UAMS doctor Damalcheruvu forced a man to undergo a second CT Scan after he determined no immediate surgery was needed after the first scan. Because the patient refused, the staff at UAMS, where Damalcheruvu is an assistant professor, used Fentanyl and benzodiazepines to try to knock him out.

When the patient still protested, the UAMS staff member bound him naked to the hospital bed with four-point restraints.

The patient is suing Dr. Damalcheruvu. The doctor is paid over $600,000 per year and has insurance. There were over 80 individuals involved in what ended as two weeks of unlawful imprisonment and battery. The first ask made by the patient turned plaintiff was a settlement of $275,000.

Damalcheruvu would rather fight and win on a procedural issue. For example, he refused to accept service that came by certified mail, until the service period expired. Then he claimed that service was late.

It appears that Dr. Damalcheruvu’s attorney cut and pasted requests for admissions from a female defendant. The doctor’s requests use feminine pronouns. It is possible that Prashanth Damalcheruvu identifies as she/her, so the plaintiff followed suit.

Similar responses were given to the female defendant and two male defendants who had identical requests (except the name and pronouns). For RFAs, the response repeats the request before the answer. Therefore, only the responses are posted here.

Comes now Pro Se Plaintiff Sean Lynn in response to requests for admission propounded by Defendant Prashanth Reddy Damalcheruvu and emailed to Lynn on September 3, 2026:

REQUEST FOR ADMISSION NO. 1: Admit that you do not have testimony from a qualified medical expert to support the allegations of negligence against Dr. Prashanth Reddy Damalcheruvu in your Complaint.

RESPONSE TO REQUEST FOR ADMISSION NO. 1: Objection. Irrelevant. I do not need an expert because the asserted negligence lies within the jury’s comprehension as a matter of common knowledge. Ark. Code Ann. § 16-114-206(a). Expert testimony is not required when the asserted negligence lies within the comprehension of a jury of laymen, such as a surgeon’s failure to sterilize her instruments or to remove a sponge from the incision before closing it. Mitchell v. Lincoln, 366 Ark. 592, 598, 237 S.W.3d 455, 460 (2006). I am questioning Prashanth Reddy Damalcheruvu, M.D.’s decision to force me not to recover from my initial head injury at home without the use of pharmaceuticals; and her failure to follow UAMS policy as explained in language lay persons can understand on the form UAMS PATIENT RIGHTS AND RESPONSIBLITIES. A copy of the 2023 version of the form is attached as Exhibit 22. Neither Prashanth Reddy Damalcheruvu, M.D. nor any other UAMS employee gave me a copy or alerted me to its existence. My mother found it on the internet after I returned home.

            The law regarding involuntary confinement and non-consensual harmful or offensive contact is easy to understand. There are model jury instructions that are understood by jurors without any expert, other than the judge, explaining the law.

            Arkansas law is clear that when a patient seeks release but is held against his will, he must be treated as an involuntary detainee with full due process protections, including a meaningful hearing with clear and convincing evidence. Von Luce v. Rankin, 267 Ark. 34, 39, 588 S.W.2d 445, 449 (1979). As in Von Luce, I was never afforded any hearing, judicial review, or due process before being confined for 14 days against my expressed wishes to leave.

            The need for expert testimony specified in Ark. Code Ann. § 16-114-206(b) does not apply here. Informed consent presupposes that a patient consented to the procedure but may have done so without all information necessary to make a reasoned decision. Millsap v. Williams, 2014 Ark. 469, 14, 449 S.W.3d 291, 300. I refused treatment after the first CT Scan and blood test, when I was told there was no need for surgery. My suit is about lack of consent; not informed consent.

A jury can understand that Prashanth Reddy Damalcheruvu, M.D. did not invoke an emergency exception at any time.

The State has a due process obligation to provide appropriate medical care to persons in its custody, which must look to the intent of the State in its decision to involuntarily medicate the confined person. Singleton v. Norris, 338 Ark. 135, 138, 992 S.W.2d 768, 769 (1999). Here, it is easy to understand that chemical restraints were used by Prashanth Reddy Damalcheruvu, M.D. to hold me for observation and to participate in the second CT scan, made on the morning of January 14, 2024.

