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DR TYNDAL JONES

Published on: November 2, 2016
Categories: NEWS

1COPY.jpg (16165 bytes)

1DNS.jpg (21089 bytes)

Dr Tyndal Jones.com 
NOTE: THIS WEBSITE &  DOMAIN NAME  & IT’S CONTENTS, DO NOT BELONG TO, OR WERE POSTED BY:
SIGNATUREWOMENSHEALTHCARE, SIGNATURE WOMENS HEALTH, SIGNATURE WOMEN’S HEALTHCARE LLC,  PERSONALIZED DX LABS AND/OR DR TYNDAL JONES . CONFORMING WITH ICANN DOMAIN NAME LEGAL DISPUTE RESOLUTION THAT IN FACT CONCERNED THE USE OF A PERSONS NAME IN THE FORM OF A DOMAIN NAME FOR AN ARTICLE ONLINE, THAT IS NEWS WORTHY, IN A  DISPUTE ACTION OR EXPOSE IS NO DIFFERENT FROM THE USE OF SAME ON THE FRONT PAGE OF A NEWSPAPER. INDIVIDUALS OR ORGANIZATIONS WHOM PUBLISH ARE CONSTITUTIONALLY PROTECTED. AN EXPOSE OF A PUBLIC PERSONA WHOM IS THE KEY INDIVIDUAL IN A PUBLIC DISPUTE AS CONCERNS PHYSICIANS ORDERING  DNA OR SPECIAL GENETIC TESTING AND/OR MAY HAVE UTILIZED FRAUD TO PROFIT FROM DOING SO. THE  REPORT BELOW WAS POSTED BECAUSE THE STORY WHETHER FACT OR FICTION IS BELIEVED TO BE CRITICAL TO THE PUBLIC AT LARGE, IT IS A FORM OF NEWS REPORTING IN THE THE PUBLIC DOMAIN PROTECTED FREE SPEECH.  THE PUBLISHER HAS A LONG HISTORY OF PUBLISHING NEWS EXPOSE  STORIES THAT ARE CRITICAL TO THE PUBLIC DOMAIN SINCE 1999. AND HAS WON NUMEROUS CHALLENGES. THE PUBLISHER BELIEVES THE FOLLOWING INFORMATION AND REPORTING ARE WORTHY OF BEING PROTECTED FREE SPEECH AND IMPORTANT TO THE PUBLIC WHOM MAY NOT BE AWARE OF THE FOLLOWING ALLEGATIONS. WE NOTE WHILE SOME OF THE INFORMATIONM, SUCH AS A  LEGAL COMPLAINT, ARE ALLEGED TO BE SWORN FACT. THE PUBLISHER MAKES NO CLAIM OTHER THAN TO LEAVE THAT TO THE PUBLIC AS CONCERNS OUR POSTING. THANK YOU


SignatureWomensFraud.Com

Dr.TyndalJones.Com

http://www.signaturewomens.com/

TWO VISITS, ONE TEST TAND THE BILL WENT TO:
1480.58
BILLING W/SPECIAL ALLEGED SCAM GENETIC TEST
5158.48

AM I
TRUST WORTHY
??????
Dr. Tyndal Jones
2775 Cruse Rd NW

Suite 2101
Lawrenceville

GA 30044
P) 770-609-1980
(F) 678-380-7494

DrTyndalJones.jpg (13226 bytes)

DID NOT INFORM 18 YEAR OLD PLAINTIFF A
“ALLEGED INSURANCE PAID DNA TEST” WOULD
COST HER OVER $3,600  NEVER INQUIRED IF
INSURANCE WOULD PAY THEN BILLED HER
SHE WAS NOT HAPPY WITH $1480.58 BILLED
FOR Two office visits

SIGNATURE
WOMENS HEALTH

Gwinnett
771 Old Norcross Road
Suite 350
Lawrence, GA 30046
(P) 678-380-1200
(F) 678-380-7494
Dekalb
5900 Hillandale Drive
Suite 245
Lithonia, GA 30058
(P) 770-323-9300
(F) 678-380-7494

OCTOBER 31 2016
AFTER FILING THE ATTACHMENTS WILL BE UPLOADED
AND YOU MAY CLICK TO READ THEM. 
1.jpg (33079 bytes)

WHAT 18 YEAR OLD JUST GRADUATED HIGH SCHOOL WOULD AGREE TO A $3,678. DOLLAR DNA TEST  WHEN SHE WAS TRYING TO EARN A  LIVING ON JUST OUT OF HIGH SCHOOL PAY? SIGNATURE WOMENS HEATHCARE WAS MAKING LOTS OF CASH!

THEY HAD ALREADY RECEIVED
1480.58
FOR ONE APPOINTMENT WITH A TEST AND THE OTHER TO FIND OUT ABOUT THE TEST

THEN DECIDED PAUPER THEIR  PATIENT WITH A 
A TEST KNOWN NOT TO BE APPROVED BY INSURANCE
YET ACTUALLY RAN THE TEST AS THE PLAINTIFF & FAMILY ATTEMPTED TO STOP IT
THEY NEVER SAID THAT THE PATIENT WOULD HAVE TO PAY
$3,678.48

PERSONALIZE DX LABS IS OWED $935.20 /  SIGNATURE WOMENS HEATH CARE WAS TO RECEIVED THE REST
THIS 18 YEAR OLD WAS LIED TO BY A SIGNATURE WOMENS HEALTH CARE  FEMALE DOCTOR
 
SHE NOTED THE PATIENTS HISTORY  & LAUNCHED INTO A RICO SCAM
CLAIMING A SPECIAL GENETIC TEST WOULD SHOW HOW TO TREAT HER
AND THAT IT WAS COVERED BY HEALTH CARE THIS 18 YEAR OLD SAID OK.
YET NO AMOUNT, NO COSTS NOTHING WAS STATED OTHER THAN
IF THE INSURANCE COMPANY DOES NOT PAY WE WILL DITCH THE  SPECIAL GENETIC TEST
BOTTOM LINE? THEY DID THE  SPECIAL GENETIC TEST ANY WAY,
CAN IT HELP THE 18 YEAR OLD HECK NO! IT WAS AND IS A SCAM
ONE OF THE ALLEGED CROOKS THE LAB  HAVE THEIR SHARE IN COLLECTIONS!
PLANTIFF ONLY AGREED IF THE INSURANCE WOULD PAY & IT COULD HELP HER
NON OF THIS OCCURRED AND THE DOCTOR HAS NEVER EVER APOLOGIZED.

