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Chief of Medical Physics and Radiation Safety Officer (See Exhibit D). ..... Plaintiff to cover up the violations at Malcolm Grove Medical Center (MGMC) at ...
Case 2:15-cv-00352-JHS Document 18 Filed 06/18/15 Page 1 of 13


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8115 Ferndale Street, Philadelphia, PA19111

Plaintiff Vs. Barack Obama, President of USA and Commander In Chief, the White House, 1600 Pennsylvania Ave; NW Washington, DC 20500 Et al; Defendants

January 2015 Case ID # 2:15-cv-00352-JHS

Dismiss Defendants Motion



And now, on this ______________ day of __________, 2015 upon consideration of Plaintiff, Dr. Gul Chughtai’s response and facts presented herewith, it is ordered that Defendants motion is dismiss with prejudice and permit the matter to proceed for trial.

By the Court

____________________________________ J.

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Plaintiff’s Reply to Dismiss Motion submitted by Defendants Here comes Dr. Gul M. Chughtai, Plaintiff requesting this honorable court to Dismiss the Motion submitted by the opposing Attorney of Defendants, Chairman AF Board of Correction of Military Record (AFBCMR); Chief, Material licensing branch, Div of fuel cycle and material, safety, NRC; Colonel Martin Valles; Alexander F. Daley, David-EW Hunter; Deborah Lee James, Lt Col John Burr; Richard C. Niemtzow; Barack Obama, President of USA; Kenneth Vanek and Ronald Walker.

JURISDICTION LIES IN THIS COURT: Plaintiff submits that jurisdiction lies in this Court based on the facts that he is a resident of the U.S. District Court for Eastern District of Pennsylvania and was such a resident when he was originally recruited in the Air Force and appointed directly as a Captain with the official title of Chief of Medical Physics and Radiation Safety Officer (See Exhibit D).

AVERMENTS OF WRONG DOING BY DEFENDANTS: The US Air Force has numerous offices and many officers and airmen serving at all relevant times in this district of Pennsylvania. The averments of wrongdoing by the defendant officers set forth in the amended complaint occurred in several districts, both on Air Force bases and in subsequent place of employment in Maryland, Washington, DC and Pennsylvania.

SEVERAL CORBORATING EXHIBITS DESCRIBING TORTUOU CONDUCTS: Plaintiff makes specific averments, supported by numerous corroborating exhibits, describing tortious conduct of the defendants while they were in the Air Force and had supervisory positions to cause the alleged harm to him (See paragraphs, 6, Exhibits N, Exhibit O and Exhibit P)

PRIOR ADMINISTRATIVE CLAIMES: Plaintiff filed prior administrative claims some of which resulted in decisions. Attached to the complaint is one decision of the Board for the Correction of Military Records, which reversed the Air Force decision setting aside one of the unfavorable Officer Evaluation Report (OER) from 5 May to 4 May 1987 at OEHL, Brooks AFB while working with Major Hunter and John Burr. The Board accepted Plaintiff’s claims at that time that the OER was due to retaliation for his report of serious safety and medical licensing violations (See EXHIBIT Q). This confirms his pursuit of claims to the appropriate administrative agency. However, the Board declined to reverse the other two OERs of 4 May 1986 and Nov 1987. Since his career in the Air Force was virtually ended as a result of the three OERs, all three would have to be set aside to reinstate him in his rank and recommend him for promotion for higher rank.

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USAF CITING WOODEN RULES TO COVER-UP CRIMEs COMMITTED BY DEFENDANTS: The government now asks the court to join in the cover up by citing wooden rules although the Plaintiff has spent years pursuing the truth and appealing to one office after another, one administrative agency after another to be heard. Plaintiff has exhausted all the avenues by

appealing to :  President of USA and Commander in Chief, Armed Forces  USAF authorities,  Congress  AF Board of Correction of Military Record (ADBCMR),  Inspector General of USAF,  Chief Justice of USA  Equal employment opportunity in AF,  Appealed to U.S. Office of Special Counsel on 8/6/2013 under regulation of 5 U.S.C. § 2302(b)(8) as I was the victim of whistle blowing retaliation. I contacted with reference to my Case # OSC: MA-13-39278/1/13,. No action was ever taken as this office does not deal with the Government employees, But all these authorities have denied my appeals after appeals. COMPARING USAF VIOLATIONS WITH VA MEDICAL CTR, PHILADELPHIA: This case can be compared to many similar cases that have come to light over the years. One memorable case occurred at the Veteran Hospital in Philadelphia where after denials for years it was disclosed that improper use of iridium seeds treatments for the mistreatment of prostate cancer patients who were given incorrect and misplaced doses of radioactive seeds had caused serious injuries to many patients (ATTACH # I)

