1. Vamsidhar R Vurimindi, Plaintiff 313 Arch Street, Unit 607, Philadelphia, PA 19106

Vs. 1. Wyeth Pharmaceuticals, C/o. Pfizer, Inc

235 East 42nd Street, New York, NY 10017 2. Accenture

1345 Avenue of the Americas, New York, NY 10105

3. Inventive Clinical Solutions 16225 Park Ten Place, Suite 200, Houston, TX 77084

4. HealthCore 800 Delaware Avenue, 5

th Flr, Wilmington, DE 19801

5. Hemispherex BioPharma 1617 JFK Blvd., 6th Flr, Philadelphia, PA 19103

6. Cyrus Hoseyni 500 Arcola Road, Collegeville, PA 19426

7. Ira Spector 500 Arcola Road, Collegeville, PA 19426

8. Greg Zhou 500 Arcola Road, Collegeville, PA 19426

9. Stephen Kopko 500 Arcola Road, Collegeville, PA 19426

10. Robert Moyer 500 Arcola Road, Collegeville, PA 19426

11. Valerie Williams 500 Arcola Road, Collegeville, PA 19426

Defendants

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Court of Common Pleas Philadelphia County, Pennsylvania

January Term 2010

No: 0007

Complaint for Promissory Estoppel Complaint for Wrongful Termination Complaint for Slander Complaint for Conspiracy to Interfere with Plaintiffs Civil Rights Complaint for Intentional Infliction of Emotional Distress Complaint for Intentional Interference with Economic Relationship Complaint for Age Discrimination Complaint for Invasion of Privacy - Intrusion of Solitude and Seclusion, Public Disclosure of Private Facts, False Light Complaint for Retaliation by Dissemination of Negative Employment Reference in Violation to CRA 1964, Title VII Complaint for Fraudulent Misrepresentation

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THIRD AMENDED COMPLAINT

(I) INTRODUCTION: This civil action arise after Plaintiff, Vamsidhar Vurimindi’ (“Vurimindi”) contractual

employment was terminated in March 2009 by Wyeth Pharmaceuticals (“Wyeth”), despite

Wyeth managers made specific promise to retain Vurimindi until end of November 2009 and in

response to specific duration Vurimindi agreed to take reduced bill rate than that Wyeth

normally pay for the position. In addition, while Vurimindi working at Wyeth under a specific

duration contractual employment, prior to terminating Vurimindi’ contractual employment,

Wyeth managers purposefully contacted Vurimindi’ classmates at Wharton, UPenn and Fuqua

School of Business, Duke University (“Duke”) and made depreciatory statements to impute

Vurimindi’ ability as a professional. In addition, Wyeth managers organized a smear campaign

against Vurimindi within Wyeth and at Duke by projecting Vurimindi as a Juvenile delinquent,

having previous criminal record and not as a person was properly grounded with a decent set of

values and permanently and irrevocably damaged Vurimindi’ image and reputation among his

peers. As a result, Vurimindi suffered from severe emotional distress and Vurimindi made a

formal complaint about possible discriminatory employment practices and hostile work

environment at Wyeth. Immediately, Wyeth Managers systematically demoted Vurimindi and

ultimately eliminated Vurimindi’ position and terminated Vurimindi’ contractual employment

eight (8) months before actual contract end date. In addition, after Vurimindi initiated this civil

action, Wyeth managers retaliated Vurimindi through purposeful dissemination of negative

employment reference.

After a great difficulty and after 18 month of unemployment and after partially

recovering from severe emotional distress, in October 2010 Vurimindi obtained a two (2)

months duration contractual employment at HealthCore, Inc (“HealthCore”). Immediately,

within few days after Vurimindi begins his contractual employment, Wyeth managers

purposefully contacted Vurimindi’ manager at HealthCore and disseminated negative

employment reference. After that Vurimindi’ colleagues begin to make depreciatory statements

about Vurimindi and when Vurimindi enquired, HealthCore terminated Vurimindi’ contractual

employment prior to the expiration of the two (2) months contractual duration without notice.

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After that, in December 2010, Vurimindi secured another contractual employment at

Hemispherex Biopharma, Inc (“Hemispherex”) and within few weeks Wyeth managers

purposefully contacted Vurimindi’ manager at Hemispherex and disseminated negative

employment reference. After receiving negative employment reference, Hemispherex manager

begin to slight, sneer and made depreciatory statements about Vurimindi to his colleagues. In

September 2011, upon enquiry, as to why his colleagues are making depreciatory statements,

without notice Hemispherex terminated Vurimindi’ contractual employment. After that, in

October 2011 when Vurimindi attempted to obtain an employment at Theorem, a CRO located

in King of Prussia, PA, Wyeth managers purposefully disseminated negative employment

reference and suggested not hire Vurimindi.

(II) NARRATIVE OPERATIVE FACTS: In June 2002, Vurimindi begins working at GlaxoSmithKline (“GSK”), Philadelphia, PA as a

Statistical Programmer. A year after, Vurimindi started working at GSK and sometime in July

2003, Vurimindi’ manager begin to disrespect Vurimindi’ dignity and interfered with his job

performance. Six months later, in December 2003, just few days before the Christmas holidays,

Vurimindi’ contractual employment was terminated by GSK and upon termination, ClinForce,

Vurimindi’ employer revoked his H1B visa. Immediately, Vurimindi filed a complaint with EEOC

for wrongful discharge and employment discrimination (sexual harassment). Because, it is

paramount for Vurimindi to retain his H1B visa status, Vurimindi focused his efforts to find an

employer to sponsor his H1B visa and after a great difficulty, Vurimindi was able find an

employer to sponsor H1B visa and a job in Maclean, VA. As soon, Vurimindi begin his new job at

Maclean, VA, Vurimindi abandons his complaint with EEOC and continued to search for a job in

and around Philadelphia, PA.

Approximately after ten (10) months, in October 2004, Vurimindi was contacted by a

recruiter from Boston, MA and told about a Philadelphia, PA based outsourcing statistical

programming project management opportunity with Cytel, Inc (“Cytel”) and arranged an

interview with Cytel. During the interview and prior to hire Vurimindi, Cytel explained nature of

outsourcing project at Wyeth Pharmaceuticals (“Wyeth”) as Wyeth proposed to outsource its

clinical trial data analysis work to India on a pilot basis for three(3) months and if the pilot

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project was successful, then Wyeth would extend the scope, size and duration of project.

During pilot period and post pilot period, Vurimindi would work two (2) days in week at Wyeth

site and three (3) days in week from his home. Cytel told to Vurimindi that a team of SAS

programmers were recruited for this project at their Pune, India location and those

programmers would remotely log-in onto Wyeth computer data servers using VPN1 connection.

In November 2004, Cytel hired Vurimindi on a three (3) months short-term contractual

employment basis. Immediately, Vurimindi and his team reported to Kopko and Moyer and in

turn Vurimindi’ team was asked to validate Wyeth Global Biostatistics SAS® Macros. Vurimindi’

team begins to work for Wyeth without having the required VPN access to Wyeth computer

data servers. Despite, many times Vurimindi told to Wyeth that VPN connection for his team in

India is vital and paramount for successful execution of outsourcing project, Wyeth didn’t give

required VPN connectivity to his team. In order to overcome the deficiency of required VPN

connection, Vurimindi begin working overtime without pay. As soon, Vurimindi overcome the

deficiency of VPN connectivity with great difficulty and start delivering Cytel’ work product

according to original Wyeth expectations, Wyeth employees Kopko, Moyer, Maria Reiss

(“Riess”), Valerie Williams, (“Williams”), Anthony Shaw (“Shaw”), Ronald Test (“Test”), Chao Li

(“Li”) an independent SAS consultant, and interns Michael Jessup (“Jessup”) and Judi Forman

(“Forman”) told to Vurimindi’ team about GSK terminating Vurimindi’ employment and

subsequent revocation of his H1B visa and Vurimindi’ sexual harassment complaint with EEOC

to Vurimindi’ female team members and asked them not to follow Vurimindi’ instructions and

told to Cytel that Vurimindi is not a capable to manage the project and asked to find a

replacement for Vurimindi.

Immediately, Cytel made enquires about Vurimindi’ ability to manage the project and

his EEOC complaint against GSK. Vurimindi was terrified with Cytel enquiry, because upon

successful completion of first three (3) months pilot project, Cytel promised to Vurimindi to

sponsor a H1B visa and his permanent residency (“Green Card”) application and possibility of

1 A virtual private network (VPN) is a technology for using the Internet or another intermediate network to connect computers to isolated remote computer networks that would otherwise be inaccessible. A VPN provides security so that traffic sent through the VPN connection stays isolated from other computers on the intermediate network. VPNs can connect individual users to a remote network or connect multiple networks together.

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losing his opportunity of H1B visa and Green Card sponsorship, due to Wyeth employees

imputing Vurimindi’ ability to manage the outsourcing project.

At that time, Vurimindi told to Cytel, that he don’t have any idea as to why Wyeth

express concern about his ability, despite, Vurimindi working over-time without pay and

delivering Cytel’ work product according to original expectations, while the original

expectations was based on Wyeth providing required VPN connection. Vurimindi assured to

Cytel that he would continue to deliver Cytel’ work product within the budget and asked Cytel

to pursue Wyeth to follow through their contractual promise of giving required VPN

connection, increase the duration, size and scope of the project. At the end of initial three (3)

month pilot project, upon successful delivery of Cytel work product, Wyeth decided to

permanently contract with Cytel. Immediately, thereafter Cytel offered a permanent

employment and sponsored H1B visa and petitioned for Vurimindi’ permanent residency status

(“Green Card”). Nevertheless, Wyeth didn’t provide the required VPN connection.

As soon Wyeth decided to permanently contract with Cytel, Vurimindi begin to explore

opportunities within Wyeth to expand outsourcing project scope into clinical data analysis

work, for which originally Vurimindi and his team was brought into Wyeth. As soon, Vurimindi

begins to talk to Wyeth therapeutic area heads, Kopko, Moyer, Zhou, Spector and other Wyeth

employees told to Wyeth therapeutic area heads not to engage Vurimindi in clinical data

analysis by saying that he “slow”, “don’t have interest in his job”, “didn’t pass high school” and

“he can’t process two things at one time”. As a result of negative publicity, Wyeth therapeutic

area heads didn’t engage Vurimindi and his team in clinical data analysis work. Subsequently, as

a result, Vurimindi permanently lost valuable time and opportunity to gain hands on experience

in the statistical analysis work, which would allow Vurimindi earn higher wages with stable

employment in future. Because, finding another employer who can sponsor H1B visa and Green

Card is very difficult, and Cytel petitioned for Vurimindi’ Green Card, Vurimindi continued to

work for Cytel and continue to validate the SAS® Macros until Wyeth asked to annotate CRFs2.

2 A case report form (or CRF) is a paper or electronic questionnaire specifically used in clinical trial research. The Case Report Form is the tool used by the sponsor of the clinical trial to collect data from each participating site. All data on each patient participating in a clinical trial are held and/or documented in the CRF, including adverse events.

Page 6 of 85

In November 2006, Wyeth hired Cyrus Hoseyni (“Hoseyni”) as head of Wyeth global

statistics division. Immediately, Kopko, Moyer, Zhou, Spector and other Wyeth employees told

to Hoseyni that Vurimindi’ team was “slow”, and Vurimindi “don’t have interest in his job”.

Quickly thereafter dynamics around Vurimindi’ work situation drastically deteriorated and

Wyeth asked Vurimindi’ team to annotate CRFs, which is a menial task, when compared with

Clinical Data Analysis work. Quickly thereafter Hoseyni decided to sign a new contract with

Accenture to outsource Wyeth Clinical Data Analysis work.

In June 2007, prior to Wyeth terminate Cytel’ contract, Vurimindi begins to explore

possibilities to get admitted into an MBA program, and applied for an admission into a Pre-MBA

course at Wharton. Upon, Wyeth give notice of termination of Cytel’ contract, Vurimindi asked

Kopko and Moyer whether they can hire Vurimindi as an independent consultant with direct

contract with Wyeth for the duration of his MBA program. Kopko and Moyer agreed to hire

Vurimindi through Inventive with flexible work hours through the duration of his MBA program

as CDISC® Subject Matter Expert with an annual pay rate of $120,000, which Kopko and Moyer

believe is less than Vurimindi is being paid by Cytel as Project Manager. Vurimindi agreed to

take reduced bill rate than that Wyeth normally pays for the position, because Wyeth managers

made specific promise to retain Vurimindi through the duration of his MBA program. Right after

that, Kopko and Moyer asked Vurimindi to submit an employment application with Inventive. In

June 2007, based on the arrangement with Kopko and Moyer, Inventive hired Vurimindi at the

salary agreed upon with Kopko and Moyer. Based on Kopko and Moyer’ assurances and quick

hiring by Inventive at agreed upon salary, Vurimindi believed promises made to him by Kopko

and Moyer. Based on the belief on these promises, while continuing his Pre-MBA, Vurimindi

begin his process of applying into an MBA program.

In July 2007, Vurimindi commenced his work as CDISC® Subject Matter Expert at Wyeth.

Kopko and Moyer asked Vurimindi to prepare data mapping document, which is a functional

and technical requirement document for Accenture to implement data migration. Accenture

employees asked Vurimindi to prepare functional and technical requirements in a specific

format and Vurimindi delivered the data mapping document in the required format.

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Nevertheless, Accenture team run into a chain of issues based on the choice their software that

they decided to use to implement data migration.

At that time, Vurimindi casually suggested using SAS® software to implement data

migration and in response Accenture employees threatened Vurimindi of losing his job making

this suggestion. While, Accenture team continues to run into issues, and when Hoseyni asked

Vurimindi told to Hoseyni about the deficiencies in the data migration process. Immediately,

thereafter, Vurimindi started to hear rumors among Vurimindi’ classmates at Wharton about

Vurimindi as Vurimindi “is not capable to handle managerial responsibilities”, “was a Juvenile

delinquent”, and “didn’t pass high school” which seriously undermined Vurimindi’ credibility at

Wharton as a student and as a professional among the student body.

Immediately, Vurimindi contacted Kopko and Moyer and asked to allow him to

complete his Pre-MBA program at Wharton and MBA program that he planned to enroll and

clarified to them that Vurimindi suggested using SAS® software only in the best interest of the

Wyeth, Accenture and people working on the data migration project. At that time, Kopko and

Moyer re-assured Vurimindi that they will retain Vurimindi through his MBA program. Hoseyni,

Kopko and Moyer write recommendation letters on behalf of Vurimindi for Vurimindi’

admission into Duke, and UPenn etc., and Vurimindi get admitted into an MBA program at Duke

and Vurimindi self financed the tuition fee.

In November 2007, Hoseyni enquired Vurimindi, about data migration project and

encouraged to make suggestions to improve the data migration process. At that time Vurimindi

presented two possible alternatives to the existing data migration process. Immediately,

Vurimindi desk was moved right opposite from Hoseyni’ office to a location where there is not

enough natural light; and Wyeth Managers along with Accenture employees continue to relay

as to how Vurimindi was shut-out at Wyeth in his day to day activity to Vurimindi’ classmates

Wharton. Vurimindi hoped that Wyeth Managers and Accenture employees stop harassing

Vurimindi, because Vurimindi isn’t making any suggestions except do his work as told by Wyeth

Managers and Accenture employees.

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In March 2008, Vurimindi begin his MBA classes at Duke and along with Vurimindi there

are three other students Jason Sundberg (“Sundberg”), Wilker Ambooken (“Ambooken”) and

Jason Link (“Link”) also get admitted into Duke MBA program who also travel from Philadelphia,

PA to Raleigh, NC. Kopko and Moyer along with Accenture employees established contact with

Vurimindi’ classmates and told them that “Vamsi is not capable to handle managerial

responsibilities”; “Wyeth couldn’t able to verify Vamsi’ credentials”, “Vamsi didn’t pass high

school” and “Vamsi was a Juvenile delinquent”. Simultaneously, Wyeth Managers (Hoseyni,

Spector, Zhou, Kopko, Moyer, and Williams) through the third party vendors of Wyeth (similar

to Accenture and Inventive) established contacts with Vurimindi’ professors and classmates at

Duke and Duke Administration. Octagon Research is one of the third party vendors for Wyeth,

and on behalf of Wyeth Managers, James Walker, CEO of Octagon Research, an Alumni of Duke

MBA program, contacted Duke and told that “Wyeth couldn’t able to verify Vamsi’ credentials”

and he shouldn’t be admitted into MBA program.

Soon after that, Vurimindi’ classmates at Duke quickly turned Duke Campus into a

hostile environment to Vurimindi by organizing a smear campaign by projecting Vurimindi as a

Juvenile delinquent, having previous criminal record by being implicated in murder case(s) and

engaged in money laundering business and not as a person was properly grounded with a

decent set of values and permanently and irrevocably damage Vurimindi’ image and reputation

among his classmates.

Between March and July 2008, simultaneously Vurimindi was harassed at three distinct

environments Wyeth, Wharton and Duke based on the same rumors and private life facts and

as result, Vurimindi dropped from Wharton. Hence, in July 2008, Vurimindi made a formal

complaint to Moyer about harassment within Wyeth and urged him to cease and desist Wyeth

and Accenture employees from harassing Vurimindi, because ongoing harassment severely

affected Vurimindi’ mental health. Instead cease and desist ongoing harassment, Wyeth

Managers systematically demoted Vurimindi’ position and ultimately eliminated Vurimindi’

position and terminated Vurimindi’ contract in March 2009, one year after Vurimindi begin his

MBA program, but 8 months before the program is completed, in direct contradiction to Kopko

and Moyer’ promise to retain Vurimindi until he completes his MBA program. After,

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terminating Vurimindi’ contract, Wyeth hired a person belongs to outside of protected class as

defined by the Civil Rights Act of 1964 to perform Vurimindi’ job function.

Despite, Vurimindi no longer work at Wyeth, Hoseyni, Spector, Zhou, Kopko, Moyer, and

Williams continued to maintain their contacts with Vurimindi’ classmates at Duke and establish

new contacts with Vurimindi’ neighbors through their third party vendors such as Octagon

Research ( Dr. Neal Walker co-founder of Octagon Research) and begin undermine Vurimindi’

credibility in and around his residence. Kopko, Moyer and other Wyeth employees contacted

more than sixty (60) recruiting companies who specialize in SAS programming and told them

not to represent Vurimindi’ resume.

After an unemployment gap of 18 months, in October 2010 Vurimindi secured software

programming job at a much lower bill rate than that ordinarily paid to programmers with

similar experience than that of Vurimindi and begin his work at HealthCore, Wilmington, DE. As

soon Vurimindi began his work, Kopko, Moyer, Zhou and Hoseyni and other Wyeth employees

contacted HealthCore employees Tracey Quimbo (“Quimbo”), Rebecca Cobb (“Cobb”), Fang

Liang (“Liang”) and other HealthCore staff and disseminated negative employment reference

and told them as to how Vurimindi was treated at Wyeth, Duke and by his neighbors.

Immediately, Vurimindi’ colleagues showing sly, reminded about Vurimindi’ tumultuous

experience at Duke and showing sly in a mocking fashion talked about private criminal

complaint that was filed by his neighbor, Allison Borowski (“Borowski”) and his ongoing private

life facts. After four (4) weeks, Vurimindi was frustrated and demanded his manager Quimbo as

to how she and other colleagues know about Vurimindi’ private life facts and why they talk

about them in work environment; and two (2) days later, HealthCore terminated Vurimindi’

employment and a day before, HealthCore terminates Vurimindi’ contract, Lauren Westfield

Nayerahmadi (“Nayerahmadi”) another Vurimindi’ neighbor who live underneath Vurimindi’

unit, shouted across the floor “hey crazy, they are going to fire you”.

In December 2010, Vurimindi secured another job as statistical consultant at

Hemispherex in Philadelphia, PA at a much lower bill rate than that ordinarily paid to someone

with similar experience than that of Vurimindi. As soon Vurimindi began his work at

Hemispherex, Kopko, Moyer, Zhou and Hoseyni along with other Wyeth employees contacted

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Vurimindi’ colleagues and disseminated negative employment reference. Immediately,

Vurimindi’ colleagues showing sly, reminded about Vurimindi’ tumultuous experience at Duke

and showing sly in a mocking fashion talked about private criminal complaint that was filed by

his neighbor, Borowski and his ongoing private life facts. After six months, Vurimindi was

frustrated and contacted Hemispherex human resources department and asked to ask

Vurimindi’ colleagues to cease and desist from contacting Vurimindi’ neighbors. Immediately,

without notice in September 2011, Hemispherex terminated Vurimindi’ contract. After that, in

October 2011, when Vurimindi begin his employment search, and applied for a position at

Theorem, a local CRO, Wyeth Managers disseminated negative employment reference to hiring

manager, Karen Curran at Theorem and told not to hire Vurimindi.

(III) THE PARTIES:

01. Plaintiff Vamsidhar Vurimindi is a resident of 313 Arch Street, Unit # 607, and Philadelphia,

PA 19106. Vamsidhar Vurimindi belongs to protected class, defined Civil Rights Act of 1964,

because Vamsidhar Vurimindi born and brought up in India and belongs to Hindu religion.

Hereafter referred as Vurimindi

02. Defendant Wyeth Pharmaceuticals, C/o. Pfizer, Inc, 235 East 42nd Street, New York, NY

10017, formerly known as Wyeth Pharmaceuticals located at 500 Arcola Road, Collegeville,

PA 19426. Hereinafter referred as Wyeth.

03. Defendant Accenture is a third party Clinical Data Management (“CDM”) services provider to

Wyeth. In Year 2000, over 150 Wyeth employees transferred to Accenture and continue to

provide CDM services in the name and fashion as Alliance for Clinical data Excellence

(“ACE”), from their usual Wyeth’ Collegeville, PA facility. Accenture corporate office is

located at 1345 Avenue of the Americas, New York, NY 10105. Hereinafter referred as

Accenture.

04. Defendant Inventive Clinical Solutions is a third party human resources provider to Wyeth. In

2006, Wyeth selected Inventive Clinical Solutions as a sole human resources provider for

Wyeth’ onsite staff augmentation needs in Clinical Trial execution, management and data

analysis areas. Inventive Clinical Solutions corporate office located at 16225 Park Ten Place,

Suite 200, Houston, TX 77084. Hereinafter Inventive Clinical Solutions referred as Inventive.

