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\rsid1837661}{\info{\title DAVID J}{\author Stephen Barrett, MD}{\operator Stephen Barrett}{\creatim\yr2010\mo4\dy4\hr20\min9}{\revtim\yr2010\mo4\dy4\hr20\min10}{\version4}{\edmins3}{\nofpages28}{\nofwords8402}{\nofchars47892}{\nofcharsws58814}
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\rtlch\fcs1 \af0 \ltrch\fcs0 \insrsid1837661 
\par }}{\footerr \ltrpar \pard\plain \ltrpar\qc \li547\ri-900\sl-234\slmult0\widctlpar
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\par }\pard \ltrpar\qr \li547\ri-900\sl-234\slmult0\widctlpar
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                                                                                                                                                                                                                       }{\rtlch\fcs1 \af38 \ltrch\fcs0 
\f38\lang1033\langfe1041\langfenp1041\insrsid1529825 First Amended Complaint for Damages
\par }}{\*\pnseclvl1\pnucrm\pnstart1\pnindent720\pnhang {\pntxta .}}{\*\pnseclvl2\pnucltr\pnstart1\pnindent720\pnhang {\pntxta .}}{\*\pnseclvl3\pndec\pnstart1\pnindent720\pnhang {\pntxta .}}{\*\pnseclvl4\pnlcltr\pnstart1\pnindent720\pnhang {\pntxta )}}
{\*\pnseclvl5\pndec\pnstart1\pnindent720\pnhang {\pntxtb (}{\pntxta )}}{\*\pnseclvl6\pnlcltr\pnstart1\pnindent720\pnhang {\pntxtb (}{\pntxta )}}{\*\pnseclvl7\pnlcrm\pnstart1\pnindent720\pnhang {\pntxtb (}{\pntxta )}}{\*\pnseclvl8
\pnlcltr\pnstart1\pnindent720\pnhang {\pntxtb (}{\pntxta )}}{\*\pnseclvl9\pnlcrm\pnstart1\pnindent720\pnhang {\pntxtb (}{\pntxta )}}\pard\plain \ltrpar\qj \li547\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin547\itap0 \rtlch\fcs1 
\af0\afs20 \ltrch\fcs0 \fs20\lang1033\langfe1033\cgrid\langnp1033\langfenp1033 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 {\*\bkmkstart OLE_LINK19}{\*\bkmkstart OLE_LINK20}DAVID J. WILZIG (CSBN 56232)

\par LAW OFFICES OF DAVID J. WILZIG
\par }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 A Professional Corporation 
\par 1801 Century Park East, Suite 2200
\par Los Angeles, California 90067
\par Tel. (310) 286-1188 Fax (310) 286-2711
\par 
\par 
\par Attorney for Plaintiff
\par Ripsime Filikyan, aka Rita Filikyan
\par 
\par 
\par 
\par }\pard \ltrpar\qc \li547\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin547\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 SUPERIOR COURT OF THE STATE OF CALIFORNIA
\par }\pard \ltrpar\qj \li547\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin547\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
\par }\pard \ltrpar\qc \li547\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin547\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 FOR THE COUNTY OF LOS ANGELES
\par }\pard \ltrpar\qj \li547\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin547\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
\par 
\par 
\par }\pard \ltrpar\qj \fi-2880\li3427\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin3427\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1837661 {\*\bkmkstart OLE_LINK21}{\*\bkmkstart OLE_LINK22}RIPSIME FILIKYAN, aka RITA\tab \tab }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 )
\tab Case No.  BC 355412
\par }\pard \ltrpar\qj \fi-5040\li5587\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin5587\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 FILIKYAN,}{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1837661 {\*\bkmkend OLE_LINK21}{\*\bkmkend OLE_LINK22} \tab \tab \tab \tab \tab }{
\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 )\tab Hon. Jon M. Mayeda, Judge
\par }\pard \ltrpar\qj \fi-5760\li6307\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin6307\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab \tab \tab \tab \tab \tab \tab )\tab Department 72
\par }\pard \ltrpar\qj \fi-5040\li5587\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin5587\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab \tab Plaintiff, \tab \tab \tab \tab )\tab 
\par }\pard \ltrpar\qj \fi-5760\li6307\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin6307\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab \tab \tab \tab \tab \tab \tab )}{\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab FIRST AMENDED COMPLAINT}{\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
\par }\pard\plain \ltrpar\s17\qj \fi-720\li6307\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin6307\itap0 \rtlch\fcs1 
\af0\afs20 \ltrch\fcs0 \fs20\lang1033\langfe1033\cgrid\langnp1033\langfenp1033 {\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825      \tab \tab \tab \tab \tab \tab \tab )\tab 
\par }\pard\plain \ltrpar\qj \fi-7027\li7027\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin7027\itap0 \rtlch\fcs1 
\af0\afs20 \ltrch\fcs0 \fs20\lang1033\langfe1033\cgrid\langnp1033\langfenp1033 {\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab \tab \tab \tab \tab \tab \tab )\tab 1.  Dental Malpractice\tab 
\par }\pard \ltrpar\qj \fi-3427\li3427\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin3427\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 UNIVERSITY OF TEXAS HOUSTON\tab \tab )\tab 2.  Lack of Informed Consent\tab 
\par }\pard \ltrpar\qj \fi-1987\li1987\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin1987\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 HEALTH SCIENCE CENTER; J.E. \tab \tab )\tab 3.  Battery   
\par }\pard \ltrpar\qj \fi-2707\li2707\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin2707\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 BOUQUOT, D.D.S.; ALIREZA\tab \tab \tab )\tab 4.  Violation of Confidentiality of 
\par }\pard \ltrpar\qj \fi-1987\li1987\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin1987\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 PANAHPOUR, D.D.S., aka ALEXANDER\tab )\tab        Medical Information Act
\par PANA; and DOES 1 through 50, inclusive,\tab )\tab        (}{\rtlch\fcs1 \ai\af0\afs26 \ltrch\fcs0 \i\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 Civil Code }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 
\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \u167\'a7\u167\'a756 et seq.)
\par }\pard \ltrpar\qj \fi-6307\li6307\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin6307\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab \tab \tab \tab \tab \tab \tab )\tab 5.  Conspiracy to Commit Fraud
\par }\pard \ltrpar\qj \fi-5587\li5587\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin5587\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab \tab Defendants.\tab \tab \tab \tab )\tab    6.  Intentional Misrepresentation
\par }\pard \ltrpar\qj \fi-1267\li1267\ri-900\sl-234\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin1267\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\ul\lang1033\langfe1041\langfenp1041\insrsid1529825                                                                               }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 )\tab 
7.  Intentional Misrepresentation
\par }\pard \ltrpar\qj \li0\ri-900\sl-234\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
\par 
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab 
COMES NOW Plaintiff RIPSIME FILIKYAN, also known as RITA FILIKYAN, and alleges as follows:\tab 
\par }\pard \ltrpar\qc \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 PARTIES
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab }{\rtlch\fcs1 \af0\afs26 
\ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 1.  Defendant ALIREZA PANAHPOUR, D.D.S., aka ALEXANDER PANA (hereinafter referred to as \u8220\'93PANA\u8221\'94) is, and at all times herein mentioned was, a dentist licens
ed to practice dentistry by the State of California with his principal place of business located at 11500 West Olympic Boulevard, Los Angeles, California 90064.
\par \tab 2.    Defendant J.E. BOUQUOT, D.D.S. (hereinafter referred to as \u8220\'93BOUQUOT\u8221\'94), is, and at all ti
mes herein mentioned was, an oral pathologist operating a biopsy service under the auspices of the University of Texas Houston Health Science Center, Dental Branch, Department of Diagnostic Sciences, Oral and Maxillofacial Pathology, located at 6516 M.D. 