FEDERAL LAW WERE VIOLATED BY USAF: Refer to the exhibits showing federal laws were violated as described in paragraphs # 6, 7( a,b) 8, 9, 10 and 11) attached to the main amended complaint- Here are the Exhibits which described Federal Laws were violated:

I. Exhibit E : Violation of Federal Law-1 BOTH DOCTORS WERE NOT PHYSICIANS: In accordance with NRC regulation 10CFR 35.3(b), Title 19, chapter 1, code of Federal Regulation- Energy Part 35, both doctors, Richard C. Niemtzo and Vinode Sachdeva working at MGMC, Andrews AFB were NOT Physicians as they did not meet the definition of Physicians as described in 10 CFR 35.3(b) as they never had any license from any State of USA and failed three times in passing Federal Licensing Examination to get license. Furthermore it is stated that: 1. Two Physicians were not qualified and have no license to impart nuclear radiation to cancer patients. It is violation of FEDERAL LAW.

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2. As per requirements and compliance with regulation, Richard C. Niemtzo: a. Niemtzow, never had Medical License from any State of United State while he was working as Radiation Oncologist at MGMC, Andrews AFB, MD. By definition as described in regulation 10 CFR 35.3(b), he was not a Physician. He never had any proper training and practical experience to treat patients with radiation and thus killed several cancer patients and management of MGMC tried to cover-up and concealed the crime and retaliated against Dr. Chughtai, Chief Medical Physicist who was duty bound to inform NRC. As retaliation, the Commander, MGMC initiated investigation against Dr. Chughtai to divert the attention from the real licensing violations. Finally Lloyd C. Harmon, Colonel, USAF, MC, Director Hospital Services at MGMC , Andrews AFB, MD confessed and put the blame on Richard C. Niemtzo for the licensing problem and NOT Dr. Chughtai. But despite of this Richard C. Niemtzow was promoted to Colonel and he is still there at MGMC treating patients and Dr. Chughtai has been fighting in seeking justice for the last several years. (Ref Colonel Lloyd Harmon letter to Niemtzo on 2 January 1986, Exhibit T ). b. Niemtzow has no Board certification in Radiation Oncology, his main practice in Radiation Oncology at MGMC. (Ref. Attach # II) c. Niemtzow never had any credentials of training in radiation oncology for submission to the USNRC; d. Niemtzow was unauthorized user of Teltherapy Cobalt-60 unit to treat cancer patients at MGMC and NRC disqualified him to issue license; He refused to stop treating patients with nuclear radiation. e. Niemtzow was using experimental drug, illegally not approved by FDA . All patients died. But management never questioned him and hr es being provided cover-up; f.

Due to Richard Niemtzow Licensing and credentials problems, Radiation Therapy Department was shut down as described in a letter of Colonel Lloyd Harman, Director of Health at MGMC, Andrews AFB (Exhibit T) and

g. Niemtzow PhD degree from Pacific Western University from California is NOT recognized and never been an issue by the USAF, while Niemtzow joined hand with Ken Vanek to criticizing Dr. Chughtai’s PhD degree and concealing and diverting the attention from his own licensing problems and his own PhD degree and training. Despite of all these disqualification ( a to g) , Richard Niemtzow was promoted to Colonel and became Commander of a base and after retirement, he is still working at as Civilian Physician doing acupuncture at MGMC Andrews AFB, MD. (See Attach #2, Niemtzow Interview).

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While the other Physician, Dr. Vinode Sachdeva, (of an Indian origin) was never promoted and forced to leave USAF. And Dr. Chughtai who was progressing steadily was also forced to resign due to politics, retaliation, discrimination, harassment, his creed and country of origin.

Where is justice in USAF?