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05. Defendant Cyrus Hoseyni, Chief Statistician, Wyeth Pharmaceuticals at 500 Arcola Road,

Collegeville, PA 19426. Hereinafter Cyrus Hoseyni referred as Hoseyni. Hoseyni reported to

Robert McGuire, COO, Wyeth clinical trial operations and Bruce Schneider, EVP, Wyeth

Research.

06. Defendant Ira Spector, Vice President, Wyeth Pharmaceuticals at 500 Arcola Road,

Collegeville, PA 19426. Hereinafter Ira Spector referred as Spector. Spector reported to

Robert McGuire, COO, Wyeth clinical trial operations and Bruce Schneider, EVP, Wyeth

Research.

07. Defendant Greg Zhou, Global Head, Clinical Data Reporting, Wyeth Pharmaceuticals at 500

Arcola Road, Collegeville, PA 19426. Greg Zhou reported to Hoseyni. Hereinafter Greg Zhou

referred as Zhou.

08. Defendant Stephen Kopko, Sr. Director, Biostatistics Department, Wyeth Pharmaceuticals.

Stephen Kopko work at 500 Arcola Road, Collegeville, PA 19426. Vurimindi reported to

Stephen Kopko. Hereinafter Stephen Kopko referred as Kopko.

09. Defendant Robert Moyer, Director, Biostatistics Department, Wyeth Pharmaceuticals.

Robert Moyer work at 500 Arcola Road, Collegeville, PA 19426. Robert Moyer reported to

Kopko. Vurimindi’ day to day tasks are supervised by Robert Moyer. Hereinafter Robert

Moyer referred as Moyer.

10. Defendant Valerie Williams, Asst. Director, Biostatistics Department, Wyeth

Pharmaceuticals. Valerie Williams work at 500 Arcola Road, Collegeville, PA 19426. Valerie

Williams reported to Moyer. Valerie Williams’ father was a retired employee of City of

Philadelphia. Hereinafter Valerie Williams referred as Williams.

11. Defendant HealthCore, Inc is a 100% subsidiary of Well Point, Inc and having its registered

office at 800 Delaware Avenue, 5th Flr, Wilmington, DE 19801. Hereinafter HealthCore, Inc

referred as HealthCore.

12. Defendant Hemispherex BioPharma, Inc having its registered office at 1617 JFK Blvd., 6th Flr,

Philadelphia, PA 19103. Hereinafter Hemispherex BioPharma, Inc referred as Hemispherex.

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(IV) FACTUAL ALLEGATIONS:

13. In October 2004, Wyeth assigned a contract to Cytel to perform statistical analysis on Wyeth

clinical trial data from Cytel’ Pune, India location on a pilot basis for three (3) months, after

assessing Cytel’ work product during pilot period, Wyeth would extend the duration of the

project and number resources utilized in the project.

14. According to contract, scope of the project is to perform all necessary tasks to conduct

statistical analysis work, including developing Statistical Analysis Protocol (SAP), developing

and validating SAS programs to conduct statistical analysis, produce data summary tables,

listings and graphs and QC the results and finally prepare a statistical report for each

protocol.

15. In order to perform all necessary tasks to conduct statistical analysis work from Cytel’ Pune,

India location, Wyeth agreed to provide VPN connectivity to Cytel employees at Pune, India

location to remotely log-on into Wyeth data servers.

16. In order to manage proper information flow between Cytel and Wyeth employees, Cytel

proposed to hire a project manager to manage the workflow; and also proposed project

manager conduct quality check on Cytel’ work product before delivery to Wyeth.

17. Cytel and Wyeth both proposed that, Cytel’ project manager will work two (2) days in a week

out of Wyeth’ Collegeville, PA location and remaining three (3) days work out of Cytel’

Philadelphia, PA location.

18. In October 2004, as per the scope of the project, Cytel formed a team in India by hiring three

(3) statisticians, who had their masters’ degree in statistics and prior working experience as

statisticians in pharmaceutical environment along with hands-on experience with SAS

programming language.

19. In October 2004, according to Wyeth requirements Cytel hired a third party to conduct 10

years background search and compiled a report for Wyeth and send to Wyeth along with

Vurimindi’ resume.

20. In October 2004, after Wyeth reviewing background search report and Vurimindi’ resume,

along with Cytel, India team members’ resumes, Wyeth signed a contract to perform

statistical analysis on Wyeth clinical trial data from Cytel’ Pune, India location.

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21. In November 2004, Cytel hired Vurimindi on a three (3) months contractual employment

basis for the duration of the pilot period and if Wyeth extend the duration of the project,

Cytel, promised to sponsor H1B visa and Green Card.

22. In November 2004, Vurimindi begin his work as Project Manager and on the first day of

starting work at Wyeth, Kopko introduced Vurimindi to Moyer, Riess, Williams, Shaw, Test,

Li, Jessup and Forman.

23. In first two weeks Moyer, Riess, Williams, Shaw, Test, Li, Jessup and Forman give orientation

about Wyeth computer systems to Vurimindi and two of his female team members from

Pune, India, who travelled to US for orientation.

24. In November 2004, Wyeth gave VPN connection to Vurimindi to its data servers but didn’t

give VPN connection to his team at Pune, India.

25. In November 2004, Vurimindi told to Kopko and Moyer that the VPN connectivity is vital for

successful execution the project and without the required VPN connectivity to his team in

India is detrimental to Cytel, and more specifically to Vurimindi.

26. In response, Kopko and Moyer told to Vurimindi that by the end of three (3) months

duration of the pilot program, Wyeth would provide required VPN connectivity to Vurimindi’

team in Pune, India.

27. In November 2004, soon after Vurimindi begin his work at Wyeth, prepared a

communication plan between Wyeth and Cytel and Kopko approved the communication

plan as follows: (i) All communications, including questions about validation tasks between

Wyeth employees and Cytel’ team at Pune, India office must be routed through Vurimindi.

(ii) Each SAS® program validation assignment initiated only after Kopko sign work order,

which contain details about the assignment (business requirements, technical design, user

guides and associated change control documents), work to performed, time to complete the

assignment, and hand-off procedure after Cytel complete the assignment.

28. As soon as orientation is completed, in December 2004 Kopko and Moyer asked Vurimindi

and his team to validate SAS® programs developed by Riess, Williams, Shaw and Li.

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29. Because, Wyeth didn’t give required VPN connectivity to Vurimindi’ team in Pune, India, in

order to begin validation of Wyeth’ SAS® programs, Vurimindi as temporary arrangement

replicated Wyeth’ Unix® SAS environment on Cytel’ Windows® SAS environment.

30. In December 2004, soon after orientation as per Kopko’ approved communication plan,

Vurimindi started to gather business requirements such as technical design, user guides and

associated change control documents for Cytel’ first validation assignment.

31. Riess, Williams, Shaw and Li didn’t able to provide the required details in a document

format, because Kopko’ team didn’t prepare those documents.

32. Vurimindi documented additional work that Vurimindi’ team required doing in the absence

of required documents and asked Kopko to sign the work order with additional time and

Kopko signed Work order.

33. As soon, Vurimindi documented all missing documents in his draft work order for first

validation assignment and asked Kopko to sign the work order, in December 2004, Li and

Riess in cantankerous voice told to Vurimindi that, “Vamsi, you are not a Project Manager

and you should work as programmer”.

34. Vurimindi believed that Li and Riess’ irascible response is two folded, first, they didn’t like

Vurimindi, performing duties of a project manager, because Vurimindi’ didn’t fit the image

what Li and Riess’ think a project manager should be. Second, Li and Riess had perception

that Vurimindi was inferior to them in his ability of writing SAS® programs, because Wyeth

outsourcing to reduce their operational cost and that cost reductions is a price signal that

Vurimindi and his team weren’t of high-quality counterparts.

35. In December 2004, when Kopko signing the first work order, Kopko and Moyer asked

Vurimindi, to re-execute the validation programs on Wyeth servers and archive Cytel’

validation programs in Wyeth Electronic Data Management System (“EDMS”).

36. In order to re-execute the validation programs on Wyeth’ UNIX® operating system, the

validation programs developed on Cytel’ Windows® operating system must be changed.

37. Despite, Kopko and Moyer’ request is tedious, labor intensive and additional work load on

Vurimindi, in anticipating that within three months this additional intermediary step, will be

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eliminated once Wyeth provide required VPN connectivity to his team and agreed to re-

execute the validation programs on Wyeth servers.

38. Immediately, after Kopko signed first work order, in December 2004, Vurimindi called Amrith

Raghavan (“Raghavan”), Cytel’ account manager for Wyeth, and told him and told him about

Li and Riess’ instructions to Vurimindi.

39. At that time, in December 2004, Vurimindi briefed about Li and Riess perception about Cytel

to Raghavan as follows: Li work as an independent consultant at Wyeth and as owner of Red

Oak Technologies had a special relationship with Wyeth by having a direct contract without

any intermediaries; and told that Li was paid at an average hourly rate of $120 per hour on

full-time basis for over a decade; and Riess is a Sr. SAS Programmer at Wyeth for over a

decade; because Wyeth outsourcing to reduce their operational cost that cost reductions is a

price signal that Vurimindi and his team weren’t of high-quality counterparts.

40. In response, Raghavan told to Vurimindi that, “not to worry about it and he will take care”.

41. As per Kopko’ approved communication plan, Vurimindi continue to gather business

requirements, technical design, user guides and associated change control documents for

other SAS® programs to be validated by Vurimindi’ team.

42. Li, Riess, Williams, Forman and Shah couldn’t able to provide all required information in a

document format. Vurimindi documented additional work that Vurimindi’ team required to

do in the absence of required documents and told to Kopko and Moyer how much additional

time is required by Vurimindi’ team to complete the task, without the required details.

43. In 2nd week of December 2004, immediately after Vurimindi notified Kopko about the details

of additional time requirement, while Vurimindi passing Test’ cubicle, and while Williams

and Forman were standing near Test’ cubicle, Test told to Williams and Forman, that “GSK

terminated his contract and revoked his visa last year, right around this time”. Because,

Vurimindi was told by Raghavan, not to respond to any non work related comments,

Vurimindi continued to walk towards the break room and didn’t say anything in reply to the

Test.

44. In January 2005, after Vurimindi notified Kopko about the details of additional time

requirement, Riess, Williams, Shaw, Li and Forman became aggressive towards Vurimindi

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and refused to answer any of Vurimindi’ questions concerning work, which Vurimindi was

brought to Wyeth to accomplish. This made all but impossible for Vurimindi to accomplish

his work.

45. At that time, Vurimindi reported the sudden change in the Kopko’ team members to

Raghavan and in turn, Raghavan told to Vurimindi that he will sort out the issue with Kopko

and asked Vurimindi to continue to remain calm and do the work as told by the Kopko’ team.

46. In March 2005, at the expiration of the pilot program, Vurimindi’ able to complete the first

three validation tasks and because of that, Wyeth decided to permanently contract with

Cytel to complete validation of all Wyeth’ SAS® Clinical Data Analysis and Reporting

computer programs.

47. In March 2005, soon after Wyeth signed a permanent contract with Cytel, in response Cytel

offered a permanent employment and sponsored H1B visa and begin processing Green Card

to Vurimindi to continue to work as a project manager.

48. In March 2005, according to Wyeth requirements Cytel hired a third party and conducted 10

years background search and compiled a report for Wyeth and send to Wyeth and after

Wyeth reviewing background search report Wyeth signed a permanent outsourcing contract

with Cytel and give access to Vurimindi to Wyeth’ enterprise wide software applications.

49. In April 2005, Jerald Schindler (“Schindler”), Vice President, Global Biostatistics &

Programming Department, Wyeth Pharmaceuticals resigned from Wyeth and join the Cytel.

50. At that time, there was a wide spread rumor among the Kopko’ team members that Kopko

will be the Vice President of Global Biostatistics & Programming. But, Wyeth didn’t fill that

position.

51. Between April and May 2005, Vurimindi follow through with Kopko for VPN connectivity to

Vurimindi’ team in India. But Wyeth expressed series of concerns for providing VPN

connectivity and declined to provide VPN connectivity to Vurimindi’ team in India.

52. Between April and May 2005, in response to Wyeth’ failure to provide VPN connectivity to

Vurimindi’ team in India, Vurimindi enquired Kopko. Initially, Kopko told to Vurimindi that all

Cytel employees working on the project to sign Wyeth approved confidentiality agreement.

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Then, Cytel employees working on Wyeth project signed Wyeth’ confidentiality agreements

and submitted the confidentiality agreements.

53. After submitting the confidentiality agreements, Kopko came up with a new issue that Cytel’

India site is not protected against unauthorized access and physical access control through

separate enclosed area. Then, Cytel shifted its India to a new location where physical access

control through separate enclosed area.

54. After, shifting to a new location, Kopko came with a new issue that, Wyeth must first install

system logs for data access by Cytel employees. Despite numerous requests by Cytel and

Vurimindi, Wyeth didn’t install the required system logs for data access on the Wyeth

servers.

55. Sometime after, Kopko came with a new issue that Cytel should submit a certificate from a

third party about the Cytel’ India site readiness. Vurimindi got the certificate and that time

Cytel and Vurimindi asked the Wyeth to system logs for data access. Despite another request

Wyeth failed to install the system logs for data access and again Cytel was told that until the

system logs for data access installed Cytel India site can’t access the Wyeth servers through

VPN connection.

56. In June 2005, Kopko refused to sign the work orders prepared by Vurimindi and altered

communication plan by proposing a biweekly teleconference between Vurimindi’ team in

India team and Kopko’ team members. Kopko also altered communication plan by asking his

team to directly communicate with Vurimindi’ team and bypass Vurimindi.

57. In June 2005, Williams, Shaw, Li and Forman started communicate with Vurimindi’ team

directly and told them, “Vamsi is not a capable Project Manager”, “Don’t follow his

instructions”, and told to his team members about GSK terminating Vurimindi’ employment

and subsequent revocation of his H1B visa and Vurimindi’ sexual harassment complaint with

EEOC to Vurimindi’ female team members.

58. In June 2005, after Williams, Shaw, Li and Forman disseminated negative information about

Vurimindi to Vurimindi’ team, Raghavan had an in person meeting with Kopko, Moyer, Riess,

Williams, Shaw, Li and Forman. At that time Kopko, Moyer and Williams told to Raghavan

that “Vamsi is not a capable project manager”. Immediately, Raghavan told to Vurimindi

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about Kopko’ team members comments about Vurimindi’ capabilities. Vurimindi was

terrified, with Kopko’ team members comments, because if Cytel decides to replace

Vurimindi then Vurimindi has to find an employer who can sponsor an H1B visa.

59. In June 2005, after Raghavan had meeting with Wyeth, Vurimindi assured to Raghavan that

he will do everything that is necessary to keep Wyeth remain satisfied with Vurimindi’ work.

60. In July 2005, after Vurimindi had a conversation with Raghavan, Kopko and Moyer asked

Vurimindi to work as validation programmer in addition to his existing responsibilities of

providing technical support, review, suggest and modify his team’ work product, modify and

re-execute his team’ validation programs and store his teams’ original validation programs in

Wyeth’ EDMS. Because, Kopko and Moyer added additional work by altering Vurimindi’ work

as a programmer and total work to Vurimindi increased by three folds.

61. July through December 2005, several times Vurimindi told to Kopko, and Moyer denying VPN

connectivity to his team in India, increased work load three times upon Vurimindi, so either

provide VPN connectivity to his team or add one more person onsite to modify his teams’

validation programs, re-execute and store on Wyeth EDMS. But Kopko and Moyer neither

increases the number of onsite resources nor give VPN connectivity to Vurimindi’ team.

62. July through December 2005, as Vurimindi’ team validating and find discrepancies in Riess,

Williams, Shaw, Li and Forman SAS® Programs functionality between intended vs. actual

functionality of program, and told them that they are releasing SAS® Programs without

performing adequate developer tests, Riess, Williams, Shaw, Li and Forman, instead

correcting the functionality of their SAS® Programs and perform adequate developer tests,

begin act like a gang, and in an abusive tone find fault with as to how Vurimindi worded the

discrepancy and in a mocking fashion ridicule Vurimindi’ English pronunciation and writing

style.

63. July through December 2005, when Vurimindi as part of his job responsibility, clearly

documented each discrepancy and how much time it take to re-validate after programmers

fixing each discrepancy, Riess, Williams, Shaw, Li and Forman habitually told to Vurimindi

team members not to follow Vurimindi’ instructions and told to Vurimindi’ team members

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and other Wyeth employees that “Vamsi is not a capable Project Manager “and GSK

terminated Vurimindi’ contract and revoked his H1B visa.

64. Vurimindi told to Kopko and Moyer about Riess, Williams, Shaw, Li and Forman’ verbal abuse

and their accusatory comments about Vurimindi to his teammates in India and other Wyeth

employees and asked to resist their team members from engaging in abusive behavior and

conduct towards Vurimindi. Kopko and Moyer didn’t ask their team members from engaging

in alleged abusive behavior and conduct towards Vurimindi.

65. By the end of December 2005, despite, Kopko and Moyer maintained a hostile environment,

refuse VPN connectivity to Vurimindi’ team, and didn’t increase number of onsite resources,

Vurimindi’ team validated core SAS® programs developed by Kopko’ team.

66. In December 20053, Bruce Schneider4, and Spector met someone representing Numoda5 in a

business gathering organized by a law firm Akin Gump and came to know that Vurimindi was

related to Ann Boris.

67. Bruce Schneider and Spector had long drawn rivalry with Vurimindi’ relatives, and as soon

they knew that Vurimindi work at Wyeth under their supervision begins to undermine

Vurimindi’ professional status and personal standing by way of isolation and destabilization.

68. Because, Kopko’ team become hostile towards Vurimindi and his team, in January 2006,

Cytel asked Wyeth to assign clinical data analysis work to Vurimindi’ team.

69. In January 2006, Wyeth asked Vurimindi’ team to begin clinical data analysis work and

Vurimindi’ team was quick to complete the clinical data analysis and reporting for first study,

because, Vurimindi’ team gained thorough understanding of the functionality of the SAS®

programs developed by Kopko’ team.

70. In January 2006, Vurimindi begin to interact with onsite clinical data analysts who were

managed by Zhou, because Zhou’ team QC’ ing the results of Vurimindi’ team work product.

71. In January 2006, clinical data analysts in Zhou’ team raised many questions about Kopko’

team SAS® programs and during that time Vurimindi become aware that Zhou’ team didn’t

use SAS® programs developed by Kopko’ team.

3 After the fact and the circumstantial situations lead Vurimindi to believe that, in December 2004, Bruce Schneider and Spector knew that Vurimindi is related to Ann Boris. 4 EVP and Chief of Operations Wyeth Research

5 Vurimindi’ wife Ann Boris engaged in clinical development business in the name and fashion of Numoda Corporation

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72. At that time, Vurimindi asked as to why Zhou’ team don’t use SAS® programs developed by

Kopko’ team and in response they told to Vurimindi, that Kopko’ team SAS® programs are

convoluted, complicated, and difficult to understand.

73. In January 2006, Zhou’ team suggested to use the programs that they have been using,

which was developed on ad-hoc basis. Vurimindi asked Zhou’ team, whether those ad-hoc

programs were validated and in response, they told ad-hoc programs are not validated but

those programs produce desired results. Vurimindi’ team refused to use non-validated

programs to conduct clinical data analysis work.

74. In January 2006, Vurimindi told to Kopko, Moyer and Zhou about Zhou’ team concern for

using SAS® programs developed by Kopko’ team.

75. Immediately, Zhou and his clinical data analysts, started to demoralize Vurimindi by

undermining Vurimindi’ character in the minds of Wyeth therapeutic area managers and told

to Wyeth therapeutic area managers that “Vamsi is not a capable Project Manager” and GSK

terminated Vamsi’ contract and revoked his H1B visa. Quickly thereafter Wyeth stopped

giving clinical data analysis work to Vurimindi.

76. In February 2006, Kopko and Moyer asked Vurimindi’ team to validate new changes made to

previously validate SAS® Programs.

77. In February 2006, Vurimindi’ team begins validating the changes and found it difficult to

track new changes made by Riess, Williams, Shaw, Li and Forman. At that time, Vurimindi

requested to implement Program Version Control System (“PVCS”) and based on his recent

experience with other onsite clinical data analysts, suggested to simplify the complicated

SAS programs into manageable size modules, so clinical data analysts will be able to use

SAS® Programs developed by Kopko’ team. Kopko and Moyer were dismissive about

Vurimindi suggestions.

78. Because, Kopko’ team didn't use PVCS, it become very difficult to Vurimindi to track down all

the changes made by these five different programmers Riess, Williams, Shaw, Li and Forman

at different times and it become impossible to Vurimindi to reproduce the same results that

he produced earlier.

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79. At that time, Vurimindi demonstrated the benefit of using PVCS with in Wyeth SAS

environment. Moyer didn’t agree to install PVCS system, and told to Kopko and other

managers, without PVCS, Wyeth were able to maintain the system for many years and can

still be able to maintain the system without PVCS.

80. In March 2006, Moyer begins to make comments about Vurimindi’ mental competence,

Cognitive abilities in a mocking fashion along with Williams, Shaw, Li and Forman. Moyer,

many times through hand gestures communicated with Williams, Shaw, Li and Forman to

convey “he can’t process two things at one time”.

81. Between March 2006 and June 2007, during bi-weekly teleconferences, Moyer, Williams,

Shaw, Li and Forman bombard Vurimindi with questions, even right before Vurimindi

finishing answer to their earlier question to exploit Vurimindi’ personal trait of handling one

question at a time.

82. After observing Moyer, Williams, Shaw, Li and Forman’ pattern, Vurimindi repeatedly

suggested to Moyer, Williams, Shaw, Li and Forman to send their questions one day prior to

bi-weekly meeting, such that it would allow Vurimindi to better prepare a through answer.