A
nderson Boulevard, Room 3.094F, Houston, Texas.  At all times herein mentioned, Defendant BOUQUOT operated his biopsy service and solicited and conducted business with Defendants practicing dentistry in the State of California by making diagnoses of denta
l specimens in conjunction with said Defendants and sending reports of his findings to said Defendants in the State of California, thereby manifesting sufficient contact with the State of California to establish personal jurisdiction over said Defendant. 

\par \tab 3. Defendant UNIVERSITY OF TEXAS HOUSTON HEALTH SCIENCE CENTER (hereinafter referred to as \u8220\'93UT HEALTH SCIENCE CENTER\u8221\'94
) is a division of the University of Texas, a public education and research institution with its Dental Branch, Department of Diagnostic Se
rvices, Oral and Maxillofacial Pathology, located at 6516 M.D. Anderson Boulevard, Room 3.094F, Houston, Texas.  At all times herein mentioned, Defendant UT HEALTH SCIENCE CENTER, in conjunction with Defendant BOUQUOT, operated a biopsy service on Defenda
nt\rquote 
s premises and solicited and conducted business with Defendants practicing dentistry in the State of California by making diagnoses of dental specimens in conjunction with said Defendants and sending reports of biopsy findings to said Defendants in the S
tate of California, thereby manifesting sufficient contact with the State of California to establish personal jurisdiction over said Defendant. 
\par \tab 4.  Defendant BOUQUOT is the discoverer of a purported disease he calls neuralgia-inducing cavitational osteonecrosis (\u8220\'93NICO\u8221\'94
).  This purported disease/condition has not been substantiated by clear etiological data, has not been the subject of credible Investigational Review Board supervised clinical studies and has not been accepted by the evidence-based scientif
ic and dental communities.  The treatment of choice for proponents of NICO is radical and disfiguring surgery, removing teeth, bone and tissue which, in most instances, results in treating normal biological phenomena as pathological. 
\par \tab 5.  Defendant PANA is a proponent of NICO and promulgates the detection and treatment of the disease as a important facet of his dental practice on his practice\rquote s web site, }{\field{\*\fldinst {\rtlch\fcs1 \af0 \ltrch\fcs0 \insrsid1529825 
 HYPERLINK http://www.eclectichealth.com }{\rtlch\fcs1 \af0 \ltrch\fcs0 \fs24\insrsid1837661 {\*\datafield 
00d0c9ea79f9bace118c8200aa004ba90b0200000003000000e0c9ea79f9bace118c8200aa004ba90b3e00000068007400740070003a002f002f007700770077002e00650063006c00650063007400690063006800650061006c00740068002e0063006f006d002f00000000}}}{\fldrslt {\rtlch\fcs1 \af0\afs26 
\ltrch\fcs0 \fs26\ul\cf2\lang1033\langfe1041\langfenp1041\insrsid1529825 www.eclectichealth.com}}}\sectd \linex0\sectdefaultcl\sftnbj {\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
, and on other office literature provided to his patients.                    
\par \tab 6.  Plaintiff is ignorant of the true names and capacities, whether individual, corporate, associate or otherwise, of defendants sued herein as DOES 1 through 50, inclusive, and therefore sues said defendants by s
uch fictitious names.  Plaintiff is informed and believes, and upon such information and belief, alleges that each of the defendants designated herein as a DOE is legally responsible in some manner for the events and happenings referred to herein and caus
ed the damages proximately thereby to Plaintiff as hereinafter alleged.  Plaintiff will seek leave of court
\par to amend this Complaint to show the true names and capacities of the defendants designated herein as DOES when the same have been ascertained.
\par \tab 
7.  Plaintiff is informed and believes and thereon alleges that, at various times herein mentioned, each of the defendants was the agent, servant, representative or employee of each of the remaining defendants and, in engaging in certain acts hereinafter 
a
lleged, was acting within the course and scope of said agency, service, representation, or employment and materially assisted the other defendants.  Plaintiff is further informed and believes and thereon alleges that each of the defendants ratified the ac
ts of the remaining defendants.
\par }\pard \ltrpar\qc \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 II
\par STATEMENT OF FACTS
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab }{\rtlch\fcs1 \af0\afs26 
\ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
8.  On or about September 27, 2005, Plaintiff  retained Defendant PANA to diagnose and treat her dental complaints of heat sensitivity in her teeth, bad breath and food collection between her teeth.  At
 that time, Defendant PANA conducted a comprehensive evaluation, took x-rays and recommended that Plaintiff return to his office for further diagnostic testing and evaluation.
\par \tab 9.  On or about September 27, 2005, at the time that Plaintiff FILIKYAN sought 
the professional dental services of Defendant PANA, said Defendant maintained his office and held himself out to the general public as a competent and skilled dentist and dental surgeon licensed by the State of California Dental Board, and Plaintiff relie
d upon said representations of skill and competency when retaining Defendant PANA to examine, diagnose and treat her dental complaints.
\par \tab 10.  On or about September 27, 2005, and thereafter on numerous occasions, Defendant PANA identified himself to Plaintif
f as a medical doctor, although Defendant PANA was not, at any time relevant herein, licensed by the State of California as a physician authorized to practice medicine.
\par \tab 11.  On or about September 29, 2005, at Defendant PANA\rquote s recommendation and in purported treatment of Plaintiff\rquote 
s dental complaints, Plaintiff returned to his office for further purported diagnostic testing which included an hour of autonomic reflex testing (known as \u8220\'93ART\u8221\'94), a purported diagnostic test accomplished by placing the examiner\rquote s
 hand on some part of the patient\rquote 
s body and palpating over that body part.  ART has not been accepted by the scientific and dental communities as an accepted therapeutic modality as there is no scientific basis for this purported diagnostic test.  Further at the September 29}{
\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\super\langfenp1041\insrsid1529825 th}{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
 appointment, Defendant gave Plaintiff chlorella pyrenoidosa, a nutritional supplement utilized in the treatment of fibromyalgia, hypertension and ulcerative colitis.
\par \tab 12.  On or about October 5, 2005, at Defendant PANA\rquote s recommendation and in purported treatment of Plaintiff\rquote 
s continuing dental complaints, Plaintiff received four separate neural therapy intravenous injections into parts of her body, some of which were unrelated to her mouth, jaw or face.  Further at the October 5}{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 
\fs26\lang1033\langfe1041\super\langfenp1041\insrsid1529825 th}{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
 appointment, Defendant PANA subjected Plaintiff to another hour of ART for purported diagnostic purposes and performed biological terrain management (BTM), which is a non-FDA approved device, and like ART, is not accepted by the scientific and 
dental communities as a legitimate diagnostic tool.  The BTM testing accomplished by Defendant PANA indicated that Plaintiff\rquote s kidneys were weak and that she needed to regulate her urine.
\par \tab 13.  On or about October 6, 2005, at Defendant PANA\rquote s recommendatio
n and inducement, Plaintiff underwent several surgical procedures, including crown removal on two separate teeth, crown build-up in four areas, bone graphs, removal of lesions, removal of adontogenic cysts, orantral fistula closure (sinus lining), surgica
l extraction of two teeth and the excision of a significant amount of the supporting bone surrounding the excised teeth and their adjacent areas.  During Plaintiff\rquote s dental surgery, she was given oxygen support and an intravenous Vitamin C drip.

\par \tab 14.  Plaintiff is informed and believes and, based thereon, alleges that on or about October 6, 2005, Defendant PANA provided to Defendants BOUQUOT and UT HEALTH SCIENCE CENTER tissue and bone specimens from Plaintiff\rquote 
s October 6, 2005, surgery and transmitted to said Defendants data, including information identifying Plaintiff by name, address, age, and date of birth.
\par \tab 15.  Plaintiff is informed and believes and, based thereon, alleges that sometime thereafter, Defendants BOUQUOT and UT HEALTH SCIENCE CENTER generated a biopsy report which reflected Defendants\rquote  microscopic diagnoses and findings.