It is worth mentioning that I G investigator of USAF keeps asking Niemtzow and Sachdeva (both unlicensed Physicians) “Why Dr. Chughtai writes PhD with his name”? But that investigator never asked about the real problems of licensing violation and why Niemtzow writes PhD with his name? Plaintiff, Dr. Chughtai’s achievements and recommendation letters from USAF and Civilian colleagues are mentioned in the following paragraphs (A and B):

A. Plaintiff Dr. Chughtai’s ’s Achievements: Here is a list of Plaintiff’s achievements (see the Exhibits which are attached to the main amended complaint) : In view of Plaintiff’s educational qualification, experience and training gained at Georgetown University, Washington, DC and Howard University, Washington, DC as Medical Physicist: 1. In 980-88 : In 1980 Plaintiff was selected by USAF directly as Captain in Bio Sciences Corps and served with distinction as Chief Medical Physicist, Radiation Safety Officer and Chairman of Radiation Safety Committee of MGMC, Andrews AFB. 2. Appointed as Health Physicist (grade 9176) in May 1980; 3. Awarded Certificate of training (Exhibit B); 4. Promoted to Chief Medical Physics in Sep 1984 (Exhibit D); 5. Appointed as Chairman Radiation Safety Committee (RSC); 6. Appointed as Research Instructor and later promoted as Assistant Research Professor at Uniformed Services University of the Health Sciences, Bethesda, MD; 7. Appointed as Radiation Safety Officer by Radiation Safety Committee (RSC) and Teltherapy Qualified Expert Physicist at MGMC, Andrews AFB in accordance with USNRC Regulation 10 CFR 35.24 (Exhibit C) 8. Awarded Commendation Medal due to meritorious services in Medical Physics ( Exhibit L). 9. Pass Squadron Officer School (SOS) in residency at Maxwell USAF Base (Exhibit K). 10. Completed residency training in Medical Physics and Training Certificates in Medical Physics was awarded by the Johns Hopkins Cancer Center, Baltimore, MD. (Exhibit V) 11. Outstanding Officer Evaluation Reports (OERs) by Gen Vernon Chong and Colonel Eugene C. Maso (Exhibit J & M). 12. Honorable discharge from USAF (Exhibit C)

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13. June 3, 1975 : Nuclear Medicine course by Dr. Thomas G. Michel at Georgetown University, Washington, DC, (Exhibit V) 14. January 19, to January 30, 1981 : Radiation Therapy Course on External Beam- The Univ of Texas Health Science Ctr at Houston, TX. 15. Jan 3 to Jan 14, 1983 Radiation Therapy Course on External Beam Dosimetry The Univ of Texas Health Science Ctr at Houston, TX 16. 4 April 1985 to 5 April 1985: Health Physics course at Wilford Hall USAF Medical Ctr, Lockland AFB, San Antonio, TX. 17. 24 Oct 1980 : Medical Effects of Nuclear Weapons at Armed Force Radiobiology Research Institute, Bethesda, MD. 18. 31 July to 5 August 1988: AAPM Summer School, Computer in Medical Physics Saint Edwards University, Austin, TX. 19. Medical Ultrasound Physics course and Instrumentation course, University of Colorado Health Science Ctr Denver, CO. 20. LICENSE #1 From State of IL as qualified Expert Medical Physicist. 21. LICENSE #2 From State of MD as qualified Expert Medical Physicist. 22. SL-18 CP-1 Medical Linear Accelerator Course from 18th to 25th April’94 at Philips Medical Systems Radiotherapy, Crawly Sussex, England. 23. SL-Series Physicist (Advanced) Course CP-ii). 2 from 1st to 12th Nov 1993 at Philips Medical Systems-Radiotherapy, Crawly, Sussex, England. 24. The Texas University at MD Anderson Hospital and Tumor Institute, Houston, (1 week-August 24- 31,1987). 25. External Beam, Interstitial, Intracavitary dosimetry Manual and Computer Methods of Calculations: (80 hours, Jan 19-30, 1981) instructions included lectures and practical tutorials in Radiation Therapy Physics. 26. The Johns Hopkins Oncology center, Baltimore, MD: Completed 9 Weeks residency program in Medical Physics(Oct1985 to February, 1986).

B. Plaintiff’s letters of recommendations from USAF and Civilian Colleagues in his support. Plaintiff always has outstanding OERs and was recommended by Col Eugene C. Maso and General Chong for promotion to the rank of Major. They also awarded me a Commendation Medal due to my meritorious services in medical and health Physics.