Arkansas courts distinguish between medical negligence requiring specialized knowledge and ordinary negligence involving basic safety measures that laypeople can understand. Prashanth Reddy Damalcheruvu’s failure to ask for preservation of the surveillance video of her interactions with me in the Emergency Department is comprehensible to any reasonable jury member. A juror can make a reasonable inference that the evidence would show that whatever “treatment” Prashanth Reddy Damalcheruvu, M.D. performed on me was adverse to standard of care. These are not complex medical decisions requiring expert interpretation, but rather basic administrative functions that any doctor must perform competently. The systematic destruction of video evidence particularly demonstrates consciousness of wrongdoing and violates fundamental principles of evidence preservation that any layperson can understand. UAMS’s own policies required preservation of such evidence because my mother clearly stated that there would be litigation and UAMS counsel was consulted before my release. The deliberate destruction suggests Prashanth Reddy Damalcheruvu, M.D.’s awareness that the recorded conduct was legally problematic. Such ordinary negligence in documentation falls outside the specialized medical knowledge requiring expert testimony.

Spoliation is the destruction or significant alteration of evidence, or the failure to preserve property for another’s use as evidence in pending or reasonably foreseeable litigation; and it has long been the rule that spoliators should not benefit from their wrongdoing. Kelsay v. Wise, No. CA98-1487, 1999 WL 1203724, at *3 (Ark. Ct. App. Dec. 8, 1999).

            A jury can comprehend as a matter of common knowledge the evidence that indicates that accepting an EMT’s unverified statement unattributed to a witness, claiming that I had a death defying 35-foot fall yet still presented with no other indicator for level 1, 2 or 3 activation, was a breach of Prashanth Reddy Damalcheruvu, M.D.’s duty. Compl. at ¶¶ 95, 11-58. Prashanth Reddy Damalcheruvu, M.D. had access to my medical record and an obligation to read it. Apparently, she[1] did not.

A jury can comprehend as a matter of common knowledge the well settled law that the violation of a safety statute is evidence of negligence. Bussell v. Missouri Pac. R. Co., 237 Ark. 812, 817, 376 S.W.2d 545, 548 (1964). A jury can comprehend, without expert testimony, that it is imprudent to commit a criminal battery and false imprisonment against a man who is already injured.

 For example, a person commits battery in the first degree if acting alone or with one or more other persons the person commits or attempts to commit a felony; and in the course of and in furtherance of the felony the person or an accomplice causes serious physical injury to any person under circumstances manifesting extreme indifference to the value of human life or another person who is resisting the felony or flight causes serious physical injury to any person. Ark. Code Ann. § 5-13-201; Compl. at ¶¶ 346-354.

A jury can comprehend as a matter of common knowledge that using physical and chemical restraints to confine a person, me, to a hospital without consent and without a lawful order is the felony of false imprisonment. Ark. Code Ann. § 5-11-103 (“A person commits the offense of false imprisonment in the first degree if, without consent and without lawful authority, the person knowingly restrains another person so as to interfere substantially with the other person’s liberty in a manner that exposes the other person to a substantial risk of serious physical injury.”); Compl. at ¶¶ 346-354.

A jury can understand, without expert testimony, that Prashanth Reddy Damalcheruvu, M.D. committed the crimes of battery and false imprisonment against me. While confining me without consent and without a lawful order, she ordered staff under her supervision and control to drug and bind me.  A jury can understand that committing these crimes was negligence per se, allowing for an inference of negligence.

A jury can understand that because the medical record contains no petition or physician certification under Ark. Code Ann. § 20-9-604—and no psychiatric hold petition—there was no legal authority to hold me. Compl. at ¶¶ 57, 58, 107-114.

Regardless of which party has the burden of proof, a jury can understand that an emergency exception did not apply, without any testimony from an expert. Arkansas law establishes that medical treatment without consent constitutes battery, but provides a narrow emergency exception. See Millsap, 2014 Ark. 469. Under Ark. Code Ann. § 20-9-603:

 “Emergency” means a situation in which, in competent medical judgment, the proposed surgical or medical treatment or procedures are immediately or imminently necessary and any delay occasioned by an attempt to obtain a consent would reasonably be expected to jeopardize the life, health, or safety of the person affected or would reasonably be expected to result in disfigurement or impaired faculties.

The emergency exception operates under a conjunctive two-pronged test established in Millsap: “Consent is not required when an emergency exists AND there is no one immediately available who can provide consent for the patient.” Millsap, 2014 Ark. 469 at 13, 449 S.W.3d at 299. Both conditions must be satisfied for the exception to apply, meaning the plaintiff can defeat the emergency doctrine by disproving either prong. Here, I was of sound mind when I initially refused treatment, subsequent intoxication was caused by the medical providers’ battery, of which Prashanth Reddy Damalcheruvu, M.D. was an active conspirator, and my mother was available to inform the defendants that I did not want treatment by the defendants. Further, it was clear to all but the most cognitively impaired individuals that I wanted to leave and I had reason and the right to leave.