\par \tab 16.  On or about October 12, 2005, at Defendant PANA\rquote s recommendation and in purported treatment of Plaintiff\rquote s continuing dental complaints, Plaintiff received six separat
e neural therapy intravenous injections into parts of her body, some of which were unrelated to her mouth, jaw or face.   Further at the October 12}{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\super\langfenp1041\insrsid1529825 th}{
\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825  appointment, Defendant PANA subjected Plaintiff to another hour of ART for purported diagnostic purposes a
nd in purported treatment,  Defendant PANA performed phosolipid exchanges to purportedly impact Plaintiff\rquote 
s cholesterol levels, gave Plaintiff fish oil, marketed as a nutritional supplement to combat heart disease, CGF chlorella, marketed to improve a person\rquote s digestion, energy and overall health and organic cilantro
\par \tab 17.  On or about October 17, 2005, at Defendant PANA\rquote s recommendation and in purported treatment of Plaintiff\rquote s continuing dental complaints, Plaintiff was subjected to another hour of ART, th
is time accompanied by a Vitamin C intravenous drip.
\par \tab 18.  On or about November 1, 2005, at Defendant PANA\rquote S recommendation and in purported treatment of Plaintiff\rquote s continuing dental complaints, Plaintiff underwent two hours of ART and received four separ
ate neural therapy intravenous injections into parts of her body, some of which were unrelated to her mouth, jaw or face.  Further at the November 1}{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\super\langfenp1041\insrsid1529825 st}{
\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825  appointment, Plaintiff was provided by Defendant PANA goat whey, which is marketed to promote health, you
thfulness and long life; digestzymes, digestive enzymes utilized to enhance absorption of food and nutrients; and antimicrobial agents, although Plaintiff was never advised that she had an infection for which antimicrobial agents would be prescribed.

\par \tab 19.  On or about November 16, 2005, at Defendant PANA\rquote 
s recommendation and inducement, Plaintiff underwent several surgical procedures, including crown sculpting, crown removal on two separate teeth, crown build-up in three areas, pontic sculpting, removal of 
lesions with bone graphs, and surgical extraction of a tooth and the excision of a significant amount of the supporting bone surrounding the excised tooth and their adjacent areas.  During Plaintiff\rquote 
s dental surgery, she was given oxygen support, an intravenous Vitamin C drip and therapeutic drug injections.
\par \tab 20.  On or about November 29, 2005, Defendant PANA provided to Defendants BOUQUOT and UT HEALTH SCIENCE CENTER tissue and bone specimens from Plaintiff\rquote s November 16, 2005, surgery and transmitted to s
aid Defendants data, including information identifying Plaintiff by name, address, age, and date of birth.
\par \tab 21.  On or about December 19, 2005, Defendants BOUQUOT and UT HEALTH SCIENCE CENTER generated biopsy report #05-4192 which reflected Defendants\rquote  microscopic diagnoses and findings.
\par \tab  22.  On or about November 17, 2005, at Defendant PANA\rquote s recommendation and in purported treatment of Plaintiff\rquote s continuing dental complaints, Plaintiff was given phosphatidyl choline, a nutritional supplement which is ma
rketed for the prevention of atheroscherosis and heart disease; immunitone, a nutritional supplement which is marketed to support immune wellness; and absorbic C, intravenous doses of Vitamin C in pill form.  
\par \tab 23.  On or about November 29, 2005, at Defendant PANA\rquote S recommendation and in purported treatment of Plaintiff\rquote 
s continuing dental complaints, Plaintiff received six separate neural therapy intravenous injections into parts of her body, some of which were unrelated to her mouth, jaw or face.  Further at the November 29}{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 
\fs26\lang1033\langfe1041\super\langfenp1041\insrsid1529825 th}{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825  appointment, Plaintiff was provided by Defendant PANA digestzymes and thyroid H/K.
\par \tab 24.  On or about December 7, 2005, at Defendant PANA\rquote s recommendation and inducement, Plaintiff underwent several surgical procedures, including crown sculpting, crown removal and pontic sculpting.  
\par \tab 25.  On or about December 21, 2005, at Defendant PANA\rquote s recommendation and in purported treatment of Plaintiff\rquote s continuing dental complaints, Plaintiff underwent an hour of ART and received six separate n
eural therapy intravenous injections into parts of her body, some of which were unrelated to her mouth, jaw or face.  Further at the December 21}{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\super\langfenp1041\insrsid1529825 st}{
\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825  appointment, Plaintiff was provided by Defendant PANA fish oil and organic freeze-dried garlic.
\par \tab 26.  On or about January 3, 2006, at Defendant PANA\rquote s recommendation, Plaintiff was fitted with three temporary crowns.
\par \tab 27.  On or about February 6, 2006, at Defendant PANA\rquote s recommendation and in purported treatment for Plaintiff\rquote s continuing dental complaint, Plaintiff was given thyroid complex and organic freeze-dried garlic by Defendant PANA.
\par \tab 28.  On or about February 14, 2006, at Defendant PANA\rquote s recommendation and in purported treatment of Plaintiff\rquote s continuing dental complaints, Plaintiff underwent an hour of
 ART, received a neural therapy intravenous injection and was given digestzymes, thyroid H/K and live life, a nutritional supplement marketed as providing general protection from environmental and dietary pollution and as an anti-aging agent.
\par \tab 29.  On or about March 13, 2006, Plaintiff underwent the placement of five permanent crowns.
\par \tab 30.  On or about May 2, 2006, at Defendant PANA\rquote s recommendation and in purported treatment of Plaintiff\rquote s continuing dental complaints, Plaintiff received four separate neur
al therapy intravenous injections into parts of her body, some of which were unrelated to her mouth, jaw or face.
\par \tab 31.  At varying times during Plaintiff\rquote s treatment with Defendant PANA and at his recommendation for continuing treatment of Plaintiff\rquote 
s dental complaints, Plaintiff was advised to take a colonic once a week and to have an enema every other day.
\par \tab 32.  During the term of Plaintiff\rquote s treatment with Defendant PANA and subsequent to the dental surgeries recommended by said Defendant and the other treatment rendered to alleviate Plaintiff\rquote 
s dental complaints, Plaintiff continued to have complaints, including but not limited to, mouth and jaw pain, difficulty eating, pain aggravated by an ill-fitting bridge and embarrassment over her unsightly and disfigured appearance.
\par \tab 33.  On or about July 7, 2006, and pursuant to }{\rtlch\fcs1 \ai\af0\afs26 \ltrch\fcs0 \i\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 California Code of Civil Procedure}{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 
\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 , Section 364, Plaintiff caused a Notice of Intent to Sue letter to be mailed by certified mail to Defendant PANA at his principal place of business
 located at 11500 West Olympic Boulevard, Suite 320, Los Angeles, California 90064.  A true and correct copy of said letter is attached hereto as Exhibit \u8220\'93A\u8221\'94 and incorporated herein by reference.
\par \tab 34.  On or about July 7, 2006, and pursuant to }{\rtlch\fcs1 \ai\af0\afs26 \ltrch\fcs0 \i\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 California Code of Civil Procedure, }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 
\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
Section 364, Plaintiff caused a Notice of Intent to Sue letter to be mailed by certified mail to Defendants BOUQUOT and UT HEALTH SCIENCE CENTER at their principal place of business located at University of Texas Houston Health Scie
nce Center, Dental Branch, Department of Diagnostic Sciences, Oral and Maxillofacial Pathology, located at 6516 M.D. Anderson Boulevard, Room 3.094F, Houston, Texas.  A true and correct copy of said letter is attached hereto as Exhibit \u8220\'93B\u8221
\'94 and incorporated herein by reference.
\par }\pard \ltrpar\qc \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 FIRST CAUSE OF ACTION 
\par (For Dental Malpractice Against Defendants PANA and
\par Does 1 through 5 inclusive)
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab }{\rtlch\fcs1 \af0\afs26 
\ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 35.  Plaintiff realleges and incorporates herein by reference all of the allegations set forth in paragraphs 1 through 34 as though fully set forth.
