphs.
19. The Defendant knowingly engaged in fraudulent billing practices, submitting false claims to Medicare for services not rendered, resulting in financial loss to the government and directly impacting the quality of care patients received.
20. As a direct and proximate result of these fraudulent activities, Plaintiffs and the deceased victims’ families have suffered economic and non-economic damages.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray that this Court:

A. Award damages in excess of [specify an amount], including but not limited to compensation for medical expenses, lost wages, wrongful death, emotional distress, and punitive damages;
B. Order a full accounting of all fraudulent claims made against Medicare and impose sanctions for unlawful actions;
C. Grant any other relief the Court deems just and proper.

JURY DEMAND

Plaintiffs demand a trial by jury on all issues so triable.

Respectfully submitted,
[Bradley Tyler Burns & Gary Smith III - Central Intelligence Agency Legal Department VSOP]