A jury can comprehend, using a small amount of common knowledge, that damage is caused by being forced to be hospitalized overnight so Prashanth Reddy Damalcheruvu, M.D. could force me to have my head scanned a second time. Besides the physical violation of detainment, my medical condition is an extremely private matter and Damalcheruvu required chemical sedation to be administered on me in order to obtain the expensive images she wanted to look at.

For example, courts find that mental anguish, an affront to personality, indignity, disgrace, humiliation and mortification to which the victim is subjected by battery is compensable. Browder v. Gahr, 258 Ark. 992, 996–97, 530 S.W.2d 359, 362 (1975).

A jury can comprehend that damalcheruvu, owing me a duty, failed to act to release me from imprisonment, therefore was a proximate cause of the damages I sustained from the time she should have tried to release me. Prashanth Reddy Damalcheruvu, M.D. is particularly liable. She was an assistant professor collecting $584,976 per year salary. Yet she approved of the imprisonment and battery committed on January 13, 2024 that continued to January 27, 2024.

REQUEST FOR ADMISSION NO. 2: Admit that you do not have testimony

from a qualified medical expert willing to testify that Dr. Prashanth Reddy Damalcheruvu failed to meet the applicable standard of care in his medical care and treatment of Sean Lynn.

RESPONSE TO REQUEST FOR ADMISSION NO. 2: Objection. Irrelevant. I do not need an expert because the standard of care that I assert Prashanth Reddy Damalcheruvu, M.D. failed to meet lies within the jury’s comprehension as a matter of common knowledge.

            A jury can understand that the majority of doctors in Arkansas studied or did a residency at UAMS. UAMS set the standard in Arkansas, as dismal as it is. Prashanth Reddy Damalcheruvu, M.D. violated almost every one of the patient rights defined by UAMS, including the right to refuse treatment and to leave UAMS against the advice of the health care providers, to the extent permitted by law. Compl. at ¶ 93.

            UAMS admitted on the record generated by UAMS staff: “Arkansas has no law (and UAMS, no policy) that covers so-called ‘medical holds,’ which means that the ability to hold a patient who wants to leave AMA can only happen in a very limited set of conditions where the team can show a significant risk of imminent harm could befall the incapacitated patient should they leave the hospital.” Compl. at ¶ 94. It does not take a brain surgeon to explain that Prashanth Reddy Damalcheruvu, M.D. violated this standard.

            A procedure performed without a valid consent would be outside the standard of care. Haupt v. Kumar, 103 Ark. App. 298, 300, 288 S.W.3d 704, 706 (2008).

            Prashanth Reddy Damalcheruvu, M.D. did not petition a court with a statement that claimed a need to override patient autonomy. Presumably, a competent doctor in Arkansas files a petition before overriding authority, unless the doctor knows the petition will be denied. It is easy to understand the triage report, initial test results and the words Dr. Bruce wrote at about 10 p.m. on the first night of the confinement: “Suspect his exam will get worse – ICU for close monitoring[.]” Compl.  at ¶¶ 55, 56. Suspicion is not imminent need that would allow Prashanth Reddy Damalcheruvu, M.D. to vary from the standard of care of allowing me bodily autonomy.

            A jury will also understand that every drugging and procedure that Prashanth Reddy Damalcheruvu, M.D. subjected me to after my right to leave UAMS Medical Center was violated by her1 was harmful or offensive.

            The need for expert testimony specified in Ark. Code Ann. § 16-114-206(b) does not apply here. Informed consent presupposes that a patient consented to the procedure but may have done so without all information necessary to make a reasoned decision. Millsap v. Williams, 2014 Ark. 469, 14, 449 S.W.3d 291, 300.

            A jury can understand the reasonable inference from the failure to ask for the preservation  of surveillance video. Spoliation is the destruction or significant alteration of evidence, or the failure to preserve property for another’s use as evidence in pending or reasonably foreseeable litigation; and it has long been the rule that spoliators should not benefit from their wrongdoing. Kelsay, No. CA98-1487, 1999 WL 1203724, at *3 (Ark. Ct. App. Dec. 8, 1999).