Plaintiff Is Asking Is That Signature Womens Health Pay 935.20 lab bill
AND DESTROY THE RESULTS OF THE SPECIAL GENETIC TEST THEY SAID WAS NOT RUN
read the complaint and view how you woman are getting ripped off

THEN GO BELOW LINKS AND LEAVE A MESSAGE
https://www.facebook.com/signaturewomenshealthcare

ladies fight for your rights go and let them know how you feel
http://www.signaturewomens.com/

{note: The Plaintiff was informed that SIGNATURE
WOMEN’S HEALTHCARE dismissed billing and/or
costs & canceled the test in 2015. Yet Sept/Oct 2016 over a  year

and a half later plaintiff learned that the TEST WAS RUN & the results
were not destroyed and the lab was not paid $935,00! And the Plaintiff
is adement that Dr Jones SAID THE FORM WAS TO GET INSURANCE APPROVAL
The Labs share of the ALLEGED scam to collect $3,678.48  which has
lead to this complaint being readied to file again

 

 

Superior Court

NOTE: actual complaint is 1/3rd smaller and laid out correctly. Changing a ” Word 2000″ legal doc to html was a no go so i used this older non-updated draft
it actually has more direct info that would be redundent and overbearing in the actual complaint that will be filed help us notify this institution

http://www.signaturewomens.com/

https://www.facebook.com/signaturewomenshealthcare

 

EDITED                  
                   Plaintiffs,
          v.
Dr Tyndal M Jones
SIGNATURE WOMEN’S HEALTHCARE, LLC
 Personalize DX Labs
[AUTOGENOMICS, INC]
Manager Charles Doe?
LM doe?
Joyce doe?
Maureen Doe?
Jasmin Doe?
Donna doe?
 
Defendants.

 

Case No.:




VERIFIED COMPLAINT FOR INTENTIONAL FRAUD, EQUITABLE DAMAGES, PUNITIVE DAMAGES, AND REQUEST FOR
DECLARATORY AND INJUNCTIVE
RELIEF AND DAMAGES FROM
RACKETEERING, CONSPIRACY
TO ENGAGE IN A PATTERN OF
RACKETEERING ACTIVITY,
AND RELATED CLAIMS;
JURY DEMANDED:
18 U.S.C. 1961 et seq.;
18 U.S.C. 1964
 JURY TRIAL DEMANDED

 

I. NATURE OF THE CASE

1.                           Plaintiff  was a recent 18 year old high school graduate earning “recent high school” minimum wage pay when she went to SIGNATURE WOMEN’S HEALTHCARE for what she believed to be a urinary track infection and to request [EDIT ANOTHER SERVICE NOT PART OR RELATED TO DNA].. She chose the facility due to the fact it was listed on her insurance plan and was local.Her visit would be the very first ever since birth with out her Mother due to the fact SIGNATURE WOMEN’S HEALTHCARE would only treat Plaintiff PLAINTIFF direct *“because she was 18”.  Once there, she met Dr Tyndal M Jones who would soon discover Plaintiff, had been born with medical problems including ;  a mysterious pain syndrome and had operations and other corrective measures accomplished for 14 years. These facts had nothing to do with her  visit nor was Plaintiff asking for assistance with these facts. It is alleged Dr Tyndal M Jones seized on these facts to convince the Plaintiff to allow SIGNATURE WOMEN’S  HEALTHCARE to apply to the insurance company for  SPECIALIZED GENETIC TESTING on the story that this testing could help the Plaintiff with care and cure.

* THIS FACT WOULD PLAY A MAJOR PART IN OUR
ALLEGATION OF FRAUD, THEFT AND MORE

2.                          Dr Tyndal M Jones stated the test would open doors and make the Plaintiff’s life better; that she would not run the test until she was sure her insurance carrier approved it and that she would check with Plaintiff’s carrier on both the DNA testing and [EDIT ANOTHER SERVICE NOT PART OR RELATED TO DNA]. Dr Tyndal M Jones never stated any fact or fiction or down side like problems with insurance, future jobs and/or other possible issues. She did not state that the Specific Procedure she was testing for was NEW or UNTESTED or EXPERIMENTAL. And, she never, ever, stated that the price for this testing: $3,678.48, with $2,743.28 going to SIGNATURE WOMEN’S HEALTHCARE, LLC and $935.20 going to the testing lab. Plaintiff was offered an alleged INSURANCE REQUEST FORM that would be used to receive approval with the insurance company for both the DNA and [EDIT ANOTHER SERVICE NOT PART OR RELATED TO DNA]. while the discussion was still ongoing. [EXHIBIT 1: American Med Systems INC Collection letter on behalf of DNA LAB demonstrating lab billing Vs total cost of Experimental or other DNA GENETIC TESTING]
 

