Government Attorney Wastes More Tax Money
MOTION TO REMOVE OBJECTIONS, COMPEL DISCOVERY RESPONSES AND IMPOSE SANCTIONS
Sean Lynn and Laura Hammett (“Lynn,” “Hammett,” and collectively “Claimants”), pro se with aligned interests, state as follows:
- Claimants made a good-faith effort to resolve these discovery disputes through emails to which the three letters filed contemporaneously here were attached, and by several unaccepted offers to discuss the discovery dispute in person.
- UAMS refused to participate in the meet and confer communications. Counsel Sherri Robinson demanded more time to respond to the written communications. Instead of responding to the Claimants privately, UAMS responded by filing what they termed “amended and substituted” answers—without leave—and a weak argument responsive to the Claimants’ meet-and-confer letters, couched as an “introduction”.
- There is no authority for parties to file amended or substitute discovery responses without first obtaining leave. The rules specifically iimpose a duty to “supplement”.
- Therefore, UAMS rendered any further efforts to resolve discovery disputes without the Commission’s intervention futile.
II. UAMS Used Dilatory Tactics
- Claimants agreed to an extension for UAMS to respond to set one of the interrogatories and RFPs. UAMS served those one day after the extended deadline passed and served set two a week late, with no request for consent to extend.
- Even after taking extra time, the UAMS responses were grossly deficient and repetitive.
- In response to the Claimants’ Requests for Admission, UAMS introduced contentions that were non-responsive and denied statements for which there is no genuine dispute, multiplying the proceedings.
- For example, UAMS denied RFA No. 1, despite statements written in the medical record and recorded on video evidence produced that Lynn told UAMS to stop, physically struggled to make UAMS stop and made several attempts to escape.
- The UAMS “amended and substituted” responses were filed on September 12, 2025, with no leave to amend sought. UAMS should be compelled to explain why it denied true statements originally, or be sanctioned for delaying the proceedings and causing a hardship on the Claimants.
- UAMS denied that it administered sedatives and antipsychotic medications to Lynn against his will. Responses to RFA Nos. 15 and 16. In the same paragraph, UAMS explains why they claim they were doing Lynn a favor when they drugged him without consent. Good motivation does not relieve the provider from failure to obtain consent to provide medical services. To act otherwise renders the rules, policies, and the United States Constitution that guarantee a person’s autonomy over their body meaningless.
- The responses and the medical record lack any indication that an emergent, life-threatening or disfiguring condition that is treated with sedatives or anti-psychotics existed.
- UAMS refused to attribute the decision to commit criminal battery on Lynn to specific employees.
- UAMS did not name any employee accountable for destroying video evidence of alleged criminal conduct.
- AMS interjected an affirmative defense that was not made timely and was therefore waived. It is also improper to raise affirmative defenses within answers to interrogatories.
- In each set of the “amended and substituted” sets of responses to interrogatories, UAMS said that they were providing information to assist the Claimants in understanding the UAMS responses to the discovery requests. Responses at page 2.
- UAMS was deceitful. The “information” argues that all responses to Claimants’ requests referring to the medical record are proper under Rule 33(d) of the Arkansas Rules of Civil Procedure. Rule 33(d) requires that “specification shall be in sufficient detail to permit the interrogating party to locate and to identify, as readily as can the party served, the records from which the answer may be ascertained.” UAMS did not cite pages and did not say what entries in the 1,300-page medical record were responsive.
- For example:
INTERROGATORY NO. 72: According to UAMS denial of Request for Admission (RFA) No. 1, “Consent is not required in Emergency Situations.” What was the Emergency Situation that UAMS claims to override the 14th amendment right to medical autonomy and the stated policy of UAMS that patients have a “right to refuse treatment”?
ANSWER: UAMS objects to this interrogatory as overly broad, unduly burdensome, argumentative, calls for a legal conclusion, and not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding the objection, UAMS refers Claimants to the medical record, which speaks for itself, for a summary of Lynn’s injuries and the emergent nature of those injuries.
- UAMS is requiring Claimants to read the minds of unnamed medical providers who UAMS claimed had found some unspecified need for treatment for unspecified “symptoms” of TBI. In fact, UAMS impermissibly substituted its judgment for Lynn’s judgment. UAMS is telling Lynn to now look at a summary of what UAMS employees say occurred over two weeks to determine why UAMS felt entitled to violate Lynn’s autonomy over his own body.
- UAMS declared that claimants are required to obtain an expert witness report. UAMS did not file a motion to have the claims dismissed and allow Claimants the opportunity to tell the Claims Commission why UAMS is wrong. UAMS is substituting its judgment for the Commissioners’ judgment.
- UAMS declared the September 12, 2025 document should replace the original Responses provided by the parties on July 18, 2025. There was no motion filed. Claimants object to any limitation on using the original responses for impeachment purposes.
- Claimants request that all UAMS objections be removed.
- Claimants request that UAMS be compelled to fulfill its obligation to respond in good faith within a 10-day safe harbor period, and that any reference to the medical record include a citation to identify where it is responsive.
- After the safe harbor period, Claimants request that where UAMS failed to answer an interrogatory or RFP fully, UAMS be restricted from using any documentary evidence at trial or on a motion for summary judgment that would have been responsive to an interrogatory or RFP, but Claimants should be allowed to use that evidence once it is produced.
- Claimants have far less economic resources than UAMS. Claimants ask that, because UAMS was evasive and outright non-compliant with its duty to respond, that UAMS pay all costs associated with the oral deposition of ten witnesses of Claimants’ choosing.
- UAMS made special note that Claimants are not allowed to collect attorney fees as pro se litigants. There must be an economic incentive for UAMS to stop lying and start producing answers and documents.
- In a general objection, UAMS objected to the instructions and definitions set forth by Claimants. Those instructions and definitions were substantially carbon copies of instructions that UAMS drafted. UAMS objected to what they propounded upon the Claimants.
- UAMS said they will supplement their responses to Claimants’ discovery after obtaining all the records and the pertinent deposition testimony of the fact witnesses and any expert witnesses. Since the responses were significantly lacking, close to null, it is apparent that either UAMS did not make a reasonable inquiry before filing its responses or withheld its findings in order to ambush Claimants at the end of the discovery period.
- In its general objection, UAMS asserts that “[a]ll references to the medical record by Respondent herein are to the Legal Medical Record generated on April 29, 2025 and provided to Claimants on May 9, 2025 by email to Claimant Laura Hammett.” By defining “the medical record” in this limited way, UAMS appears to exclude from discovery both earlier-produced materials and documents that remain withheld—specifically, records referenced via apparent hyperlinks in the 4/29/25 record and essential imaging reports (radiology, CT scans, and x-rays) not included in production. These omissions contradict both customary medical record definitions and the duty to produce all relevant medical documentation responsive to Claimants’ requests.
- The most repeated answer, in full: “UAMS objects to this interrogatory as it calls for pure conjecture and speculation, is not reasonably calculated to lead to the discovery of admissible evidence and is not relevant to any of the claims raised by Claimants. Moreover, this request is unduly burdensome as Claimants have the burden of proving their claims through expert testimony, and this Request impermissibly attempts to shift this burden to UAMS. Notwithstanding the objection, UAMS refers Claimants to the medical record, which speaks for itself.”