83. Despite, Vurimindi repeatedly suggested Moyer and others to send their questions in

advance, Moyer, Williams and Forman continue to ask complex questions without prior

notice and insist an answer from Vurimindi in that meeting. When, Vurimindi attempted to

provide an answer under the assumption of a most likely real-life scenario, then Williams

and Forman ask questions about scenarios that only possible in theory and not in practice,

when Vurimindi explain practicality, Williams and Forman start a debate, which at all costs,

Cytel asked Vurimindi to avoid, so Vurimindi back out from defending his position.

84. As soon, Vurimindi back out, Moyer, Williams and Forman in a mocking fashion, ridicule

Vurimindi’ explanation. Very few occasions, that too when Moyer, Williams and Forman

blatantly argue an impossible scenario, and Vurimindi contradict with their opinion, at that

time, Moyer, Williams and Forman told to other Wyeth employees, that Vurimindi is not a

team player.

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85. In June 2006, Kopko asked Vurimindi to re-write all validation documents written by

Vurimindi as per Forman’ advice and dictation, while Forman who just completed her tenure

as an intern and just been hired by Wyeth as programmer/analyst.

86. At that Vurimindi asked Kopko, “you just approved these documents and why do you think

that these documents must be changed” and in response Moyer, Williams, Li, and Forman

ridicule Vurimindi’ English writing style in a mocking fashion.

87. In June 2006, Vurimindi told to Cytel, about the way Moyer, Williams, Li, and Forman is

treating Vurimindi and immediately, in a bi-weekly meeting, Kopko made remarks against

Vurimindi and told to Moyer, Williams, Li, and Forman that Vurimindi is a “Hot Potato” and

“Tattle teller”. When Kopko make a remark at Vurimindi is a “Hot Potato”, he is implying

that Vurimindi is an unpleasant and risky to deal as a person. When Kopko make a remark at

Vurimindi is a “Tattle teller”, he is implying that Vurimindi is snitching and informing to

Kopko’ higher-ups on Kopko, Moyer, Williams, Li, and Forman. However, Vurimindi always

humble with Kopko and his team and didn’t snitch on them. Kopko made a deliberate

attempt to mischaracterize Vurimindi among his team members.

88. In July 2006, once again Vurimindi begin his efforts to get clinical data analysis work from

Wyeth. At that time, Spector, Kopko, Moyer and Williams made depreciatory remarks about

Vurimindi to Wyeth therapeutic area managers, and other Wyeth employees as Vurimindi is

slow and don’t have interest in the work and that is why there is no progress in Vurimindi’

work.

89. In July 2006, upon enquiry Vurimindi found that Spector, Kopko, Moyer and Williams are

saying that Vurimindi didn’t complete the validation documents since two (2) years, when

Kopko and Moyer asked Vurimindi to rewrite all signed off validation documents as per

Forman instructions just recently.

90. In November 2006, Wyeth hired Cyrus Hoseyni (“Hoseyni”) as the Vice President of Global

Biostatistics & Programming and Chief Statistician. By that time, Vurimindi and his team re-

write all validation documents and validated all new changes made to SAS ® Programs and

look forward to begin work on Clinical Data Analysis.

Page 23 of 85

91. As soon, Hoseyni assumed his position at Wyeth, begin to reorganize Wyeth’ Global

Biostatistics and Programming division and made Zhou as head of clinical programming area

and Hoseyni begin to direct his comments at Vurimindi as “we will box him”. At that time,

Vurimindi was under the impression that, Hoseyni means that he is referring to Hoseyni’

effort of re-organizing the organizational chart and place Vurimindi in one of the boxed in his

organization chart. However, after that fact, Hoseyni meant to send Vurimindi out of Wyeth.

92. In December 2006, Kopko and Moyer assign validation of Wyeth’ Application Framework

environment (“CIDER2B”, “CIDER3”) SAS® programs and PL/SQL programs work to Vurimindi’

team.

93. At that time, Vurimindi told to Kopko and Moyer that Cytel crafted Vurimindi’ team to work

as Clinical Data Analysts, and not work on 100% validation assignments. In response, Moyer

told to Vurimindi that validating SAS® and PL/SQL programs for CIDER2B and CIDER3 is their

priority and as soon Vurimindi’ team complete the validation, they can start work on clinical

data analysis.

94. In December 2006, Vurimindi begin to interact with William Bond (“Bond”) Director, IT

Systems, who manage Wyeth Application Framework environment and commenced

validation of SAS® and PL/SQL programs. Vurimindi found that there are several

programmatic issues within CIDER2B and CIDER3 and those issues must be fixed first, in

order to develop, test and validate the SAS® and PL/SQL Programs.

95. Kopko and Moyer had prior knowledge, because few months earlier, when Williams started

to develop SAS Programs she found the same problem that Vurimindi found. However,

Kopko and Moyer didn’t inform the known issues to Vurimindi, prior to his team start

working on this assignment.

96. In December 2006, Vurimindi contacted Bond and told him about the issues and in response

he told to Vurimindi that a new patch has to be released to fix those issues, nonetheless

Bond’ team failed to release a new patch to fix the issue.

97. In December 2006, Vurimindi told to Kopko and Moyer to pursue with Bond to release the

required patch sooner than later, but, Kopko and Moyer failed to pursue Bond’ team to fix

the issue.

Page 24 of 85

98. In January 2007, Kopko and Moyer told to Hoseyni that Vurimindi didn’t work hard to find

ways to develop the SAS® and PL/SQL Programs instead, simply escalating the issue.

99. In January 2007, Hoseyni enquired Vurimindi, and suggested to work hard to find ways to

develop the SAS® and PL/SQL Programs. In response, Vurimindi told to Hoseyni that, in fact,

few days before he demonstrated the issue with the CIDER2B and CIDER3 Application by

showing the different versions of the code that Vurimindi developed to find a work around

solution and to that effect Kopko and Moyer agreed with Vurimindi that the CIDER2B and

CIDER3 application must be fixed, in order to successfully develop the SAS® and PL/SQL

Programs.

100. In February 2007, Moyer, Williams and Forman asked Cytel to replace Vurimindi and

immediately, Cytel enquired Vurimindi about his work situation at Wyeth.

101. In March 2007, Hoseyni, Zhou, Kopko, Moyer, and Williams told to Wyeth therapeutic area

managers that, Vurimindi is not capable to handle clinical data analysis work and asked Cytel

to replace Vurimindi.

102. In March 2007, Vurimindi heard from other Wyeth employees that Cytel is replacing

Vurimindi. At that time Vurimindi’ application for permanent residency is pending and must

stay with Cytel to get his permanent residency, so Vurimindi became anxious and nervous

and asked Kopko, Moyer, and Williams why they ask Cytel to replace Vurimindi, but their

response was vague and abrupt.

103. In March 2007, Hoseyni proposed to outsource clinical data analysis work to Accenture.

104. In March 2007, Kopko and Moyer assigned a task of annotate Case Report Forms (CRFs) to

Vurimindi’ team, which Wyeth SAS programmers consider as menial task.

105. In April 2007, Zhou begins to make depreciatory statements about Vurimindi’ team work

product of annotate Case Report Forms to many Wyeth therapeutic area managers that

Vurimindi and his team isn’t capable to annotate Case Report Forms, despite Vurimindi’

team correctly annotated and the same annotated Case Report Forms submitted to FDA

without doing re-work.

106. In April 2007, Kopko and Moyer told to Vurimindi that Wyeth don’t extend its contract with

Cytel.

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107. In April 2007, Vurimindi suggested to Cytel to pursue Hoseyni to get the contract to migrate

the 900 clinical studies data from Wyeth data standards to the CDISC® data standards,

because it is paramount to Vurimindi to continue to work with Cytel, because, Vurimindi’

application for his permanent residency in USA was pending and Cytel was his sponsor.

108. In May 2007, Hoseyni signed a contract with Accenture to migrate clinical studies data.

109. In May through June 2007, Vurimindi took a course on CDISC® data standards, because

Wyeth need a person who is through in Wyeth data standards and as well as CDISC® data

standards.

110. In May 2007, Vurimindi begins explore alternative arrangement for his H1B Visa and Green

Card sponsorship and opportunities to get admitted into an MBA program, and applied for

an admission into a Pre-MBA course at Wharton.

111. In June 2007, Wyeth terminated the contract with Cytel.

112. In June 2007, prior to end of the contract between Wyeth and Cytel, Vurimindi contacted

Kopko and Moyer and asked whether they can hire Vurimindi as an independent consultant

for the duration of his MBA program with direct contract with Wyeth, similar to the

arrangement that they made with Li and Lijun Tian6 (“Tian”).

113. In response, Kopko and Moyer told to Vurimindi that Hoseyni proposed to canalize all

existing contract staff through Inventive and revising hourly bill rates. If Vurimindi wants a

job, they can hire Vurimindi through Inventive at an annual pay rate of $120,000, which

Kopko and Moyer believe is less than Vurimindi is being paid by Cytel.

114. In June 2007, in response, Vurimindi asked Kopko and Moyer to provide flexible work hours

through the duration of his MBA program and agreed to work at Wyeth through Inventive.

115. In June 2007, Kopko and Moyer told to Vurimindi that they can hire Vurimindi as CDISC®

Subject Matter Expert for the duration of MBA program at an annual pay rate of $120,000.

116. In June 2007, in response, Vurimindi agreed to take less money, if Wyeth can promise to

keep Vurimindi for the duration of his MBA program.

6 Tian joined Wyeth in 2004 and prior to that worked for Cephalon; between years 1992 and 1996 worked in Psychology

Department at UPenn and studied Actuary Science at Wharton; and was acting chair for Peking University Philadelphia

Alumni (PUPA) for many years.

Page 26 of 85

117. Kopko and Moyer agreed to keep Vurimindi through the duration of his MBA program and

asked Vurimindi to submit his employment application with Inventive.

118. In June 2007, immediately after the meeting, Vurimindi submitted application with Inventive

and Inventive hired Vurimindi, at the salary agreed upon with Kopko and Moyer.

119. Based on Kopko and Moyer’ assurance and quick hiring Vurimindi at agreed upon salary,

Vurimindi believed the promises made to him by Kopko and Moyer and relying on the their

promises, Vurimindi then get admitted in his Pre-MBA course at Wharton7 and begin the

process of admittance into an MBA program.

120. In July 2007, Vurimindi started his work as for the CDISC® Subject Matter Expert at Wyeth.

Vurimindi reported to Kopko and his day to day tasks are managed by Moyer.

121. In July 2007, Vurimindi came to know that, Tian continue to work as an independent

consultant at Wyeth and had direct contract with Wyeth at an hourly bill rate of $100, which

equates to over $200,000 per year, which is approximately $80,000 higher than that Wyeth

paid to Vurimindi.

122. In July 2007, Accenture deployed two management consultants Daniel Farina (“Farina”) and

Jeff Neal (“Neal”) to scope data migration project that Hoseyni recently awarded to

Accenture.

123. Vurimindi was responsible to prepare standard data migration technical and functional

requirements based on CDISC® standards, Peter Cheng (“Cheng”), an Accenture’ employee

was responsible to implement technical and functional requirements and Tian was

responsible to validate data results after data migration technical and functional

requirements are implemented.

124. Between July and September 2007, Vurimindi worked closely Kopko, Moyer, Tian and Cheng

to finalize standard data migration technical and functional requirements based on CDISC®

standards.

7 In July 2007, when Vurimindi attending classes at Wharton through self finance, Vurimindi found that Wyeth sponsored

its employee, Neeraj Bagga (“Bagga”) into the same class of Vurimindi and Bagga work with Bond, Cheng, Farina and Neal.

At the same time Encorium, a CRO who had satellite office in King of Prussia, sponsored Hank Davis (“Davis”) into the same

class of Vurimindi. Davis worked in the past at Wyeth as Clinical Scientist.

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125. In September 2007, Vurimindi produced standard data migration technical and functional

requirements based on CDISC® standards; Cheng wrote PL/SQL code to implement data

migration technical and functional requirements; Tian wrote SAS® code to validate the

results after implementing technical and functional requirements.

126. Until 3rd week of October 2007, Vurimindi, Kopko, Moyer, Cheng and Tian worked together

as a team and work is completed in a timely fashion.

127. In October 2007, Wyeth was very quick to give VPN connectivity to Accenture team in

Bangalore, India to Wyeth secure data servers and after 3rd week of October 2007, data

migration and validation work has been transferred to Accenture’ team in Bangalore, India.

128. In October 2007, Kopko and Moyer asked Cheng and Tian begin to supervise Accenture’

team in Bangalore, India.

129. In November 2007, data migration progressed from legacy to the ongoing clinical studies,

Accenture team at Bangalore, India asked Vurimindi to prepare customized technical and

functional requirements separately for each clinical study.

130. At that time, Vurimindi asked more information from Accenture team as to why customized

technical and functional requirements are required for standard data tables. In response,

Accenture team told to Vurimindi that PL/SQL code developed by Cheng wasn’t designed to

handle simple differences between the studies, arise due to changes overtime in the way

clinical studies were setup.

131. In November 2007, in response, Vurimindi suggested Kopko, Moyer, Cheng and Tian to

modify PL/SQL code to automatically recognize the data pattern and transform data into pre

determined data format at least for standard data tables. If any other consultant with

software programming experience were in Vurimindi’ position would also, suggest improving

PL/SQL code to automatically detect the data pattern.

132. Nonetheless, for reasons not known to Vurimindi at that time, Kopko, Moyer, Cheng and

Tian dismissed Vurimindi’ suggestion and asked to prepare customized technical and

functional requirements for each study separately. Vurimindi begins preparing customized

technical and functional requirements for each study separately.

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133. In November 2007, added additional task to verify the results of the migrated data with his

technical and functional requirements. During verification, Vurimindi found the data was not

migrated per standard technical and functional requirements.

134. In November 2007, Vurimindi reported the discrepancy to Kopko and Moyer and

immediately, Cheng, Tian, Farina and Neal asked Vurimindi not to document discrepancies.

Immediately, Vurimindi told to Kopko and Moyer about Cheng, Tian, Farina and Neal

demand. Kopko and Moyer asked Vurimindi not to document discrepancies.

135. Right after that, in November 2007, Vurimindi prepared a prototype of PL/SQL code to

demonstrate how easy to built–in minimum automation and showed to Kopko, Moyer,

Cheng, Tian, Farina and Neal.

136. Immediately, Farina and Neal was furious with Vurimindi and asked to stay away from

implementation of technical and functional requirements and in retaliation, begins to point

petty issues, such as color and formatting of the text in Vurimindi’ technical and functional

requirements document and blown those issues out-of-proportion.

137. Immediately right after that, in November 2007, Moyer proposed a daily working session

between Vurimindi, Moyer, Farina, Neal, Tian and Cheng and Moyer, Farina and Neal set

majority opinion as decision criteria as to how to resolve a technical and functional

requirements issue, when there is no consensus among the three Vurimindi, Tian and Cheng.

138. In general most of data migration technical and functional requirement issues arise due to

the PL/SQL code can’t migrate data per technical and functional requirements. Generally,

Vurimindi suggests to improve PL/SQL code, which was developed by Accenture, but Moyer,

Tian and Cheng oppose Vurimindi’ suggestion. When, Vurimindi attempt to explain

ramifications for not following the CDISC® standards, Moyer use his authority over

Vurimindi, and ask Vurimindi to type technical and functional requirements, how Farina and

Neal want;

139. Since November 2007 onwards, everyday in the daily working session Moyer, Tian, Cheng,

Farina, and Neal squash Vurimindi’ ability to be creativity, in preparing technical and

functional requirements and validating migrated data in a way that is most productive for

Vurimindi and Wyeth. Verbally abused Vurimindi for frivolously reasons, such as letter font

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size, color of the font in the technical and functional requirements document; Angrily, in an

accusatory style conversations are routine against Vurimindi, when Vurimindi suggest to

improve PL/SQL code and others Accenture process to eliminate irregularities in Accenture

work product;

140. Since November 2007 onwards, everyday in the daily working session Moyer, Tian, Cheng,

Farina, and Neal habitually had angry conversations with Vurimindi and said “Hoseyni and

his next three levels of upper management is not happy with you, because you are not

producing technical and functional requirements as per our direction” and instruct Vurimindi

what to type as technical and functional requirements and how to format the text in the

excel document.

141. In an essence, Moyer, Tian, Cheng, Farina, and Neal together changed Vurimindi’ CDISC®

Subject Mater Expert job description by making Vurimindi’ expert opinions insignificant and

constrained Vurimindi’ individuality and created role ambiguity by over controlling

Vurimindi’ work, which, caused Vurimindi to suffer from fatigue, inability to sleep,

moodiness, and anxiety.

142. Despite, data migration technical and functional requirements were prepared as told by

Moyer, Farina, Neal Tian and Cheng, Accenture’ team at Bangalore, India couldn’t able to

implement data migration technical and functional requirements using PL/SQL code.

143. In response, in November 2007, Vurimindi suggested to use SAS® software to implement

data migration technical and functional requirements. Immediately, Farina, Neal and other

Accenture’ employees publically, angrily, in an accusatory style accused Vurimindi, causing

delay.

144. Immediately right after that, in November 2007 Vurimindi asked Kopko and Moyer to

intervene and analyze the Accenture process to identify the real issues, despite that, Kopko

and Moyer didn’t intervene and analyze the Accenture process to identify the real issues.

145. In November 2007, after Kopko and Moyer didn’t respond to Vurimindi’ request to identify

real issues, Vurimindi wrote an email to Kopko and Moyer to explain the benefit to Wyeth

from improving the PL/SQL code to automatically detect data patterns and transform the

values as per the standard data migration technical and functional requirements; and

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alternatively if improving the PL/SQL code is cost prohibitive, suggested to use SAS®

software to implement data migration technical and functional requirements. In response,

Kopko and Moyer dismissed Vurimindi’ proposals and instructed to follow Accenture’ Farina

and Neal’ direction.

146. Vurimindi’ first proposal, improving PL/SQL code would reduce the total number of people

and time it takes to complete the implementation, which ultimately reduce the total

contract price to Accenture. Vurimindi’ second proposal, using SAS to implement data

migration technical and functional requirements, would reduce the total number of people

and time it take to complete the implementation and also Accenture must re-tool its team

who has expertise in SAS® software. This second proposal possibly might have some limiting

effect on Chang, Clark and their Bangalore, India team’ role in the implementation of data

migration technical and functional requirements.

147. In November 2007, there was a wide spread rumor among the Wyeth employees, that Pfizer

might takeover Wyeth and while the rumor is widespread, Vurimindi believed that Kopko

and Moyer would have more reason to ask Accenture to adopt an efficient process. It was

surprising to Vurimindi, that Kopko and Moyer as senior employees at Wyeth, and Moyer is

an adjunct professor for Computer Science at Montgomery Community College and

specifically teach object oriented programming languages, were actively supporting

Accenture’ inefficient process, without insisting Accenture to improve efficiency either by

enhancing the PL/SQL code or implementing the data migration technical and functional

requirements with much easier SAS software.

148. It appear to Vurimindi, that Kopko and Moyer are under some pressure for not to make any

changes to data migration project; or they might have been allowing the Accenture for

adopting inefficient process, with a long-term view that if in case anything happen to their

employment within Wyeth, they could leverage this “social currency” to get a job at

Accenture.

149. In November 2007, Kopko, Moyer, Farina and Neal met Hoseyni and told him that Vurimindi’

suggestions are useless. Soon after that, Hoseyni called for an open forum meeting and two

days prior to the open forum meeting, Kopko, Moyer, Farina and Neal called for a rehearsal

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meeting and at the end of the meeting Kopko and Moyer suggested to Vurimindi not to

speak in the open forum meeting. As per, Kopko and Moyer suggestions, Vurimindi didn’t

talk in the open forum meeting.

150. In November 2007, in that open forum meeting Kopko, Moyer, Farina and Neal told to

Hoseyni that Vurimindi is a ‘maverick’ and bottleneck for data migration project and

Vurimindi making suggestions in bad faith. When Kopko make a remark at Vurimindi is a

“maverick”, he is implying that Vurimindi is a disruptive element and no one else agrees with

Vurimindi’ point.

151. In November 2007, after open forum meeting, Hoseyni asked Vurimindi as to why Vurimindi

didn’t speak in the open forum meeting, and in response Vurimindi send an email explaining

the technical issues that stifling the progress of the data migration work. After receiving

Vurimindi’ email, Hoseyni told to Vurimindi that he will talk to Kopko and Moyer, but didn’t

seek any further information from Vurimindi.

152. In November 2007, immediately after open forum meeting, Vurimindi begins hearing many

depreciatory rumors among student body at Wharton, such as “Vamsi is not capable to

handle managerial responsibilities”, “was a Juvenile delinquent”, and “didn’t pass high

school” which seriously undermine Vurimindi’ credibility as a student and as a professional.

153. Vurimindi believe that Wyeth and Accenture employees reached Vurimindi’ classmates

through Tian, Hank, and Bagga.

154. In November 2007, immediately after open forum meeting, Vurimindi observed that his

work computer is closely monitored and Vurimindi became aware that his computer is

closely monitored only after, Kopko, Moyer, Farina, Neal, Tian and Cheng start whispering

about Vurimindi’ computer activity. When, Vurimindi enquired Farina, Neal, Tian and Cheng,

“how can you exactly talk what I am doing on my computer”, at that time they were

dismissive.

155. In November 2007, after Vurimindi hear rumors at Wharton and start believing that his work

computer is closely monitored, Vurimindi contacted Kopko and Moyer and asked them to

allow Vurimindi to complete his Pre-MBA program at Wharton and MBA program that he

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planned to enroll. At that time, Kopko and Moyer re-assured Vurimindi that they will retain

Vurimindi through his MBA program.

156. Right after that, in November 2007, Vurimindi made applications for his admission into

weekend MBA programs. Hoseyni, Kopko and Moyer write recommendation letters on

behalf of Vurimindi to the Duke, UPenn, Yale and University of Virginia.

157. In November 2007, Hoseyni enquired Vurimindi, about data migration project and

encouraged to make suggestions to improve the data migration process. At that time

Vurimindi explained his earlier two proposals that he made with Kopko and Moyer which

were dismissed.

158. Right after Vurimindi had a conversation with Hoseyni, in November 2007, Vurimindi’ work

desk was moved to a location where there is not enough natural light from right opposite

from Hoseyni’ office.