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Here are the USAF high rankings Generals and Colonels and some Civilians Colleagues have provided recommendation letters in my support: 1. Lt Gen. Monte B. Miller, Surgeon General, EX Commander MGMC Head Quarter USAF, Bolling AFB, DC 20332. He was my Ist Commander in 1980 (See Exhibit U-1) 2. Major General Thomas P. Ball, EX Commander MGMC, Andrews AFB, MD; Now at Murphy Memorial VA Hospital San Antonio, TX. He supported me after I was exonerated by OSI and transferred to Brooks AFB. (See Exhibit S).

3. Major General Vernon Chong, EX Commander MGMC, Andrews AFB, MD; DCS Medical Services and training, HQ Air Training Command (ATC) Randolph AFB, TX. (He made recommendation for promotion and gave me outstanding OERs)

(See Exhibit U-2 4. Dr. Eugene C. Maso, Col USAF, MC, Chairman, Radiology, MGMC, Andrews AFB,

Chief of Radiology Services, Kaiser Permanente Piedmont Rd, Atlanta GA. He was my Boss, rated my outstanding and provided recommendation.

( See Exhibit U-3, 4). 5. Dr. Frank Vieras, Col, USAF, Chief Nuclear Medicine, MGMC, Andrews AFB, MD;

He was my Colleague, Chief of Nuclear medicine, provided recommendation letters.

(See Exhibit U- 5). 6. Dr. Asghar Hussain, Chief of Radiation Oncology at VA Hospital, Washington, DC.

He was my Colleague at Georgetown University and also was a Consultant for MGMC, Andrews AFB.

7. Dr. Holmer Twigg, MD, Chairman of Radiology, Georgetown Univ. Washington, DC; He was the Chairman of Radiology at Georgetown University, Washington, DC.

8. Professor Richard C. Grankee, Chief Physicist, Georgetown Univ. Washington, DC. He was my Colleague at Georgetown University, Washington, DC.

9. Dr. Wing Chee Lam, Associate Professor at the Johns Hopkins Oncology Center, Baltimore, MD


II. Exhibit F: Violation of Federal Law-2 (Unauthorized Physicians imparting radiation and were in noncompliance with the licensing conditions#13 set forth by US NRC at MGMC, Andrews AFB, MD.)

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In accordance with NRC Instructions and licensing requirements as set forth in NRC license # 08-08401-02 dated 1-19-1984 Docket # 30-00129, thru letter by Francis A. St. Mary, Material Licensing Branch Div of Fuel Cycle and Material Safety, both doctors (Richard C. Niemtzo and Vinode Sachdeva) working at MGMC, Andrews AFB were not in compliance of the NRC federal laws. NRC ‘s Advisory Committee members reviewed the qualifications and experience of both doctors and found that they were nor certified by the American Board of Radiology so they recommended that both doctor must have: a. License from any state b. Submit completed supplement Form NRC-313T and c. Letters of reference from each Physician under whom Niemtzow and Sachdeva received training. To implement these NRC conditions, Dr. Chughtai as Radiation Safety Officer (RSO) approached both doctors to provide the required documents to comply with NRC requirements. Both doctors were uncooperative and refused to provide as they never had any documents to present. Dr. Chughtai was duty bound RSO and under the authority in accordance with USNRC regulation 10 CFR 35.21, it was very important to protect MGMC, the institution from violations and it was my part of official duty to manage and implement licensing conditions and ensure the compliance with all the regulations as set forth by NRC.

III. Exhibit G : Violation of Federal Law- 3 RADIATION SAFETY OFFICER (RSO) MUST REPORT VIOLATIONS: In accordance with authority of Radiation Safety Officer (RSO) per regulation 10 CFR 35.21, # 36954 Federal Register /Vol 51 No 200, Thursday October 10, 1966/ Rules and Regulation, Plaintiff, Dr. Chughtai as duty bound Radiation Safety Officer reported LICENSING VIOLATIONS at MGMC, Andrews AFB. Thus he was punished, downgraded in his OERs, not promoted, retaliated, discriminated, harassed, humiliated and was forced to leave USAF. Is this is a Justice in USAF System?

IV. Exhibit H :

Violation of Federal Laws-4

REPORTING OF MISADMINISTRATION BY RSO: In accordance with regulation 10 CFR 35.43 report of misadministration of radioactive material 10CFR Chapt 1, (1-86 edition). Captain Chughtai was the officially appointed Radiation Safety Officer (RSO) by the Radiation Safety Committee(RSC) of MGMC in accordance with NRC regulations. As a duty bound RSO, Dr. Chughtai reported the violation to NRC as per regulation and thus he was downgraded in his OERs, not promoted, retaliated, discriminated, harassed, humiliated due to his creed, color, country of origin and was forced to leave USAF. Is this is a Justice in USAF System?