\par \tab 36.  Pursuant to Plaintiff\rquote s retention of Defendants PANA and Does 1 through 5, inclusive, to diagnose and treat her complaints of heat sensitivity in her teeth, bad breath and food collection between her teeth, said Defendants rendered
 professional dental services in the diagnosis, treatment and care of Plaintiff.
\par \tab 37.  On or about September 27, 2005, and continuing thereafter through May 2, 2006, Defendants negligently failed to exercise the proper degree of knowledge, skill and compet
ence in examining, diagnosing, treating and caring for Plaintiff by incompetently and negligently performing surgical services, resulting in the excessive, permanent and unnecessary loss of teeth, bone and tissue causing Plaintiff to suffer gross jaw and 
mouth disfigurement.
\par \tab 38.  On or about September 27, 2005, and continuing thereafter through May 2, 2006, Defendants negligently failed to exercise the proper degree of knowledge, skill and competence in examining, diagnosing, treating and caring for Plaint
iff by incompetently and negligently undertaking diagnostic testing, including but not limited to ART and BMT as described above, which have no clinical support in the scientific and dental communities for the diagnosis of dental complaints.
\par \tab 39.  On or ab
out September 27, 2005, and continuing thereafter through May 2, 2006, Defendants negligently failed to exercise the proper degree of knowledge, skill and competence in examining, diagnosing, treating and caring for Plaintiff by incompetently and negligen
tly prescribing treatment, including but not limited to the provision of nutritional supplements and the recommendation of colonics and enemas, which are not proper nor scientifically recognized appropriate methods for treatment of dental complaints.  

\par \tab 40.
  On or about September 27, 2005, and continuing thereafter through May 2, 2006, Defendants negligently failed to exercise the proper degree of knowledge, skill and competence in examining, diagnosing, treating and caring for Plaintiff by incompetently an
d negligently providing medical services to Plaintiff beyond their skill and competency and beyond that which Defendants were authorized and licensed by the State of California to provide.
\par \tab 41.  As a proximate result of the negligence of Defendants, and eac
h of them, Plaintiff suffered the unnecessary loss of healthy fixed teeth and the healthy supporting bone surrounding and adjacent to the excised teeth, resulting in the necessity for reconstructive activities, including surgery, augmentation and installa
tion of prosthetic appliances.
\par \tab 42.  As a further proximate result of the negligence of Defendants, and each of them, Plaintiff has sustained injury to her health, strength and activity, all of which injuries have caused, and continue to cause, Plaintiff gr
eat mental, physical and nervous pain and suffering.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 43.  As a further proximate result of the negligence of Defendants, and each of them, Plaintiff has sustained, and will continue to sustain, disabling, serious and permanent physical injuries, all to Plaintiff\rquote 
s general damage in an amount presently unascertainable.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage when ascertained.\tab 
\par \tab 44.  As a further proximate result of the negligence of Defendants, and each of them, Plaintiff has incurred medical, hospital and related expenses in an unknown sum.  Plaintiff wil
l seek leave of Court to amend her Complaint to set forth the amount of damage when ascertained.
\par \tab 45.  As a further proximate result of the negligence of Defendants, and each of them, Plaintiff will in the future incur medical, hospital and related expense
s , the exact nature and extent of which are currently unknown to Plaintiff.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage when ascertained.
\par \tab 46.  As a further and proximate result of the negligence of s
aid Defendants, and each of them, Plaintiff has sustained, and will in the future sustain, loss of earnings and loss of earning capacity, the exact amounts of which are presently unknown to Plaintiff.  Plaintiff will seek leave of Court to amend this Comp
laint to set forth the full extent of her loss of earnings and loss of earning capacity when same has been ascertained. }{\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
\par }\pard \ltrpar\qc \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 SECOND CAUSE OF ACTION
\par (For Lack of Informed Consent Against Defendants PANA and 
\par Does 1 through 5, inclusive)
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab }{\rtlch\fcs1 \af0\afs26 
\ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 47.  Plaintiff realleges and incorporates herein by reference all of the allegations set forth in paragraphs 1 through 34 as though fully set forth herein.
\par \tab 48.  Pursuant to Plaintiff\rquote s retention of Defendants PANA and Does 1 through 5, inclusive, to treat her complaints of heat 
sensitivity in her teeth, bad breath and food collection between her teeth, said Defendants rendered professional dental services in the diagnosis, treatment and care of Plaintiff.
\par \tab 49.  On or about September 27, 2005, and continuing thereafter through May 2, 2006, in purported treatment of Plaintiff\rquote s ongoing complaints, including but not limited to, surgical procedures for the removal of Plaintiff\rquote 
s teeth, Defendants negligently failed to disclose to Plaintiff the inherent risks involved in the excision of teeth and bone from Plaintiff\rquote s mouth during the surgical procedures and negligently failed to obtain Plaintiff\rquote 
s informed consent for the excision of teeth and bone in light of the undisclosed risks.    
\par \tab 50.  As to Plaintiff\rquote s November 16, 2005, surgery, Defendants negligently failed to obtain any release from Plaintiff as the release which purports to relate to Plaintiff\rquote 
s November 16, 2005, surgery was signed by Plaintiff on November 17, 2005, the day after her surgery.  
\par \tab 51.  If Plaintiff had been adequately informed of the inherent risk associated with the excision of teeth and bone, including but not limited to, jaw pain and disfigurement, Plaintiff would not have consented to said treatment.
\par \tab 52.  As a proximate result of the conduct of Defendants, and each of them, in improperly and unnecessarily excising healthy teeth and bone from Plaintiff\rquote s mouth without Plaintiff\rquote 
s consent and without advising Plaintiff of the inherent risks involved in the excision of teeth and bo
ne, Plaintiff suffered exacerbated jaw pain and jaw and facial disfigurement, resulting in the necessity for reconstructive activities, including surgery, augmentation and installation of prosthetic appliances.
\par \tab 53.  As a further proximate result of the ne
gligence of Defendants, and each of them, Plaintiff has sustained injury to her health, strength and activity, all of which injuries have caused, and continue to cause, Plaintiff great mental, physical and nervous pain and suffering.  Plaintiff will seek 
leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 54.  As a further proximate result of the negligence of Defendants, and each of them, Plaintiff has sustained, and will continue to sustain, disabling, serious and permanent physical injuries, all to Plaintiff\rquote 
s general damage in an amount presently unascertainable.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage when ascertained.\tab 
\par \tab 
55.  As a further proximate result of the negligence of Defendants, and each of them, Plaintiff has incurred medical, hospital and related expenses in a sum presently unascertainable.  Plaintiff will seek leave of Court to amend this Complaint to set fort
h the full amount of damage when ascertained.
\par \tab 56.  As a further proximate result of the negligence of Defendants, and each of them, Plaintiff will in the future incur medical, hospital and related expenses, the exact nature and extent of which are currentl
y unknown to Plaintiff.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage when ascertained.
\par \tab 57.  As a further and proximate result of the negligence of said Defendants, and each of them, Plaintiff has susta
ined, and will in the future sustain, loss of earnings and loss of earning capacity, the exact amounts of which are presently unknown to Plaintiff.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full extent of her loss of ear
nings and loss of earning capacity when same are ascertained.
\par }\pard \ltrpar\qc \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 THIRD CAUSE OF ACTION 
\par (For Battery Against Defendants PANA and Does 6 through 10, inclusive)
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab }{\rtlch\fcs1 \af0\afs26 
\ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 58.  Plaintiff realleges and incorporates herein by reference all of the allegations set forth in paragraphs 1 through 34 as though fully set forth herein.