- UAMS claimed Claimants’ discovery requests were “not reasonably calculated to lead to the discovery of admissible evidence”. The rule is that leeway is given in discovery requests so long as they may reasonably lead to relevant evidence.
- Respondent’s purported reason that the requests are burdensome, “Claimants have the burden of proving their claims through expert testimony, and this Request impermissibly attempts to shift this burden to UAMS”. UAMS is wrong. The only negligence claimed is a matter that can be comprehended with common knowledge. UAMS is liable for supervisory negligence because it does not require its triage nurses to verify the mechanism of injury reported by an EMT without attribution. UAMS accepts the EMT report, even if it is inconsistent with the patient’s condition and despite the patient asking to correct the medical record. UAMS as Respondeat superior condoned and continues to condone false imprisonment, battery, and fraud by its employees.
- “UAMS refers Claimants to the medical record, which [they falsely claim] speaks for itself”, instead of providing additional documentation or information requested. For example, there are no surveillance videos produced. There are no handwritten notes. Hammett observed the entire team of residents and trainees typing notes into electronic devices outside Lynn’s room during rounds with a professor. Those notes are all HIPPA protected and should be maintained according to UAMS policy. There were no policies provided, such as the policy to inquire if there is dissatisfaction with the care if a guest is video recording the hospitalization, which Hammett obtained through a FOIA request. There are no studies or written protocols produced that address the use of opioids, benzodiazepines, and restraints on TBI patients. There is no paperwork required for a “72-hour hold” or “psych hold”, words that UAMS used to describe the incarceration. There are no emails discussing the case, though all the uams.edu emails belong to UAMS, not the user.
- Of the forty-one (41) separate requests for production of documents, Claimants objected and refused to respond to all but three of those. The response to RFP No. 8 included the floor plan for the fourth floor, but excluded the floor plan for the emergency room. Hammett was not allowed to see the emergency room at all on July 1, 2025, when given a whirlwind tour of the fourth floor. The response to RFP No. 14 included only the correspondence between Claimants and UAMS. There were no intra-organizational communications, such as inquiries by HIM to the medical providers by email or a secure clinical communication and collaboration platform, such as PerfectServe.
BRIEF IN SUPPORT
III. Boilerplate Objections, purposefully false answers and non-responsive material are improper.
The party submitting the interrogatories may move for an order under Rule 37(a) with respect to any objection to or other failure to answer an interrogatory. Rule 33 – Interrogatories to Parties, Ark. R. Civ. P. 33(b)(5)
All grounds for an objection to an interrogatory shall be stated with specificity. Ark. Rule. Civ. P. 33(b)(4). General or boilerplate objections are improper. The objecting party must show specifically how each interrogatory is burdensome, irrelevant, or otherwise objectionable.
If a deponent fails to answer a question propounded or submitted under Rule 33, or if a party, in response to a request for inspection submitted under Rule 34, fails to allow for inspection, the discovering party may move for an order compelling an answer, or a designation, or an order compelling inspection in accordance with the request. Rule 37 – Failure to Make Discovery; Sanctions, Ark. R. Civ. P. 37(a)(2).
Sanctions are appropriate when there are no good reasons for a failure to admit. Fed. R. Civ. P. 37 Notes.
Blanket objections made by UAMS are entirely improper. Blanket objections do not comply with either the spirit or the letter of the Arkansas Rules of Civil Procedure. Rules 33 and 34 of the Arkansas Rules of Civil Procedure state that each request should be answered separately unless the objecting party objects and states the reason for the objection, and shall answer to the extent the interrogatory is not objectionable. Ark. R. Civ. P. 33(b)(1),34(b)(2). There is nothing in the Rules that would suggest general objections are appropriate. UAMS should be compelled to remove all general objections and answer each interrogatory and request for production of document as the Claimants did.
IV. The UAMS statement that Claimants have the burden of proving their claims through expert testimony is false.
Hammett is claiming non-medical causes of injury. Her claims are not subject to the Medical Malpractice Act, and therefore, UAMS must respond to joint requests made by both claimants.
Taking Lynn’s claims alone, expert testimony is still not required to support the Claimant’s assertions. “Expert testimony is only required when the asserted negligence does not lie within the jury’s comprehension; when the applicable standard of care is not a matter of common knowledge; and when the jury must have the assistance of expert witnesses to decide the issue of negligence.” Prater v. St. Paul Ins. Co., 293 Ark. 547, 739 S.W.2d 676 (1987).
“So too, a surgeon who performs an operation upon a patient who has refused to submit to it is not relieved from liability by the fact that he honestly and, indeed, justifiably believes that the operation is necessary to save the patient’s life. Indeed, the fact that medical testimony shows that the patient would have died had the operation not been performed and that the operation has effected a complete cure is not enough to relieve the physician from liability. See § 892A, Illustration 2.” Restatement (Second) of Torts § 13 (1965)
Lack of any consent to treatment is different from lack of informed consent referred to in section 16-114-209. There is an exception to the general requirement of expert testimony in medical malpractice cases when the asserted negligence lies within a jury’s comprehension as a matter of common knowledge, such as when a surgeon fails to sterilize his instruments or remove a sponge from an incision before closing it. See Rogers v. Sargent, 2010 Ark. App. 640, at 5 (citing Spears v. McKinnon, 168 Ark. 357, 270 S.W. 524 (1925)); Haase v. Starnes, 323 Ark. 263, 269, 915 S.W.2d 675, 678 (1996) (citing Lanier v. Trammell, 207 Ark. 372, 180 S.W.2d 818 (1944)). In Pry v. Jones, expert testimony was held unnecessary where a physician severed a ureter that he had failed to identify and locate while removing an ovary. 253 Ark. 534, 539–40, 487 S.W.2d 606, 608–09 (1973). The Arkansas Civil Justice Reform Act of 2003 retains this exception to the requirement of expert testimony. Ark. Code Ann. § 16-114-206(a). comment, AMI 1501.
Expert testimony must be supplied by the claimant only when trying to prove the medical provider did not use the proper level of medical care. Lanier v. Trammell, 207 Ark. 372, 379.
Where the plaintiff claimed that the patient either did not consent to the procedure or was unable to give consent because of mental impairment, the plaintiff was not required to obtain expert medical testimony. West’s A.C.A. §§ 20–9–601 to 20–9–603. Cited in Millsap v. Williams, 2014 Ark. 469, 449 S.W.3d 291 (2014)
With respect to the failure to obtain consent, the patient has the burden of proving each of three essential propositions: First, that the Plaintiff sustained damages; second, that the medical care was provided without consent; third, that such failure was a proximate cause of damages to the Plaintiff. Id. There is no burden on the patient to prove the treatment was unnecessary.
Black’s Law dictionary defines “common knowledge” as a fact that is so widely known that a court may accept it as true without proof.” COMMON KNOWLEDGE, Black’s Law Dictionary (12th ed. 2024)
The Commission knows that a person who falls from three-and-a-half stories would not say it hurt “a little”, have vitals all within healthy range and when offered treatment, say “how much does it cost?” No medical expert would be required to determine that adopting an unattributed, false statement that defied common knowledge was negligent.