159. Between December 2007 through February 2008, despite Vurimindi continued to follow

Accenture’ Farina and Neal’ suggestions, Wyeth Managers (Hoseyni, Spector, Zhou, Kopko,

Moyer, and Williams) and Accenture employees continue to relay as to how Vurimindi was

shut-out at Wyeth and his day to day activity to Vurimindi’ classmates Wharton.

160. In the middle of February 2008, Kopko and Williams together enquired the status of

Vurimindi’ MBA admission and in response, Vurimindi told to Kopko and Williams that

Vurimindi was accepted by the Fuqua School of Business, Duke University and classes will

start from 15th March 2008. In response, Kopko and Williams both whispered that “if it is

Duke, then it is very easy for us”. At that time, Vurimindi asked Kopko and Williams, that

what are they talking about, but they didn’t responded to Vurimindi.

161. In 4th week of February 2008, Vurimindi approached Kopko and Moyer and requested

flexible work hours as promised and asked similar to the arrangement made by Kopko with

Baldovin. But, Kopko and Moyer denied Vurimindi’ request and offered an alternative work

schedule, that Vurimindi can complete is 40 hour week in four days and take Friday off to

attend the his weekend classes.

162. In 4th week of February 2008, when Vurimindi asking for flexible work hours, during that

conversation, Moyer told to Vurimindi, by completing an MBA, you don’t get paid more than

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what you have been getting paid, despite Kopko and Moyer continued to pay over $200,000

per anum to Tian, despite Tian didn’t have an MBA.

163. Sometime between 4th week of February and 2nd week of March 2008, Wyeth Managers

(Hoseyni, Spector, Zhou, Kopko, Moyer, and Williams) purposefully contacted Vurimindi’

classmates and Professors at Duke through Wyeth third party vendors such as (Accenture,

Inventive, Octagon Research, ClinForce, etc). More specifically, Wyeth Managers (Hoseyni,

Spector, Zhou, Kopko, Moyer, and Williams) contacted someone at Duke Administration and

told them that “Wyeth couldn’t able to verify Vamsi’ credentials” and he shouldn’t be

admitted into MBA program. James Walker, CEO of Octagon Research, and an Alumni of

Fuqua School of Business contacted Duke Administration on behalf of Wyeth Managers and

obtained list of Vurimindi’ classmates and give to Kopko and Moyer.

164. After 4th week of February and sometime before 2nd week of March 2008, Kopko, Moyer,

Zhou and Hoseyni contacted Vurimindi’ classmates and told them “Vamsi is not a good fit

within Wyeth and not capable to handle managerial responsibilities”, “we couldn’t able to

verify Vamsi’ credentials”, “Vamsi was a Juvenile delinquent” and “Vamsi didn’t pass high

school”.

165. In March 2008, Vurimindi started attending his Weekend MBA(“WEMBA”) classes at Duke

University, Raleigh, NC, which Vurimindi self financed the course. Even before, Vurimindi

introduce himself to other students in his class, and on the first day of the WEMBA program

Vurimindi’ classmate Moira Ringo (“Ringo”) a GlaxoSmithKline employee, gathered other

students Jason Link (“Link”) and David Mitchell (“Mitchell”) near to Vurimindi and dubbed

Vurimindi is a ‘cheater’ and subsequently Mitchell suggested to Vurimindi to read a book

about, “How to Lie Without Getting Caught” by the lie detector.

166. In March 2008, immediately, thereafter, Vurimindi classmates at Duke told to other

classmates that, “Vamsi is having rough time at Wyeth; Vamsi has been demoted, because

he is messing with Accenture”. Since thereafter, Vurimindi’ classmates periodically told to

Vurimindi, “Vamsi, you are going to be fired from your job”. When Vurimindi asked, “How do

you know?” his classmates response was vague and abrupt.

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167. In April 2008, during bi-weekly meeting, Clark and Bond told to Vurimindi, “Vamsi we don’t

want to cause any more trouble to you, than that you already been exposed, so it is better

for you not to point issues in our work”. At that time, Vurimindi asked Clark and Bond what

you mean by that statement. In response, Clark and Bond told to Vurimindi that “you know

what you are up to at your school”. In response, Vurimindi told to Clark and Bond as, “I am

only raising genuine issues that are in violation to the CDISC® data standards and my job

responsibility is to prepare the data migration rules as per CDISC® data standards and don’t

have any other motives”. Right after that, Clark and Bond didn’t responded back to

Vurimindi. After this Bond turn towards Clark, and said in a very loud voice, while Vurimindi

was in the meeting room, “He is OK, here; why he is nervous there at the School?” In the

same meeting, Kopko and Moyer told to Vurimindi that “CDISC® data standards are only

guidelines and we need not follow” and “we have more important work at hand and don’t

have time to talk about philosophy”.

168. At that time, it is clear to Vurimindi that, if Vurimindi raises any issue at work, Kopko, and

Moyer along with Accenture employees create trouble to Vurimindi at Duke University. So,

between April and June 2008, Vurimindi didn’t raise any issues, and requested Moyer to

setup a quick meeting between with Tian, Cheng, Farina and Neal to sort out personal

differences, but Moyer didn’t setup a meeting. In spite, Vurimindi has been doing whatever

Kopko, Moyer, Tian, Cheng, Farina and Neal asked Vurimindi to do, but Vurimindi classmates

continue ridicule Vurimindi in a mocking fashion how Moyer, Tian, Cheng, Farina and Neal

control Vurimindi’ work.

169. In July 2008, Sarah Rosen Shah (“Rosen Shah”), admissions counselor for Vurimindi at Duke,

purchased a condo in Hoopskirts Factory Lofts Building, and relocated from Raleigh, NC to

Philadelphia, PA. Immediately, thereafter Rosen Shah conferred Vurimindi’ private and

confidential information that she obtained as part of admission application, along with the

false information, baseless allegations and stories branched out of Vurimindi’ situation at

Duke University to several people in and around Vurimindi’ neighborhood. Thereafter,

Vurimindi was simultaneously subjected to harassment at distinct environments (1) Wyeth

(2) Wharton, (3) Duke University and (4) in and around Vurimindi’ residence, based on same

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false information, baseless allegations and stories, branched out of situations during

Vurimindi’ time at Wyeth, Wharton, and Duke.

170. In July 2008, Vurimindi wrote an email to Moyer and told him that Accenture's bullying

tactics, insults and harassment caused emotional pain and Vurimindi suffering from resulting

effects. Vurimindi asked Moyer to intervene and put a stop to Accenture's unethical,

unprofessional and unlawful behavior. Nevertheless, Moyer didn’t respond to Vurimindi’

email. Cheng, Tian, Farina and Neal continued to instruct Vurimindi in an abused tone what

to type in the data migration technical and functional requirements document.

171. By August 2008, Vurimindi prepared data migration rules documents for 45 clinical studies,

whereas Accenture team migrate 15 clinical studies data and Accenture team continued to

have issues with PL/SQL code.

172. In August 2008, Hoseyni enquired Vurimindi about data migration project and Vurimindi told

to Hoseyni that Accenture team was reluctant to improve PL/SQL code and distracting

everyone by escalating non-issues blow out of proportion.

173. In August 2008, immediately next In August 2008, in continuation Vurimindi told to Hoseyni,

that Vurimindi estimated the true cost of data migration based on the activity and resource

utilization, and told to Hoseyni that current Accenture process costing Wyeth an average

$78,000 to migrate single clinical study, where as if SAS® software is used, the actual cost

could be brought down to approximately $15,000.

174. day after Vurimindi had conversation with Hoseyni, Vurimindi prepared SAS code for two

tables that exactly have the functionality that Vurimindi is proposing to add to PL/SQL code,

which was developed in four (4) hours of Vurimindi’ own time, and attached SAS code with

his email, and told to the Hoseyni that, in about 2 to 3 weeks, Vurimindi can develop the SAS

code for all tables. At that time, Hoseyni told to Vurimindi that he will get back to Vurimindi,

but didn’t ask any further questions.

175. In August 2008, immediately after Vurimindi send prototype SAS® code to Hoseyni, Kopko

and Moyer changed Vurimindi’ cubicle, to a place where previously an administrative

assistant to Kopko use to sit and moved Krishna Padmanabhan (“Padmanabhan”), a

Biostatistician, next to Vurimindi’ cubicle.

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176. In August 2008, Vurimindi introduced himself to Padmanabhan, in turn Padmanabhan told

to Vurimindi that he hails a neighboring state Vurimindi’ in India. Then, Vurimindi assumed

that Padmanabhan don’t understand Vurimindi’ native language. But, Vurimindi become

aware that Padmanabhan understand Vurimindi’ native language, only after Vurimindi

realized that Padmanabhan eavesdropping into Vurimindi’ conversations.

177. In October 2008, Vurimindi realized that, Padmanabhan listen to Vurimindi’ conversations

with his relative about his situation at Wyeth and Duke and relay that information to his

supervisor Vladimir Dragalin (“Dragalin”), Senior Director, Michael Krams (“Krams”), VP

Adaptive Trials and Applied Program Strategies at Wyeth and other Wyeth employees. Then

Vurimindi asked Padmanabhan to stop eavesdropping and relay such information to others.

178. In October 2008, Padmanabhan and Dragalin together contacted Wyeth security and HR

department and told them that Vurimindi is threatening Padmanabhan. Few days later,

Padmanabhan told to Vurimindi, “Do you think that we don’t know anyone within Wyeth?”

Your contract will be terminated soon”. Immediately, Vurimindi contacted Kopko and Moyer

and told them about Padmanabhan’ statements. At that time, Kopko and Moyer told to

Vurimindi, “Don’t not worry about your contract, just do your work”.

179. In October 2008, next weekend, when Vurimindi go to Duke for his classes, Vurimindi’

classmate Lei Zhu (“Zhu”) a statistician working for GlaxoSmithKline, told to Vurimindi that

“you will be fired from your job.” Since then Zhu constantly ridicule Vurimindi’ work

situation in front of his classmates at Duke and Padmanabhan and Dragalin ridicule

Vurimindi at Wyeth campus for Vurimindi’ situation at Duke. Upon, enquiry, Vurimindi came

to know that, Dragalin worked at GSK along with Zhu. At that time, it is evident to Vurimindi

that Padmanabhan and Dragalin are in contact with Zhu.

180. In November 2008, Hoseyni signed a contract with MediData to prepare customized data

migration technical and functional requirements document, and eliminated ONLY Vurimindi’

position, but didn’t inform Vurimindi that they have eliminated Vurimindi’ position.

181. In 1st week of November 2008, Kopko and Moyer told to Vurimindi to annotate CRFs and

that too under the supervision of Tian, Cheng, and Farina.

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182. Despite, Vurimindi diligently did his work and obtaining high value education from Wharton

and Duke, Kopko and Moyer assign menial tasks to Vurimindi and make Vurimindi to follow

instructions from consultants or Wyeth employees don’t have as much experience or

knowledge that he brings to Wyeth and hoped that the situation would improve and thought

that Wyeth Managers (Hoseyni, Spector, Zhou, Kopko, Moyer, and Williams) start treating

Vurimindi at least at par with other employees and consultants.

183. In November 2008, soon after Kopko and Moyer asked Vurimindi to annotate CRFs, the

monotony of annotating CRFs, role conflict and ambiguous demands by Kopko and Moyer, at

one side they are asking Vurimindi to prepare the data migration technical and functional

requirements per CDISC® standards, and simultaneously use their power over Vurimindi to

write the data migration technical and functional requirements in contradiction to CDISC®

standards; and despite Vurimindi attending Wharton and Duke University to gain high value

education, Kopko and Moyer, demoting Vurimindi from CDISC® Subject Matter Expert to CRF

Annotator; and lack of opportunity for advancement; and repetitive low level tasks,

unrealistic workloads and short timelines to annotate the CRFs, Vurimindi attempted to

reach out Kopko.

184. In December 2008, Vurimindi wrote an email to Kopko and requested a performance

evaluation, job & task analysis and told him that Vurimindi is about to complete his Wharton

course and joined his MBA program at Duke and it is a perfect time to re-evaluate his career

growth strategy. In order to finalize his strategy, asked Kopko’ opinion about his

performance. But, Kopko didn’t respond to Vurimindi.

185. In December 2008, after Kopko didn’t respond to Vurimindi, it become clear to Vurimindi

that Wyeth is about to terminate his contract, because Kopko and Moyer’ actions such as

over controlling, demotion, assign menial tasks, frequently changing Vurimindi’ work desk,

lead Vurimindi to believe that Vurimindi’ job is coming to an end.

186. In December 2008, after Kopko didn’t respond to Vurimindi, Vurimindi contacted Hoseyni

and enquired for a permanent job opportunity and Hoseyni told to Vurimindi that once he

complete his MBA, Vurimindi could be recruited by Wyeth at a different role and at the

moment Wyeth froze all hiring.

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187. In December 2008, Vurimindi contacted Wyeth’ HR Manager, Jennifer Hanson and enquire

about job opportunities within Wyeth. In response, Jennifer Hanson told to Vurimindi’ that

currently Wyeth froze all hiring. Immediately, thereafter Vurimindi contacted Dennis

Peppered, Sr Vice-president for Human Resources at Wyeth and communicated Vurimindi’

intention to become an employee of Wyeth. But, Dennis Peppered never replied to

Vurimindi’ communication.

188. In December 2008, despite Hoseyni told to Vurimindi Wyeth froze all hiring, Hoseyni hired

two Accenture employees, Melissa Binz (“Binz”) as Director, Central Standards Group and

Debra Rittenhouse (“Rittenhouse”) as Asst. Director, Central Standards Group. After that,

Hoseyni and Binz filled several positions, but completely bypassed Vurimindi.

189. In December 2008, prior to Christmas holidays, Kopko gave $10.00 gift certificate as bonus

for the year 2008 and told to Vurimindi that, “Vamsi, you might have better chances to make

money by buying lottery tickets”, implying that, the chance of getting a job within Wyeth is

similar to the chance of winning a lottery ticket.

190. In December 2008, after Kopko give $10.00 gift certificate, Kopko told to Vurimindi that as

“If you one more time talk to my boss, you are out from here”.

191. In December 2008, Inventive refused to enroll Vurimindi into its health benefit plan for the

year 2009. When, Vurimindi insisted to enroll into health benefit plan, Paul Freeman

(“Freeman”), Program coordinator for inVentiv Clinical Solutions at Wyeth, told to Vurimindi

to find a job somewhere else, who can offer health benefits for the year 2009. At that time

Vurimindi asked, Freeman, “What made him to say like that?” Freeman didn’t respond to

Vurimindi.

192. In December 2008, after having a conversation with Freeman, Vurimindi enquired Kopko and

Moyer and asked, “Why Freeman is asking me to find another job?” “Did you inform him

that my contract is getting terminated?” In response, Kopko and Moyer told to Vurimindi

that, “you are reading into too much into the health benefits issue. Don’t worry about your

job.”

193. In December 2008, after Vurimindi contacting Wyeth HR, an unknown Vurimindi’ classmate

made a complaint against Vurimindi plagiarized his class work and another unknown

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Vurimindi’ classmate made complaint against Vurimindi that they saw that Vurimindi

carrying a gun in Duke campus. Vurimindi wasn’t informed by Duke immediately after they

received complaints against Vurimindi.

194. When Vurimindi attending for his MBA at Duke, Vurimindi also enrolled into Duke’ Health

Sector Management (“HSM”) program. In the 1st Week of January 2009, Duke and as part of

HSM program, organized a week long immersion program with PhRMA, FDA, Public Citizen,

Office of Management and Budget at White House in Washington DC.

195. In January 2009, prior to Kopko asking Vurimindi to tender his resignation, Specter, Kopko,

Moyer, Zhou and Hoseyni contacted statisticians at PhRMA (The Pharmaceutical

Manufacturers Association) and told them “Wyeth couldn’t able to verify Vamsi’

credentials”, “Vamsi was a Juvenile delinquent”, “Vamsi is not a good fit within Wyeth” and

“Vamsi is not capable to handle managerial responsibilities”, when PhRMA represents the

country’s leading pharmaceutical research and biotechnology companies and have access to

every pharmaceutical company in US and around world.

196. On 14th January 2009, after Vurimindi returned from his weeklong Washington DC trip, and

just 10 days before Vurimindi’ Term 3 final examinations, John Gallagher (“Gallagher”),

Assistant Dean, Fuqua School of Business, called Vurimindi on his mobile telephone, when

Vurimindi is at Wyeth and asked whether Vurimindi carried a gun on Duke University

campus. Vurimindi was shocked for that question and replied that Vurimindi never carried a

gun on the campus. At that time, Vurimindi reminded to the John Gallagher that Vurimindi

travel to Duke by flying through commercial airline and passing security checks and it is

impossible to carry a gun in Vurimindi’ luggage. At that time, Vurimindi informed to John

Gallagher that on 23rd and 24th January 2009, Vurimindi need to write Term 3 final exams

and whoever complained that Vurimindi is carrying a gun on the campus is a deliberate

attempt to distract Vurimindi from his preparation of examinations. Since January 2009,

Vurimindi was continuous surveillance of Duke Police and Duke Private Security until end of

Vurimindi’ WEMBA program in November 2009.

197. In January 2009, after Vurimindi received a call from Gallagher, Kevin Chartier (“Chartier”),

Assistant Vice President of Global Biostatistics & Programming and Hoseyni standing behind

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Vurimindi, looking towards Vurimindi, Hoseyni and said that, “you will go to Jail”. Vurimindi

was surprised to Hoseyni’ comment and then asked what made him to say like that. At that

time, either Hoseyni or Chartier didn’t respond to Vurimindi.

198. In January 2009, next day after Hoseyni told to Vurimindi that “you will go to Jail”, Zhou told

to Vurimindi, “I will inform to the Federal Bureau of Investigation (FBI) on you”. At that time,

Vurimindi asked Zhou, “What is the matter with you?” However, Zhou didn’t respond to

Vurimindi.

199. In January 2009, two days after Zhou told to Vurimindi, “I will inform to FBI on you”, while

Zhou standing behind Vurimindi’ work desk and while Hoseyni passing Vurimindi’ work desk

said to Zhou, “if Vamsi come with this dress code, what dress code should you follow?”.

Vurimindi was surprised to Hoseyni’ comment, because Vurimindi always go to his work in a

formal business attire with a blazer and sometimes with a tie. Hoseyni never made a low

level comment and Vurimindi begin to wonder as to why a such a senior level employee

even take time to make such a comment about Vurimindi’ dress.

200. In January 2009, after Hoseyni and Zhou begin to make threatening comments, Test using

Andrea Chrupcala (“Chrupcala”), Administrative Assistant for Hoseyni, Lori Gonzalez

(“Gonzalez”), Administrative Assistant for Kopko, Linda Vasile (“Vasile”), Administrative

Assistant for Zhou, as an anchor for his conversations, looking at Vurimindi and told to them,

“he is a juvenile delinquent” and “he didn’t pass high school”.

201. In January 2009 until termination of Vurimindi’ contract in March 2009, Chrupcala, Gonzalez,

and Vasile frequently in a mocking fashion using each other as an anchor, repeat the verbal

attacks made by Vurimindi’ classmates at Duke University.

202. Vurimindi used to carry an electronic copy of his WEMBA course material on his computer

and in January 2009 until termination of Vurimindi’ contract in March 2009, Chrupcala,

Gonzalez, and Vasile frequently repeated key words and phrases from Vurimindi’ course

material and course case study names and this lead Vurimindi to believe that Kopko, Moyer,

Zhou and Hoseyni o constantly monitored Vurimindi’ work computer 24 hours X 7 days a

week until termination of Vurimindi’ contract in March 2009.

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203. In January 2009 until termination of Vurimindi’ contract in March 2009, several onsite

contract SAS® programmers who directly report to Zhou, approach Vurimindi and start

enquiring Vurimindi about his issues at Duke University and suggested to drop from WEMBA

program. At the time Vurimindi asked those contract SAS® programmers what made them to

advice Vurimindi to drop from the School. At that time the contract SAS® programmer told

to Vurimindi that they heard stories against Vurimindi at Duke. When Vurimindi asked them

how they came to know about the Duke’ stories, they refused to answer.

204. In January 2009, during a biweekly teleconference, Kopko asked Vurimindi to resign from the

job, while Moyer, Williams, Cheng, Binz and other Wyeth employees present in the meeting.

In response to Kopko’ demand to tender Vurimindi’ resignation, Vurimindi told to Kopko that

he would resign, if Kopko arranges an exit interview with Wyeth President. Vurimindi asked

for an exit interview with Wyeth President, is to ask Wyeth President to provide a favorable

reference for Vurimindi’ future job, because at that point Specter, Hoseyni, Zhou, Kopko and

Moyer would sabotage Vurimindi’ job opportunities.

205. In February 2009, Kopko and Moyer stopped giving work to Vurimindi, so Vurimindi asked

the Kopko and Moyer ‘What is going on and why you have stopped giving any work?” At

that time, Kopko and Moyer told to Vurimindi that “You need not worry specifically;

everyone within Wyeth is worried that Wyeth was being bought by Pfizer”.

206. In February 2009, after Kopko and Moyer stopped giving work to Vurimindi, organized a late

Christmas party in a Kopko’ relatives restaurant near Wyeth Collegeville facility. During that

Christmas party, Kopko told about Vurimindi’ private life facts to Vurimindi’ colleagues, such

as Vurimindi’ married life and about Vurimindi’ wife and her business.

207. On 4th March 2009, Freeman told to Vurimindi that Kopko and Moyer want to meet with

Vurimindi on 5th March 2009 late evening and in response Vurimindi requested to postpone

the meeting until Vurimindi return from his class on Monday, because he has to catch flight

to attend his classes at Duke. As soon, Vurimindi go to the Duke campus, Vurimindi’

classmates ridiculed Vurimindi and said, “You are fired from your job”.

208. On 5th March 2009, Vurimindi called Kopko over telephone from Duke Campus and at that

time Kopko told to Vurimindi that “Wyeth terminated your contract”. In response, Vurimindi

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told to Kopko that, “Steve, my classmates know that Wyeth terminated my position before, I

know it and this confirms that someone from Wyeth are in constant touch with my

classmates”.