\par \tab 59.  Pursuant to Plaintiff\rquote s retention of Defendants PANA and Does 6 through 10, inclusive, on or about September 27, 2005, to diagnose and treat her complaints of heat sensitivity in her teeth, bad 
breath and food collection between her teeth, said Defendants rendered professional dental services in the diagnosis, treatment and care of Plaintiff.
\par \tab 60.  Pursuant to \u167\'a71625 of the Dental Practice Act, \u8220\'93dentistry is the diagnosis or treatment, by surgery 
or other method, of diseases and lesions and the correction of malpositions of the human teeth, alveolar process, gums, jaws, or associated structures\u8221\'94.  Pursuant to \u167\'a71625(b) of the Dental Practice Act, one who practices dentistry \u8220
\'93performs, or offers to perform, an operation or diagnosis of any kind, or treats diseases or lesions of the human teeth, alveolar process, gums, jaws, or associated structures, or corrects malposed positions thereof\u8221\'94.  
\par \tab 61.  On or about September 27, 2005, and continuing thereafter throughout Plaintiff\rquote 
s treatment with Defendant PANA, Defendant PANA identified himself to Plaintiff as a medical doctor, as well as a licensed dentist, although Defendant PANA was not, at any time relevant herein, licensed by the State of California a
s a physician authorized to practice medicine.
\par \tab 62.  Irrespective of Defendant PANA\rquote s lack of medical licensure, Defendant made \u8220\'93dental findings\u8221\'94 after performing a purported dental examination of Plaintiff of a lower right shoulder, neck tilted to the rig
ht side and irregular cycles; diagnosed night sweats, cardiovascular problems and abdominal pain; and recommended colonics, enemas and oxygen therapy, all of which were not customary and accepted dental treatment.
\par \tab 63.  On or about September 27, 2005, and continuing thereafter throughout Plaintiff\rquote s treatment with Defendant PANA, Defendant PANA used his dental practice as a pretext to practice medicine in violation of \u167\'a7
1684 of the Dental Practice Act\rquote s prohibition on licensed dentists holding themselves \u8220\'93ou
t as able to perform professional services beyond the scope of his or her license and field or fields of competence as established by his or her education, experience, training, or any combination thereof\u8221\'94... including \u8220\'93
the use of any instrument or device in a manner that is not in accordance with the customary standards and practices of the dental profession\u8221\'94.
\par \tab 64.  On or about October 5, 2005, October 12, 2005, November 1, 2005, November 29, 2005, December 21, 2005, February 14, 2006 and May 2, 2006, by virtue of Defendant PANA\rquote 
s misrepresentations as to his capacity as a medical doctor, his misrepresentations as to his qualifications and expertise, his misrepresentations as to the efficacy of the treatment he recommended, and in purported treatment of Plaintiff\rquote 
s ongoing dental complaints, Plaintiff was  subjected to neural therapy injections of foreign substances into her lower back, left knee, abdomen and the back of her neck, areas not associated with \u8220\'93
human teeth, alveolar process, gums, jaws or associated structures\u8221\'94 as described in \u167\'a71625(b) of the Dental Practice Act as being within the purview of dentistry.
\par \tab 65.  The injections of foreign substances into Plaintiff\rquote s lower back, left knee, abdomen and the back of her neck were harmful and offensive to
 Plaintiff and was conduct by Defendant PANA which exceeded the scope of his license, experience and training and, as such, was medical treatment which was beyond the scope of Plaintiff\rquote s consent to treatment for her dental complaints.
\par \tab 66.  As a proximate
 result of the wrongful conduct of Defendants, and each of them, in improperly and unnecessarily medically treating Plaintiff with neural therapy injections to her lower back, left knee, abdomen and the back of her neck, Plaintiff suffered bleeding and ot
her deleterious side effects.
\par \tab 67.  As a further proximate result of the wrongful conduct of Defendants, and each of them,  Plaintiff has sustained injury to her health, strength and activity, all of which injuries have caused, and continue to cause, Plaint
iff great mental, physical and nervous pain and suffering.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 68.  As a further proximate result of the wrongful conduct of Defendants, and each of them, Plaintiff has sustained, and will continue to sustain, disabling, serious and permanent physical injuries, all to Plaintiff\rquote 
s general damage in an amount presently unascertainable.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage when ascertained.\tab 
\par \tab 69.  As a further proximate result of the wrongful conduct of Defendants, and each of them, Plaintiff has incurred medical, hospital and related expenses in a sum presen
tly unascertainable.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage when ascertained.
\par \tab 70.  As a further proximate result of the wrongful conduct of Defendants, and each of them, Plaintiff will in the fut
ure incur medical, hospital and related expenses, the exact nature and extent of which are currently unknown to Plaintiff.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage when ascertained.
\par \tab 71.  As a furth
er and proximate result of the wrongful conduct of said Defendants, and each of them, Plaintiff has sustained, and will in the future sustain, loss of earnings and loss of earning capacity, the exact amounts of which are presently unknown to Plaintiff.  P
laintiff will seek leave of Court to amend this Complaint to set forth the full extent of her loss of earnings and loss of earning capacity when same are ascertained.
\par \tab 72.  The aforementioned acts of Defendants, and each of them, were wilful, wanton, malicious and oppressive, thereby justifying the award of exemplary and punitive damages as against Defendants, and each of them.
\par }\pard \ltrpar\qc \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 FOURTH CAUSE OF ACTION 
\par (For Violation of the Confidentiality of Medical Information Act
\par Against Defendants PANA, BOUQUOT, UT HEALTH SCIENCE
\par CENTER and Does 11 through 20, inclusive)
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab }{\rtlch\fcs1 \af0\afs26 
\ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 73.  Plaintiff realleges and incorporates herein by reference all of the allegations set forth in paragraphs 1 through 34 as though fully set forth herein.    
\par \tab 74.  Defendants PANA, BOUQUOT, UT HEALTH SCIENCE CENTER and Does 11 through 20, inclusive, are providers of health care as defined in }{\rtlch\fcs1 \ai\af0\afs26 \ltrch\fcs0 \i\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 Civil Code }{
\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 Section 56.05(i) who, during the course of Plaintiff\rquote s treatment, had access to personal and confidential medical information pertaining to Plaintiff.
\par \tab 75.  In the course of Plaintiff\rquote s dental treatment with Defendant PANA, Defendant had in his possession tissue and bone specimens from Plaintiff\rquote s dental surgeries, as well as radiographs and photographs of Plaintiff\rquote 
s face and oral cavity.
\par \tab 76.  On two occasions between September 27, 2005 and May 2, 2006, Defendant PANA transmitted to Defendants BOUQUOT and UT HEALTH SCIENCE CENTER tissue and bone specimens from Plaintiff\rquote s two dental surgeries on October 6, 2005 an
d November 16, 2005, for microscopic analysis.  At the same time, Defendants PANA willfully and wrongfully transmitted to Defendants BOUQUOT and UT HEALTH SCIENCE CENTER radiographs and photographs of Plaintiff\rquote 
s face and oral cavity, dissemination of which identified Plaintiff and was made without her written authorization.  Said radiographs and photographs of Plaintiff\rquote 
s face and oral cavity were not necessary for the diagnosis and/or treatment of Plaintiff\rquote s dental complaints and were not utilized by Defendants BOUQUOT and UT HEALTH SCIENCE CENTER for the purpose of conducting microscopic analyses.
\par \tab 77.  Thereafter, Plaintiff is informed and believes, Defendants BOUQUOT and UT HEALTH SCIENCE CENTER willfully and wrongfully further disseminated Plaintiff\rquote s
 confidential medical information without her knowledge nor her written authorization by using said information in research studies which were published on the Internet and elsewhere and by using said information for teaching purposes and as teaching tool
s.