3.                           SIGNATURE WOMEN’S HEALTHCARE and Dr Jones were aware the DNA GENETIC procedure was “HIGHLY SPECIALIZED” and not covered by Plaintiff’s Insurance, yet, with out saying, notifying, or including the COST to Plaintiff, Dr Tyndal M Jones and SIGNATURE WOMEN’S HEALTHCARE sent a swab  to  Personalize DX Labs to test.  after both the Plaintiff and her Mother demanded it not be done.[exhibit 2 personalize dx labs notification “your physician has requested highly specialized genetic tests” note date: 5/20/15 2 days before 1st office visit? ]

4.                           On Plaintiff’s return visit to discover the test results for her urinary track infection and to see about insurance approval for the alleged SPECIALIZED GENETIC testing and [EDIT ANOTHER SERVICE NOT PART OR RELATED TO DNA]., she was informed she would have to wait until the infection was healed for the [EDIT ANOTHER SERVICE NOT PART OR RELATED TO DNA]. and as to the status of the DNA GENETIC TESTING ?  “ we are waiting”.  When Plaintiff returned home she explained all the above and requested her Mother’s help her. When her mother attempted to help she was rebuffed first by “Officer Manager Charles X”? ‘Charles’ rudely dismissed her when she stated she had a paper drawn up and the Plaintiff signed it for her to have access. She learned that the SPECIALIZED GENETIC testing was in fact “EXPERIMENTAL TESTING” – the SWAB had been sent  to run the test.with out approval! Later, after paper work was received, it seemed that dates had been altered because it “pre-dated” the office visit. And was approved with out “checking her Insurance Company”. She also discovered that a test for the infection and request for an [EDIT ANOTHER SERVICE NOT PART OR RELATED TO DNA]. –which never occurred, and the follow up visits was billed at $1480.00

[Consent of Plaintiff for her Mother to have access]
[exhibit 4 the billings and dates for the two visits 1-4/22/15 2- 4/29/15]
 

5.                             Up to this point, Plaintiff, nor her Mother, were aware that the test  had been run, it was added to her medical record, and that Plaintiff, who was working as an apprentice, owed $3,678.48 Plaintiff’s Mother made approximately 50 phone calls and contacts to all parties. After threatening a law action/complaint [see exhibit 5 multiple calls notations dates and first names of parties]

{note: The Plaintiff was informed that SIGNATURE WOMEN’S HEALTHCARE dismissed billing and/or costs & canceled the test. Yet , over a  year and a half , later plaintiff learned that the results were not destroyed and the lab was not paid $935,00! oct 2016}

6.                           The end result was that even after all the calls and demands to stop, halt end the Testing, the test was performed, it was added to Plaintiffs Health History- yet Plaintiff has no idea what was added or how it may effect her for the rest of her life. In addition, she was notified September 15th, 2016 that American Med Systems, on the behalf of Personalized Dx Labs, is demanding that she submit $935,00 to Personalized Dx Labs because the insurance co denied billing for her claim for an Experimental, Medical Necessity No Prior Authorization, Not A Covered Procedure was listed, yet no insurance denial can be discovered!  This is a a medical collections agency demanding  $935,00 for Personalized Dx Labs, their share of the $3,678.48  billing. [see exhibit 5 letter of demand]




7.                                 
II. JURISDICTION and PARTIES

. [Plaintiff has yet to initiate and complete discovery and will update]
1-Defendant, SIGNATURE WOMEN’S HEALTHCARE A Domestic Limited Liability Company resides at 771 Old Norcross Rd, SUITE 350, LAWRENCEVILLE, GA, 30046  2-Defendant Dr Tyndal M Jones works in the Gwinnett County, State Of Georgia Office of  SIGNATURE WOMEN’S HEALTHCARE3- Personalize DX  Labs 2980 Scott St., Vista, California, 92081   Defendant Personalize DX Labs is listed in California Secretary Of State Business search as as “AUTOGENOMICS, INC located in the States of California, and conducts business within the state Of Georgia, County of Gwinnett   4- Discovery and Interrogatories will provide the information as to the other defendants. At the moment, Plaintiff only has the first names of some of these Defendants and will make appropriate alterations and inclusions through discovery. SIGNATURE WOMEN’S HEALTHCARE STAFF:
E:  Office Manager Charles Doe?;
f:  LM doe?;
g: Joyce doe?;
e: Maureen Doe?;
f: Jasmin Doe?;
g Donna doe?;
h; Lois doe?;

8.                              8
III. FACTUAL ALLEGATIONS  All DEFENDANTS   
    
        

All Defendant listed are alleged to have participated and engaged in a conspiracy to defraud the Plaintiff with intent to profit by utilizing costly “Specialized” Genetic Testing as the basic component to said fraud. Specialized Testing is the most refused to be covered by an insurance company and part of that is because it is the most costly. What this term actually means is there is nothing standard about it, like  testing standard DNA test.. a normal inexpensive type where you can even get a $99.00 dollar test kit for. It was, in fact, listed as NEW, UNTESTED and/or EXPERIMENTAL and not covered by most if not all Health Insurance Companies. And it’s cost in this instance? $3,678.48! Yet none of the defendants ever stated, listed or informed the Plaintiff to what the cost of this test was. Defendants are alleged to have furthered their intended fraud in a manor that id allegations are true, surely demonstrates that there was inclusion. False statements, not forwarding calls, blocking calls, sending forms and papers where dates and information were clearly altered, lying about when the swab was sent, about contacting the insurance company first, when the testing began , costs, and in fact speeding up the test as the Plaintiffs were on the phone with Personalize DX   Labs ordering the test not to be run …in the end the fraud continued after SIGNATURE WOMEN’S HEALTHCARE  were notified that a law action would be filed! They stated they would forgive any funds owed, not run the test [we had to notify it was run!] and destroy the results. Yet September 2016 Plaintiff learned that SIGNATURE WOMEN’S HEALTHCARE  did not destroy the report,  and that they had not paid the lab for testing.