209. On 5th March 2009, during the same telephone conversation, Vurimindi reminded Kopko and

Moyer about their promise to retain Vurimindi until end of his MBA program. In response,

Kopko told to Vurimindi that, “well we tried to keep you, but our business needs are

changed”. In response, Vurimindi told to Kopko, that, “Padmanabhan and Freeman told to

me exactly what is going on behind the scene, but you and Moyer kept asking me not to

worry about my job” and asked Kopko, “at least get me an exit interview with Wyeth

President”. In response Kopko told to Vurimindi that he has another meeting and need to

get off the phone.

210. On 8th March 2009, Vurimindi contacted Wyeth executive management Richard DeLuca,

Timothy Cost, Mikael Dolsten, Geno Germano, Thomas Hofstaetter, Michael Kamarck, Joe

Mahady, Greg Norden, Denise Peppard, Bernard Poussot, Ann Rappleye, Cavan Redmond,

and Lawrence Stein and referred an article from Harvard Management Update on 'Getting

the Best Employee Ideas’, which reported that there is an advantage in hearing proposals on

innovation from employees to achieve improved operational performance. Companies have

sought this important information from the public at large, when it might be easy to seek it

from the trenches. Also, told to them, that it might be a value for them and to their

management team to hear personally the many ideas proposed by Vurimindi to the Global

Biostat & Programming team on innovative ways to save money, because they have

dismissed Vurimindi’ ideas are not being part of the grand plan. Also requested an

appointment to have a 15-minute exit interview. However, Vurimindi didn’t get any

response from the Wyeth executive management.

211. On 9th March 2009, Vurimindi contacted Freeman as told him that, “I did spoke with Kopko

on last Thursday afternoon and asked him to setup an exit interview with the President of

Wyeth. If you get the exit interview date and time, please let me know.” Right after that,

Freeman responded to Vurimindi and told, “Vamsi, Good to hear from you. I am very sorry

that the business needs at Wyeth have changed, I’m sure it’s just the beginning of how

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things will evolve here as Pfizer takes over. Unfortunately, there are no presidents at

Wyeth that do exit interviews so we won’t be able to set that up for you. However, Wyeth

has very graciously offered to give you an extra week of pay and we will be happy to get that

out to you as soon as the equipment is returned, so please let me know when you can meet

me to do that. Also, let me know if you left anything in your cube so that I can get that for

you as well. Thanks Vamsi, Paul”.

212. On 9th March 2009, Vurimindi contacted Freeman as told that, “Paul, Laptop, Access ID Card,

and Remote Secure ID belongs to Wyeth has been mailed to the attention of Kopko. I left my

cell phone charger at my desk. Can you mail the charger to my mailing address on your file?”

However, Freeman didn’t returned Vurimindi’ belongings.

213. In March 2009, prior to terminating Vurimindi’ employment contract, Specter, Hoseyni,

Zhou, Kopko and Moyer and many other Wyeth employees contacted at least a minimum

sixty (60) recruiting agencies who are active in and around Greater Philadelphia region and

told them “Wyeth couldn’t able to verify Vamsi’ credentials”, “Vamsi was a Juvenile

delinquent”, “Vamsi is not a good fit within Wyeth” and “Vamsi is not capable to handle

managerial responsibilities”.

214. In March 2009, after terminating Vurimindi’ employment contract, Wyeth entered into

another contract with Cytel and Vurimindi contacted Cytel for an employment, Cytel didn’t

offer a job.

215. In March 2009, after terminating Vurimindi’ position, Wyeth outsourced Vurimindi’ function

to a third party solution provider MediData Solutions, and in turn MediData Solutions

deployed at least 10 years younger resource and that too from someone outside of

protected class as defined by the Civil Rights Act of 1964 to do Vurimindi’ job function.

216. As aforementioned, between December 2004 and March 2009, Wyeth and Accenture

employees deliberately consistently retaliated Vurimindi, every time Vurimindi identify a

required document wasn’t prepared by Wyeth (or) give constructive notice about far less

than optimal process to Wyeth middle management. When Vurimindi identifies missing

technical requirements and user guide document, which preventing his team to complete

validation and document additional time it took for Vurimindi’ team, Wyeth retaliated

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Vurimindi by asking Vurimindi to take on additional job duties as programmer and Wyeth

encroached on Vurimindi’ managerial responsibilities. When Vurimindi asked his team to

consistently document additional time it take to complete validation, because Wyeth

Programmers releasing programs without adequate developer tests, Wyeth retaliated

Vurimindi by saying to it his team members that, “Vamsi is not a capable Project Manager”,

“Don’t follow his instructions”, and told to his team members about GSK terminating

Vurimindi’ employment and subsequent revocation of his H1B visa and Vurimindi’ sexual

harassment complaint with EEOC to Vurimindi’ female team members. When Vurimindi

consistently pursued Wyeth for VPN Connectivity to its team in India, Wyeth retaliated

asking Cytel to replace Vurimindi. When, Vurimindi’ team insist to only validated software to

perform data analysis, Wyeth retaliated by asking Wyeth Therapeutic area heads not to

engage Vurimindi in clinical data analysis work. When Vurimindi identified and report a

chaotic maintenance of SAS® environment, Wyeth retaliated Vurimindi assigning validation

task, where there is known inherent serious issues, which permeate a standstill in Vurimindi’

work. When Vurimindi told about known problems first resolve and then Vurimindi’’ team

will be ready for validation, terminate Cytel’ contract and before terminating Cytel’ contract

assign a menial task to Vurimindi of annotate CRFs. After, rehiring Vurimindi what Wyeth

believed at far less than what Vurimindi was paid by Cytel, and when Vurimindi identified a

issues with PL/SQL code, Wyeth reached Vurimindi’ classmates at Wharton and told “Vamsi

is not capable to handle managerial responsibilities”; “Wyeth couldn’t able to verify Vamsi’

credentials”, “Vamsi didn’t pass high school” and “Vamsi was a Juvenile delinquent”. When

Hoseyni asked and at the time Vurimindi told about inefficiencies in the Accenture process,

Wyeth reached Vurimindi’ classmates at Duke and told “Vamsi is not a good fit within

Wyeth”, “Vamsi is not capable to handle managerial responsibilities”; “Wyeth couldn’t able

to verify Vamsi’ credentials”, “Vamsi didn’t pass high school” and “Vamsi was a Juvenile

delinquent”. When, Vurimindi asked Wyeth to stop imputing Vurimindi’ abilities and ask to

treat him at par with his colleagues terminated Vurimindi’ employment contract.

217. As aforementioned, Wyeth systematically and gradually in small downward increments,

demoted Vurimindi from a Project Manager role to a programmer role and then to a QA

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Programmer role and then to a CRF annotator role and then terminated Vurimindi’ contract.

After rehiring Vurimindi in June 2007 as a stop gap arrangement, until someone else picks

Wyeth and CDISC® data standards and as soon, Wyeth believed that Tian and Cheng picked

up Wyeth and CDISC® data standards, Wyeth attempted push out Vurimindi. When,

Vurimindi didn’t quit the job on his own, Wyeth make all but impossible to Vurimindi to

maintain his mental health through creating horrendous situations at Wyeth, Wharton and

Duke.

218. As aforementioned Wyeth’ unethical, unlawful and discriminatory practices against

Vurimindi for over four (4) years, and permanently, irrevocably and irretrievable destroying

Vurimindi’ reputation at Wyeth, Wharton and Duke, Vurimindi repeatedly had nightmares

about his plight at Wyeth and suffered from lack of interest in social relationships; preferred

solitary lifestyle; become secretive about his activities; forgetting to remember and answers

that he had just learned during the semester and answer to Duke term exam questions;

become getting easily startled, and getting irritated easily which leads Vurimindi suffer from

chronic anxiety, depression, worrying, irritability, restlessness, constant inner tension,

inability to sleep and relax, increasing defensiveness and moodiness. Without realizing that

Wyeth’ abusive environment causing fatigue and inability to concentrate, Vurimindi take

prescription medications thinking that there is an inherent medical problem and that is

causing his fatigue and inability to concentrate, Vurimindi take prescription medications to

overcome the symptoms of fatigue and inability to concentrate.

219. In April 2009, after terminating Vurimindi’ employment contract, Kopko, Moyer, Zhou and

Hoseyni contacted CDISC® and told them “Wyeth couldn’t able to verify Vamsi’ credentials”,

“Vamsi was a Juvenile delinquent”, “Vamsi is not a good fit within Wyeth” and “Vamsi is not

capable to handle managerial responsibilities”, when CDISC® had a global reach to all

pharmaceutical companies. When, Kopko, Moyer, Zhou and Hoseyni contacting CDISC® and

relaying information which directly impute Vurimindi’ ability as a professional, they implied

that not to hire or recommend Vurimindi for a consulting opportunity.

220. In April 2009, after terminating Vurimindi’ employment contract, Kopko reached a Pub called

Charlie’ Place in Vurimindi’ neighborhood and through his relatives who own a bar in and

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around Collegeville, PA and told them “Wyeth couldn’t able to verify Vamsi’ credentials”,

“Vamsi was a Juvenile delinquent”, “Vamsi is not a good fit within Wyeth” and “Vamsi is not

capable to handle managerial responsibilities” and in turn placed his known people at

Charlie’ Place and through them further assassinated Vurimindi character by propagating

same information over and over repeatedly to Charlie’ Place customers, who are Vurimindi’

neighbors.

221. In April 2009, after terminating Vurimindi’ employment contract, Kopko, Moyer, Zhou and

Hoseyni and other Wyeth employees contacted Vurimindi’ classmates at Duke and told

them, Vurimindi recently win a lottery and he don’t want to work.

222. In May 2009, Kopko, Moyer, Zhou and Hoseyni other Wyeth employees contacted MaxisIT

Inc, a recruiting firm and told them “Vamsi is not a good fit within Wyeth” and “Vamsi is not

capable to handle managerial responsibilities”.

223. Between April 2009 through June 2010 Vurimindi attempted to obtain an employment

opportunity, but didn’t get response from recruiting companies particularly specialized in

SAS® and related software packages in and around greater Philadelphia region.

224. Between April 2009 through June 2010, Kopko, Moyer, Zhou, Spector and Hoseyni reached

Vurimindi’ neighbors Allison Borowski, Lauren Westfield, Rajani Pattinson, Jason Tiefenback,

Kendra Brill, Nicole Beden, Sarah Rosen Shah, Anthony Felice, Daniel Segal, Thomas

McCracken, Nicholas Palmer, Elliot Hodgson, Dena Young, Joseph Vitella, Leo Addimando,

Adam Stanley, Jeffery Engel, and many other people in the neighborhood through their

acquaintances working at Centacor, J & J, Merck Research Laboratories, GlaxoSmithKline,

Children’ Hospital, Temple University and Physicians specifically involved in Cancer

Treatment and Pain Management and told to residents in his condominium complex that

“Wyeth couldn’t able to verify Vamsi’ credentials” and “Vamsi was a Juvenile Delinquent ”

and there by implying that Vurimindi not as a person was properly grounded with a decent

set of values with an intent to profoundly, permanently and irrevocably damage Vurimindi’

image and reputation among his neighbors.

225. In April 2010, after Vurimindi made passing remarks against Richard DeLuca, Timothy Cost,

Mikael Dolsten, Geno Germano, Thomas Hofstaetter, Michael Kamarck, Joe Mahady, Greg

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Norden, Denise Peppard, Bernard Poussot, Ann Rappleye, Cavan Redmond, and Lawrence

Stein in his complaint, a new resident in Vurimindi’ condominium building where Vurimindi

was residing, identified himself as Jarred Wallace, and recent Rutgers Law School Graduate

and begin to interact with Vurimindi and lead Vurimindi to believe that he is helping

Vurimindi as to how to use WestLaw and other legal websites and gathered Vurimindi’ latest

private facts as to his intentions about pursuing his lawsuit against Wyeth and other facts

related to his investments and banking information.

226. While, Jarred Wallace is teaching Vurimindi as to how to use WestLaw and other legal

websites for a nominal fee, told that he play golf with one of Wyeth executive that Vurimindi

named in his complaint and he would never do things that Vurimindi alleged in his

complaint. When Vurimindi asked the executive name, Jarred Wallace didn’t give that

executive name. However, after Jarred Wallace take a check from Vurimindi stopped

interacting with Vurimindi. Vurimindi believe that one of the Wyeth Executive planted Jarred

Wallace to obtain Vurimindi’ banking information and related facts.

227. In June 2010, Kopko, Moyer, Zhou and Hoseyni arranged a fake job interview with PPDI and

Centacor without informing MaxisIT Inc, that they set-up those interviews with PPDI and

Centacor.

228. In 1st week of June 2010, MaxisIT Inc told to Vurimindi has to attend an in person interview

on 4th June 2010 for a job with PPDI. When Vurimindi travelled from Philadelphia to PPDI

location at The Neuman Building, Suite 201, 3575 Quakerbridge Rd. Hamilton, NJ 08619 for

in--person interview, at that time PPDI interviewer asked Vurimindi whether Vurimindi

passed high school, despite knowing that Vurimindi had an MBA degree from Duke. Despite,

PPDI told to MaxisIT Inc that this particular job responsibility is to prepare an analysis

datasets per CDISC® standards, PPDI told to Vurimindi at the interview that his job

responsibility to annotate CRFs and other menial tasks as Vurimindi’ responsibilities. After

that, PPDI interviewer continue to ask questions tangential to the issues that made

Vurimindi upset at Wyeth. Despite, Vurimindi told to PPDI interviewer that they can ask

questions about Vurimindi’ technical competitiveness and Vurimindi would answer those

questions and PPDI interviewer insisted answers. At that time, it become evident to

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Vurimindi that no matter, how elegantly Vurimindi answer PPDI not going to hire Vurimindi

and at that time, Vurimindi left the interview, by saying thank you for the opportunity and I

am not suitable for this job.

229. On 11th June 2010, an interviewer called Centacor and her questions are similar to PPDI, but

Vurimindi without getting irritated, answered all her questions. Despite, Vurimindi

unwearyingly answered to interviewer questions, Centacor didn’t extend job offer and didn’t

give any feedback as to why they didn’t extend the job offer to Vurimindi.

230. In June 2010 after Centacor interview, Vurimindi contacted MaxisIT Inc to obtain feedback.

In response Vurimindi was asked whether Vurimindi’ credentials was verifiable? In response,

Vurimindi told, to MaxisIT can perform a back ground search and could verify Vurimindi’

credentials. After, that MaxisIT didn’t contact Vurimindi.

231. In September 2010, Cytel set-up an in-person interview and Vurimindi traveled from

Philadelphia, PA to Cytel’ office at Boston, MA and after the interview, Vurimindi was told by

Cytel that Wyeth told them that Vurimindi is not ready for employment because Vurimindi

was mentally impaired.

232. In October 2010, an interviewer called Allergan8 and her questions are similar to PPDI, but

Vurimindi without getting irritated, answered all her questions. Despite, Vurimindi

unwearyingly answered to interviewer questions, Allergan didn’t extend job offer and didn’t

give any feedback as to why they didn’t extend the job offer to Vurimindi

233. In October 2010, Iconma, LLC (“Iconma”) told to Vurimindi about two (2) months

Programmer Analyst at HealthCore in Wilmington, DE and setup in person interview with

Quimbo, Cobb, and Liang and after the interview Quimbo extended job offer.

234. After unemployment of 18 months, in 1st week of November 2010, Vurimindi begin his work

as contract Programmer at a much lower bill rate than that ordinarily paid to software

consultants with similar experience that of Vurimindi.

235. In November 2010, as soon Vurimindi began his work at HealthCore Specter, Kopko, Moyer,

Zhou and Hoseyni contacted statisticians at HealthCore and told them “Wyeth couldn’t able

to verify Vamsi’ credentials”, “Vamsi was a Juvenile delinquent”, “Vamsi is not a good fit

8 Ira Spector, is now working as Senior Vice President, Global Development Operations at Allergan.

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within Wyeth” and about as to how Vurimindi has been treated by his classmates at Duke

and his neighbors.

236. In November 2010, Specter, Kopko, Moyer, Zhou and Hoseyni facilitated and established a

direct communication between his neighbors and Vurimindi’ colleagues at HealthCore and

enabled his neighbors to communicate his private facts on daily basis to Vurimindi’

colleagues.

237. In November 2010 through 1st Week of December 2010, Vurimindi’ colleagues sat

HealthCore showing sly in a mocking fashion, sarcastically talked about Vurimindi’ ongoing

private life facts and talked about Vurimindi’ horrendous experience at Duke, Wyeth and

Borowski’ criminal complaint against Vurimindi.

238. In 4th week of November 2010, Vurimindi’ colleagues started to talk about Vurimindi’

background search report prepared by Iconma for HealthCore. Then, Vurimindi become

frustrated and asked Quimbo, his manager as to how she and other colleagues know about

Vurimindi’ private facts and why they talk about them in work environment.

239. In 1st week of December 2010, and a day before, HealthCore terminates Vurimindi’ contract,

Vurimindi’ neighbor, Lauren Westfield Nayerahmadi (“Nayerahmadi”), who live in a condo

underneath Vurimindi’ condo shouted across the floor “hey crazy, they are going to fire

you”. In response, Vurimindi enquired as to how she knows about Vurimindi’ employment

situation, prior to Vurimindi know himself. Nayerahmadi didn’t answer Vurimindi’ enquiry.

240. In 1st week of December 2010, two days after Vurimindi’ conversation with his manager,

HealthCore terminated Vurimindi’ employment.

241. In 2nd week of December 2010, Vurimindi secured another job as statistical consultant at

Hemispherex.

242. In December 2010, Kopko, Moyer, Zhou and Hoseyni reached Vurimindi’ colleagues at

Hemispherex through Octagon Research sales team and told “Wyeth couldn’t able to verify

Vamsi’ credentials”, “Vamsi was a Juvenile delinquent”, “Vamsi is not a good fit within

Wyeth”.

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243. In January 2011, Kopko, Moyer, Zhou and Hoseyni told to Vurimindi’ colleagues at

Hemispherex as to how Vurimindi has been treated by his classmates at Duke and his

neighbors.

244. In February 2011, Kopko, Moyer, Zhou and Hoseyni facilitated and established a direct

communication between his neighbors and Vurimindi’ colleagues William Carter, Wayne

Pambianchi, Wayne Springate, Charles Bernhardt, David Strayer, Chaunce Bogard, Diane

Young and Lori Santos at Hemispherex and enabled his neighbors to communicate his

private facts on daily basis.

245. In February 2011, one of Vurimindi’ immediate neighbor Rajani Pattinson (“Pattinson”) sold

her unit and before she moved out, without any warning on a Friday night when Vurimindi

walking out of his unit, just like that she spayed oil based pepper on Vurimindi’ face. On

immediate next Monday, when Vurimindi go to his work, Vurimindi’ colleagues enquired

Vurimindi about the incident.

246. Since February 2011 through September 2011, until Hemispherex terminate Vurimindi’

contract, on day to day basis, Vurimindi’ neighbors communicate with Vurimindi’ colleagues

at Hemispherex and in turn Vurimindi’ colleagues daily at some point talk about Vurimindi’

private life facts, and his horrendous experience with his neighbors.

247. Specifically, Wayne Springate and Diane Young, at least two to three times in a week in

mocking fashion talk about Vurimindi’ neighbors such as Allison Borowski, Rajani Pattinson,

Kendra Brill, and Rachel Wood and they have been doing lately with their acquaintances.

248. On or about in March 2011, SVP for Frontage Labs moved into Vurimindi’ condominium

complex and Greg Zhou was employed by Frontage Labs. Later, In May 2011, Frontage Labs

solicited an in licensing/ out licensing opportunity from Hemispherex.

249. In April 2011, Vurimindi came to know that Pattinson sold her unity to Anna Osmushkina

(“Osmushkina”) a senior bio-statistician at AstraZeneca. Vurimindi don’t have any facts that

Osmushkina was in contact with Vurimindi’ colleagues at Hemispherex, but Hemispherex

was negotiating a contract with AstraZeneca’ wholly owned subsidiary MedImmune to

conduct a joint Phase III study on using MedImmune’ flu vaccine FluMist along with

Hemispherex’ experimental drug as an Adjuvant.

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250. It is suspicious to read with other fact, Rosen Shah, Duke’ executive recruiter purchasing a

condo in Vurimindi’ condominium complex that after Rosen Shah recruited Vurimindi into

Duke and aftermath smear campaign, and now a bio-statistician purchasing a condo next to

Vurimindi’ unit, when in fact Vurimindi had been harassed by bio- statisticians at GSK and

Wyeth; and an executive from Frontage Labs moved into Vurimindi’ condominium, while

Greg Zhou was employed by Frontage Labs.

251. In May 2001, Vurimindi asked Wayne Springate as how and why he and other employees at

Hemispherex were inquisitive about Vurimindi’ private facts. At that time, Wayne Springate

told that Mary Schaheen, CEO of Numoda Corporation is passing information about

Vurimindi. Prior to commencing this civil action, Vurimindi contacted Wayne Springate and

asked him to testify as he told to Vurimindi that Mary Schaheen is conducting smear

campaign against Vurimindi. Wayne Springate didn’t respond to Vurimindi.

252. In August 2011, after six months of continuous relay of private life facts to his colleagues by

his neighbors and in turn Vurimindi’ colleagues talk about them at work, Vurimindi was

frustrated with his colleagues conduct and contacted Hemispherex’ HR Manager and asked

her to restrain his colleagues contacting his neighbors and talk about his private life facts at

work.

253. On 12th September 2011, Vurimindi’ father suffered from heart attack and Vurimindi told to

Wayne Springate that he needs to travel to India and initially Wayne Springate asked

Vurimindi to take Hemispherex laptop to India, such that Vurimindi can log-on to

Hemispherex and work from India, as long as Vurimindi need to stay in India.

254. On or about 22nd September 2011, Wayne Springate asked not to take Hemispherex laptop

to India and ask Vurimindi to call him after Vurimindi return from India.

255. On 2nd October 2011 Vurimindi’ father expired and on or about 15th October 2011, Vurimindi

returned from India and contacted Wayne Springate to return to his work.

256. At that time, Wayne Springate told to Vurimindi that Hemispherex don’t have work for

Vurimindi.