\par \tab 78.  As a proximate result of the unauthorized disclosure of Plaintiff\rquote 
s confidential medical information, first by Defendant PANA and, thereafter, by the republication of said confidential medical information by Defendants BOUQUOT and UT HEALTH SCIENCE
 CENTER, Plaintiff has sustained injury to her health, strength and activity, all of which injuries have caused, and continue to cause, Plaintiff great mental, physical and nervous pain and suffering.  Plaintiff will seek leave of Court to amend this Comp
laint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 79.  As a further proximate result of the unauthorized disclosure of Plaintiff\rquote s confidential medical information, first by Defendant PANA and, thereafter, by the 
republication of said confidential information by Defendants BOUQUOT and UT HEALTH SCIENCE CENTER, Plaintiff has sustained, and will continue to sustain, disabling, serious and permanent physical injuries, all to Plaintiff\rquote 
s general damage in an amount presently unascertainable.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.}{\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 
\b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
\par }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab 80.  As a further proximate result of the unauthorized disclosure of Plaintiff\rquote s con
fidential medical information, first by Defendant PANA and, thereafter, by the republication of said confidential information by Defendants BOUQUOT and UT HEALTH SCIENCE CENTER, Plaintiff has incurred medical, hospital and related expenses in a sum presen
tly unascertainable.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 81.  As a further proximate result of the unauthorized disclosure of Plaintiff\rquote s confide
ntial medical information, first by Defendant PANA and, thereafter, by the republication of said confidential information by Defendants BOUQUOT and UT HEALTH SCIENCE CENTER, Plaintiff will in the future incur medical, hospital and related expenses, the ex
act nature and extent of which are currently unknown to Plaintiff.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 82.  As a further proximate result of the unauthorized disclosure of Plaintiff\rquote 
s confidential medical information, first by Defendant PANA and, thereafter, by the republication of said confidential information by Defendants BOUQUOT and UT HEALTH SCIENCE CENTER, Plaintiff has sustained, and will in
 the future sustain, loss of earnings and loss of earning capacity, the exact amounts of which are presently unknown to Plaintiff.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result the
reof when ascertained.
\par \tab 83.  The aforementioned conduct of Defendants PANA, BOUQUOT, UT HEALTH SCIENCE CENTER and Does 11 through 20, inclusive, was willful, intentional and malicious and, pursuant to }{\rtlch\fcs1 \ai\af0\afs26 \ltrch\fcs0 
\i\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 Civil Code }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 Section 56.35, entitles Plaintiff to an award attorney\rquote 
s fees not to exceed $1,000 and reimbursement of the costs of litigation.
\par }\pard \ltrpar\qc \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 FIFTH CAUSE OF ACTION 
\par }\pard \ltrpar\qc \fi-720\li1267\ri-900\sl-468\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin1267\itap0 {\rtlch\fcs1 
\ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 (For Conspiracy to Commit Fraud Against Defendants
\par }\pard \ltrpar\qc \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
PANA, BOUQUOT and Does 21 through 25, inclusive)
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab }{\rtlch\fcs1 \af0\afs26 
\ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 84.  Plaintiff realleges and incorporates herein by reference all of the allegations set forth in paragraphs 1 through 34 as though fully set forth herein.
\par \tab 85.  Plaintiff is informed and believes and, thereon alleges, that at times presently unknown to Plaintiff, Defendants PANA, BOUQUOT and Does 21 th
rough 25, inclusive, knowingly and wilfully conspired and agreed among themselves to perpetrate a fraud on the dental patients of Defendant PANA in order to justify past and additional unwarranted dental treatment and to induce the dental patients of PANA
 to agree to said treatment for their own enrichment.
\par \tab 86.  Pursuant to said conspiracy, and in furtherance thereof, Defendants PANA, BOUQUOT and Does 21 through 25, inclusive, falsely and fraudulently represented to Plaintiff that:
\par \tab \tab a.  Bone and tissue specimens from Plaintiff\rquote s two dental surgeries would be transmitted by Defendant PANA and would be used by Defendant BOUQUOT for the purpose of obtaining microscopically valid and accurate biopsy results;
\par \tab \tab b.  Bone and tissue specimens from Plaintiff\rquote s two dental surgeries would be transmitted by Defendant PANA and would be used by Defendant BOUQUOT for the purpose of performing microscopically accurate biopsy results;
\par \tab \tab c.  Bone and tissue specimens from Plaintiff\rquote s two dental surgeries would be transmitted by Defendant PANA and would be used by Defendant BOUQUOT for the sole purpose of performing valid and accurate microscopic analyses;
\par \tab \tab d.  No medical information or materials other than bone and tissue specimens necessary for the performance of microscopic analyses would be provided by Defendant PANA to Defendant BOUQUOT;
\par \tab \tab e.  Any medical information and/or materials supplied to Defendant BOUQUOT by Defendant PANA would be used exclusively for the performance of microscopic analyses, the results of 
which would be supplied only to Defendant surgeons and to Plaintiffs;
\par \tab 87.  Defendants PANA, BOUQUOT and Does 21 through 25, inclusive, demonstrated their agreement to perpetrate a fraud on Plaintiff, by virtue of the fact that they knew that the representations made by them were false and that the true facts were:

\par \tab \tab a.  Bone and tissue specimens from Plaintiff\rquote s two dental surgeries were transmitted by Defendants PANA and used by Defendant BOUQUOT for the purpose of obtaining biopsy results which were not 
supported by evidence and/or science, but which validated the bogus diagnoses of Defendant PANA;
\par \tab \tab b. Bone and tissue specimens from Plaintiff\rquote s two dental surgeries  were provided by Defendant PANA and utilized by Defendant BOUQUOT for the purpose of prod
ucing consistently fraudulent, inaccurate and/or misleading microscopic findings and results;
\par \tab \tab c.  Bone and tissue specimens from Plaintiff\rquote s two dental surgeries were utilized not only for microscopic analyses, but were utilized by Defendant BOUQUOT for 
research studies, research projects and as teaching materials and tools, with the full knowledge of Defendant PANA, but without Plaintiff\rquote s knowledge and/or consent.
\par \tab \tab d.  Photographs and radiographs of Plaintiff\rquote s face and oral cavity which were transmitted by Defendant PANA and which were received and utilized by Defendant BOUQUOT were not necessary for the performance of microscopic analyses.
\par \tab \tab e.  Bone specimens, tissue specimens, photographs and radiographs pertaining to Plaintiff were utilized by Defendant BOUQUOT, with the full knowledge of Defendant PANA, for research studies, research projects and as teaching materials and tools;

\par \tab 88.  When Defendants PANA, BOUQUOT and Does 21 through 25, inclusive, made these representations, they knew them to be f
alse.  Defendants made such material misrepresentations with an intent to deceive Plaintiff and with the intent and reasonable expectation of inducing Plaintiff to rely upon these representations, all to Plaintiff\rquote s detriment.
\par \tab 89.  Plaintiff, at the time these representations were made by Defendants PANA, BOUQUOT and Does 21 through 25, inclusive, and at the time Plaintiff took the actions herein alleged, was ignorant of the falsity of Defendants\rquote 
 representations and believed them to be true.  In justifiab
le reliance on these representations, Plaintiff was induced to and did have performed unnecessary dental surgeries and other dental work which she would not have agreed to had Plaintiff known the actual facts.
\par \tab 90.  As a proximate result of the wrongful ac
ts perpetrated by Defendants PANA, BOUQUOT and Does 21 through 25, inclusive, Plaintiff was induced to undergo unwarranted and unnecessary dental treatment which would not have been justified by accurate microscopic findings and results.
\par \tab 91.  As a further
 proximate result of the wrongful acts perpetrated by said Defendants, Plaintiff has sustained injury to her health, strength and activity, all of which injuries have caused, and continue to cause, Plaintiff great mental, physical and nervous pain and suf
fering.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 92.  As a further proximate result of the wrongful acts perpetrated by said Defendants, Plaintiff has sustained, and will continue to sustain, disabling, serious and permanent physical injuries, all to Plaintiff\rquote 
s general damage in an amount presently unascertainable.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.}{\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 
\b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
\par }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab 
93.  As a further proximate result of the wrongful acts perpetrated by said Defendants, Plaintiff has incurred medical, hospital and related expenses in a sum presently unascertainable.  Plaintiff
 will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 94.  As a further proximate result of the wrongful acts perpetrated by said Defendants, Plaintiff will in the future i
ncur medical, hospital and related expenses, the exact nature and extent of which are currently unknown to Plaintiff.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when asc
ertained.