 9 

Defendant Dr Tyndal M Jones

Defendant Dr Tyndal M Jones, is the physician who began this alleged fraud. It is the allegation of the Plaintiff that discovery may allegedly prove that Defendant Dr Tyndal M Jones may have been involved in a SPECIAL GENETIC TESTING RACKET. Her profit surely was included some her for her to do what is alleged herein. Her alleged target, on or about 04/22/15, [note date is off billing receipts] was a young 18 year old girl who was naïve to handling her first ever doctors appointment. Her mother had always been the person handling everything since birth. Plaintiff’s first visit concerned a Urinary Infection and request for a [EDIT ANOTHER SERVICE NOT PART OR RELATED TO DNA]., It is alleged that Dr Tyndal M Jones quickly utilized the Plaintiffs 18 years of operations, treatments and pain as a means to profit rather than assist. Dr Tyndal M Jones did not ADVISE the Plaintiff of the down side of the Genetic testing as concerned it’s inclusion into her Health Records. She stated she would check with her insurance company before submitting the swab, and never informed Plaintiff it was a new procedure or that most insurance companies would not pay for! And, she left out the fact that if they refused to cover the test, Plaintiff, and/or her family, would have to pay $3,678.48. Instead, she encouraged the Plaintiff to “sign the insurance request because it was necessary for her to apply for coverage for both the [EDIT ANOTHER SERVICE NOT PART OR RELATED TO DNA]. and the testing”. Dr Tyndal M Jones took a swab from the Plaintiff and then ABSOLUTELY stated she would wait until SIGNATURE WOMEN’S HEALTHCARE received permission from Plaintiff’s insurance company before submitting the SWAB to Personalize DX  Labs, And,  when the contacts, pleading and orders to halt the testing were made, Plaintiff alleges she ignored or informed her staff to ignore them.

 10

DEFENDANT
SIGNATURE WOMEN’S HEALTHCAR
E


Both Plaintiff and her family were calling, arguing, pleading and requesting information, from SIGNATURE WOMEN’S HEALTHCARE.  All calls pleadings questions and orders to cease and desist were ignored because the company had already placed the test, ignored the calls and where thinking of the profits, They, as the company or entity, were in fact the reason Plaintiff made her appointment. SIGNATURE WOMEN’S HEALTHCARE is listed in the data base for the Plaintiffs health plan. Plaintiff alleges that it was SIGNATURE WOMEN’S HEALTHCARE that submitted the paper work, had first hand knowledge of the entire process and stood to collect fees and costs directly. . It was employees whom acted against the wishes and concerns and pleadings of the Plaintiff, especially when the $3,678.48 fee was realized and Plaintiff was devastated. It is alleged that the employees conducted the mailings, the make up of the papers, forms and billing. It was employees whom SUBMITTED THE SWAB! While Law in general would state employees are not actors, it is the plaintiff’s contention that until discovery and deposition, it would not be in Plaintiff’s interest not to include those whom were informed and educated to the concerns, pleadings and requests of the Plaintiff, and if, in fact, they knew of this alleged scam or if it had or has occurred before

11

Defendant Personalize DX Labs

Personalize DX Labs was/is alleged to be the very heart of these tests, their costs and from a letter dated September 2016, where responsible to the alleged racket group, to secure   information on  their acceptance by Insurance Companies. With out Personalize DX Labs this alleged fraud could not occur. The Plaintiff is looking towards discovery because the facts demonstrate that this Defendant is alleged to have:
1- Starting the testing before seeking approval
2- covered up facts and made alterations to documents
3- refused the information, facts, worries and complaints of the Plaintiff on the telephone and by email and stated the testing would be accomplished irregardless to what the Plaintiff stated, informed or plead—even when advised that they believed it was a fraud and. would send certified letters or do what ever Personalize DX Labs required to stop the test4- Finally, They were primary to the fact the insurance company was never checked. Recent information demonstrates that this Defendant Company and. SIGNATURE WOMEN’S HEALTHCARE knew it never would have been approved yet raced to perform the test even while Plaintiff attempted to stop it. 
[see exhibit 6 insurance approval or not]

12
                           CONCLUSION TO FACTUAL ALLEGATIONS


 . Plaintiff could not use legal means to halt the process because the time the defendants used to hold up the Plaintiff with a waiting for Insurance Company Approval was a lie. The fact is, our exhibits show the notice of approval or denial came from the LAB and not the doctors office!  The test was rushed to completion.. Their alleged well thought out plan was enough for the defendants to run the test! It is alleged that it was already planned out to run the test no matter what.  With alleged prior knowledge, Fraud, and Negligence, all defendants acted in a Criminal Conspiracy to defraud the Plaintiff. The object was to get the test run before any “outside” intervention stopped the alleged gravy train. . It was processed quickly. When the Plaintiff returned to check on the results of her visit she was informed it was a urinary track infection and that she could not pursue the [EDIT ANOTHER SERVICE NOT PART OR RELATED TO DNA]. until her infection was cleared up. Nothing was discussed concerning the SPECIAL GENETIC TEST other than “waiting”.
13

 Plaintiff’s Mother was blocked out;  DEFENDANTS were working as one to stop, block, slow down the notification process until the test facts were sent from Personalize DX Labs because then they could get the cash from the patient and say they had nothing to do with it accept run the test. Yet, we believe this was accomplished before! The clinic acted as if it was their job selling it and the lab acted as if it was their job billing it! Signature Womens
Health absolutely stated and drilled the alleged fact that they would check with the insurance company, but the billing and paper work show it was the LAB! Statements of waiting for insurance approval are shown hereto be nothing more than giving time to build the ship then demand payment no matter that it was not the
patient! Just view the attachments …..