            Further, a jury needs no expert to explain Damalcheruvu’s failure to check for consent, ask for consent or contact my family, whose numbers were in my cell phone.

REQUEST FOR ADMISSION NO. 3: Admit that you do not have testimony from a qualified medical expert that there was an act or omission on the part of Prashanth Reddy Damalcheruvu, M.D. that was a proximate cause of injury or damage to Sean Lynn.

 RESPONSE TO REQUEST FOR ADMISSION NO. 3: Objection. Irrelevant. I do not need an expert because the fact there was an act or omission on the part of Prashanth Reddy Damalcheruvu, M.D. that was a proximate cause of injury or damage to me lies within the jury’s comprehension as a matter of common knowledge.

Advertisements for the drugs Prashanth Reddy Damalcheruvu, M.D. forced into me are required to be written comprehensible to an ordinary person. They include side effects, warnings, precautions, and contraindications of the drugs. 21 C.F.R. § 202.1. I intend to read the warnings from each drug Prashanth Reddy Damalcheruvu, M.D. forced into me to the jury. I am not an expert and I understand those labels. So will the jury.

The jury can easily comprehend that there was foreseeable harm and injury to a person who wants to go to sleep in his own bed, to be bound in one position for days at a time, woken as often as captors torture their prisoners, starved, dehydrated and humiliated, instead. I accused Prashanth Reddy Damalcheruvu, M.D. of this conduct.

A jury can easily comprehend Prashanth Reddy Damalcheruvu’s violation of my right to have a family member or representative of my choice notified promptly of my admission to the hospital. 42 C.F.R. § 482.13(b)(4).

Further, courts find that mental anguish, an affront to personality, indignity, disgrace, humiliation and mortification to which the victim is subjected by battery is compensable. Browder, 258 Ark. at 996–97, 530 S.W.2d at 362. No expert is required to show that it was foreseeable that being battered at Prashanth Reddy Damalcheruvu, M.D.’s direction was reasonably certain to cause the mental anguish, affront to personality, indignity, disgrace, humiliation and mortification that it caused me.

A jury can comprehend using common knowledge that it was foreseeable that forced dehydration, starvation, lack of uninterrupted sleep, administration of a pharmacology of controlled substances and being bound in one position for days at a time would foreseeably cause injury and damage. The same jury can easily understand that my claim that because Dr. Prashanth Reddy Damalcheruvu was a supervising assistant professor at the time of the false imprisonment and battery, she did not discourage those working under her from continuing with the false imprisonment and battery, and she “ordered” the conduct, that she was a proximate cause of the injury and damage.

A jury can comprehend using common knowledge that the numbers on the blood tests recorded by the defendants started in healthy range and got much worse, then within four days of leaving against medical advice, my blood was in the healthy range again.

It was foreseeable that I would be traumatized by being falsely imprisoned and battered as that is a natural consequence of Damalcheruvu’s conduct. Missouri Pac. R. Co. v. Yancey, 178 Ark. 147, 10 S.W.2d 22, 24 (1928).

REQUEST FOR ADMISSION NO. 4: Admit that Prashanth Reddy Damalcheruvu, M.D. was

not negligent in any way in connection with the care and treatment provided to Sean

Lynn.

 RESPONSE TO REQUEST FOR ADMISSION NO. 4: Objection. This request should not be considered because it is legal in nature. The firm representing Prashanth Reddy Damalcheruvu, M.D. knows or should know that this request is impermissible. The Damalcheruvu requests are identical to the requests for admission filed and answered by the now dismissed defendants who were represented by Wright, Lindsey and Jennings LLP. (Those defendants will be named in my 42 USC 1983 federal case.) It is reasonable to believe that when Amelia H. Sandrock on behalf of Damalcheruvu accessed the WLJ requests, Ms. Sandrock also read my answers. To proceed otherwise would violate Rule 11’s admonishment to make a reasonable inquiry before certifying a document.

As per my filed answers to the WLJ defendants, Wright, Lindsey and Jennings LLP represented Baptist Health and Dr. Patrick O’Connell in a medical malpractice case in 2013. The firm propounded, “REQUEST FOR ADMISSION NO. 4: Admit that Baptist was not negligent in the care and treatment of Vernon Hardesty.” Hardesty v. Baptist Health, 2013 Ark. App. 731, 3, 431 S.W.3d 327, 330. The circuit court did not consider Baptist’s fourth request, finding that it was legal in nature. Hardesty, 2013 Ark. App. at 4, 431 S.W.3d at 330. The same request was made on behalf of Dr. O’Connell and the lower court did not invalidate that request, erroneously, but not prejudiciously. Id. at 5, 431 S.W.3d at 331.