V. Exhibit I : Misadministration INCIDENT of Radioactive material: The incident of misadministration of radioactive material to a patient took place on 10 Sep 1985 at MGMC, Andrews AFB. To comply with regulation 10CFR 35.43, as Radiation

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Safety Officer, an incident report was submitted to NRC and thus Dr. Walker, Chief of Nuclear became furious and he started a negative campaign against Plaintiff to retaliate and formulated a Gange consisting of Ken Vanek, John Burr, David Hunter( from Texas ) and Alexander Daley from MGMC, Andrews AFB, MD) ( See Exhibit I ). CONGRESS AUTHORISES US DISTRICT COURTTO SET ASIDE ALL BAD OERs: 1.. Contrary to the arguments of the defendant’s brief, in Exhibit A attached to the amended complaint, the US Air Force representative wrote on September 20, 2014 that Congress authorizes the US District courts to review final AFBCMR decisions and set them aside if due cause is found. USAF Inspector General initiated probe for the sake of justice in accordance with AF regulation , AFI 36-2603 (AFBCMR) Paragraph 3.5.2 and reinstatement to higher rank as appropriate. But no progress was made and the case was forwarded to AF equal employment opportunity unit for review. However with reference to the letter of 29 Sep’14 sent by colonel Mathew Yetishefsky, Plaintiff has filed this complaint with pursuant to 5 U.S.C. Section 701, et. Seq and 28 U.S.C Section 1491, Congress authorizes applicants to pursue final FBCMR decisions through the US District Court. The court has the authority to set aside the AFBMR decision. (Exhibit


RETALIATION and DOWN GRADING OERs of Plaintiff, Dr. CHUGTAI: After reporting the violations, Plaintiff was targeted for retaliation. No one in the USAF dare to stop these five officers who were out there to get me. Is this the equal opportunity and justice in USAF system for Dr. Chughtai, Chief Medical Physicist and RSO who was awarded Commendation Medal, pass Squadron Officers School(SOS) in residency at Maxwell AFB, Trained at the Johns Hopkins Cancer Center and received outstanding OERs from General Chong and Col Maso who recommended him for the promotion to the rank of Major.

( see Exhibits J, K,L and M for outstanding OERs and Exhibit # N, O, P and R for downgraded OERs).

Their mission and impact on Plaintiff’s life : Their mission was to retaliate and harass Plaintiff with malicious intention. They did not leave any stone unturned to get me terminated unlawfully, down grading my OERs and forcing me to resign from my professional job as Chief Medical Physicist. Alex Daley and Ron Walker of MGMC, Andrews AFB, MD were the budy budy of Ken Vanek and they keep calling David Hunter and John Burr and Vanek in Texas to make sure Plaintiff get BAD OER. I got the worse OER and never got promoted to Major and was forced to resign. Ken Vanek chased me and started to call employers where I was doing Medical Physics Consulting, even after Plaintiff left USAF. Due to Ken Vanek, Plaintiff lost contracts at DC General Hospital Washington, DC; Howard Univ Hospital Washington, DC; Walter Reed Army Medical Center, Washington DC and the Johns Hopkins Cancer Center, Baltimore, MD.

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My family got dismembered as my wife left me and we were divorced, my two young children’s life got affected and Plaintiff lost a house in Silver spring, Maryland. Plaintiff suffered severe depression and left USA for several years for change and could not follow to appeal my case. RETALIATION AGAINST PLAINTIFF TO COVER-UP VIOLATIONS: The service has used a combination of the blue line of silence and retaliation against Plaintiff to cover up the violations at Malcolm Grove Medical Center (MGMC) at Andrews Air Force Base in Maryland leading to the injury and death of several patients there.