Lynn does not need to prove his decision to refuse treatment from UAMS was correct. Though it was.
Regardless, when the defense of emergent need is asserted, the burden of proof falls on the medical provider who acted without consent.
Presumed consent is only available as a defense if justified under prevailing social norms and if the defendant had no reason to believe that the plaintiff would object to the contact if given the chance. Proser, Torts, 15th edition, page 49. Also see Chapter 3, section 1. It is absurd to suggest that leaving Lynn naked with his genitals fully exposed to UAMS employees of various sexual orientations and genders was acceptable. It is chilling that Nurse Shannon Cobb alluded to Lynn being ungrateful for being fed 1,000 calories per day of pudding and sugar water during his imprisonment. Smashing a TBI patient’s head into walls and bedrails in order to strap him down is well outside of the prevailing social norms.
V. The medical record does not “speak for itself”.
UAMS’s reliance on Rule 33(d) to refer Plaintiffs to a 1,300-page medical record is procedurally deficient. The rule requires that the responding party specify the records in sufficient detail to permit the requesting party to locate the answer “as readily” as the responding party. UAMS failed to identify page numbers, timestamps, or custodial sources, placing an unequal burden on Plaintiffs.
Neither is UAMS allowed to act as if its original answers do not exist. UAMS’s “substituted” responses materially alter prior answers and introduce new factual assertions and legal defenses. These changes were made without leave of court and without explanation, violating procedural norms and undermining the integrity of the discovery process. Black’s defines “amendment by substituting (1821)” as a “special type of amendment by striking out and inserting that replaces an entire main motion or a paragraph or other readily divisible part within a main motion; an amendment of greater scope than a perfecting amendment. Cf. perfecting amendment.” AMENDMENT, Black’s Law Dictionary (12th ed. 2024). “Amendment” is a “formal and usu. minor revision or addition proposed or made to a statute, constitution, pleading, order, or other instrument; specif., a change made by addition, deletion, or correction; esp., an alteration in wording.” Id. “amendment as of course (1925) An amendment, usu. to pleadings, that a party has a statutory right to apply for without the court’s permission. See Fed. R. Civ. P. 15(a).” Id.
There is no statutory right to amend or substitute a discovery response. There is only permission, and, in fact, a requirement to “supplement”. Ark. R. Civ. P. 26(e). A search on Westlaw Precision+ of Arkansas Authorities with the search terms “amend! /3 substitut! /p response! /p discov!” returns zero mentions of amended and substituted discovery responses. UAMS is hallucinating procedures. (It is noteworthy that Co-Pilot AI also mistook the ability to “amend” discovery responses, by citing Ark. R. Civ. P. 15. Only pleadings are addressed in that section. Discovery responses are not one of the enumerated pleadings. See, Ark. R. Civ. P. 7(a).)
VI. Prayer for Relief
Claimants request that the Commission compel UAMS to remove all objections from its responses to discovery, answer the interrogatories with specificity and thoroughness, provide access to all the documents requested, and do it quickly. UAMS has known about the litigation since January 2024. It should have its documentation collected by now.
Further, the motion filed by UAMS to limit discovery, both in quantity and a cut-off, should be denied. UAMS should pay the costs of 10 depositions of witnesses chosen by Claimants, and any other relief the Commission finds appropriate.
Respectfully submitted,
UAMS Lawyer Admits Some Lies; Creates Others
Mrs. Sherri Robinson, the $160,000 per year public attorney representing UAMS, filed what she called Amended and Substituted Answers to the Requests for Admissions.
I can’t make this up. So, with no more ado:
REQUESTS FOR ADMISSIONS
REQUEST NUMBER 1: Admit that Sean Lynn gave no informed consent to be treated at UAMS.
[OLD] ANSWER: Denied. Consent is not required in Emergency Situations. Moreover, the person who was with Lynn in the emergency room gave consent for his admission and treatment at UAMS.
AMENDED AND SUBSTITUTED ANSWER: UAMS admits that Lynn’s written consent was not received upon his admission to UAMS; however, UAMS denies that it was required. Arkansas Code Annotated § 20-9-603 provides that “when an emergency exists and there is no one immediately available who is authorized, empowered to, or capable of consent,” then “consent is excused or implied at law” for a licensed physician to provide medical treatment. Lynn arrived at UAMS by ambulance, and EMS personnel notified medical providers that he had fallen from a ladder at a height of 30-35 feet. EMS advised UAMS that Lynn had experienced a loss of consciousness, and UAMS providers observed that Lynn was continuing to have confusion. As a result of the initial assessment, Lynn was admitted to the Emergency Department Trauma Service. No one was with Lynn in the emergency room, and he was not capable of giving consent at that time. Based on the information that UAMS had at that moment and the nature of Lynn injuries, an emergency under Ark. Code Ann. § 20-9-603 existed which excused the requirement for UAMS to obtain consent to treat him.
REQUEST NUMBER 15: Admit that UAMS staff administered sedatives to Sean Lynn against his will.
[OLD] ANSWER: Denied.
AMENDED AND SUBSTITUTED ANSWER: UAMS denies that it administered sedatives to Lynn against his will. UAMS admits that Lynn was given medications for the purpose of treating the symptoms he was experiencing as the result of his injuries, significantly, a traumatic brain injury. While some of those medications may have had a sedating effect, the treatment goal was to ease the symptoms Lynn was experiencing and to improve his overall condition.
REQUEST NUMBER 16: Admit that UAMS staff administered antipsychotic medications to Sean Lynn against his will.
[OLD] ANSWER: Denied.
AMENDED AND SUBSTITUTED ANSWER: UAMS denies that it administered antipsychotic medications to Lynn against his will. UAMS admits that Lynn was given medications for the purpose of treating the symptoms he was experiencing as the result of his injuries, significantly, a traumatic brain injury. While some of those medications may have been classified pharmacologically as antipsychotics, the treatment goal was to ease the symptoms Lynn was experiencing and to improve his overall condition.
REQUEST FOR ADMISSION NO.20: Admit that UAMS used Chemical Restraints on Sean Lynn.
[OLD] ANSWER: Denied.
AMDENDED AND SUBSTITUTED ANSWER: UAMS denies that it used a chemical restraint on Lynn. UAMS admits that Lynn was given medications for the purpose of treating the symptoms he was experiencing as the result of his injuries, significantly, a traumatic brain injury. While some of those medications, in other settings and at certain doses, may be used as a chemical restraint, the treatment goal in using the medications administered to Lynn was to ease the symptoms he was experiencing and to improve his overall condition.
Here, I’ll throw out a couple of snippets from cases from my 1L studies:
With respect to the failure to obtain consent, a patient has the burden of proving each of three essential propositions: First, that the Plaintiff sustained damages; second, that the medical care was provided without consent; third, that such failure was a proximate cause of damages to the Plaintiff. Millsap v. Williams, 2014 Ark. 469, 12, 449 S.W.3d 291, 298 (2014). “No” means “No”.