            Objection. This is an improper request for admission because Prashanth Reddy Damalcheruvu, M.D. knows or should know that I would not admit this; it is in direct contradiction to my complaint. The purpose of requests for admission is to decrease the costs of litigation by narrowing the issues. It is not meant to be a tool to cause busy work for a pro se litigant in the hopes that the litigant fails to respond timely.

The request for admissions within our discovery procedure is intended to eliminate the effort, expense and time involved in proving such facts as are admitted and is not intended as some new or modern legal method of winning law suits without trial. The object of the civil court trial still remains to attain justice between the parties as nearly as possible, and the rules of civil procedure, including discovery, are intended to aid in that object.

Widmer v. Fort Smith Vehicle & Mach. Corp., 244 Ark. 626, 632, 427 S.W.2d 186, 190 (1968).

            Notwithstanding my objections, I deny that Prashanth Reddy Damalcheruvu, M.D. was

not negligent in any way in connection with the care and treatment provided to Sean

Lynn.

REQUEST FOR ADMISSION NO. 5: Admit that Dr. Prashanth Reddy Damalcheruvu did not fail to meet the applicable standard of care in his medical care and treatment of Sean Lynn.

 RESPONSE TO REQUEST FOR ADMISSION NO. 5: I deny that Dr. Prashanth Reddy Damalcheruvu did not fail to meet the applicable standard of care in his medical care and treatment of Sean Lynn.

REQUEST FOR ADMISSION NO. 6: Admit that there was no act or omission by Prashanth Reddy Damalcheruvu, M.D. that was the proximate cause of injury or damage to Sean Lynn.

 RESPONSE TO REQUEST FOR ADMISSION NO. 6: Objection. This request should not be considered because it is legal in nature. The firm representing Prashanth Reddy Damalcheruvu, M.D. knows this request is impermissible. The Damalcheruvu requests are identical to the requests for admission filed and answered by the now dismissed defendants who were represented by Wright, Lindsey and Jennings LLP. (Those defendants will be named in my 42 USC 1983 federal case.) It is reasonable to believe that when Amelia H. Sandrock on behalf of Damalcheruvu accessed the WLJ requests, Ms. Sandrock also read my answers. To proceed otherwise would violate Rule 11’s admonishment to make a reasonable inquiry before certifying a document.

As per my filed answers to the WLJ defendants, Wright, Lindsey and Jennings LLP represented Baptist Health and Dr. Patrick O’Connell in a medical malpractice case in 2013. The firm propounded, “REQUEST FOR ADMISSION NO. 5: Admit that any actions or inactions on the part of Dr. Patrick O’Connell were not the proximate cause of any damages or injuries alleged in your complaint.” Hardesty, 2013 Ark. App. at 3, 431 S.W.3d at 330. The circuit court did not consider Dr. O’Connell’s fifth request, finding that it was legal in nature. Hardesty, 2013 Ark. App. at 4, 5, 431 S.W.3d at 330, 331.

            Notwithstanding my objection, I deny that no act or omission by Dr. Prashanth Reddy Damalcheruvu was the proximate cause of injury or damage to me.

REQUEST FOR ADMISSION NO. 7: Admit that Prashanth Reddy Damalcheruvu, M.D. complied with the standard of care required of him in the medical care and treatment provided to Sean Lynn.

RESPONSE TO REQUEST FOR ADMISSION NO. 7: Objection. Prashanth Reddy Damalcheruvu, M.D. asked substantially the same request for admission No. 5, “Admit that Dr. Prashanth Reddy Damalcheruvu did not fail to meet the applicable standard of care in his medical care and treatment of Sean Lynn.” The only difference is using “complied with” in place of  “did not fail to meet the applicable[.]” Prashanth Reddy Damalcheruvu, M.D. and the other defendants already stole two weeks of my life and I will probably die sooner than if I had been allowed to heal properly in my home after jumping 10 feet from a falling ladder. Stop asking the same questions over and over.

            Notwithstanding the objection, I deny that Prashanth Reddy Damalcheruvu, M.D. complied with the standard of care required of him in the medical care and treatment provided to Sean Lynn.