14

They used foils like contacting each other; or were waiting for insurance approval; or would get back and other deceit while rushing the process of the test! . Plaintiff’s Mother and Plaintiff had advised the defendants
that Plaintiffs mother was involved with approval, yet defendants moved forward so that no cease and desist letters could be sent, or would be sent! While Dr Tyndal M Jones, the Physician whom initiated the SPECIAL
DNA test, knew it would never be insurance approved, she ignored the Plaintiff actual requests. She had rushed the sample swab to her co-defendant Personalized

15
Are we to assume that Personalize DX LABs simply disregarded the Plaintiff and the Doctor? They were allegedly informed, on the ball, ready to earn a huge windfall.    Direct before the tests calls below are noted in the various attachments:

CALLS TO DX  date 2015:
first call DX 5/27 Charles LM?
second call DX dated 5/29 5/28 .
third call DX 5/29 Charles
fourth call DX 6/1 Joyce  accounting
fifth  cal DX 6/2 marreen
sixth call DX 6/2 jasmine
seventh call 7/14   Donna

on 5-20-2015 DX sent a letter on how the Physician requested PersonalizedDx Labs to perform  highly specific genetics tests Yet Plaintiff Was Told Informed And Made to Sign A INSURANCE REQUEST FORM Not A DNA or GENTETIC TEST FORM! … and how the Plaintiff could get the insurance company to pay the bill or part of it!!!  It leaves the Plaintiff with a question to this Honorable Court, if as it is written by the lab and not SIGNATURE WOMEN’S HEALTHCARE or  Tyndal M Jones, why is the lab sending what obviously is a standard letter stating they and not the doctor are showing how the Plaintiff can get at least partial relief from that 4k bill for but a urinary infection gone wild???

16
It states that it is new advanced technology for which most insurance companies have not yet established coverage polices?  Plaintiff alleges this lone letter demonstrates the Plaintiff’s allegation that is was and is a scam at this point. Whether or not the science is founded in good principles of hope and cure, it surely was not as Dr Tyndal M Jones or SIGNATURE WOMEN’S HEALTHCARE had stated that first day when the Plaintiff was allegedly, by this proof, lied to. Only weeks later, after stating they had rescinded the request a FORM Letter arrives reinforcing the Plaintiff’s belief it was about near $3600.00 and not a message of hope and reality! A furious call by Plaintiff herself and her Mother soon offered a light of hope,


17
By August 2015, Plaintiff had believed it was over but received another letter from the lab. A call to SIGNATURE WOMEN’S HEALTHCARE was taken by a “Lois”-she stated that the “owner of SIGNATURE WOMEN’S HEALTHCARE had made the decision to take care of the issue. and PLAINTIFF would not be billed for the lab work. Then on September 15th 2016, a letter from whom we allege is the third party to this alleged DNA testing scam arrived in the form of a collection agency [American Med Systems] that did not contract to buy the debt, but actually represents one of the alleged guilty parties arrived demanding over 935.20 for services by DX Labs But the amazing fact is what it states!
”Our records indicate your insurance carrier has denied your claim for one or more of the following:”
1. experimental /investigational
2. medical necessity
3. no prior authorization
4. not a covered procedure
5. other

18
While the Defendants may say that The Plaintiff signed a paper offering the right to perform this  test, the Plaintiff has demonstrated she was but 18, had no knowledge of what and how, only the pain of her health issues, that she believed this Woman Doctor who informed her she would check with the insurance company and NEEDED A FORMAL REQUST FORM SIGNED THAT WOULD BE SENT TO THE INSURANCE COMPANY..

That the tests would be wonderful to/for her., That it could not be accomplished unless the insurance company agreed. Then after would not Halt, Decease. Stop the train even when it sat for months empty of debt! But they as a group, continued and if not for her Mother this amount owed would be nearly 4000.00.

LET US STATE THAT PLAINTIFF STATED THAT THE TEST WAS DESTROYED!!   THAT IT WAS STOPPED ALL KINDS OF ALLEGED TALK

YET Plaintiff learned only recently that the test is in her record!  DX labs knew it was told over and over not to run any tests.  To stop!  Way back— only one week after that exam!  And when the Plaintiff discovered it was an Alleged Scam, She did every thing she could along with her family to no avail. The Defendant’s as a whole covered up and kept the issue buried waiting to bill the Plaintiff! I ask this honorable court of Justice, if the Lab charge was 935.20  …who received the balance of the 3600.00?? We are talking over 3000.00 dollars and even more for interpretation of those findings~! The Company and The Physician are the true alleged thieves. 3600.00 plus + 2 visit costs of billed at $1480.00 for 10 minutes of talk and a swab. Tthis is why insurance costs keep rising./
[see exhibit 7 phone calls]    [see exhibit 8 bill of demand]

IV. CAUSES OF ACTION
FIRST CAUSE OF ACTION

INTENTIONAL FRAUD and Theft

19
“In all cases of [fraud], knowledge of the falsehood constitutes an essential element of the tort. A fraudulent or reckless representation of facts as true when they are not, if intended to deceive, is equivalent to knowledge of their falsehood even if the party making the representation does not know that such facts are false. Actual fraud involves five key elements:

(1) a false representation by the defendant;
(2) knowledge that the representation is false or with reckless disregard as to whether it was true;
(3) an intent to induce you to act or refrain from acting based on the knowingly false representation;
(4) reasonable reliance by you on the knowingly false representation; and
 (5) damage done to you because you reasonably relied on the false representations made by the defendant. 


