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NORMAN J CLEMENT RPH., DDS, NORMAN L. CLEMENT PHARM-TECH, MALACHI F. MACKANDAL PHARMD, BELINDA BROWN-PARKER, IN THE SPIRIT OF JOSEPH SOLVO ESQ., INC., SPIRIT OF REV. IN THE SPIRIT OF WALTER R. CLEMENT BS., MS, MBA. HARVEY JENKINS, MD, PH.D., IN THE SPIRIT OF C.T. VIVIAN, JELANI ZIMBABWE CLEMENT, BS., M.B.A., IN THE SPIRIT OF THE HON. PATRICE LUMUMBA, IN THE SPIRIT OF ERLIN CLEMENT SR., EVELYN J. CLEMENT, IN THE SPIRIT OF WALTER F. WRENN III., MD., JULIE KILLINGSWORTH, IN THE SPIRIT OF FOREST TENNANT, MD., RENEE BLARE, RPH, DR. TERENCE SASAKI, MD LESLY POMPY MD., CHRISTOPHER RUSSO, MD., NANCY SEEFELDT, IN THE SPIRIT OF WILLIE GUINYARD BS., JOSEPH WEBSTER MD., MBA, BEVERLY C. PRINCE MD., FACS., NEIL ARNAND, MD., IN THE SPIRIT OF RICHARD KAUL, MD., IN THE SPIRIT OF LEROY BAYLOR, JAY K. JOSHI MD., MBA, AISHA GARDNER, ADRIENNE EDMUNDSON, ESTER HYATT PH.D., WALTER L. SMITH BS., IN THE SPIRIT OF BRAHM FISHER ESQ., MICHELE ALEXANDER MD., CUDJOE WILDING BS, MARTIN NJOKU, BS., RPH., IN THE SPIRIT OF DEBRA LYNN SHEPHERD, BERES E. MUSCHETT, STRATEGIC ADVISORS
Anand: The Motion to Vacate for Fraud Upon the Court
This legal motion asserts that a lead prosecutor committed fraud upon the court by delivering a series of deliberately fabricated factual representations directly to a judge during a critical post-trial proceeding. The text argues that the prosecution moved beyond mere advocacy into a “carefully executed scheme” to sustain a conviction by mischaracterizing witness testimony and ignoring objective medical evidence found within the government’s own files.
RULE 29 DISCREPANCIES A SERIOUS CASE OF PROSECUTORIAL AND FEDERAL JUDGE MISCONDUCT IN THE CASE OF USA vs. DR. NEIL K. ANAND, MD
By presenting these falsehoods during a Rule 29 hearing—where no jury was present and the judge served as the sole arbiter of truth—the prosecutor allegedly corrupted the judicial machinery and undermined the court’s impartial function. The document seeks to preserve these claims of prosecutorial misconduct for appellate review, contending that the integrity of the legal process was violated when the government prioritized securing a conviction over factual accuracy and institutional honesty.
Legal Analysis: Prosecutorial Transformation of Trial Error into Fraud Upon the Court
1. Strategic Context and Jurisprudential Framework
The Rule 29 proceeding represents a critical juncture in the federal criminal process, acting as a dispositive bench function where the district court serves as the sole arbiter of both fact and law. At this stage, the adversarial check of the jury is absent, and the corrective lens of immediate cross-examination is unavailable. Consequently, the prosecutor’s duty of candor undergoes a fundamental shift: it moves from the role of trial-level advocacy to a heightened, absolute responsibility to the “judicial machinery” itself. In this vacuum, the court’s reliance on the prosecutor’s factual representations is total; the integrity of the proceeding depends entirely upon the government’s fidelity to the evidentiary record.