257. Immediately, in October 2011, Vurimindi contacted Hemispherex to send his W2 form. At

that time Hemispherex told to Vurimindi that you have signed W9 form stating that

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Vurimindi is not subject to back-up withholding and thus indirectly accepted to receive 1099

and hence, accordingly Vurimindi should pay his taxes.

258. In response, Vurimindi wrote to Hemispherex stating that Hemispherex employment offer

letter didn’t state that Vurimindi will receive a 1099 and during the interview or after the

interview at no time Hemispherex specifically told to Vurimindi will receive a 1099 form.

Now Hemispherex asserting that because Vurimindi signed W9 form stating that Vurimindi is

not subject to back-up withholding and thus indirectly accepted to receive 1099, is nothing

but Hemispherex indulging in deceptive practice to hire people at lower bill rates, which is

unlawful and demanded to pay employer taxes.

259. In October 2011, Hemispherex refused to pay employer taxes on for the Vurimindi’ wages.

260. In October 2011, Vurimindi begin to search for an employment and CSG, Inc told about work

from home SAS® Programmer opportunity at Theorem, a CRO and Vurimindi applied for that

opening.

261. In October 2011, after reviewing Vurimindi’ resume, hiring manager Karen Curran contacted

Vurimindi’ managers at Wyeth and in turn Wyeth managers told to Karen Curran not to hire

Vurimindi.

262. In October 2011, after Vurimindi’ managers at Wyeth know about Vurimindi’ job search,

contacted the following recruiting companies: [Aerotek Scientific, AETEA Information

Technology, Ajilon Consulting, Arcus Technology, Artech Information Systems L.L.C, Aten

Solutions, Inc, Benton Search Associates, Inc, The Cambridge Group LTD, The Cambridge

Group, CE Recruiting, ClinForce, Inc, Clinprobe, LLC Computer Aid, Inc. (CAI), COMSYS Clinical

and SAS Analytics, Contemporary Staffing Solutions, CoreTech Consulting Group, LLC, Devon

Consulting, H.L. Yoh Company LLC, Joulé Scientific Staffing, Judge Technical Services, Kforce

Professional Staffing, Matlen Silver Group Makro Scientific, Ockham (formerly ASG, Inc.), On

Assignment Clinical Research, Orbis Data Solutions, Professional Resources, Inc, Q-Lytics

Consulting Inc, RCG Information Technology, Sapphire Technologies, SCFoster Solutions,

LLC, Scientific Search, Segula Technologies, Softworld, Inc, Spherion Professional Services,

Strong Tower Solutions, Inc, TEKsystems, TripleScreen Search & Staffing, and TPG Direct] and

told them not to present Vurimindi’ resume to their clients.

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263. Between October through December 2011, Inventive subsidiary SmithHanley Consulting

solicited Vurimindi’ resume for several employment opportunities and after obtaining

Vurimindi’ resume they told that they have submitted Vurimindi’ resume to their clients, but

didn’t get a single response for Vurimindi’ resume. Vurimindi, believe that SmithHanley

Consulting either didn’t submit Vurimindi’ resume or told to their client that Vurimindi is not

available after submitting Vurimindi’ resume and submit another candidate resume to their

same client.

(V) COUNT – 1: CAUSE OF ACTION – PROMISSORY ESTOPPEL AGAINST WYETH, KOPKO AND MOYER:

264. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

265. Prior to June 2007, Vurimindi worked at Wyeth under the direct supervision of Kopko and

Moyer, nearly about two and half years.

266. In June 2007, Vurimindi explained to Kopko and Moyer that Vurimindi was joining an MBA

program and require an employment opportunity with flexible work hours until end of his

MBA program.

267. In June 2007, Kopko and Moyer told to Vurimindi would be employed at Wyeth as CDISC®

Subject Matter Expert with flexible work hours through the duration of his MBA program

with an annual pay rate of $120,000 which Kopko and Moyer believe is less than Vurimindi is

being paid by Cytel as Project Manager.

268. In June 2007, immediately after the above said conversation, Vurimindi, agreed to take less

money, if Wyeth can promise to retain Vurimindi with flexible work hours for the duration of

his MBA program.

269. In June 2007, immediately after the above said conversation, Kopko and Moyer agreed to

retain Vurimindi with flexible work hours for the duration of his MBA program.

270. In June 2007, immediately after the above said conversation, Kopko and Moyer asked

Vurimindi to submit his employment application with Inventive.

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271. In June 2007, based on the arrangement with Kopko and Moyer, Vurimindi submitted his

employment application with Inventive and soon thereafter Inventive hired Vurimindi, at the

salary agreed upon with Kopko and Moyer.

272. Based on Kopko and Moyer’ assurances, and Vurimindi’ quick hiring at the agreed upon

salary, Vurimindi believed the promises made to him by Kopko and Moyer.

273. Based on the belief on these promises, Vurimindi then began the process of admittance into

an MBA program some 10 months later, Vurimindi began MBA program, while still working

at Wyeth under the arrangement made with Kopko and Moyer.

274. In November 2007, Kopko and Moyer altered Vurimindi’ CDISC® Subject Mater Expert job

description by making Vurimindi’ expert opinions insignificant and constrained Vurimindi’

individuality and created role ambiguity by over controlling Vurimindi’ work.

275. In February 2008, refused to give flexible work hours similar to the arrangement made by

Wyeth with Baldovin.

276. In March 2009, one year after starting MBA program, but 8 months before the program is

completed, the Kopko and Moyer eliminated Vurimindi’ position and terminated Vurimindi’

contract, in direct contradiction to the promise they made in June 2007.

277. Because, Kopko and Moyer didn’t provide flexible work hours as promised and as result, in

the year prior to the termination, Vurimindi’ annual salary was some $35,000 less than

promised.

278. By the reason of breach of promise by Kopko, Moyer and Wyeth, Vurimindi has suffered loss

of employment, loss of pay, loss of reputation, and emotional distress due to the loss of

employment, while Vurimindi attending his WEMBA program at Duke. Therefore given that,

Kopko, Moyer and Wyeth breached their promise and such breach was the proximate cause

of damage to Vurimindi.

279. Because, Kopko, Moyer and Wyeth’ breach of promise was reckless disregard to the promise

to keep Vurimindi for the duration of his MBA program; and reckless disregard to the

physical, emotional and financial wellbeing of Vurimindi, punitive damages should be

awarded against Kopko, Moyer and Wyeth in an amount to be determined at trial.

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(VI) COUNT – 2: CAUSE OF ACTION – WRONGFUL TERMINATION PURSUANT TO PENNSYLVANIA HUMAN RELATIONS ACT (“PHRA”) AGAINST SPECTOR, HOSEYNI, ZHOU, KOPKO, MOYER, WILLIAMS AND WYETH:

280. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

281. In July 2008, Vurimindi contacted Moyer and made a formal complaint about the ongoing

harassment by Wyeth employees, contractor and consultants and Accenture Employees and

possible Wyeth’ discriminatory employment practices.

282. Vurimindi making a formal complaint to Moyer about Wyeth and Accenture possible

discriminatory employment practices is a protected activity.

283. Vurimindi incorporates herein by reference preceding paragraphs [139] through [217].

284. After Vurimindi making a formal complaint’ July 2008 formal complaint, as summarized in

paragraphs [216 and 217], Spector, Hoseyni, Zhou, Kopko, Moyer, Williams and Wyeth,

systematically and gradually demoted Vurimindi in small downward increments.

285. In March 2009, Spector, Hoseyni, Zhou, Kopko, Moyer, Williams and Wyeth terminated

Vurimindi’ contract and thereby Vurimindi suffered adverse employment action after making

a formal complaint about possible discriminatory employment practices.

286. By the reason of terminating Vurimindi’ contract in violation to public policy, Vurimindi has

suffered loss of employment, loss of pay, loss of reputation, and emotional distress due to

the loss of employment, while Vurimindi attending his WEMBA program at Duke. Therefore

given that, the Spector, Hoseyni, Zhou, Kopko, Moyer, Williams and Wyeth, Wrongfully

Terminated Vurimindi’ contract and such Wrongful Termination was the proximate cause of

damage to Vurimindi.

287. Because, Spector, Hoseyni, Zhou, Kopko, Moyer, Williams and Wyeth and Wyeth’ Wrongfully

Terminated Vurimindi’ contract was reckless disregard to the public policy and reckless

disregard to the physical, emotional and financial wellbeing of Vurimindi, punitive damages

should be awarded against Spector, Hoseyni, Zhou, Kopko, Moyer, Williams and Wyeth in an

amount to be determined at trial.

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(VII) COUNT – 3: CAUSE OF ACTION – WRONGFUL TERMINATION PURSUANT TO C. R. A 1964 TITLE VII - ABUSIVE WORK ENVIRONMENT AGAINST SPECTOR, HOSEYNI, ZHOU, KOPKO, MOYER, WILLIAMS, WYETH, ACCENTURE AND INVENTIVE:

288. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

289. In October 2004 after reading Vurimindi’ background report compiled by a third party and

Vurimindi’ resume and after working few weeks of interaction with Vurimindi and observing

Vurimindi’ type and having in-person direct interaction with Vurimindi’ two female team

members for few weeks, Kopko and Moyer, stereotyped Vurimindi as, unhappy, mid-level

educated Indian migrant come to the U.S. on H-1B visas because he is not "good enough" to

break into the elite schools and best high-tech operations in India.

290. Kopko and Moyer had a firsthand knowledge about hourly bill rates that they paid to

independent SAS® consultants such as Li and others and being a party to read and

recommend for final inking of the Wyeth and Cytel contract, also had firsthand knowledge

about hourly bill rates that they paid to Cytel and that reduced bill rate is a price signal that

Vurimindi and his team were inferior in terms of ability to perform job duties with high-

quality as Kopko and Moyer believe that Li and others programmers in their team

performing.

291. As above said stereotyped perception, and with the knowledge that GSK terminated

Vurimindi’ employment contract, revoked his H1B visa and subsequently Vurimindi filing his

wrongful termination and sexual harassment complaint with EEOC, Kopko and Moyer

expected a poor performance and that lack of expectation of good performance from

Vurimindi, lead to dislike Vurimindi, because Vurimindi’ didn’t fit the image what Kopko and

Moyer think a project manager should be.

292. After Vurimindi’ team begin to deliver its work product, despite Wyeth didn’t provide the

required VPN connectivity and identifying missing documents and detecting bugs in the

Kopko’ team work product and proved Kopko and Moyer’ stereotyped perception was

grossly wrong, it escalated anger among Kopko’ team.

293. Kopko, Moyer and Williams exhibited their anger against Vurimindi by sabotaging Vurimindi’

efforts to obtain VPN connectivity to his team, influenced Wyeth to delay and deny VPN

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connectivity to Vurimindi’ team and begins to propagate selective negative information

about Vurimindi to his female team members in India, his employer Cytel, and to Senior

management at Wyeth to influence their emotions, and their negative behavior towards

Vurimindi.

294. Kopko, Moyer and Williams deliberately attempted to demoralize Vurimindi and thereby

affect his work product, because the negative information that Kopko, Moyer and Williams

disseminating against Vurimindi is unrelated to Vurimindi work at Wyeth and no legitimate

reason for Kopko, Moyer and Williams disseminating negative information generated out of

Vurimindi’ time at GSK, overtly and openly to Vurimindi’ employer and to Senior

management at Wyeth.

295. Despite Kopko’ team release their code without conducting adequate developer testing, and

without required VPN connectivity to his team in India, Vurimindi consistently delivered

quality work product, and tolerating the dissemination of negative information, and signaled

through his performance that Vurimindi begin to make his career at Wyeth and using his

project manager role as stepping stone, Kopko, Moyer and Williams begin to disseminate

false negative information about Vurimindi’ managerial abilities to his employer Cytel,

because Vurimindi asked Kopko’ team release their code only after conducting adequate

developer testing for Vurimindi’ team validation.

296. Further, Kopko, Moyer and Williams asked Cytel to ask Vurimindi to work as validation

programmer in addition to his existing responsibilities knowingly that additional work alter

Vurimindi’ original job description and increased total work to Vurimindi by three folds,

because Kopko and Moyer know that Cytel’ contract with Wyeth depends upon Kopko

Kopko, Moyer and Williams’ favorable upward feedback to Wyeth senior management and

Kopko, Moyer and Williams knows that Vurimindi depend upon Cytel for his H1B visa and

H1B visa tantamount to indentured servant and gives Cytel additional leverage over wages

and benefits, as well as working conditions of Vurimindi.

297. When Kopko and Moyer asking to assign additional work load to Vurimindi, didn’t increase

the bill rate that they are paying on account of Vurimindi and as expected by Kopko and

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Moyer, Cytel compelled Vurimindi to agree to take additional work as validation

programmer without additional consideration.

298. Vurimindi had hoped that over-time Kopko, and Moyer and other Wyeth manager change

their perception and conduct towards Vurimindi after observing that Vurimindi consistently

and objectively delivering his quality work product. Despite, Vurimindi consistently delivered

his quality work product, Wyeth didn’t engage Vurimindi in clinical data analysis pursuant to

Wyeth and Cytel contract and continue to assign unfavorable tasks, which don’t have scope

for career development for Vurimindi in Wyeth.

299. In November 2006, Wyeth decided to terminate contract with Cytel and didn’t inform to

either Vurimindi or Cytel, Hoseyni, Zhou, Kopko, and Moyer continue to lead Vurimindi to

believe that Wyeth will engage Vurimindi in clinical data analysis as soon Vurimindi’ team

accomplish a known impossible and an unfavorable task. This careful design of a task by

Hoseyni, Zhou, Kopko, and Moyer tantamount to expecting a failure from Vurimindi and his

team.

300. After, Vurimindi’ team failed to accomplish a known impossible task and put forth all facts

before Hoseyni, Zhou, Kopko, and Moyer, in May 2007, after Wyeth signed a contract with

Accenture for Clinical Data Analysis and data migration per CDISC® standards, informed Cytel

that Wyeth would terminate its contract in June 2007.

301. Between November 204 and until May 2007, Vurimindi expected that Kopko and Moyer

recognize his talent and promote him as a manager to next level and in May 2007, Vurimindi

realized that Hoseyni, Zhou, Kopko, and Moyer bypassed Vurimindi. Hence, Vurimindi take

his own initiative and decided to obtain an MBA from top 10 business school of US and made

plans accordingly.

302. As aforementioned Vurimindi mastered CDISC® standards and obtained a promise from

Kopko and Moyer to retain Vurimindi until completion of his MBA and begin his Pre-MBA

course at Wharton in June 2007 and his MBA course in March 2008 at Duke.

303. Between July 2007 and April 2008, Spector, Hoseyni, Zhou, Kopko, Moyer and Williams

acting like to helping Vurimindi achieve his goal of attaining his MBA, reached Vurimindi’

classmates at Wharton through Davis, Tian and Bagga; and Vurimindi’ classmates at Duke

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through Sundberg, Ambooken and Link and Wyeth vendors James Walker and ClinForce and

Wyeth employees , Patterson and Dragalin and told that “Wyeth couldn’t able to verify

Vamsi’ credentials”, “Vamsi was a Juvenile delinquent”, “Vamsi is not a good fit within

Wyeth” and “Vamsi is not capable to handle managerial responsibilities”, when Vurimindi

specifically attending his MBA program to launch his career as a professional business

manager and paying tuition fee out of his pocket.

304. After disseminating negative references about Vurimindi at Wharton and Duke, Spector,

Hoseyni, Zhou, Kopko, Moyer and Williams begin disseminating negative references within

Wyeth for Vurimindi and begin to assign repetitive menial tasks, with unrealistic short

timelines, make Vurimindi’ opinions insignificant, constrained Vurimindi’ individuality,

created role ambiguity, over controlled Vurimindi’ work, habitually had angry conversations

with Vurimindi and made Vurimindi to follow instructions from Wyeth and Accenture

employees & consultants who don’t have as much experience or knowledge that Vurimindi

brings to Wyeth.

305. Because, Vurimindi like many Indians inherit high context culture, valued honor, reputation

and tradition and try to avoid surprises and minimize confrontation, Vurimindi patiently

waited with a hope that Spector, Hoseyni, Zhou, Kopko, Moyer and Williams start treating

Vurimindi at least at par with other employees and consultants.

306. In July 2008, after Vurimindi repeatedly had nightmares about his plight at Wyeth and

forgetting to remember and answers that he had just learned during the semester and

answer to Duke term exam questions; and suffer from chronic anxiety, depression, worrying,

irritability, restlessness, constant inner tension, inability to sleep and relax, increasing

defensiveness and moodiness, Vurimindi made a formal complaint to Moyer and asked to

correct the situation.

307. As soon, Vurimindi made a formal complaint, instead correcting hostile work environment

Spector, Hoseyni, Zhou, Kopko, Moyer and Williams as aforementioned, carefully and

consistently in small upward increments continued inequities and aggressions towards

Vurimindi in various forms as aforementioned and terminated Vurimindi’ contract in March

2009.

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308. As aforementioned, just before Wyeth terminate Vurimindi’ contract, Kopko and Moyer

organized a late Christmas party and during that time, Kopko with scornful facial expression,

told to his team members (Moyer, Williams, Forman, Test and Shaw) that Vurimindi married

to an older woman and Vurimindi didn’t give much attention to Kopko’ statement.

309. After Wyeth terminate Vurimindi’ contract, Spector, Hoseyni, Zhou, Kopko, Moyer and

Williams continued dissemination of negative employment reference for Vurimindi and

taking note of Wyeth’ actual retention and promotions among its existing human resources

prior and after Pfizer takeover, Wyeth didn’t retain and promote people of Indian origin, but

instead exploited the foreign status, precariousness of the H-1B immigration status as a

"high-tech braceros” and leverage the dependency of the H-1B visa holder for corporate

sponsorship, and treated them like indentured servants, by paying below market wages

when compared to their American counterparts with equivalent experience and with

barebones vacation and benefits.

310. In Vurimindi’ case, Wyeth and its employees exploited Vurimindi’ foreign (Indian) and H-1B

immigration status as just above mentioned and in addition Wyeth prejudiced Vurimindi

because of his marital status and “age difference between him and his wife” as a proxy to

Wyeth management “illusionary” defect on part of Vurimindi and that defect preventing him

from marrying a woman of his age or less and because of that defect Vurimindi was not

“good enough” to retain and promote Vurimindi into managerial position, despite Vurimindi

demonstrated his intelligence, creativity and quality of work through his work and

educational qualifications and other personal accomplishments and asked for an

employment in every department of Wyeth, because of his personal accomplishments and

academic qualifications make him eligible for any senior management position at Wyeth.

311. In Vurimindi’ case, Wyeth and its employees went beyond just refusing to retain and

promote Vurimindi, and made credible efforts to prevent Vurimindi obtain his education

from elite educational institutions by purposefully disseminate negative information about

Vurimindi at Wharton and Duke. Further, Wyeth and its employees persistently maintain

their grudge and against Vurimindi and continued to disseminate negative employment

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reference to two (2) employers (i) HealthCore; and (ii) Hemispherex after Vurimindi begins

his work and directly lead to termination of his employment.

312. As aforementioned, along with Wyeth and its employees, Accenture and Inventive personnel

are willful participants in creating and maintaining hostile environment against Vurimindi at

Wyeth by disseminate negative information about Vurimindi at Wyeth, Wharton, and Duke;

by refusing to offer health benefits; and after Wyeth terminate Vurimindi’ employment,

Inventive and its affiliate companies (MedFocus and Smith Hanley) continue to disseminate

negative employment reference for Vurimindi.

313. As aforementioned, Wyeth, Accenture and Inventive employees systematically converted

their transitory deprecatory statements about Vurimindi, into institutional memory across

Wyeth’ Biostatistics Department, among Vurimindi’ classmates at Wharton and Duke,

among recruiters who specialized in SAS® consultants recruitment, among many employers

such as PharMA®, CDISC®, Theorem, Paraxel, PPDI, Centacor, J & J, and Merck who employ

SAS® consultants and in and around Vurimindi’ residence.

314. By the aforementioned methods and reasons, Wyeth, Accenture and Inventive created and

maintained a hostile environment to make Vurimindi abandon his employment at Wyeth on

his Pre-MBA and MBA programs at Wharton and Duke.

315. By the reason of maintain hostile environment and then terminate Vurimindi’ employment

in violation to CRA 1964 Title VII, Vurimindi has suffered loss of employment, loss of pay, loss

of reputation, and emotional distress due to the loss of employment, while Vurimindi

attending his WEMBA program at Duke. Therefore given that, the Wyeth, Accenture,

Inventive, Hoseyni, Zhou, Kopko, Moyer and Williams, Wrongfully Terminated Vurimindi’

employment and such Wrongful Termination was the proximate cause of damage to

Vurimindi.

316. Because, Wyeth, Accenture, Inventive, Spector, Hoseyni, Zhou, Kopko, Moyer and Williams

wrongfully terminated Vurimindi’ employment was reckless disregard to the public policy

and reckless disregard to the physical, emotional and financial wellbeing of Vurimindi,

punitive damages should be awarded against Wyeth, Accenture, Inventive, Spector, Hoseyni,

Zhou, Kopko, Moyer and Williams in an amount to be determined at trial.

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(VIII) COUNT – 4: CAUSE OF ACTION – RETALIATION BY DISSEMINATION OF NEGATIVE

EMPLOYMENT REFERENCE IN VIOLATION TO CIVIL RIGHTS ACT OF 1964, TITLE VII AGAINST SPECTOR, HOSEYNI, ZHOU, KOPKO, MOYER, WILLIAMS, WYETH, ACCENTURE AND INVENTIVE:

317. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

318. Vurimindi incorporates herein by reference preceding paragraphs [262 through 287] to show

discriminatory motive for Wyeth, Accenture, Inventive, Hoseyni, Zhou, Kopko, Moyer and

Williams.