20
The Plaintiff alleges all defendants were invested in the profits, whether by weekly pay or other reunification. They were all important cogs in a wheel of alleged fraud. The company failed through it’s hired and integrated staff with intent. A $3,678.48 costly process that most insurance companies did not cover was ordered. There were adequate attempts to stop the process, yet, even with the Plaintiff, her family with consent, and the threat of a law action, the alleged scam would go on until that that near $3,678.48 would be billed and demands to pay. with most going to SIGNATURE WOMEN’S HEALTHCARE! 

21
Truth of fraud is demonstrated by the facts that though the defendant’s knew the insurance company would likely not pay, they would move forward and complete the test w/o informing a young girl to
the amount of the test! ! The price of the procedure was kept from the billing patient the  Whom would pay that +3600.00 bill?  This brings fact and truth to the issue, no one knew the price except the defendants! Thus, some how the defendants believed that the plaintiff could pay that bill!  An 18 year old Plaintiff would have to foot a $3,678.48 bill? The insurance company had paid nearly all of the $1480.58. that was billed for just two visits –one that included a PAP SMEAR-and time to SELL A “SPECIAL GENETIC TEST” the other to discover results.

22
A claim of a possible scientific “cure” from a Special Genetic Test seems fraudulent on it’s own! Because a young girl, who has carried pain and the horror of operations and that nagging ever present knowledge at any moment she would be out of action unable to participate; yet the defendants utilized her 18 year minute time on this earth and her illness for an alleged SPECIAL GENETIC TEST in order to bill some one; any one…

23
 It is/was a SPECIAL DNA SCAM! A Nightmare? Hardly, Nightmares go away, Scams hurt, deny, harm and leave people hopeless!  Using the US Mail, Computer and Phones, across state lines, in a criminal endeavor, that involved three separate entities [the collection agency] , all working together TO STEAL ONES FINANCES, EMOTIONS, PRIDE? . All the defendants, allegedly were responsible. .Yes,  in fact it may harmed the Plaintiff!. The use of different employees to keep the alleged scam going while still determined to run that test then use that piece of paper that said yes, do it! They knew, as a crew, as a group, not just as individual company or peoples. It is as close to racketeering as one can get.! We do not have to ask why when  DO NOT RUN THAT TEST was stated over and over… they should have halted! Plaintiff and Family received and sent notes, calls and pleadings, why the very answers in response were also alleged lies? 

24
Justices dislike the inclusion of the same facts over and over. “NO ONE TOLD THE PLAINTFF THAT THE COST WAS 3,678.48” ! And no one said the insurance company is not paying, they shipped the swab before even attempting to see if it was covered?? And, did the test knowing it was not covered. Then attempted to say they THOUGHT IT WOULD BE COVERED. And finally, employed a Medical Collection Agency to attack the now 20 year old! Theft by deception is committed when a person “obtains property by any deceitful means or artful practice with the intention of depriving the owner of the property.” OCGA 16-8-3 (a). Note that is Criminal Law! “A person deceives if he intentionally: (1) Creates or confirms another’s impression of an existing fact or past event which is false and which the accused knows or believes to be false; [or] (2) Fails to correct a false impression of an existing fact or past event which he has previously created or confirmed. . . .” OCGA 16-8-3 (b). we request treble damages


24V

        SECOND CAUSE OF ACTION
Conspiracy and Fraud in Violation of the Racketeer Influenced and
Corrupt Organizations Act (RICO), 18 U.S.C. (sec) 1962, and Request for Treble Damages.

      . The primary cause for the addition of the Rico Act is 
 the fact this action challenges and exposes a widespread 
criminal enterprise engaged in a pattern of racketeering activity
 across State lines, a conspiracy to engage in Fraud, Abusive 
Debt Collection, Intimidation, Threats, both Physical and Mental,
 and the threat of disseminating DNA Reports that were acquired
 originally through active fraud; and racketeering activity 
involving numerous RICO predicate acts 

25

The Plaintiff alleges Defendants acted with intent to 
defraud across state lines. 3 different yet intimately 
connected Companies, working together, to defraud the
public. A Civilian Criminal Operation that involved all levels 
of precise trained Individuals whom are alleged to be Doctors,
 Scientists and Debt Collectors as well as Office Managers,
 Billing Managers, Department Heads, Assistants and Staff —whom,
 it is alleged, had a hand in the pot. Plaintiff alleges them to
 be like a Mafia Crew committing Fraud with experience. They used 
answers and false documents and statements to belie there alleged
 true scam and con game. 
26
Quick SPECIAL GENETIC TESTING. DNA testing for absurd Tremendous 
Profits. Only an Action such as this one can provide the tools
 to discover victims whom may be aware or not aware of what we
 see as an alleged criminal conspiracy 
27
The quick testing performed and billed while Plaintiff’s 
believed their demands, worries and conversations were being 
accepted! 
28
The fact they state it was done, ended, no charge and no DNA 
record to the TRUTH BEING REVEALED 2 year later through Collection 
Agencies and Actual Records showing a SPECIAL DNA Test that was 
stated to be destroyed not destroyed and part of that record! 
29
The debt never removed! By September of 2016, 2 years after 
the fact, it surfaces to the top. It is alleged that documents 
from the LAB show the test would not be approved yet run WITH
 Fees literally enough to bankrupt an 18 year old Plaintiff, 
The Defendants Utilized the Internet, Mail, Both Internet and 
Regular Mail, and conducted their business across state lines. 
i Alleged Criminal acts that were well planned, to actually get 
the 18 year old’s family to pay the bill, those parents whom
were denied access or the ability to BE INVOLVED for 2 weeks.  
30
No information or answers at the beginning because they were
 being strung along with a claim that Plaintiff, at 18 years 
of age, would be competent to make decisions in a room of 
alleged experienced fraud? 
31
When the Defendants were informed that Plaintiff had given
 permission, they rushed the test, with the lab stating the 
testing before ever receiving an answer from insurance company 
32
After all the calls to all defendants by Plaintiff and Family! 
They, all defendants, acted as a group. They all knew what was
 going on from the office managers and billing people to the 
front desk, all had a part of this alleged fraud where all parties
 acted as if they each would take care of the matter discussed, 
whether it was attempting to talk with the Company or an individual, 
they all allegedly lied.  
33
In fact, after the billing was discovered, before the test was
 to be done, PLAINTIFF and her Mother made every attempt to halt the 
test and did not stop until they were informed it was over—the DR and
 LAB would not do the test! And they would forgive all the billing! 
Yet in Sept 2016 it began to “pop up”, including the test! Personalize
 DX Labs stated they could not destroy the test until they were
 paid! Collection agencies began to call and write and send. 
34
At least 5 staff members and a Doctor were involved locally, 2 
individuals  in the California Lab, at least one 
from Ohio Collection Agency
. From billing manager to office manager and other positions were 
involved. The alleged scam may include others. When the Plaintiff 
finally received the information that it was over, that the test 
WAS canceled and Plaintiff not billed.  The rush to collect the 
$3,678.48 is alive. Even as this action is being filed, the message 
of “do not worry” rings as false as the facts of the testing being
 performed to help anyone!
35
Plaintiff Alleges SIGNATURE WOMEN'S HEALTHCARE and the other prime 
defendants, including DX Labs, have not ended their
 attempts to collect money or destroy the test results. 