The distinction between a standard trial error and fraud upon the court turns on the shift from the Napue standard to the more stringent Hazel-Atlas framework. While Napue v. Illinois addresses the government’s knowing use of false testimony before a jury, Hazel-Atlas Glass Co. v. Hartford-Empire Co. identifies a more profound injury—conduct directed at the court that corrupts its impartial function.
| Feature | Napue v. Illinois | Hazel-Atlas Glass Co. |
| Target of Deception | The Jury (Fact-finder) | The Court (Tribunal/Judicial Machinery) |
| Nature of Misconduct | Passive use of perjured testimony | Active fabrication/misrepresentation by an officer of the court |
| Legal Remedy | Due Process violation; Retrial | Inherent authority to vacate; Dismissal to preserve integrity |
This transition from trial-level perjury to direct, fabricated representations to the bench during a dispositive motion constitutes a “transformation” of the legal injury. It is no longer a matter of witness credibility for a jury to weigh, but a direct assault on the court’s ability to perform its impartial task, necessitating the exercise of the court’s inherent authority.
2. Analysis of Divergence I: The Glasgow Fabrication and Criminalization of Practice
The government’s theory of a criminal conspiracy relied heavily on the “pre-signing” of prescriptions. This was strategically vital; without evidence that Dr. Anand signed blank forms for later use by others, the government possessed only a record of a physician performing standard medical paperwork. To bridge this evidentiary gap during the Rule 29 proceeding, the prosecutor fundamentally altered the trial testimony of Frederick Glasgow.
A CASE OF ADJECTIVE PHRASE PERSECUTION
(OR THE IBSEN-CLEMENT, KOOB EFFECT (ICK))
The prosecutor’s April 8, 2025, misrepresentations or ICK to the court introduced three specific, invented elements that were entirely absent from the “ground truth” of the trial transcript:
- “Whole Pad”: Substituted for Glasgow’s actual word, “book.” While a “book” of prescriptions implies patient-specific scripts prepared for signature, a “whole pad” implies blank forms being pre-signed—an essential element of a criminal vacuum.
- “Unlicensed Folks”: This element was a pure invention by the prosecutor. Glasgow never mentioned the licensure status of any staff, nor did he describe anyone other than the doctor “filling out” drugs.
- “Going out the door”: A phrase manufactured to suggest a volume-based criminal enterprise that was never described by the witness.
The “So What?” Layer: These lexical substitutions did not merely exaggerate the testimony; they invented a crime. By transforming a description of a physician at his desk doing paperwork into a prima facie federal crime involving unlicensed conspirators and blank pads, the prosecutor misled the court’s evaluation of evidentiary sufficiency. Physical evidence in Exhibit NA-1 (including patient files for T.G., Glasgow, and Stevenson) confirms the objective impossibility of the claim: the production contains thousands of completed scripts, yet not a single blank, pre-signed prescription form exists in the government’s records.
3. Analysis of Divergence II: The T.G. Dispensing Record and the Coercion Theory
To sustain convictions for prescribing outside the usual course of professional practice, the government relied on a “coercion theory,” alleging that patients like Tamara Gage (T.G.) were forced to accept “Goody Bags” of non-opioid medications as a quid pro quo for opioids. The prosecutor’s ICK represented to the court that T.G. “continued to get the bag every month” to establish a continuous criminal act.
Callout: Mathematical Impossibility
- Prosecutorial Claim: T.G. “continued to get the bag every month.”
- Objective Data (Government File 303): Documented nine consecutive months of zero entries for in-house dispensing (December 2018 through September 2019).
The element of Knowledge is established by the prosecutor’s own trial preparation. The prosecutor personally conducted the direct examination of T.G. based on File 303—the government’s own foundational dispensing record. It is a logical and professional impossibility for the prosecutor to have vetted the witness and built the case-in-chief without realizing the file showed a total cessation of dispensing nine months before the patient left the practice. By asserting a monthly occurrence that the file in his hand directly refuted, the prosecutor corrupted the court’s ability to evaluate the “quid pro quo” element of the charges.
4. Analysis of Divergence III: The Deconstruction of the “No Need/No Use” Narrative
The government’s medical necessity argument required the court to believe that patients did not “want, need, or use” the non-opioid medications dispensed. The prosecutor asserted that patients gave notice of their lack of need, framing the dispensing as forced.