Flores v. Santiago, 986 N.E.2d 1216 (Ill. App. Ct. 2013) (patient of defendant eye doctor sufficiently alleged an inability to consent due to defendant repeatedly plying her with illegal drugs in order to facilitate sexual contact).
Here are the docs for download:
Watch UAMS General Counsel Try to Wiggle Out of This One
From UAMS Answer to the Third Amended Claim for medical injury and fraud: “Affirmatively pleading, EMS notified UAMS personnel that Lynn fell from a height of 30 feet, and UAMS had no evidence to the contrary.”
Not to quibble, but UAMS recorded it as a fall greater than 30 feet, 34 feet, and 35 feet. It’s their fantasy, so, what if the number changes ever so slightly?
The big whopper is that UAMS had no evidence to the contrary. Here is their very own initial assessment.
A 33-year-old male, my son, said his injuries hurt a little bit, was calm, told UAMS he lived at home, had clear speech, no limitations on mobility, no behavioral issues, no confusion, “Delirium NOT suggested”, and no barriers to learning.
I’m not a brain surgeon, but this assessment is an indication to me that he did not fall from the roof of a three-story house.
After a CT scan, and being told he did not require surgery, he asked to leave.
After two weeks of torture and escape attempts, UAMS allowed him to leave. He had hyponatremia (low sodium). He could not hear out of one ear and had 50% loss of hearing in the other. He was traumatized worse than ever before in his excruciatingly traumatic life. He had lost 17 pounds. And he had severe aphasia (the inability to speak).
Oh, UAMS sent him a bill for over $46,000.
Here is a video of day 7. After I told a resident (trainee doctor) that I was looking for an attorney to get my son out, they bound and drugged him. I accidentally recorded his pleas to be freed when my phone was in my pocket. No psychological evaluation was conducted before day 10. Compare how he seems here to the initial presentation.
UAMS Doubts a Man Who Falls 35 Feet Will Hurt More Than “A Little Bit”
UAMS held my son, Sean Lynn, in a $4,700 per day ICU unit based solely on the fact that an EMT (who was not a witness to the accident) wrote in a tiny space that the accident was a fall from about 35 feet from a ladder. Hint: The ladder was about 35 feet.
Now, UAMS general counsel senior associate Sherri Robinson concurred with the doctors. UAMS refused to answer interrogatories because they determined that they should believe the EMT over the man who fell. Well, they didn’t actually give a reason why; they said only that we must have an expert witness – we found the statute UAMS is probably basing its statement upon. A.C.A. § 16-114-206. It begins:
In any action for medical injury, when the asserted negligence does not lie within the jury’s comprehension as a matter of common knowledge, the plaintiff shall have the burden of proving:
(1) By means of expert testimony provided only by a medical care provider…
Here are some of the interrogatories, responses, and my meet and confer letters sent in the hopes of saving public resources instead of going through motion practice to compel removal of UAMS’s objections.
Judges Who Do Favors for Friends
OMG! How do we get a prosecutor to investigate Judge Susan Weaver in Arkansas?
She dismissed me with prejudice as a defendant in a “trespass/eviction” action, then ordered the County Recorder to void a document I filed earlier, even though the document was a cloud on title to the property I was not trespassing on or occupying in violation of a true owner’s rights.
If that is not an improper seizure, what is?
Judge Susan Weaver Must Have Skipped Law School 101
Judge Susan Weaver was once quoted as saying she loved “every stinking minute” of law school.
But what was she doing those three years? It does not appear that she read a book.
Here I am, going into the second week of school… the first week of regular classes… and reading material that makes Judge Weaver’s violations of my rights clear.
For instance, optional reading for Real Property I includes this explanation of trespass:
“Trespass to real property involves intentional wrongful entrance onto or physical disturbance of a plaintiff’s land. The intent requirement, however, like the intent requirement for conversion, is a general intent requirement, and not a specific intent.” – Intro to Property Law, Foster.
Here are two examples given by Professor Foster to illustrate specific intent:
“Example: While walking in a wooded area behind his home, A wandered onto B’s property.
A did not intend to commit trespass, but A did intend to put his feet down in such a way that
he is now standing where he is. A has general but not specific intent, and A has committed
trespass.”
“Example: L and M kidnapped N and placed him in the trunk of their car. They tossed him out
onto O’s property and drove away. N not only did not intend to trespass, but he had no intent
to be in the specific place he is in when thrown from the vehicle. N has neither general nor
specific intent. N has not committed trespass. Have L and M? Answer: Yes.”
In a case over which Judge Weaver presided, I was a co-defendant for a cause of action for what the Plaintiff called “ejectment/trespass” on real estate brought by my former boyfriend, Mike Pietrczak. The other defendant was my living trust, for which I was sole non-contingent beneficiary, sole settlor and sole trustee.
Judge Weaver would not allow me to represent the trust, because I am not a licensed attorney, even though there were no other individuals involved in the trust.
I represented myself zealously and was dismissed with prejudice after a year. (The substantially identical action was filed previously and dismissed against both the trust and me without prejudice. I could retain an attorney at that time and there was a different judge.)
So, it was decided, by Judge Weaver, that I did not trespass on the land and there was no need to eject me. Pietrczak was clear in his complaint and in the evidence presented that he did not want me on the land. I was on the land during much of the time he complained about, or I gave permission to others to be on the land. I intended to be on the land. No one tied me to the bed and forced me to stay there. I intended to have tenants on the land. But I was not trespassing and there was no need for ejectment.
How then could my trust be trespassing on the same land? How does one even eject a trust? Ejectment entails removal. The trust is a fictitious person, to the extent a trust is a person at all. It is really a vessel to hold assets. Even if the trust is considered a separate “person” from me, so too was the tenant I rented the property to for a year and so too were my other invitees.
Inviting the use of the land by the tenants and the trust was a physical disturbance of the land. But Judge Susan Weaver opined that I was not liable for any trespass on the property.
Then Judge Weaver entered default judgment and damages against the trust. She inexplicably said any further inhabitation of the land by me would be considered trespass. She ordered the county recorder to void the record of title to the land passing to the trust. And she allowed Pietrczak to transfer title to the “person” of his choosing.
The Court of Appeals claimed it lacked jurisdiction to upset the lower court orders based on my unopposed appeal, and the Arkansas Supreme Court affirmed the COA decision. I petitioned the United States Supreme Court for Writ of Certiorari. It is extraordinarily rare for such a petition from a pro se litigant to be granted. But I maintain hope.
Arkansas Makes False Imprisonment by Hospital “Medical Malpractice”
For those who have been following along on my son’s and my case against UAMS, we made a third amendment to the claim.
It seems that the legislature made false imprisonment by a medical provider a “medical injury” under the Medical Malpractice Act. Our elected officials decided also that medical providers, in the context of providing medical services, consensual or not, cannot be sued civilly for any other tort.
It is not a big deal to our case. Really just semantics. The clause in the Med Mal Act that requires an expert witness does not apply, because the claim is easily comprehended based on common sense without specialized medical knowledge.
Here is a summary of the Third Amended Complaint generated by AI using Westlaw Co-Counsel.