36

            As a result of this collective action to defraud the public, Plaintiff has suffered injuries indicated above. Treble damages are therefore appropriate under RICO to punish the conspiratorial nature of Defendants’ planned concealment of known facts, health risks, and production of a Genetic Testing document that will  cause for denial of services, from Defendants  resulting fraud.

37

V1
THIRD CAUSE OF ACTION

Negligence

The Defendants Dr Tyndal M Jones and SIGNATURE WOMEN’S HEALTHCARE were negligent in handling the information, facts, history of Plaintiff and failed to warn the Plaintiff of the down side, problems and possible future discovery of the results of such an invasive Special Genetics Test. Not only was that test performed to the objections of Plaintiff and Family, it was conducted without Plaintiffs approval or knowledge. Yes a paper [as Plaintiff explained it] was signed, BUT IT WAS SAID TO BER A INSURANCE REQUST FORM NOT A DNA FORM OR GENETICS FORM! , AND SHE WAS  under duress and heavy false demanding input by The Defendant Dr Tyndal M Jones, who disregarded the proper format of informing the Plaintiff of those concerns. And, Defendants Dr Tyndal M Jones and SIGNATURE WOMEN’S HEALTHCARE, were negligent in guiding the testing process; making sure if it was carried out properly, and that insurance would pay for the test; and finally, they did not inform the Plaintiff that she would have to pay any amount for the testing, let alone $3,678.48.

 38

VII
FOURTH CAUSE OF ACTION

Failure to Warn

 The Defendants Dr Tyndal M Jones and SIGNATURE WOMEN’S HEALTHCARE were negligent in handling the information, facts, history of Plaintiff and failed to warn the Plaintiff of the down side, problems and possible future discovery of the results of such an invasive Special Genetics Test. Not only was that test performed to the objections of Plaintiff and Family, it was conducted without Plaintiffs approval or knowledge. Yes a paper [as Plaintiff explained it] was signed FOR AN INSURANCE REQUEST FORM   under duress and heavy false demanding input by The Defendant Dr Tyndal M Jones, who disregarded the proper format of informing the Plaintiff of those concerns

39

Punitive Damages

. The conduct of Defendants described above is outrageous. Defendants’ conduct demonstrates a reckless disregard for human and legal rights and a conscious disregard for patient and/or public safety. The acts and omissions described above were willful and performed with actual or implied malice. Punitive and exemplary damages are therefore appropriate and should be imposed in this instance.

 

40

V. PRAYER FOR RELIEF
[THIS IS THE ACTUAL NAME! PRAYER!]

WHEREFORE, Plaintiffs respectfully pray for a judgment against Defendants for:

  1. Injunctive and equitable relief as the Court deems appropriate including:

i)                     Requiring Defendants 

ii)                    Requiring Defendant ;

iii)                  Compelling

  1. Compensatory damages to be paid by all Defendants, according to proof at trial;
  2. Punitive damages as the court deems appropriate;
  3. Costs and attorneys fees of this lawsuit, with interest;
  4. Any other relief as the court deems appropriate.

Dated: Oct 28, 2016                                         Council For Plaintiff

 

                                                                        __________________________,

                                                                       

 

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 4 [TOPIC

 


THIS TRAVESTY HAD ANOTHER PLAYER AND WITH OUT THIS PLAYER THE ALLEGED FRAUD WOULD NEVER HAD OCCURRED, AND WE ARE NOT TALKING ABOUT THE FACT THEY PERFORM THE TESTING, WE ARE SAYING THAT EVEN THOUGH THEY WERE ADVISED THAT THE PATIENT WAS 18, FIRST TIME EVER ON HER OWN W/DOCTOR, DID NOT GO FOR ANYTHING RELATED TO GENETIC TESTING. THIS COMPANY ACTED IN BAD FAITH AND RATHER THAN DROPPING THE EXTREME FEES, FEES THAT WERE NEVER EVER DISCUSSED BECAUSE THE SALES PITCH WAS “ONLY IF INSURANCE PAYS” .. WHAT PART OF ONLY IF INSURANCE PAYS. IT WAS NOT THE DOCTOR WHO EVER SAID THEY WOULD NOT PAY IT WAS THIS LABORATORY. WE HAVE TRIED TO NO AVAIL, THESE GUYS SIMPLY DO NOT BELIEVE WHAT IS SET TO HAPPEN…

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Greetings, please read this thoroughly.