\par \tab 95.  As a further proximate result of the wrongful acts perpetrated by said Defendants, Plaintiff has sustained, and will in the future sustain, loss of earnings and loss of earning capacity, the exact amounts of which are presently unknown to Pl
aintiff.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 96.  The aforementioned acts of Defendants, and each of them, were wilful, wanton, malicious and oppressive, thereby justifying the award of exemplary and punitive damages as against Defendants, and each of them.
\par }\pard \ltrpar\qc \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab }{\rtlch\fcs1 \ab\af0\afs26 
\ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 SIXTH CAUSE OF ACTION
\par (For Intentional Misrepresentation Against Defendants PANA
\par and Does 26 through 30, inclusive
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab }{\rtlch\fcs1 \af0\afs26 
\ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 97.  Plaintiff realleges and incorporates herein by reference all of the allegations set forth in paragraphs 1 through 34 as though fully set forth herein.
\par \tab 98.  On or about October 6, 2005 and November 16, 2005, during Plaintiff\rquote s dental treatment with Defendants PANA, and Does 2
6 through 30, inclusive, at their dental office, said Defendants falsely and fraudulently represented to Plaintiff that:
\par \tab \tab a.  Bone and tissue specimens from her two dental surgeries would be transmitted by said Defendants to Defendants BOUQUOT and  UT HEALTH SCIENCE CENTER for the purpose of obtaining microscopically accurate biopsy results;
\par \tab \tab b.  Bone and tissue specimens from her dental surgeries would be utilized by Defendants BOUQUOT and UT HEALTH SCIENCE CENTER for the purpose of performing microscopically accurate biopsy results; 
\par \tab \tab c.  Bone and tissue specimens from her dental surgeries would be transmitted to Defendants BOUQUOT and UT HEALTH SCIENCE CENTER for the sole purpose of performing valid and accurate microscopic analyses;
\par \tab \tab d.  No medical information or materials other than bone and tissue specimens necessary for the performance of microscopic analyses would be provided to Defendants BOUQUOT and UT HEALTH SCIENCE CENTER;
\par \tab \tab e.  Any medical information or materials supplied to 
Defendants BOUQUOT and UT HEALTH SCIENCE CENTER by Defendant PANA would be used exclusively for the performance of microscopic analyses, the results of which would be supplied only to Defendants and Plaintiff;
\par \tab 99.  The above representations made by Defendant PANA, and Does 26 through 30, inclusive, were false.  The true facts were:
\par \tab \tab a. Bone and tissue specimens from Plaintiff\rquote s two dental surgeries were transmitted by Defendant PANA to Defendants BOUQUOT and UT HEALTH SCIENCE CENTER for the purpose of obt
aining results to validate the bogus diagnoses of Defendant PANA;
\par \tab \tab b.  Bone and tissue specimens from Plaintiff\rquote s two dental surgeries which were provided to Defendants BOUQUOT and UT HEALTH SCIENCE CENTER by Defendant PANA were utilized by Defendants BOU
QUOT and UT HEALTH SCIENCE CENTER for the purpose of producing consistently fraudulent, inaccurate and/or misleading microscopic findings and results;
\par \tab \tab c.  Bone and tissue specimens were utilized by Defendants BOUQUOT and UT HEALTH SCIENCE CENTER for rese
arch studies, research projects, and as teaching materials and tools with the full knowledge of Defendans YOUNG, SHEN, PACIFIC DENTAL and PAIN CENTER, but without Plaintiff\rquote s knowledge and/or consent;
\par \tab \tab d.   Photographs and radiographs of Plaintiff\rquote s face 
and oral cavity were transmitted by Defendant PANA to Defendants BOUQUOT and UT HEALTH SCIENCE CENTER which were not necessary for the performance of microscopic analyses and were in direct violation of the limited authorization Plaintiff gave for release
 of medical information and materials;
\par \tab \tab e.  Bone specimens, tissue specimens, photographs and radiographs pertaining to Plaintiff were utilized by Defendants BOUQUOT and UT HEALTH SCIENCE CENTER}{\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 
\b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 , }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 with the full knowledge of Defendant PANA, for research stud
ies, research projects and as teaching materials and tools;
\par \tab 100.  When Defendants PANA and Does 26 through 30, inclusive, made these representations, they knew them to be false.  Defendants made such material misrepresentations with an intent to deceive P
laintiff and with the intent and reasonable expectation of inducing Plaintiff to rely upon these representations, all to Plaintiff\rquote s detriment.
\par \tab 101.  Plaintiff, at the time these representations were made by Defendants PANA and Does 26 through 30, inclusive, and at the time Plaintiff took the actions herein alleged, was ignorant of the falsity of Defendants\rquote 
 representations and believed them to be true.  In justifiable reliance on these representations, Plaintiff was induced to and did have performed unnec
essary dental surgeries and other dental work which she would not have agreed to had Plaintiff known the actual facts.
\par \tab 102.  As a proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff was induced to undergo unwarrant
ed and unnecessary dental treatment.  Said treatment would not have been justified if Defendants had provided accurate microscopic findings and results.
\par \tab 103.  As a further proximate result of the wrongful acts perpetrated by Defendants, and each of them, 
Plaintiff has sustained injury to her health, strength and activity, all of which injuries have caused, and continue to cause, Plaintiff great mental, physical and nervous pain and suffering.  Plaintiff will seek leave of Court to amend this Complaint to 
set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 104.  As a further proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff has sustained, and will continue to sustain, disabling, serious and permanent physical injuries, all to Plaintiff\rquote 
s general damage in an amount presently unascertainable.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.}{\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 
\b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
\par }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab 
105.  As a further proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff has incurred medical, hospital and related expenses in a sum presently unascertainable.  Plaintiff will seek leave of Court to amend this Com
plaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 106.  As a further proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff will in the future incur medical, hospital and re
lated expenses, the exact nature and extent of which are currently unknown to Plaintiff.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 107.  As a further 
proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff will in the future sustain, loss of earnings and loss of earning capacity, the exact amounts of which are presently unknown to Plaintiff.  Plaintiff will seek lea
ve of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 108.  The aforementioned acts of Defendants, and each of them, were wilful, wanton, malicious and oppressive, thereby justifying the award of exemplary and punitive damages as against Defendants, and each of them.
\par }\pard \ltrpar\qc \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 SEVENTH CAUSE OF ACTION
\par (For Intentional Misrepresentation Against Defendants, BOUQUOT,
\par UT HEALTH SCIENCE CENTER and Does 31 through 35, inclusive).
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 \b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab }{\rtlch\fcs1 \af0\afs26 
\ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 109.  Plaintiff realleges and incorporates herein by reference all of the allegations set forth in paragraphs 1 through 34 as though fully set forth herein.
\par \tab 110. Prior to Plaintiff\rquote s two dental surgeries performed by Defendant PANA on October 6, 2005 and November 16, 2005, Plaint
iff signed authorizations created by Defendants BOUQUOT, UT HEALTH SCIENCE CENTER and Does 31 through 35, inclusive, entitled \u8220\'93Important \lquote }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\ul\lang1033\langfe1041\langfenp1041\insrsid1529825 Patient
\rquote  }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 Billing Information\u8221\'94 which, by their language, falsely and fraudulently represented to Plaintiff that:
\par \tab \tab a.  Bone and tissue specimens from Plaintiff\rquote s two dental surgeries would be used by said Defendants for the purpose of performing biopsies to determine cellular changes in the submitted tissue;
\par \tab \tab b.  Bone and tissue specimens from Plaintiff\rquote s two dental surgeries would be used by said Defendants to verify Plaintiff\rquote s clinical diagnosis;
\par \tab \tab c.  Bone and tissue specimens from Plaintiff\rquote s two dental surgeries would be used by said Defendants to insure proper care.