- The claimants, Sean Lynn and Laura Hammett, allege that the University of Arkansas for Medical Sciences (UAMS) unlawfully confined Sean Lynn for two weeks, during which he was subjected to repeated battery and denied autonomy over his body.
- They claim that UAMS failed to treat Laura Hammett as a surrogate, causing her physical, economic, and severe emotional harm.
- Sean Lynn alleges that he suffered various harms, including emotional trauma, iatrogenic harm, and physical injuries such as hearing loss and pain from non-consensual invasive procedures.
- Laura Hammett claims emotional trauma and loss of ability to manage her health conditions, as well as a loss of future income due to the situation.
- The claimants assert that UAMS acted under the color of law and that its workforce’s actions can be attributed to UAMS, which is liable under the doctrine of respondeat superior.
- They allege that UAMS engaged in spoliation of evidence and obstruction of justice.
- The claimants argue that UAMS did not obtain consent for medical treatments and that Lynn was held against his will without due process.
- They claim that UAMS misled Hammett about Lynn’s condition and legal rights, causing her to encourage Lynn to remain in the hospital.
- The claimants allege that UAMS violated Lynn’s rights under the UAMS Patient Rights and Responsibilities and Arkansas law, and that its actions were outrageous and malicious.
- They assert that UAMS committed fraud against Hammett by deceiving her about Lynn’s condition and the treatments administered.
- The claimants allege a breach of fiduciary duty by UAMS for not allowing Hammett to act as Lynn’s surrogate and for failing to inform her of his rights.
- They seek monetary compensation for damages, including attorney fees and costs of litigation, and specific compensatory damages for Hammett.
Second Amended Claim Against UAMS for False Imprisonment and Battery & Medical Record
FACTS
10. Lynn was taken to UAMS and admitted to the emergency room on January 13, 2024 at or about 5:13 PM. He had full capacity. He submitted to testing to determine if immediate surgery was necessary. The doctors decided there was not an emergent need for surgery. Lynn asked to leave. Instead of allowing Lynn to use his phone to call Hammett or the woman he lived with, UAMS doctors and nurses poisoned Lynn with Fentanyl. They continued to drug him for two weeks, claiming that the effects of the drugs were “incapacity”, and telling Hammett he might be this “out of it” the rest of his life because of the brain injury from the fall.
11. No one witnessed the fall that caused Lynn’s need for emergency care. Despite evidence to the contrary, the UAMS Workforce adopted the narrative that Sean Lynn fell from 30 to 35 feet.
12. Lynn remembered the accident in detail on or about February 8, 2024. He was on a ladder with his head at about 16 feet and his feet about 10 feet above ground. The ladder began to fall away from the house it leaned against. There was a steep slope in the direction of the fall, so Lynn decided to jump. He did not calculate for inertia and flipped backwards, landing on his head. He remembers his thoughts as he fell, primarily, concern for his daughter if he died.
13. This was unquestionably a severe injury, though survival rates from 10 feet are significantly better than from 30 feet. Miraculously, Sean Lynn was relatively unscathed. There was no damage except to his head.
14. According to a scanned copy of the handwritten triage notes first produced to Claimants on May 9, 2025, 15 months after they requested a copy of the entire medical record:
15. Upon entry to the ED, Lynn had blood pressure 120/70, heart rate 60, Glasgow Coma Scale 14 (13 – 15 is a “mild” TBI). GCS evaluates three key responses:
- Eye Opening (E): Spontaneous, to voice, to pain, or none
- Verbal Response (V): Oriented, confused, inappropriate words, incomprehensible sounds, or none
- Motor Response (M): Obeys commands, localizes pain, withdraws, abnormal flexion, extension, or none
16. The only one of 37 Primary Scene Trauma Level 1, 2 and 3 Activation criteria Lynn met was fall greater than 20 feet, which was an error based on an unattributed statement written by an EMT who was not a witness to the fall. There are no known witnesses to the fall except Lynn himself;
17. Neither “Emergency Physician Discretion” nor “MD/Charge RN discretion” were checked off;
18. Lynn was noted on the Behavior & Suicide Screen as saying that over the past 2 weeks he had not felt down, depressed, hopeless, nor had thoughts of killing himself, and never had thoughts of killing himself;
19. There was no indication that patient Lynn “refused” to answer, was “unable to complete” or “was not assessed due to severity of illness”;
20. It was noted that Lynn’s sensory, motor, and circulatory systems were intact.
21. iSTAT blood test results at 17:22 showed
sodium: 141 mmol/L [Ref Range: 135 – 145];
potassium: 3.8 mmol/L [Ref Range: 3.5 – 5.0];
chloride: 106 mmol/L [Ref Range: 98 – 109];
CO2: 23 mmol/L [Ref Range: 22 – 31];
BUN: 13 mg/dL [Ref Range: 6 – 20];
Glucose: 155 mg/dL [Ref Range: 70-105];
Hct: 47 % [Ref Range: 40 – 52];
Hb: 16.0 g/dL [Ref Range: 14.0 – 18.0];
pH: 7.34 [Ref Range: 7.31 – 7.41];
PCO2: 41.2 mmHg [Ref Range: 41.0 – 51.0];
HCO3: 22.2 mmol/L [Ref Range: 23.0 – 28.0];
BE: -4 mmol/L [Ref Range: -2 – 3]
22. These results are unremarkable, except for mild metabolic acidosis, which might indicate trauma or dehydration, and slightly elevated glucose, also a normal sign of trauma. There are over 363,000 people in Arkansas with chronic elevated glucose plus those who have trauma induced elevated glucose. There are only about 1,197 ICU beds in Arkansas. It is a matter that can be concluded by any person of reasonable intelligence that a glucose level of 155 mg/dL does not demand intensive care.
23. At 17:24-17:25, CT scans were performed on Lynn’s cervical spine, maxillofacial area, head & neck, abdomen and pelvis.
24. No need for surgical intervention was documented.
25. Olivia Speed, MD (Resident) commented, “No need to keep admitted from facial fracture standpoint.” Some of the fractures were plausibly pre-existing.
26. Lynn had a left frontoparietal temporal subdural hematoma, left frontal hemorrhagic contusion, left tentorial subdural hematoma, and scattered subarachnoid hemorrhages. Despite the radiographic presence of intracranial bleeding across multiple compartments, his condition remained neurologically stable, and no surgical or interventional procedures were deemed necessary or administered. The absence of emergent curative treatment further underscores the lack of medical justification for prolonged involuntary restraint and chemical sedation.
27. Yet, at 7:33, Sarah E. Martin, MD (Resident) placed an order for levETIRAcetam (Keppra) 500 mg/5 mL (injection). No consent to treat was obtained from Lynn.
28. Levetiracetam is a prophylactic.
29. UAMS documented no Electroencephalogram (EEG) in the ED or at any time during the two-week forced hospitalization.
30. At 17:48 Nolan R. Bruce, MD was assigned as admitting physician. UAMS is a teaching hospital where the residents and trainees are required to be supervised, and the standard consent form requires the signatory to acknowledge and agree to be treated by trainees. Lynn did not consent and was bothered that the people who were performing intrusive procedures on him looked inexperienced.