REQUEST FOR ADMISSION NO. 8: Admit that Dr. Prashanth Reddy Damalcheruvu is not liable in any way to you.

RESPONSE TO REQUEST FOR ADMISSION NO. 8: Objection. As the firm representing Prashanth Reddy Damalcheruvu, M.D. knows or should know from reading my answer to requests for admission to the exact requests (other than defendant’s name) filed in this case by the WLJ defendants, a request for admission of a purely legal matter is impermissible. A request for admission that asks a party to admit that a person is not liable is also legal in nature, as it pertains to a legal conclusion rather than a factual matter.

            Where there are no facts mentioned in the request, it cannot be called an “application of facts to law.” Matter of Adoption of Dailey, 30 Ark. App. 8, 11, 784 S.W.2d 782, 783 (1989).

            Notwithstanding the objection, I deny that “Prashanth Reddy Damalcheruvu, M.D. is not liable in any way to” me.

REQUEST FOR ADMISSION NO. 9: Admit that you do not have a reasonable cause affidavit against Prashanth Reddy Damalcheruvu, M.D. from a qualified expert as required by Ark. Code Ann. § 16-114-209(b).

RESPONSE TO REQUEST FOR ADMISSION NO. 9: Objection. Irrelevant. It is also unclear as to what the affidavit would address.

            Ark. Code Ann. § 16-114-209(b) was ruled as unconstitutional, because the legislature was infringing on the court’s ability to make rules concerning procedural law. See Summerville v. Thrower, 369 Ark. 231, 253 S.W.3d 415 (2007). The court concluded that § 16–114–209(b) is procedural and turned to its asserted conflict with Rule 3. Summerville, 369 Ark. at 238, 253 S.W.3d at 420. The Arkansas Constitution is clear that rules of pleading, practice, and procedures for our courts fall within the domain of the Arkansas Supreme Court. Ark. Const. amend. 80, § 3.
Summerville, 369 Ark. at 238, 253 S.W.3d at 420.

            Further, before being deemed unconstitutional, the statute would not be applicable to this case. It begins, “In all cases where expert testimony is required under § 16-114-206[.]” § 16-114-209(b). I am not required to have expert testimony because the issues addressed by my claims are within the comprehension of a jury of my peers. § 16-114-206. No expert testimony is required to understood that I was falsely imprisoned and battered by Prashanth Reddy Damalcheruvu, M.D. A jury can read the UAMS patient rights, exhibit 22, and understand that Damalcheruvu violated my right to have a family member or other person of your choosing to be notified promptly upon my admission to UAMS Medical Center; know the name of the physician who had primary responsibility for coordinating my care and the names of other health care providers who cared for me; to be informed that I was injected with Fentanyl, Benzos and other medication during the time Damalcheruvu was actively involved in my non-consensual treatment; refuse treat; and almost every other one of the listed rights.

REQUEST FOR ADMISSION NO. 10:  Admit that you have no evidentiary support for the allegations made in your Complaint against Prashanth Reddy Damalcheruvu, M.D..

RESPONSE TO REQUEST FOR ADMISSION NO. 10: I deny that I have no evidentiary support for the allegations made in my Complaint against Prashanth Reddy Damalcheruvu, M.D..

REQUEST FOR ADMISSION NO. 11:  Admit you have no evidentiary support for the damages claimed in your Complaint.

RESPONSE TO REQUEST FOR ADMISSION NO. 11: I deny that I have no evidentiary support for the damages claimed in your Complaint.

REQUEST FOR ADMISSION NO. 12:  Admit Sean Lynn’s injuries and

damages as alleged in the Complaint were due to his pre-existing medical conditions

and not a result of the medical care and treatment he received from Defendants.

 RESPONSE TO REQUEST FOR ADMISSION NO. 12: Objection. This request is compound and the second clause is pregnant. Damalcheruvu is referring to non-consensual, harmful and offensive contact as “medical care and treatment” instead of “battery.”

Notwithstanding my objection, I deny that my injuries and damages as alleged in the Complaint were due to my pre-existing medical conditions and not a result of the battery by the defendants as alleged in my complaint.

I, Sean Lynn, declare under penalty of perjury under the laws of the State of Arkansas that the foregoing Responses to Requests for Admission are true and correct to the best of my knowledge, information, and belief.

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[1] The requests for admission served on behalf of Prashanth Reddy Damalcheruvu show a preference for using the pronouns “She/her” so I am using her preferred pronouns.