\par \tab \tab d.  The written authorizations signed by Plaintiff, by their language, limited dissemination of medical information and materials pertaining to Plaintiff solely to information and materials necessary to perform microscopic analyses.
\par \tab 111.  The above representations made by Defendants BOUQUOT, UT HEALTH SCIENCE CENTER and Does 31 through 35, inclusive, were false.  The true facts were:
\par \tab \tab a.  Bone and tissue specimens were utilized by Defendants BOUQUOT and UT HEALTH SCIENCE CENTER not only to determine cellular changes, but for research studies, research projects, and as teaching materials and tools without Plaintiff\rquote 
s knowledge and/or consent;
\par \tab \tab b.  Bone specimens, tissue specimens, photographs and radiographs pertaining to Plaintiff were utilized by Defenda
nts BOUQUOT and UT HEALTH SCIENCE CENTER not only to verify clinical diagnoses, but for research studies, research projects and as teaching materials and tools;
\par \tab \tab c.  Bone specimens, tissue specimens, photographs and radiographs pertaining to Plaintiff wer
e utilized by Defendants BOUQUOT and UT HEALTH SCIENCE CENTER not only to insure proper care, but for research studies, research projects and as teaching materials and tools;
\par \tab \tab d.  Defendants BOUQUOT and UT HEALTH SCIENCE CENTER violated the terms of the l
imited written authorizations signed by Plaintiff by utilizing medical information and materials pertaining to Plaintiff for purposes not covered by the authorization and disseminated medical information and materials in violation of the limited authority
 given by Plaintiff.  
\par \tab 112.  When Defendants BOUQUOT, UT HEALTH SCIENCE CENTER, and Does 31 through 35, inclusive, made these representations, they knew them to be false.  Defendants made such material misrepresentations with an intent to deceive Plaintiff
 and with the intent and reasonable expectation of inducing Plaintiff to rely upon these representations, all to Plaintiff\rquote s detriment.
\par \tab 113.  Plaintiff, at the time these representations were made by said Defendants and at the time Plaintiff took the actions herein alleged, was ignorant of the falsity of Defendants\rquote 
 representations and believed them to be true.  In justifiable reliance on these representations, Plaintiff was coerced to and did sign an authorization for limited dissemination of medical info
rmation and materials, all of which she would not have agreed to had Plaintiff known the actual facts.
\par \tab 114.  As a proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff was induced to undergo unwarranted and unnecessa
ry dental treatment.  Said treatment would not have been justified if Defendants had provided accurate microscopic findings and results.
\par \tab 115.  As a further proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff has su
stained injury to her health, strength and activity, all of which injuries have caused, and continue to cause, Plaintiff great mental, physical and nervous pain and suffering.  Plaintiff will seek leave of Court to amend this Complaint to set forth the fu
ll amount of damage sustained as a result thereof when ascertained.
\par \tab 116.  As a further proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff has sustained, and will continue to sustain, disabling, serious and permanent physical and emotional injuries, all to Plaintiff\rquote 
s general damage in an amount presently unascertainable.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.}{\rtlch\fcs1 \ab\af0\afs26 \ltrch\fcs0 
\b\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
\par }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab 
117.  As a further proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff has incurred medical, hospital, psychological and related expenses in a sum presently unascertainable.  Plaintiff will seek leave of Court to a
mend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.
\par \tab 118.  As a further proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff will in the future incur medical, ho
spital, psychological and related expenses, the exact nature and extent of which are currently unknown to Plaintiff.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when asce
rtained.
\par \tab 119.  As a further proximate result of the wrongful acts perpetrated by Defendants, and each of them, Plaintiff will in the future sustain, loss of earnings and loss of earning capacity, the exact amounts of which are presently unknown to Plaintif
f.  Plaintiff will seek leave of Court to amend this Complaint to set forth the full amount of damage sustained as a result thereof when ascertained.\tab 
\par \tab 120.  The aforementioned acts of Defendants, and each of them, were wilful, wanton, malicious and oppressive, thereby justifying the award of exemplary and punitive damages as against Defendants, and each of them.
\par \tab WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, as follows:
\par \tab FIRST and SECOND CAUSES OF ACTION:
\par \tab 1.  For general damages according to proof;
\par \tab 2.  For medical and related expenses according to proof;
\par \tab 3.  For future medical and related expenses according to proof;
\par \tab 4.  For loss of earnings and future loss of earnings according to proof;
\par \tab 5.  For interest thereon at the legal rate;
\par \tab 6.  For costs of suit incurred herein; and
\par \tab 7.  For such other and further relief as the Court deems just and proper.
\par \tab THIRD and FIFTH through SEVENTH CAUSES OF ACTION:
\par \tab 1.  For general damages according to proof;
\par \tab 2.  For medical and related expenses according to proof;
\par \tab 3.  For future medical and related expenses according to proof;
\par \tab 4.  For loss of earnings and future loss of earnings according to proof;
\par \tab 5.  For exemplary and punitive damages according to proof;
\par \tab 6.  For interest thereon at the legal rate;
\par \tab 7.  For costs of suit incurred herein; and
\par \tab 8.  For such other and further relief as the Court deems just and proper.
\par \tab FOURTH CAUSE OF ACTION:
\par \tab 1.  For general damages according to proof;
\par \tab 2.  For medical and related expenses according to proof;
\par \tab 3.  For future medical and related expenses according to proof;
\par \tab 4.  For loss of earnings and future loss of earnings according to proof;
\par \tab 5.  For interest thereon at the legal rate;
\par \tab 6.  For attorney\rquote s fees and costs pursuant to }{\rtlch\fcs1 \ai\af0\afs26 \ltrch\fcs0 \i\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 Civil Code }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 
\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 Section 56.35;
\par \tab 7.  For costs of suit incurred herein; and
\par \tab 8.  For such other and further relief as the Court deems just and proper.
\par \tab 
\par 
\par }\pard \ltrpar\qj \fi-2707\li2707\ri-900\sl-468\slmult0\widctlpar
\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480\tx7200\tx7920\tx8640\tx9360\tx10080\tx10800\tx11520\tx12240\tx12960\tx13680\tx14400\tx15120\tx15840\tx16560\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin2707\itap0 {\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 Dated: }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\ul\lang1033\langfe1041\langfenp1041\insrsid1529825                         }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 
\fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab \tab \tab LAW OFFICES OF DAVID J. WILZIG
\par }\pard \ltrpar\qj \li0\ri-900\sl-468\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 
\par }\pard \ltrpar\qj \li0\ri-900\sl-234\slmult0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin-900\lin0\itap0 {\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab \tab \tab \tab \tab \tab }{\rtlch\fcs1 
\af0\afs26 \ltrch\fcs0 \fs26\ul\lang1033\langfe1041\langfenp1041\insrsid1529825                                                                                 }{\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 

\par \tab \tab \tab \tab \tab \tab \tab DAVID J. WILZIG
\par }\pard \ltrpar\ql \li0\ri0\widctlpar\wrapdefault\aspalpha\aspnum\faauto\adjustright\rin0\lin0\itap0 {\rtlch\fcs1 \af0\afs26 \ltrch\fcs0 \fs26\lang1033\langfe1041\langfenp1041\insrsid1529825 \tab \tab \tab \tab \tab \tab \tab Attorney for Plaintiff}{
\rtlch\fcs1 \af0 \ltrch\fcs0 \lang1033\langfe1041\langfenp1041\insrsid1529825 {\*\bkmkend OLE_LINK19}{\*\bkmkend OLE_LINK20}
\par }}