WHEREFORE, for all the reasons set forth above, Plaintiff requests this honorable Court to deny the Motion of Defendants, submitted to dismiss the amended complaint against all the defendants and permit the matter to proceed. Submitted respectfully

Date : 06/18/2015

Dr. Gul M. Chughtai, MS, PhD. (USA) Pro Se 8115 Ferndale Street, Philadelphia, PA 19111 Cell# 267-593-0876

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Dr. Gul M. Chughtai, MS, PhD. (USA) Pro Se 8115 Ferndale Street, Philadelphia, PA 19111 Cell# 267-593-0876 -------------------------------------------------------------------------------------------------------------------------------

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA -------------------------------------------------------------------------------------------------------------------------Dr. Gul M. Chughtai ) ) 8115 Ferndale Street, Philadelphia, PA19111 ) January 2015 ) Plaintiff ) Case ID # 2:15-cv-00352-JHS Vs. ) ) Barack Obama, President of USA and ) Commander In Chief, the White House, ) 1600 Pennsylvania Ave; NW Washington, ) Certification of Service DC 20500 ) Et al ; ) ) Defendants )

Certification of Service I, Dr. Gul M. Chughtai, certify that I have on this date filed the response to Defendant’s motion electronically and it is available for viewing and downloading from the ECF System. Electronic service of the Notice of Electronic Case Filing generated by the ECF System constitutes service of the filed document on the following parties who have consented to electronic service: LANDON Y. JONES III Assistant United States Attorney 615 Chestnut Street, Suite 1250 Philadelphia, PA 19106-4476 Email : [email protected]

Date : 06/18/2015

Thomas J. Wagner LAW OFFICES OF THOMAS J. WAGNER Eight Penn Center, 6th Floor 1628 John F. Kennedy Boulevard Philadelphia, PA 19102 Email : [email protected]

Dr. Gul M. Chughtai, MS, PhD. (USA) Pro Se 8115 Ferndale Street, Philadelphia, PA 19111 Email: [email protected]

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ATTACHMENT - I Report: VA center in Philadelphia had widespread problems By Walter F. Roche Jr. Wednesday, Feb. 10, 2010

The report from the VA's Medical Inspector, obtained under the federal Freedom of Information Act, recounts the complaints from a surgical resident who told inspectors of the dead patient and another case in which a patient at the facility was allowed to sit in a bed of urine. The report, dated Dec. 12, 2007, cites the poor care on the thoracic surgery unit as the reason that doctors routinely shifted major chest surgery cases to the nearby University of Pennsylvania/Presbyterian Medical Center. "The general surgery resident physician voiced 'no confidence' in the care provided on the ward and went so far as to say that the surgical ward was 'not a nursing unit,' care was non-existent," the 10page report states. Dale Warman, spokesman for the Philadelphia center, said the problems cited in the report have been corrected. "Many improvements have been made over the past three years for the well-being of our veterans, and this situation does not at all reflect the current state of patient care," he said in an e-mail. U.S. Rep. Joseph Sestak, D-Delaware County, said some of the findings in the report were "completely intolerable and reflects a gross lack of accountability at many levels." The Philadelphia facility is awaiting a decision by the Nuclear Regulatory Commission on penalties stemming from the mistreatment of prostate cancer patients who were given incorrect and misplaced doses of radioactive seeds. "That those two programs were simultaneously sub-standard is more than another wake-up call -- it is indication that the equivalent of a two-alarm fire was raging without the appropriate knowledge of Veterans Service Organizations, Congress or even the VA," Sestak said. The inspectors found that problems in the unit, which includes 32 post-operative beds and an intensive care unit, contributed to a backlog in cases with many surgeries being delayed or canceled. Employees interviewed by the inspection team complained of staff shortages and the lack of support services such as respiratory therapy.

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Acupuncture in the Air Force Interview with Richard C. Niemtzow, MD, PhD, MPH

Interviewed by Daniel Redwood, DC, Editor-in-Chief of Health Insights Toda

Col. Richard Niemtzow, MD, PhD, MPH, is a military medical physician practices acupuncture on a full-time basis for the United States Air He is the President-Elect of the American Academy of Medical Acupunctu serves as Major Consultant to the Air Force Surgeon General for complementary and alternative medicine.

Dr. Niemtzow received his undergraduate degree from Goddard College in Vermont and his medical degree from the Faculty of Medicine in Mon France. He received his PhD from Pacific Western University in Cal and his Masters in Public Health from the Medical College of Wisconsin. He d residency in radiation oncology at the University of Texas Medical Bra Galveston and received his acupuncture certification through the U Acupuncture Course for Physicians. Dr. Niemtzow is board certi the American Board of Forensic Medicine and the American Board o Forensic Examiners.