319. As aforementioned prior and after terminating Vurimindi’ employment, Wyeth, Accenture,

Inventive, Hoseyni, Zhou, Kopko, Moyer and Williams, habitually, persistently, and

purposefully, disseminated negative employment reference for Vurimindi to his teammates

in India, his employer Cytel, Wyeth Therapeutic area heads, his classmates at Wharton and

Duke, hiring managers at PharMA® and CDISC® ; to more than sixty (60) recruiting

companies who specifically engage in recruiting professionals with SAS® back ground in and

around greater Philadelphia and while these companies have access to 95% of SAS® based

consulting opportunities nationwide; to managers at Career Management Center at Duke; to

hirinmg managers at Therom, PPDI, Paraxel, Centacor, J & J, and Merck ; to Vurimindi’

manager at HealthCore and Hemispherex;

320. By the reason of purposeful dissemination of negative employment reference for Vurimindi

in violation to CRA 1964 Title VII, Vurimindi has suffered loss of employment at HealthCore

and Hemispherex; loss of pay, loss of reputation, and emotional distress due to the loss of

employment. Therefore given that, the Wyeth, Accenture, Inventive, Hoseyni, Zhou, Kopko,

Moyer and Williams, retaliated Vurimindi through purposefully disseminating negative

employment reference for Vurimindi and such retaliation and dissemination of negative

employment reference was the proximate cause of damage to Vurimindi.

321. Because, Wyeth, Accenture, Inventive, Hoseyni, Zhou, Kopko, Moyer and Williams retaliated

Vurimindi through purposefully disseminating negative employment reference for Vurimindi

was in reckless disregard to the public policy and reckless disregard to the physical,

emotional and financial wellbeing of Vurimindi, punitive damages should be awarded against

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Wyeth, Accenture, Inventive, Hoseyni, Zhou, Kopko, Moyer and Williams in an amount to be

determined at trial.

(IX) COUNT – 5: CAUSE OF ACTION – CONSPIRACY TO INTERFERE WITH EQUAL ENJOYMENT OF RIGHTS UNDER EQUAL EMPLOYMENT OPPORTUNITY STATUTES AGAINST SPECTOR, HOSEYNI, ZHOU, KOPKO, MOYER, WILLIAMS, WYETH, ACCENTURE AND INVENTIVE:

322. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

323. At Wyeth, it’s a practice (i) stunt career growth development for people of color, people of

foreign origin (India) and immigration status (H1B or Green Card); (ii) not to retain and

develop people of color, people of foreign origin (India) and immigration status (H1B or

Green Card) into leadership roles; (iii) only to encourage and promote tall, looking handsome

with blue eyes male Caucasians as managers for outsourcing companies or service providers

(such Accenture and Inventive).

324. Vurimindi belongs to protected class, defined Civil Rights Act of 1964, and alleging violations

of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2, and 42 U.S.C. § 1981.

325. Vurimindi incorporates herein by reference preceding paragraphs [262 through 287] to show

discriminatory animus and motive for Wyeth, Accenture, Inventive, Spector, Hoseyni, Zhou,

Kopko, Moyer and Williams against Vurimindi.

326. Vurimindi begin his work at Wyeth as project manager for Cytel to manage the work flow

between Cytel and Wyeth, and promote Cytel’ work product quality and value proposition

and thereby attract more work across therapeutic areas.

327. Immediately after Vurimindi begin to perform his job duties Wyeth employees Kopko, Moyer

and Williams, begin to make deprecatory statements about Vurimindi’ ability as manager

and ability to understand the clinical data analysis work.

328. After Wyeth hired Hoseyni, along with Zhou joined Kopko, Moyer and Williams, and begin to

systematically convert their transitory deprecatory statements about Vurimindi into

institutional memory across Wyeth.

329. As a result, therapeutic area heads across Wyeth didn’t engage Cytel in the Clinical Data

Analysis work, when Vurimindi managing Wyeth-Cytel outsourcing project.

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330. In June 207, after Wyeth terminate Cytel’ contract, and hire Vurimindi as a non-manager and

as CDISC® Subject Matter Expert, Wyeth employees Hoseyni, Zhou, Kopko, Moyer and

Williams begin to treat Vurimindi less favorably than Li, Tian, Farina and Baldovin, who work

along with Vurimindi at Wyeth and are outside of Vurimindi’ CRA of 1964 protected class as

follows: (i) Wyeth paid higher hourly bill rates or wages to than Li, Tian, Farina and Baldovin

than Wyeth paid to Vurimindi; (ii) Wyeth offered work from home for at least two (2) days in

a week for many of its employees and consultants who attending graduate and/or

undergraduate and/or doctoral programs and denied work from home for at least two (2)

days in a week for Vurimindi; (iii) Wyeth, offered favorable, interesting, and fun job tasks

having high visibility across Wyeth with future career development opportunities to Li, Tian,

Farina and Baldovin and in contrast Wyeth, offered uninteresting, boring and repetitive with

low visibility across Wyeth with no future career development opportunities to Vurimindi.

331. After Vurimindi join his Pre-MBA In June 2007, at Wharton and join his MBA in March 2008

at Duke to obtain his high value education, and explicitly make it know to Hoseyni and Kopko

and Wyeth HR Department, that Vurimindi is extremely interested to obtain managerial role

at Wyeth commensurate to his academic knowledge, experience, and personal

accomplishments, Hoseyni and Kopko created and maintained an hostile work environment

for Vurimindi to quit his job on his own and when Vurimindi didn’t quit his job, Wyeth

terminated Vurimindi’ employment prior completing his MBA and thereby sealed his

opportunities to even to try to seek managerial role within Wyeth.

332. In order to prevent Vurimindi complete his MBA course and if by chance, Vurimindi compete

his MBA program, in order to make Vurimindi leave Wyeth prior to his attempt to seek a

managerial role at Wyeth, Spector, Hoseyni, Zhou, Kopko, Moyer and Williams indulged

Accenture and Inventive employees in disseminating selective negative information about

Vurimindi to Wyeth Senior management to influence their emotions, and their behavior

towards Vurimindi.

333. Wyeth employees Hoseyni, Zhou, Kopko, Moyer and Williams and Accenture and Inventive

employees, voluntarily, willfully and actively participated in disseminating selective negative

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information about Vurimindi and creating and maintaining a hostile work environment in

violation to CRA 1964 Title VII.

334. By the reason of Wyeth, Accenture and Inventive employees willful participation in

implementing Wyeth practice of discourage career growth of people with Vurimindi’

characteristics, in violation to CRA 1964 Title VII, Vurimindi suffered from loss of

employment, loss of pay, loss of reputation, and emotional distress due to the loss of

employment, while Vurimindi attending his WEMBA program at Duke. Therefore given that,

the Wyeth, Accenture, Inventive, Hoseyni, Zhou, Kopko, Moyer and Williams, conspired to

implement Wyeth’ unlawful retention and career growth policy and conspiracy was the

proximate cause of damage to Vurimindi.

335. Because, Wyeth, Accenture, Inventive, Hoseyni, Zhou, Kopko, Moyer and Williams

wrongfully terminated Vurimindi’ employment was reckless disregard to CRA 1964 Title VII

and reckless disregard to Vurimindi’ physical, emotional and financial wellbeing, punitive

damages should be awarded against Wyeth, Accenture, Inventive, Hoseyni, Zhou, Kopko,

Moyer and Williams in an amount to be determined at trial.

(X) COUNT – 6: CAUSE OF ACTION – SLANDER AGAINST SPECTOR, HOSEYNI, ZHOU, KOPKO, MOYER, WILLIAMS, WYETH, ACCENTURE AND INVENTIVE:

336. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

337. As a supervisor talking to about his/her subordinate, supervisor “opinion” has official tone,

and message receiver is conditioned to accept supervisor’ “opinion” as true, because

supervisor is responsible for making decisions of work quality and attitude.

338. It is even truer, when supervisor talking to about one of his/her subordinate with other

subordinates under his/her supervision, the other subordinates accept their supervisor

“opinion” as true, and get on supervisor good side and supervisor knows that those

comments has propensity to start division and began a gang like mentality.

339. Wyeth managers Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams, who occupy

managerial positions purposefully made deprecatory following statements about Vurimindi

with their superiors, subordinates, and peers such as Eleuteri, Test, Jessup, Forman, Reiss,

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Shaw, Chrupcala, Gonzalez, Vasile, Padmanabhan, Baldovin, Cheng, Farina, Neal, Tian, Bagga,

Bond, Clark, Schindler, Chartier, Patterson, Dragalin, Baker, Stieglitz, Binz, Yost, Bennett,

Bond, Zhou, and Moores.

(i) GSK terminated Vamsi’ contract and revoked his H1B and Vamsi filed Wrongful

Termination and Sexual Harassment complaint with EEOC.

(ii) Vamsi is slow

(iii) Vamsi don’t have interest in his job

(iv) Vamsi didn’t pass high school

(v) Wyeth couldn’t able to verify Vamsi’ credentials

(vi) Vamsi was a Juvenile delinquent

(vii) Vamsi is not a good fit within Wyeth

(viii) Vamsi is not capable to handle managerial responsibilities.

(ix) Vamsi is a Hot Potato

(x) Vamsi is a Tattle teller

(xi) Vamsi can’t process two things at one time. (imputing mental processing capacity)

340. As expected and anticipated by Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams, to their

superiors, subordinates, and peers accepted their purposeful deprecatory statements about

Vurimindi and began a gang mentality.

341. These many number of Wyeth employees, and consultants nearly for five (5) years

repeatedly many times, transitory deprecatory statements become converted into

institutional memory across Wyeth.

342. Wyeth managers Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams induced, Bagga, Hank

and Tian purposefully disseminate deprecatory statements to Vurimindi’ classmates at

Wharton, as a longtime employees and consultants of Wyeth, Vurimindi’ classmates are

conditioned to accept Bagga, Hank and Tian’ statements as a result, as expected and

anticipated by Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams, Vurimindi was forced to

drop from Wharton Pre-MBA course.

343. Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams occupy managerial positions and

contacting Jeff Walker and Neal Walker at Octagon Research, and Jeff Walker and Neal

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Walker are depending upon these managerial references for business from Wyeth, and

naturally inclined to believe these managers deprecatory statements to Duke and Vurimindi’

classmates at Duke and facilitate these managers to establish direct contact with Vurimindi’

classmates Jason Link, Kristoffer Singleton, David Mitchell, Moira Ringo, Douglas Bashar,

Johnny Williams, John Dohnal, Alissandro Castillo, Robert Ross, Sudheer Dharanikota, Sunil

Balasaheb Patil, Amit Khare, Peter Walton, Eugene White, Rajiv Prasad Kolagani, Pratibhash

Chattopadhyay, Jennifer Erickson, Seth Gillespie, Shana Keating, Gregory Valentine, Pradeep

Rajagopal, Rajiv Patnaik, Lei Zhu, John Espey, Sanjay Mishra, Sankar Ramesh, Kevin Giusti,

and Sreedhar Manjigani.

344. Vurimindi’ classmates at Duke are conditioned to accept Wyeth managers Spector, Hoseyni,

Zhou, Kopko, Moyer, and Williams statements as true as a result, as expected and

anticipated by Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams, Vurimindi has been

subjected to horrendous harassment by just above mentioned Vurimindi’ classmates until,

end of his MBA program and even after two years after completing his MBA program,

Vurimindi didn’t get any meaningful employment opportunity based on his MBA, through

Career Management Center at Duke and Vurimindi’ classmates and professors.

345. Wyeth managers Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams reaching more than

sixty (60) recruiting companies who specifically engage in recruiting professionals with SAS®

back ground in and around greater Philadelphia and while these companies have access to

95% of SAS® based consulting opportunities nationwide; to hiring managers at CRO such as

Therom, PPDI, and Paraxel and purposefully disseminated deprecatory statements about

Vurimindi, and as expected by Wyeth managers, Vurimindi didn’t get any meaningful

employment opportunity for about eighteen (18) months, after Wyeth terminated

Vurimindi’ employment contract.

346. Wyeth managers Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams reaching hiring

managers at Centacor, J & J, and Merck and purposefully disseminate deprecatory

statements, sealed Vurimindi’ opportunity for employment at above said pharmaceutical

companies.

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347. Wyeth managers Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams contacting Vurimindi’

manager at HealthCore and Hemispherex and purposefully disseminate deprecatory

statements about Vurimindi, managers at HealthCore and Hemispherex believed Wyeth

managers, because, Vurimindi worked five (5) years at Wyeth and quickly thereafter

terminated Vurimindi’ employment contract.

348. Except, “GSK terminates Vurimindi’ contract, revoke H1B and Vurimindi filing a complaint

with EEOC” all other statements false. Even if this one true statement, there is no

meaningful reason for Wyeth managers, except they are publishing with discriminatory

animus against Vurimindi.

349. Wyeth managers Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams’ purposeful

dissemination of false deprecatory statements impute Vurimindi ability as a professional

business manager and thereby prejudiced Vurimindi from obtaining an employment as a

manager.

350. As aforementioned, Accenture and Inventive employees were voluntary and willful

participants in publishing and disseminating to other Accenture employees and Inventive

employees of Wyeth managers purposeful false deprecatory statements, which impute

Vurimindi ability in the minds of Accenture and Inventive employees and as results,

Vurimindi’ resume never been presented to their clients in a meaningful manner.

351. By the reason of purposeful false deprecatory statements of Wyeth managers Hoseyni,

Zhou, Kopko, Moyer, and Williams’ and Accenture and Inventive employees, Vurimindi

suffered from (i) termination of Vurimindi’ employment contract by Wyeth, HealthCore and

Hemispherex, (ii) loss of employment, (iii) loss of salary (iv) loss of reputation (v) loss of loss

of future employment opportunities through the Vurimindi’ classmates at Wharton and

Duke. Therefore given that, the Kopko, Moyer and other Wyeth and Accenture employees

purposefully disseminated false deprecatory statements about Vurimindi and such

purposeful dissemination of false deprecatory statements was the proximate cause of

damage to Vurimindi.

352. Because, Wyeth managers Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams and

Accenture and Inventive employees purposeful dissemination of false deprecatory

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statements about Vurimindi was made reckless disregard to the truth, and current and

future employability of Vurimindi and thereby to eventual Vurimindi’ economic, physical,

emotional wellbeing, punitive damages should be awarded against Wyeth managers

Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams and Accenture and Inventive employees

in an amount to be determined at trial.

(XI) COUNT – 7: CAUSE OF ACTION – INVASION OF PRIVACY AGAINST HOSEYNI, ZHOU,

KOPKO, MOYER, WILLIAMS AND WYETH, ACCENTURE 353. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

Intrusion of Solitude and Seclusion:

354. In November 2004, Wyeth provided a laptop to Vurimindi to access Wyeth data servers and

during orientation Wyeth told to Vurimindi that his computer activity is monitored by Wyeth

transparently in the background and it is invisible to Vurimindi.

355. In November 2004, during orientation Wyeth specifically told to Vurimindi that Wyeth had

software to records all activities performed on his computer such as start and stop time of

each computer applications launched, opened documents, and visited web-sites. Wyeth also

told to Vurimindi that the software they used is monitoring software, only to monitor

functionality of computer applications and that software don’t support any form of spying,

such as record passwords, screens captures, keystrokes, emails or chat content and don’t

violate Vurimindi’ privacy.

356. After the fact, Vurimindi believe that sometime in year 2005, Kopko and Moyer installed as

“keylogger” program on Vurimindi’ computer to collect password for his personal email IDs

such as Vurimindi@yahoo.com ; vamsidhar2000@hotmail.com ; vamsidhar@usa.com and

his personal bank online account UserID and password.

357. Kopko and Moyer illegally and unlawfully read Vurimindi’ personal emails and collated and

coalesce that personal information with the third party back ground search report prepared

for Wyeth.

358. In Year 2005, after Vurimindi start reporting discrepancies in Kopko’ team work product,

Kopko and Moyer begin to manufacture a rumor tangentially surrounding a topic that might

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elicit fear in Vurimindi and at the same time undermine Vurimindi’ credibility as a

professional within Wyeth setting.

359. When Kopko and Moyer manufacture a rumor that “Vamsi is a Juvenile delinquent”, Kopko

and Moyer get hold of his personal email between him and his family members exchanging a

an interesting situation that they had to deal with Vurimindi, when he first participated in a

public protest. As a matter of fact there were no charges made against Vurimindi and a

conviction doesn’t arise. However, branding Vurimindi as a “Juvenile delinquent” served

Kopko and Moyer because they elicited fear in Vurimindi and at the same time, undermine

Vurimindi’ credibility.

360. After Kopko and Moyer hired Vurimindi in June 2007, at that time, Hoseyni had knowledge

about installation of “keylogger” program on Vurimindi’ computer.

361. In October 2007, after Vurimindi identified problems in Accenture work, Hoseyni, Kopko and

Moyer, divulged information about websites that Vurimindi reading for his Wharton course

work, and created doubts in minds of his classmates, that Vurimindi might have been

possibly plagiarizing his course.

362. In December 2008, Hoseyni, Kopko and Moyer, divulged information about websites that

Vurimindi reading for his Duke Course work, and created doubts in minds of his classmates,

that Vurimindi might have been possibly plagiarizing his course.

Public Disclosure of Private Facts:

363. In December 2008, Hoseyni, Kopko and Moyer private married life facts that has been

exchanged in the form of email between Vurimindi and his wife and family in India to

Vurimindi’ colleagues at Wyeth and Duke. Later in February 2009, during Christmas party

Kopko told about Vurimindi’ private married life facts to Kopko’ team members.

False Light:

364. As detailed in factual allegations section, between January 2005 and until October 2011,

Wyeth managers disseminate deprecatory statements such as “Vamsi is slow”, “Vamsi don’t

have interest in his job”, “Vamsi didn’t pass high school”, “Wyeth couldn’t able to verify

Vamsi’ credentials”, “Vamsi was a Juvenile delinquent”, “Vamsi is not a good fit within

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Wyeth”, “Vamsi is not capable to handle managerial responsibilities”, “Vamsi is a Hot

Potato”, “Vamsi is a Tattle teller” ,“Vamsi can’t process two things at one time” (imputing

mental processing capacity).

365. Wyeth managers Hoseyni, Zhou, Kopko, Moyer, and Williams know that all just above said

statements are false, because they manufacture those statements and overtime,

systematically made the above said transitory deprecatory statements to become converted

into institutional memory across Wyeth.

366. On its face, itself those statements are highly offensive false statements, because, those

statements seriously undermine the credibility of Vurimindi across several distinct

environments such as Wyeth, Wharton, Duke, HealthCore, and Hemispherex.

367. By the reason of Intrusion of Solitude and Seclusion, Public Disclosure of Private Facts, False

Light, publication of purposeful false deprecatory statements of Wyeth managers Spector,

Hoseyni, Zhou, Kopko, Moyer, and Williams’ and Accenture and Inventive employees,

Vurimindi suffered from (i) termination of Vurimindi’ employment contract by Wyeth,

HealthCore and Hemispherex, (ii) loss of employment, (iii) loss of salary (iv) loss of

reputation (v) loss of loss of future employment opportunities through the Vurimindi’

classmates at Wharton and Duke. Therefore given that, the Kopko, Moyer and other Wyeth

and Accenture employees purposefully publicized false deprecatory statements about

Vurimindi and such purposeful publication of false deprecatory statements was the

proximate cause of damage to Vurimindi.

368. Because, Wyeth managers Spector, Hoseyni, Zhou, Kopko, Moyer, and Williams and

Accenture and Inventive employees Intrusion of Solitude and Seclusion, Public Disclosure of

Private Facts, False Light, publication of purposeful false deprecatory statements about

Vurimindi was made reckless disregard to the truth, and current and future employability of

Vurimindi and thereby to eventual Vurimindi’ economic, physical, and emotional wellbeing,

punitive damages should be awarded against Wyeth managers Spector, Hoseyni, Zhou,

Kopko, Moyer, and Williams and Accenture and Inventive employees in an amount to be

determined at trial.

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(XII) COUNT – 8: CAUSE OF ACTION – INTENTIONAL INTERFERENCE WITH ECONOMIC RELATIONSHIP AGAINST ACCENTURE:

369. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

370. In May 2007, Accenture enter into an agreement with Wyeth to migrate 900 clinical trial

data from Wyeth data standards to CDISC® standards.

371. In July 2007, under the arrangement made with Kopko and Moyer, Vurimindi started to work

as CDISC® Subject Matter Expert at Wyeth.

372. Accenture employees know that Vurimindi and Wyeth had an economic relationship and

such relationship is in existence, because, Accenture employees asked to terminate

Vurimindi’ employment contract.

373. Vurimindi job duty is to prepare Data Migration Rules and validate the migrated data and

notify the irregularities in Accenture work product.

374. Kopko and Moyer asked Vurimindi to validate the migrated data and report data

discrepancies.

375. According to validation results, Vurimindi begin document to document all discrepancies.

376. Accenture employees Cheng, Farina, Neal, and Clark asked Vurimindi not to report the

irregularities, but rather change the data migration rules.

377. Vurimindi didn’t accede to Accenture employees demand.

378. Accenture employees Cheng, Farina, Neal, and Clark retaliated Vurimindi by asking Kopko,

Moyer, Hoseyni and other Wyeth Sr. Management to terminate Vurimindi’ contract; and

reach-out Vurimindi’ classmates at Wharton and Duke University and told them “Vamsi is

not capable to handle managerial responsibilities”; “Wyeth couldn’t able to verify Vamsi’

credentials”, “Vamsi didn’t pass high school” and “Vamsi was a Juvenile delinquent”.

379. When, Vurimindi show visible emotional pain for Vurimindi’ classmates verbal remarks, at

that time, Cheng, Farina, Neal, and Clark suggested to Vurimindi, the problem at Wharton

and Duke University will go away, if Vurimindi stop reporting Accenture irregularities.

380. Vurimindi didn’t accede to Accenture employees demand.

381. Accenture employees Cheng, Farina, Neal, and Clark retaliated Vurimindi by asking Kopko,

Moyer, Hoseyni and other Wyeth Sr. Management to terminate Vurimindi’ contract.

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382. In March 2009, Wyeth terminated Vurimindi’ contract.

383. Accenture employee’s interference with Vurimindi’ contract by inducing Wyeth to terminate

Vurimindi’ contract and subsequent Wyeth termination of Vurimindi’ employment contract

and as result, Vurimindi suffered from loss of employment, loss of pay and reputation and

suffer from mental distress.