31. At 17:48, Natalie J. Applebaum, MD (Resident) placed an order for fentaNYL (Sublimaze) (injection) 50 mcg. No consent to treat was obtained from Lynn. No consent to allow students, trainees or residents to treat Lynn was obtained.
32. At 17:51, the fentanyl was started by Nathan Ernst, RN (possibly a Trainee).
33. At 17:52, the fentanyl was “stopped”.
34. In answer to Interrogatory No. 11 propounded by claimants, UAMS wrote, after objections: “on page 84 of the UAMS medical record, it indicates that Dr. Applebaum, an Emergency Department physician, ordered a 50 mcg dose of fentanyl via injection into the IV line for Lynn while he was in the Emergency Department, and Emergency Department nurse Nathan Ernst administered the fentanyl per the order.”
35. UAMS did not explain why an entry on page 69 of the medical record generated 4/29/25 showed “0 mcg Intravenous Stopped 1/13/24 1752.” There was twice the .1 mg = 100 mcg ordered, but no coding on the record to indicate discarding the remaining 50 mcg (JW). This along with contradictory records on other medication administration make it more probable than not that there was diversion of some expensive medications and controlled substances diverted for the personal use or sale by the staff. UAMS has shown no meaningful investigation into our claim.
36. A subdural hematoma might put pressure on the language center of Lynn’s brain, which might cause three types of aphasia. The effect of Fentanyl can mimic aphasia or exacerbate it. It can also delay or blunt recovery. Regardless, aphasia is an ADA disability that does not affect reasoning.
37. There was no objective evidence that Lynn’s ability to reason was affected. Lynn was always an iconoclast. He was and is brilliant. He just had trouble finding the right words after the administration of Fentanyl.
38. At admission there was specifically “no evidence of ossicular disruption or otic capsule involvement” in Lynn’s right ear. There was no mention of injury to the left ear. By the time Hammett learned that her son was in the hospital, he had been tackled and restrained and struggled with his superhuman strength to escape, and his hearing, which was already a little impaired before the fall, seemed to approach deafness. Post escape medical exams showed ossicular disruption and virtual deafness in the left ear. It is plausible that the disruption occurred while struggling to escape.
39. At no time during the two-week imprisonment did UAMS file a petition for an order of detention pursuant to AR Code § 20-47-211 (2023). UAMS failed to serve Lynn or his Accommodator with a copy of his statement of rights, including that he has the right to effective assistance of counsel, including the right to a court-appointed attorney, despite Hammett demanding a copy of “the paperwork” several times.
40. Following his admission to UAMS, claimants were not informed of Lynn’s rights as required, including not being advised of his right to be released upon the expiration of a legal 72-hour-hold and UAMS Patient Rights and Responsibilities (Exhibit A).
41. An order for detention could not be justified. At no time did Lynn express an intent to hurt himself or anybody else. There are a small number of boiler plate notes that Lynn made a comment to hurt himself or others well into his imprisonment. There was no quotation. There was no report made to security nor to UAMS police department. Neither Hammett nor Lynn remember any such threat. In fact, Lynn specifically remembered not hurting a healthcare worker because of signs he read, and Hammett specifically remembers and documented Lynn being oddly polite to his captors, saying “sir” and holding out his hand to shake theirs.
42. Lynn did not want to use benzodiazepines, sedatives, opioids, be catheterized, restrained physically, be fed through a tube or defecate in a bed pan. He used none of these substances or techniques after leaving AMA and survived a year and eight months so far. If God decided it was time for Lynn to go to Heaven, he wanted to die at home, with a chance to “num num” his daughter, giving her big funny kisses like Cookie Monster. But he would do nothing to hasten his death, and he would do everything that in his informed opinion would lengthen his life without destroying the quality of that life.
43. Positive treatments not allowed by UAMS included eating enough and only healthful food, getting any fresh air, sunshine, adequate water, enough gentle exercise, uninterrupted sleep, and the constant company of his loved ones.
44. Lynn was able to escape four-point restraints by somehow breaking his right foot free, then bringing his right foot to his left hand and using his toes to loosen the restraints. This took flexibility rarely found in 34-year-old men, dexterity and, most importantly, ingenuity.
45. Soon after leaving UAMS, Hammett asked Lynn why he did not use force against the staff to escape. He said he read a sign that says it is a felony to assault a healthcare worker. During a whirlwind tour of the 4th floor on July 1, 2025, there were none of the signs posted on the floor. Either UAMS took them down subsequently, or Lynn was cognizant enough to remember reading the sign in his past.
46. His speech improved dramatically the moment he got home. He said that he knew he was in a hospital, but thought it was “in the middle of nowhere” and initially thought that the doctors were like those “Nazis that did experiments in World War Two.” (Lynn is Catholic, but half his ancestors are Jews who escaped persecution in Eastern Europe. UAMS kept Lynn isolated from family for the first 14 hours, and were “locking” him to the cot, which was extra confusing with aphasia and hearing loss.)
47. After leaving the hospital AMA and getting a mile or so away, Lynn knew exactly where he was and pointed out landmarks in relation to his house. (i.e. There is the place we like (for Chinese), and my house is just a few blocks away.)
48. Lynn was held against his will from January 13-January 27, 2024 despite repeated requests to go home, and numerous attempts to escape, several of which are noted in his medical record using the base word “elope” instead of “escape”.
49. Lynn was starved. Typical meals served by UAMS included the following:
- 4 ounces of vanilla ice cream (~100 calories)
- 3.5-ounce Kraft chocolate pudding (~110 calories)
- 4-ounce serving of Ardmore Farms cranberry juice cocktail (~60 calories)
- One cup of tomato soup (~90 calories)
- 8-ounce carton of whole milk (~150 calories)
- 8-ounce glass of sweetened tea (~30 calories if sweetened)
50. This meal, totaling approximately 540 calories, was representative of the hospital’s nutritional offerings—high in sugar and processed ingredients, and lacking in protein, fiber, fresh vegetables, or healthy fats. These foods are inconsistent with dietary standards for any adult, let alone a neurologically compromised patient with increased metabolic needs. Standard clinical guidelines recommend between 2,000 and 2,800 calories per day for adult males, depending on medical condition and activity level. Mr. Lynn was consistently underfed.
51. UAMS, in response to interrogatory No. 6, claimed it does not routinely document when food or drinks were presented, how Lynn was supposed to eat or drink (whether his hands were restrained), and an ingredient list for the food and drinks he was given. The full response to our inquiry about his diet during the hospitalization was that “Lynn was given only a liquid diet and/or a feeding tube until just a few hours before he left the hospital against medical advice.”
52. On January 14, 2024, UAMS told Hammett that Lynn could only eat ice chips until the SLP practitioner evaluated his ability to swallow.
53. On January 15, 2024, Hammett observed Emily Gray, CCC-SLP allow Lynn to brush his teeth. When given a small cup, approximately 2 oz. of water, Lynn swished it around to rinse, then he looked around like a criminal who was going to snatch something from a shop, and he swallowed the water. He was dehydrated and begging for water before Ms. Gray came into the room. Ms. Gray wrote that “Pt was unable to swish and spit water to remove toothpaste from oral cavity; pt swallowed water instead.”