I am contacting you direct and prior to our council files the Federal Complaint.  It is our Councils opinion that predicate acts were engaged by your company and SIGNATUREWOMENSHEALTHCARE et al., yet he believes that he can separate them, one in Superior Court and the Other Federal. The end result is to provide a young girl with closure. That  once 18 year old recent high school graduate who never went to a doctor on her own until the SPECIAL TEST FRAUD which you revived through a recent collection scheme; we are all tired of the fraud!.

A Fraud and Rico Complaint is what we are thinking. Dr Tyndal Jones et al and with your Organization, Defendant Personalized DX Labs[AUTOGENOMICS, INC?]. It is a two pronged Complaint, The one against Dr Jones et al is to be in Superior Court, your complaint will be in Federal Court in The Northern District Georgia. I have yet to approve the filing of the  complaint on your company and it’s chief employees and officers. When I do, I will surely have your copy sent and you will have the opportunity for 60 day reply or 30 day–  the court would rather you accept. 60 days to answer w.o  process server.    Please understand that this is a Fed District Court factor to save money and lessen the packing of cases. Both cases will  occur in Georgia. I would recommend that you research the acceptance of the 60 day offer. You may do so by:  GOOGLE [Fed Complaint Process Serving 30 or 60 days]. You will note that the court attempts to have 60 and desires that defendants accept the 60 day because it saves cash and lessens the rush of cases. 

Plaintiff’s complaint is focused on the fact you ran a Highly Specialized Procedure with a cost of 3600.00 in a fraudulent manner and then billed an 18 year old fresh out of high school with no experience in anything about doctors or appointments and when interested parties with credentials attempted to halt it you ran the test irregardless of their pleas or credentials.and please, do not say you lowered the price or you will sound like Dr Jones….

Juliana never approved it. It was Fraud. Please, do not take this lightly or as a threat or that it is not going to occur. We have left you alone due to the fact we believed that you pointed your finger at the Physician. We were not aware of certain facts that have come to light that demonstrate RICO PREDICATE ACTS. What triggered this action was the billing you sent Juliana. That shows that you waited all this time so that you and your would not be implicated. But, our Physician seems to be blaming you. Plus, Phone records of her mother informing your people back when are in the councils  possession. Other papers, documents also point that way. This is fraud across state lines. Use of mail,Phone and Internet in a criminal conspiracy. Intimidation, force, lies then attempts to defrauded the VICTIM into paying you?

In fact, we have proof that calls were made and conversations exist that show fraud was the main act and that “stuff” happened long before Juliana. Also, it seems your superior court persona points to you as the culprit. After all, it was your tests, you were the one pricing, checking, offering help with insurance companies after you already ran the tests and were trying to get paid. We understand that the app 3600.00 was not actually a mutual decision, rather you made a deal on the costs. How you showed Doc Jones to sell these expensive tests. Dr Jones new Juliana was concerned as to the insurance approval after she was bullied politely to say yes to discovering if she was covered! He never approved anything and your company employee stated something completely different! Yes, we saved everything.

It took this long to get confirmation that Jones received information stating that the insurance company was not going to approve the test, and that leaves it in your lap. Jones knew this long before Scarfone was bullied and lied to in order for Jones and your company to use predicate acts.

I will say that we tried to go our way before deciding to file. But your hiding in your laboratories waiting to put a debt collector on  a person already terrorized simply wet our appetite. We realized as long as you act as if the test was Juliana’s Idea, That she KNEW the price, That she did not say only if covered — she is protected by truth and fact!  It is time to protect and deliver victory to that poor young ladies life!

The only way to stop, halt and end your demeaning attack with these false allegations is to bring your company into the ring of Federal Court. Believe you me, it will occur and you will be there. Your company ran a 3600.00 test on an 18 year old at her first appointment who never ever was by herself with a heath care professional. And whom has a long history of pain and sorrow and now you want to bill her for your mistakes?

You set the dogs on her trying to destroy her credit which she has yet to build— trying to take more than that poor handicapped young  girl can make in 2 months!

I will use certified mail to contact you if that is the route you want to go,. Note, there is no statute of limitations as of the nest 10 months seeing that you wanted to continue your fraudulent collection by sending a collection agency to hound that poor young lady who has suffered enough,. Thanks to you yours and your partner in crime, you have made her frightful of seeing doctors or having any testing done, She did not use Jones for anything but an infection. But you folk simply saw a pawn…

you can have whom ever is in the position to talk contact me with a phone number and the right time to call, if not, we will be sending you the complaint acceptance notification….

thank you.
Rock Scarfone

Call us at: 760-517-1653
For general inquiries: info@personalizedxlabs.com
For customer service: customerservice@personalizedxlabs.com
For website issues: admin@personalizedxlabs.com

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http://www.signaturewomens.com/tyndal-m-jones-md
http://www.dekalbmedical.org/find-doctor/J/jones-tyndal-m
http://www.yellowpages.com/lawrenceville-ga/mip/signature-womens-healthcare-dr-tyndal-m-jones-1570387
http://localreviewdirectory.com/obstetrics-gynecology/ga/lithonia/signature-womens-healthcare-dekalb
signaturewomenshealthcare5900@gmail.com
Signature Women’s Healthcare (Lawrenceville)
http://localreviewdirectory.com/obstetrics-gynecology/ga/lawrenceville/signature-womens-healthcare-lawrenceville
https://www.facebook.com/pages/Jones-Tyndal-MD/115849385143483

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Welcome , today is Wednesday, July 26, 2017