384. Accenture employee’s intentional acts caused Wyeth to terminate Vurimindi’ employment

contract, and subsequently Vurimindi suffered an unexpected job loss, loss of pay, loss of

reputation, shame, mortification, and injury to his feelings. Inducing Wyeth to terminate

Vurimindi’ contract is a disruption of economic relationship between Wyeth and Vurimindi.

385. By the reason of intentional tortious / wrongful Interference with the economic relationship

between Vurimindi and Wyeth by Accenture employees, Vurimindi suffered loss of

employment, salary and reputation. Therefore, given that the Accenture wrongfully

interfered between Vurimindi and Wyeth business relationship, and such intentional

Wrongful Interference was the proximate cause of damage to Vurimindi.

386. Because, Accenture purposefully Interfered with Vurimindi’ employment contract in

reckless disregard to the truth, and current and future employability of Vurimindi and

thereby to eventual Vurimindi’ economic, physical, and emotional wellbeing, punitive

damages should be awarded against Accenture in an amount to be determined at trial.

(XIII) COUNT –9: CAUSE OF ACTION – WRONGFUL TERMINATION AGAINST HEALTHCORE (WELL POINT INC)

387. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

388. On 11th October 2010, Kim Dixon, Recruiter with Iconma, LLC (“Iconma”) via email inform

Vurimindi about a two (2) months contract position as Senior Research Programmer/Analyst

at HealthCore in Wilmington, DE and quickly thereafter setup an in-person interview with

Quimbo, Cobb, and Liang and after the interview Quimbo extended the job offer.

389. Upon HealthCore manager Quimbo extend a job offer, Vurimindi signed an employment

contract with Iconma.

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390. After an unemployment gap of eighteen (18) months, in 1st week of November 2010,

Vurimindi begin his work as Senior Research Programmer/Analyst at a much lower bill rate

than that ordinarily paid to software programmers with similar experience that of Vurimindi.

391. In November 2010, as soon Vurimindi began his work at HealthCore Kopko, Moyer, Zhou and

Hoseyni, purposefully disseminated negative employment reference for Vurimindi to

someone at HealthCore and told them that “Wyeth couldn’t able to verify Vamsi’

credentials”, “Vamsi was a Juvenile delinquent”, “Vamsi is not a good fit within Wyeth” and

about as to how Duke, his classmates at Duke and his neighbors treated Vurimindi.

392. In November 2010, after Vurimindi begin his work at HealthCore, Wyeth managers Hoseyni,

Zhou, Kopko, Moyer and Williams facilitated a direct communication between his neighbors

at Hoopskirts Factory Lofts Building and Vurimindi’ colleagues at HealthCore.

393. Since then, Vurimindi’ neighbors on day to day basis communicated Vurimindi’ private life

facts on daily basis to Vurimindi’ colleagues at HealthCore.

394. Since beginning of November 2010 through 1st Week of December 2010, Vurimindi’

colleagues at HealthCore showing sly, sneer in a mocking fashion, and talked about

Vurimindi’ day to day private life facts surrounding private criminal complaint filed by his

neighbor Borowski and Vurimindi’ horrendous experience at Duke.

395. In 4th week of November 2010, Vurimindi’ colleagues started to talk about results of

Vurimindi’ background search conducted by Iconma for HealthCore.

396. At that time, Vurimindi take a serious objection for purposefully releasing facts in

background search report to colleagues at HealthCore, when there is no reason for them to

know the contents of Vurimindi’ back ground search report compiled by Iconma.

397. Immediately, Vurimindi made a formal oral complaint about possible discriminatory practice

of purposeful dissemination of facts in background search report to Vurimindi’ colleagues,

when they don’t have privilege to know, Vuriminfdi’ privileged private facts. Vurimindi, also

asked as to how asked Quimbo, as to how she and other colleagues know about Vurimindi’

day–to–day private life facts and why they talk about them at HealthCore work

environment.

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398. In 1st week of December 2010, and a day before, HealthCore terminate Vurimindi’ contract,

Vurimindi’ neighbor, Lauren Westfield Nayerahmadi (“Nayerahmadi”), who live in a condo

bellow Vurimindi’ condo, and shouted across the floor “hey crazy, they are going to fire

you”. In response, Vurimindi enquired as to how Nayerahmadi know about Vurimindi’

employment situation, prior to Vurimindi know himself. Nayerahmadi didn’t answer.

399. In 1st week of December 2010, two days after Vurimindi’ conversation with his manager,

HealthCore terminated Vurimindi’ employment contract, prior to the expiration of two (2)

months contract period.

400. By the reason of terminating Vurimindi’ contract in violation to public policy, Vurimindi has

suffered loss of employment, loss of pay, loss of reputation, and emotional distress due to

the loss of employment. Therefore given that, HealthCore, Wrongfully Terminated

Vurimindi’ contract and such Wrongful Termination was the proximate cause of damage to

Vurimindi.

401. Because, HealthCore Wrongfully Terminated Vurimindi’ contract was reckless disregard to

the public policy and reckless disregard to the physical, emotional and financial wellbeing of

Vurimindi, punitive damages should be awarded against HealthCore in an amount to be

determined at trial.

(XIV) COUNT –10: CAUSE OF ACTION – WRONGFUL TERMINATION AGAINST HEMISPHEREX BIOPHARMA:

402. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

403. In October 2010, Nancy Schocklin (“Schocklin”), HR Manager at Hemispherex reviewed

Vurimindi’ resume on Monster.com and feel that Vurimindi was a potential candidate for a

contract to permanent position of Biostatistician at its corporate office located in center city

of Philadelphia, PA.

404. On 26th October 2010, in response to Hemispherex job opening, Vurimindi told to Schocklin,

that Vurimindi wasn’t trained to work as a biostatistician, but can work as a statistical

programmer.

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405. On 26th October 2010, Schocklin send a Clinical Programmer job description ad set-up an in-

person interview with Wayne Springate (“Springate“) and Diane Young (“Young”).

406. In November 2010, Springate and Young interviewed Vurimindi and after verifying

references, Hemispherex extended an offer and willing to pay at substantially lower bill rate

than people with similar experience of Vurimindi.

407. On 6th December 2010, Hemispherex emailed an offer letter for contract Clinical

Programmer IV position and if Vurimindi accept the offer, he can begin his work on 8th

December 2010.

408. On 6th December 2010, Vurimindi accepted Hemispherex offer letter and send his

acceptance by email.

409. Hemispherex offer letter state that “Either you or Hemispherex BioPharma, Inc may

terminate this agreement at anytime by providing notice of termination in writing to the

other party”

410. In December 2010, soon after, Vurimindi begin his work at Hemispherex, yeth managers

Hoseyni, Zhou, Kopko, Moyer, and Williams contacted Springate and Young at Hemispherex

via Octagon Research sales team and purposefully disseminated negative employment

reference for Vurimindi and told that “Wyeth couldn’t able to verify Vamsi’ credentials”,

“Vamsi was a Juvenile delinquent”, “Vamsi is not a good fit within Wyeth”.

411. In January 2011, Wyeth managers Hoseyni, Zhou, Kopko, Moyer, and Williams contacted

Vurimindi’ colleagues William Carter, Wayne Pambianchi, Wayne Springate, Charles

Bernhardt, David Strayer, Chaunce Bogard, Diane Young and Lori Santos at Hemispherex and

told them as to how Vurimindi has been treated by his classmates at Duke and his neighbors.

412. In May 2011, after six (6) months of his work at Hemispherex, Vurimindi vexed with his

colleagues talk about Vurimindi’ private life facts, Vurimindi directly enquired Springate,

how he is able to get Vurimindi’ private life facts on day-to-day basis.

413. In May 2011, in response, Springate told Mary Schaheen (“Schaheen”) is passing Vurimindi’

day-to-day private life facts. In response, Vurimindi asked Springate would he be amenable

to testify in court, that Schaheen purposefully disseminating deprecatory statements to him

or to someone at Hemispherex. Springate didn’t respond to Vurimindi’ request.

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414. In August 2011, Vurimindi frustrated with his colleagues and contacted Schocklin, and asked

her to ask Springate to cease and desist from maintaining a communication channel to

obtain Vurimindi’ private life facts at work.

415. On 12th September 2011, Vurimindi’ father suffered from heart attack and Vurimindi told to

Wayne Springate that he needs to travel to India and initially Wayne Springate asked

Vurimindi to take Hemispherex laptop to India, such that Vurimindi can log-on to

Hemispherex and work from India, as long as Vurimindi need to stay in India.

416. On or about 22nd September 2011, Wayne Springate asked not to take Hemispherex laptop

to India and ask Vurimindi to call him after Vurimindi return from India.

417. On 2nd October 2011 Vurimindi’ father expired and on or about 15th October 2011, Vurimindi

returned from India and contacted Wayne Springate to return to his work.

418. At that time, Wayne Springate told to Vurimindi that Hemispherex don’t have work for

Vurimindi.

419. Hemispherex didn’t send a written notice of termination of the contract.

420. By the reason of Hemispherex terminating Vurimindi’ contract in violation to public policy,

Vurimindi has suffered loss of employment, loss of pay, loss of reputation, and emotional

distress due to the loss of employment. Therefore given that, Hemispherex Wrongfully

Terminated Vurimindi’ contract and such Wrongful Termination was the proximate cause of

damage to Vurimindi.

421. Because, Hemispherex Wrongfully Terminated Vurimindi’ contract was reckless disregard to

the public policy and reckless disregard to the physical, emotional and financial wellbeing of

Vurimindi, punitive damages should be awarded against Hemispherex in an amount to be

determined at trial.

(XV) COUNT – 11: CAUSE OF ACTION – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

AGAINST SPECTOR, HOSEYNI, ZHOU, KOPKO, MOYER, WILLIAMS, WYETH, ACCENTURE, INVENTIVE, HEALTHCORE AND HEMISPHEREX:

422. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

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423. As aforementioned discriminatory animus against Vurimindi, Wyeth managers Hoseyni,

Zhou, Kopko, Moyer and Williams created a hostile work environment through purposeful

dissemination of depreciatory statements about Vurimindi throughout Wyeth.

424. As aforementioned, Wyeth managers Hoseyni, Zhou, Kopko, Moyer and Williams exploited

Vurimindi’ foreign (Indian) status and H1B immigration status, treated Vurimindi like an

indentured servant as follows:

i) Kopko, Moyer and Williams implemented unlawful methods to accede Vurimindi to their

unlawful demand from not to report discrepancies in their computer programs, when

Vurimindi reported discrepancies in their team’ work product as part of his job duty,

squash Vurimindi from being creative in performing his job duties, exert coercive

pressure upon Vurimindi, by mobbing and ganging-up to create psychological terror on

Vurimindi through verbal abusive and angry conversations with Vurimindi for frivolously

reasons, ridiculing Vurimindi’ English pronunciation, writing style in a mocking fashion,

asking to rewrite all signed-off validation documents under the guidance of less

experienced person than Vurimindi.

ii) On daily basis, threatening Vurimindi that they have power to influence Cytel to

terminate Vurimindi’ employment contract.

iii) Demoting Vurimindi from being Project Manager to Validation programmer

iv) Denying VPN connectivity to his team India to create undue burden upon Vurimindi.

v) Deprive Vurimindi from the opportunity to work on clinical data analysis work, which

would allow Vurimindi gain hands on experience in the statistical analysis and

subsequently allow Vurimindi earns higher wages with stable employment.

vi) Assigning menial job tasks

vii) Purposefully disseminating depreciatory statements about Vurimindi at Wharton and

Duke.

viii) Demoting Vurimindi from CDISC® Subject Matter Expert role to Data Mapping Document

Coordinator role.

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ix) Demoting Vurimindi from Data Mapping Document Coordinator role to Data Mapping

Document Writer by changing job description and by constrain individuality and create a

role conflict to make Vurimindi’ opinions insignificant.

x) At one hand encourage Vurimindi by writing recommendation letters for his MBA

program and making Vurimindi incur exorbitant amount of tuition fee and loss of pay to

attend MBA program and on the other hand contact university authorities to dismiss

Vurimindi from MBA program

xi) When Vurimindi made a formal complaint about hostile work environment, and resulting

mental health problems, changing Vurimindi’ work desk, to a physical location where an

inadequate natural light and electric lighting;

xii) After, Vurimindi told to Wyeth about inadequate natural light, Vurimindi’ work desk

moved to corner spaces, where administrative assistants usually sit and no natural light.

xiii) Threatening that they will make a complaint to FBI and send Vurimindi to Jail.

xiv) On day-to-day basis contacting Vurimindi’ classmates at Duke and informing them as to

how they have been treating Vurimindi at Wyeth.

xv) Specifically eliminate Vurimindi’ position and terminate employment contract by

disregarding their promise to retain Vurimindi until completion of his MBA program.

xvi) After terminating Vurimindi’ employment contract, purposefully disseminate negative

employment reference to more than sixty (60) recruiting companies and obstructing

Vurimindi from obtain a reasonable employment opportunity.

xvii) After eighteen months of unemployment and after a great difficulty, Vurimindi obtained

an employment at a substantially lower wages than that of his peers, and purposefully

disseminate negative employment reference for Vurimindi and caused HealthCore to

terminate Vurimindi’ employment contract.

xviii) After HealthCore terminate its employment contract with Vurimindi and after Vurimindi

obtains another employment at Hemispherex, purposefully disseminate negative

employment reference for Vurimindi and caused Hemispherex terminate Vurimindi’

employment contract.

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xix) After Hemispherex terminate Vurimindi’ employment contract, when Vurimindi

attempted to obtain an employment at Theorem, a local CRO, purposefully disseminate

negative employment reference for Vurimindi to Theorem and influencing Theorem not

to hire Vurimindi.

425. As aforementioned Accenture, Inventive HealthCore and Hemispherex employees were

willful and voluntary participants in furthering Wyeth managers agenda to destroy and ruin

Vurimindi’ mental health and thereby destroying Vurimindi’ financial and familial status.

426. In July 2008, Vurimindi specifically told to Wyeth that the hostile work environment had a

devastating effect on his mental health and asked Wyeth, to rectify the situation,

unfortunately, despite Vurimindi give a constructive notice about his mental health, Wyeth

managers intensified the hostility towards Vurimindi and continued to their hostility after

Vurimindi left Wyeth nearly three (3) years ago. The actions of Wyeth managers along with

Accenture, Inventive HealthCore and Hemispherex employees’ repeated, regular and

ongoing objectionable behavior had a cumulative effect on Vurimindi.

427. Because of the Wyeth managers along with Accenture, Inventive HealthCore and

Hemispherex employees’ repeated, regular and ongoing objectionable behavior was

intentional, willful and wanton and malicious and as result of their conduct Vurimindi,

repeatedly had nightmares, become uncomfortable to talk to his wife, relatives, colleagues,

and neighbors, lacked interest in social relationships, preferred solitary lifestyle, become

secretive about his activities; lack of sexual interest, while simultaneously had elaborative

sexual fantasies lead his wife to get separated and file for divorce, forgetting to remember

and answers that he had just learned during the semester and answer to Duke term exam

questions; forget about his years of software programming language techniques and his

important job activities and responsibilities that he had done for many years and unable to

answer during his interviews for his new job interviews; become getting easily startled,

irritated and outbursts of anger with normal noise levels and lead to become more vigilant

and suspicious about his neighbors, which lead to install security monitoring system in his

condo; which leads Vurimindi suffer from chronic anxiety, depression, worrying, irritability,

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restlessness, constant inner tension, inability to sleep and relax, increasing defensiveness,

moodiness and suffered from PTSD and GAD;

428. The above described conduct of Wyeth managers along with Accenture, Inventive

HealthCore and Hemispherex employees, was extreme, outrageous in character, and so

extreme in degree that exceed all bounds of decency, utterly intolerable by civilized society

and Defendants above described conduct was designed, engineered and intended to and

inflict mental anguish and severe emotional distress upon Vurimindi and were committed

with reckless disregard for their foreseeable impact on Vurimindi emotional state.

429. Aforementioned Wyeth managers along with Accenture, Inventive HealthCore and

Hemispherex employees actions were intentional, willful, wanton and malicious; and they

were intended to and inflict mental anguish and severe emotional distress on the Vurimindi.

Aforementioned Wyeth managers along with Accenture, Inventive HealthCore and

Hemispherex employees actions were committed with reckless disregard for their

foreseeable impact on the Vurimindi emotional state.

430. After, his classmates at Duke publicly talk about his prescription medications, and

stigmatized and become prejudice against Vurimindi, become fearful to take psychotherapy

and take psychiatric drugs, because Vurimindi will be discriminated, and prejudice by being

seen as mentally ill by his peers, because prescription medication records will be publicized

by his adversaries as the defendants did in Vurimindi vs. Fuqua School of Business et al and

started to adopt other remedies to take control of his mental health.

431. By the reason of intentional infliction of emotional distress by Wyeth managers along with

Accenture, Inventive HealthCore and Hemispherex employees Vurimindi has suffered loss of

his employment, loss of income, loss of his mental health, reputation, shame, mortification,

and injury to his feelings.

432. Because, Wyeth managers along with Accenture, Inventive HealthCore and Hemispherex

employees, intentional infliction of emotional distress was wanton, willful and in reckless

disregard for the safety and financial wellbeing of the Vurimindi, punitive damages should be

awarded against it in an amount to be determined at trial.

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(XVI) COUNT – 12: CAUSE OF ACTION – FRAUDULENT MISREPRESENTATION AGAINST HEMISPHEREX:

433. Vurimindi incorporates herein by reference all preceding paragraphs 01 through 263 of this

Complaint the same as if fully set forth hereinafter.

434. Hemispherex hired Vurimindi on a consulting basis for a position as Clinical Programmer IV.

435. Hemispherex agreed to pay at the rate of $51.75 per hour for Vurimindi’ services.

436. Hemispherex told to Vurimindi, that Vurimindi must come to Hemispherex Philadelphia

office five (5) days in a week and work from 8:00 AM to 5:00 PM.

437. At no time, during his telephone conversations with Nancy Schocklin or his in-person

interview with Springate and Young told to Vurimindi that Hemispherex will be issuing a

1099, instead of W2.

438. Hemispherex offer letter didn’t state that Hemispherex will be issuing a 1099, instead of W2.

439. Vurimindi, throughout his career as SAS® / Clinical Programmer, his employers paid

employer taxes and issued W2.

440. On 6th December 2010, Vurimindi accepted Hemispherex offer letter, under the assumption

that Hemispherex will be issuing a W2 at the end of year, by duly paying its portion of

employer taxes towards Vurimindi’ compensation.

441. On 6th December 2010, after Vurimindi accepting Hemispherex offer, and duly signed the

offer letter and send back to Hemispherex.

442. On 6th December 2010, Schocklin replied by email and told to Vurimindi that she is sending a

packet of paperwork by FedEx Philadelphia office and upon receipt of the paper work, asked

Vurimindi to sign and return the forms to Hemispherex.

443. On 9th December 2010, Vurimindi received a FedEx envelope from Schocklin and that

envelope contain blank template for daily work report and a sample invoice and blank W9

form.

444. On 9th December 2010, Vurimindi filled his personal information in the blank W9, signed

and send to Schocklin.

445. Since then, Hemispherex issued a pay-check for every fifteen (15) days and Vurimindi was

under the assumption that Hemispherex isn’t withholding Vurimindi’ portion of federal

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taxes, because Vurimindi signed W9 form by stating that Vurimindi is not subject to back-up

withholding.

446. In October 2011, after Hemispherex told to Vurimindi that they don’t have work for

Vurimindi and at that time Vurimindi contacted Hemispherex for his W2 form for the year

2010 and at that time, Schocklin told to Vurimindi that you have signed W9 form stating that

Vurimindi is not subject to back-up withholding and thus indirectly accepted to receive 1099

and hence, accordingly Vurimindi should pay his taxes.

447. Vurimindi responded that if Hemispherex will be issuing a 1099, then Vurimindi wouldn’t

have accepted an hourly rate of $51.75; and stated that Hemispherex indulging in unlawful

deceptive practices to hire people at lower bill rates.

448. Vurimindi made a demand upon Hemispherex to pay employer portion of the taxes, but

Hemispherex refused to pay employer taxes on Vurimindi’ wages.

449. By the reason of fraudulent misrepresentation by Hemispherex, Vurimindi is burdened with

paying employer portion of the tax on his wages.

450. Because, Hemispherex fraudulent misrepresentation was wanton, willful and in reckless

disregard for the safety and financial wellbeing of the Vurimindi, punitive damages should be

awarded against it in an amount to be determined at trial.

(XVII) PRAYER FOR RELIEF: 451. Wherefore, Vurimindi prays for the following relief:

a) Damages, in an amount to be established at trial, as compensation for injuries to

reputation, emotional suffering, past and future economic losses, invasion of

privacy, constitutional deprivations, loss of educational opportunities, loss of

future career prospects, legal and other expenses and other injuries proximately

caused enhanced by defendants wrongful conduct;

b) Damages in an amount to established at trial, to punish defendants for

fraudulent, willful and wanton and malicious conduct; to punish defendants for

outrageous conduct pursued with actual malice that recklessly and callously

disregarded Vurimindi physical and emotional well being and constitutional

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rights; to discourage defendants from engaging in similar conduct in the future;

and to deter others similarly situated from engaging in similar wrongful conduct;

c) An award for reasonable and customary costs, expenses and interest incurred in

pursuit of this action;

d) Any other relief deemed just and proper.

(XVIII) JURY TRIAL DEMAND: 452. Plaintiff hereby requests a trial by jury on all claims so triable.

Dated: September 5, 2012

0 1 .

Vamsidhar R Vurimindi , Plaintiff, Pro Se 1782 Frankford Ave, Unit 1, Philadelphia, PA 19125

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VERIFICATION

I, Vamsidhar Reddy Vurimindi, am a Vurimindi in the above-entitled action. I have read the

foregoing complaint and know the contents thereof. The same is true of my own knowledge,

except as to those matters which are therein alleged on information and belief, and as to those

matters, I believe it to be true.

I declare under penalty of perjury that the foregoing is true and correct and that this

declaration was executed at Philadelphia, Pennsylvania.

0 2 . Dated: September 5, 2012

0 3 . Vamsidhar Reddy Vurimindi , Plaintiff, Pro Se 1782 Frankford Ave, Unit 1, Philadelphia, PA 19125