54. On January 14, 2024, UAMS also told Hammett that Lynn should not eat solid food for approximately six weeks due to a fracture in his jaw. This limitation was not noted by the doctor who diagnosed Lynn’s facial fractures, Dr. Olivia Speed (Resident) or her supervising physician. Regardless, UAMS fed Lynn pudding and ice cream. Hammett was willing to feed Lynn a soft food diet at home, but she would have ground proteins, fresh whole fruits and vegetables, and used soft cheeses. Lynn did not need to eliminate solids, introduced them immediately at home and had no problem with his jaw.
55. UAMS refused to keep foods for Lynn and Hammett in the refrigerator. UAMS left the healthful foods Hammett brought for Lynn unused.
56. Hammett was on a strict elimination diet in a successful attempt to manage Hashimoto’s Disease and gastrointestinal problems. Hammett was also living on about a $650 per month pension. She could not afford the few foods offered by the UAMS cafeteria that had none of her eliminated foods, such as black pepper, tomatoes and onions.
57. UAMS forbid Lynn to have the company of CL, his beloved daughter, based on her age, 8 years old. UAMS told Hammett while Lynn was in ICU that CL could not visit. They did not tell her the restriction does not apply when he moved to F4. Jaliyah Rucker, PCT noted how well Lynn responded when he got to talk to CL on the phone.
58. UAMS failed to bring in a priest, despite their feigned concern that Lynn was on the verge of death.
59. UAMS ceased administration of Keppra after six days. If the hospital was truly concerned about the seizure risk, they should have continued Keppra. Their failure to do so indicates that the seizure risk was exaggerated to justify keeping Lynn in the hospital. (Lynn did not consent to the use of Keppra. The claim is not that it should have been continued, but that it was not necessary or emergent.)
60. Incurring billable charges is a more plausible motivation for the false imprisonment.
61. Hammett was physically free to leave but was kept at the hospital by the coercive measure of keeping her son there and threatening to have the police come, with the implication that she would be arrested if she helped Lynn leave. Hammett explained to UAMS Workforce that both she and Lynn had a history of traumatic experiences with police who refused to protect them from Lynn’s abusive father. Since there were people in uniform and surveillance cameras all around, claimants’ concern for inaction and worse, improper action against claimants by the police was reasonable. In fact, when Lynn finally agreed to get the police involved, they flat out refused to investigate.
62. UAMS condoned the denial of Lynn’s rights, denying each and every “material” allegation in the answer to the claim.
63. Lynn, on and after January 13, 2024, repeatedly told the UAMS Workforce that he did not consent to be there and wanted to go home but he was not allowed to do so. UAMS Workforce further participated in a scheme to cover up their violations of Claimants’ rights. Respondent in the furtherance of the conspiracy by coercion, trickery and deceit convinced Hammett that Lynn’s behavior that was similar to when he abused substances in his teens, was caused by the traumatic brain injury instead of by the drugs UAMS administered. On several occasions UAMS Workforce said, verbatim, “we never give opioids to TBIs” and “we never give Benzos to TBIs.” UAMS convinced Hammett it was illegal for her to help Lynn leave. UAMS insisted Lynn consented to treatment and Hammett could not make decisions as next of kin. In defeat and wanting to mitigate the damages done in escape attempts and pulling out the invasive apparatus, Hammett begged Lynn to stay and “cooperate” with his captors. This was a huge breach of trust between mother and son. On January 29th, when Lynn woke at home, he said to Hammett that he had a bad dream that she was being mean to him. We will prove at trial that UAMS Workforce’s conduct was especially cruel in light of the history Hammett shared with UAMS about Lynn and Hammett’s traumatic past and the trust issues it caused.
64. UAMS further showed malice by making an inaccurate record and refusing to amend it completely upon claimants’ request.
65. UAMS supposedly destroyed the surveillance videos that would show that the imprisonment was not consensual and that it was UAMS that was belligerent and at risk of harming others, not Hammett and Lynn as noted by UAMS in the inaccurate record.
66. UAMS was aware of the illegal action taken by UAMS Workforce against Lynn but failed to take any action to secure his discharge and return him to his home.
67. UAMS sent a bill to Lynn, upon his release, demanding $42,095.78 plus a separate bill demanding an additional $4,188.40 for a total of $46,284.18.
68. Hammett asked to speak with a “social worker” or “case manager” about getting Medicaid for Lynn on January 14, 2024 and January 16, 2024 and was told both times that someone would speak to her. But no one ever did. Hammett obtained and paid for other insurance for Lynn that would begin on February 1, 2024, told UAMS that, and UAMS Workforce noted it in the record.
69. Because UAMS tricked Hammett into thinking the effects of the drugs they forced on him were due to the TBI, Hammett intended to have Lynn live with her for an unspecified length of time, maybe forever. Hammett was able to help Lynn obtain Medicaid to cover the legal charges incurred before February 1, 2024. This was the ambulance and emergency room charges. UAMS convinced Medicaid to pay charges for the non-consensual imprisonment.
70. UAMS knew of the illegality of detaining Lynn on what they called a “72-hour hold” (even though it was a two-week hold) and a “psych hold” without first
filing a petition with the court for an order for inpatient detention and
treatment pursuant. Nevertheless, UAMS Workforce willfully, intentionally,
and in utter disregard of Claimants’ legal and human rights refused to allow Lynn to leave UAMS.
71. The actions UAMS took violated Lynn’s rights under the “UAMS Patient Rights and Responsibilities” and under AR Code § 20-47-207 et seq., (2023)., and his rights to be discharged upon request, to informed consent and to refuse medication and invasive procedures without force or coercion.
72. The actions and inactions of Respondent, their agents and employees were in
direct violation of Claimants’ rights to liberty and freedom from restraint, to be
released from detention, and to live or die in his own home. The actions of Respondent in incarcerating Lynn against his will at UAMS were knowingly taken, without legal authority and in direct violation of well settled standards of medical ethics. The action of Respondent, their agents and employees were intentionally taken and not taken in good faith.
73. Respondent further denied Lynn his right to counsel to challenge his detention. UAMS failed to provide an experienced aphasia accommodator. UAMS failed to provide someone with experience communicating with newly deaf patients. UAMS, who claimants were supposed to be able to trust, lied to Hammett about Lynn’s condition and legal rights, who then conveyed those lies to Lynn. (Lynn never believed the lies and asked Hammett why she was being “weird”.)
74. UAMS did not have a psychiatrist or therapist speak with Lynn until January 24, 2024.
75. UAMS did not discuss their treatment plans with Lynn. None of them were
presented to Lynn, discussed with him, or signed by him.
76. UAMS discussed some treatment plans with Hammett but refused to allow Hammett to make decisions for Lynn. UAMS Workforce repeated that Lynn consented. When Hammett pointed out that he did not consent, UAMS Workforce said he does not have capacity. When Hammett said she had capacity, UAMS Workforce said Lynn was a consenting adult.
77. Hammett tried to play a YouTube video by a doctor about TBIs to Lynn. A nurse demanded Hammett cease informing Lynn, as she claimed it would upset him.
78. Respondent’s actions and those of UAMS Workforce in illegally holding Lynn against his will not only denied him due process of law, but exposed him to a significant, foreseeable, and unreasonable risk of harm and actual harm and exposed Lynn and Hammett to traumatic emotional distress.
79. The ordeal was so traumatizing that when Hammett begged her younger son to voluntarily seek hospitalization in the best hospital in Nevada for mental health issues, he refused. Hammett, in writing, had to acknowledge that the experience at UAMS was horrifying, but not all hospitals are that bad and evil. Her efforts were of no avail. Her younger son died of drug toxicity while using methadone prescribed to a housemate, exactly one year after Sean Lynn was allowed to leave UAMS. It is not possible to apply a certain percentage of fault for Hammet’s son, Lynn’s brother on UAMS. But his refusal to seek help at a hospital shows how the public that UAMS is supposed to serve would view the conduct of the medical providers if informed.
80. In November 2024, Hammett’s husband was diagnosed with stage IV prostate cancer metastasized to his bones, lungs and lymph nodes. His PSA was 1,299 (one-thousand, two hundred and ninety-nine. That was not a typo.) Healthy range is under .5 (point five). His PCP referred him to UAMS for treatment. He refused to go to UAMS. His PCP changed the referral to Carti. Again, the citizens UAMS is supposed to serve would not enter UAMS knowing what they did to Lynn and Hammett.
81. Hammett was in an early consultation with her husband at Carti. She heard the doctor ask what his pain level was on a scale of one to ten and his reply. “15”. Hammett asked the doctor how long her husband might live without treatment. Without hesitation the doctor said he would be dead in six months. Even as foreboding as his situation was, Carti did not strap him to the chair and inject him with Fentanyl. He gave informed consent and proudly displays his Carti Certificate of Completion on the fireplace mantle.
82. Respondent’s actions and those of UAMS Workforce made it impossible for Hammett to care for and advocate for her son unless she was also confined in ICU. This caused Hammett to lose sleep. She is treated for insomnia and had to break her sleep protocol. UAMS caused Hammett difficulty in following the diet that helps her manage Hashimoto’s Disease. UAMS caused Hammett severe emotional distress from watching her son be tortured, having to wipe blood and feces off her 34-year-old son’s genitalia and anus, being forbidden to stay with her son at times, such as on January 21, 2024, when UAMS Workforce demanded Hammett wait in the waiting room. Hammett could not be in two places at once. She, her son and CL would all have benefitted greatly by having Sean stay in Hammett’s house while he needed 24/7 care.
83. Respondent UAMS has obtained payment from the United States by illegally
billing Medicaid for treatment during Lynn’s detention in ICU. UAMS has shown an intent to use the charges that were not covered by Medicaid to make fraudulent statements on grant applications and public relations literature, overstating the charity and good UAMS does for the community.
84. The actions of Respondent violate the criminal laws of the State of Arkansas
and the United States.
General Counsel for UAMS Exposed
Public servants are supposed to serve the public.
Instead, the attorneys for University of Arkansas’s teaching hospital condone the cover-up of the false imprisonment and battery of a man who fell off the ten-foot-high rung of a ladder. (The victim is my son.)
At best, the doctors and nurses at UAMS made a bone head mistake. My favorite saying these days, “they aren’t brain surgeons.”
Someone at MEMS, the EMTs who brought the injured man into the Emergency Department, wrote that the chief complaint was “fall from approximately 35 ft from ladder”. The EMT gave no attribution. There were no known witnesses. It would have been correct to write “fall from approximately 35 ft ladder”. He added an extra “from”.
The only criteria that suggested this injury deserved trauma activation was “fall > 20 ft.”
Ignoring the physical evidence they were staring at, UAMS decided to adopt the narrative of a 35-foot fall with the injured man having vitals better than most men his age on a good day. They started shooting him up with Fentanyl, Lorazepam, Diazepam, Haldol…. binding him to the $4,700 per day hospital bed.
Which brings us to the worst-case scenario. The doctors who are paid as much as $560,000 per year salary wanted to drum up business. They said my son would probably not qualify for Medicaid. Another illogical statement, since Medicaid is income based, and they were claiming the TBI patient would need months of intensive care followed by inpatient rehab. It was likely, according to them, that he wouldn’t be working any time soon.
Self-pays are charged about 2.5 times what UAMS has negotiated to pay Medicaid.
He looked like a lucrative mark.
Well, our claim to the Arkansas Claims Commission is heating up. Here are a couple documents I filed today. If you are an attorney licensed in Arkansas who would like to represent Mr. Lynn in a case against the insured individuals involved, shoot me an email. bohemian_books@yahoo.com.
If you want to dig deeper, here is a copy of the full medical report. It has a lot of inaccuracies. But you can check the pages I reference, to make the unbelievable believable.
Sunday Funday. What I wish I could tell the court.
ChatGPT and that woman wearing a white business suit and a halo who sits on my right shoulder will try to talk me into taming my sarcasm. I’m rooting for the lady in the red, tight-fitting gown who sits on my left shoulder. The questionable tone is in my motion for spoliation sanctions against UAMS for “writing over” videos of the doctors and nurses who allegedly falsely imprisoned, drugged, battered and raped my son, repeatedly over a two-week span. Then charged him $46,000 after letting him leave in far worse condition than when he was brought in.
Imagine a video of a man who allegedly needed intensive care running down the hallway carrying a full grocery bag of his belongings in each arm, breaking loose of grasping hands of the gang following him, both men and women, all dressed in scrubs, and he outran them to the elevator. A bunch of them, including the man they claim to want to save from having a deadly seizure, get into the closest elevator to H4. A skirmish ensues. The patient’s 60-year-old mother, who was sitting in the waiting area as ordered, sees the chase and moves toward the elevators. The patient yells, “I just want to give these things to my mom.” He is allowed to hand the bags off to his mother. Then he jumps across the aisle to the second elevator, kitty corner to the one closest to ICU. He moves to press a button with his left hand and someone shoves him, causing the left side of his head to hit the wall. This subdues him and the group of healthcare workers is able to bring him back to confinement. This imagery should bring to mind a man who does not consent to treatment and who is amazingly fit, despite this being the second week of his imprisonment, starvation and poisoning after falling on his head from the 10-foot rung of a ladder and being denied uninterrupted sleep or proper hydration. But UAMS destroyed the video. They claim now that they had no indication that there might be criminal or civil misconduct alleged. Nope, they say, this is a routine event. Shred away.
SPOILER ALERT: The patient did not die after we left UAMS against unsolicited advice. 18 months later and he is enroute home from an African Photo Safari. He hopes to find an attorney who will represent him against UAMS and a list of doctors and nurses including Dr. Mary Kimbrough, Dr. Jordan Greer, Dr. Joseph Deloach, Dr. Elizabeth Brown, Nurse Shannon Cobb and a host of others.
Send emails of interest to bohemian_books@yahoo.com. You can watch videos that we took against the intimidations of the alleged criminals on Youtube.
A Higher Law 