However, an analysis of six patient witnesses reveals that these patients were voluntarily filling identical medications at retail pharmacies, proving the “want and need” was internal to the patient and independent of the doctor’s office.
- Tamara Gage (T.G.)
- Representation: Did not want or use medications.
- Counter-Evidence: PDMP File 711 shows voluntary fills of zolpidem and tizanidine at Yorke Pharmacy independent of Dr. Anand’s office.
- Jodi Stevenson
- Representation: Was not using the medications.
- Counter-Evidence: FBI records (INT_001109) show empty and partially used bottles recovered from her home; records show she used these medications (Lyrica, ibuprofen) prior to seeing Dr. Anand.
- Jacqueline Culver
- Representation: No need for “Goody Bag” medications.
- Counter-Evidence: Sworn testimony (Tr. 1771–1772) confirmed she currently takes gabapentin and ibuprofen prescribed by independent physicians.
- Geraldine Lynch
- Representation: Did not want or use medications.
- Counter-Evidence: Admitted at trial (Tr. 1297) to using lidocaine patches and gabapentin for diabetic neuropathy.
- Frederick Glasgow
- Representation: No medical use for medications.
- Counter-Evidence: Exhibit NA-2 contains a neurosurgeon’s determination of a lifetime need for these medications. Retail records show fills of gabapentin and tizanidine at Rite Aid prescribed by multiple other physicians.
- Andrea Scicluna
- Representation: No use for non-opioids.
- Counter-Evidence: PDMP File 732 shows seven consecutive months of voluntary retail fills for temazepam and carisoprodol at Yorke Pharmacy.
These independent retail fills—requiring travel, insurance, or out-of-pocket payment—destroy the theory of forced dispensing. This repeated pattern of discrepancy across six witnesses satisfies the Hazel-Atlas requirement for a “planned and executed scheme.”
5. Analysis of Divergence IV: The Categorical Denial of Diagnostic Basis
For the Count 10 conspiracy charge, the prosecutor made a categorical representation to the court: “The documentation doesn’t support that there is any basis for prescribing those opioids.” This was designed to satisfy the “no legitimate medical purpose” element. However, the government’s own patient files contained objective diagnostic markers that the prosecutor categorically denied existed.
| Patient | Objective Diagnostic Finding (MRI/EMG) | Source Document | Prosecutorial Representation |
| Tamara Gage | MRI: Central canal and foraminal narrowing; stenosis | Exhibit NA-3 | “No basis for prescribing.” |
| Jodi Stevenson | EMG: Bilateral chronic axonal motor polyneuropathy | Exhibit NA-4 | “No basis for prescribing.” |
| Geraldine Lynch | MRI: Central canal stenosis; EMG: C5-C6 radiculopathy | Exhibit NA-5/6 | “No basis for prescribing.” |
| Frederick Glasgow | MRI: L4-5 traumatic disc bulge; Neurosurgeon report | Exhibit NA-2 | “No basis for prescribing.” |
| Andrea Scicluna | Active denervation in S1 innervated muscles bilaterally | Exhibit NA-7/8 | “No basis for prescribing.” |
| Jacqueline Culver | Aria 3B Orthopaedic records: Four prior knee surgeries | Exhibit NA-9 | “No basis for prescribing.” |
These findings—stenosis, active denervation, and traumatic disc bulges—are not matters of “competing expert opinion” but are objective factual markers. By holding these files while asserting their non-existence, the prosecutor blinded the court to the actual state of the evidentiary record.
6. Conclusion: Satisfaction of the Hazel-Atlas Criteria
The conduct identified herein satisfies the six-element test for fraud upon the court under the Hazel-Atlas standard:
- False Representation: Fabricated testimony and misrepresented data.
- Direct to Tribunal: Statements made directly to the bench during Rule 29.
- Dispositive Proceeding: Conduct occurred where the court was the sole decision-maker on evidentiary sufficiency.
- Knowledge of Falsity: The prosecutor personally prepared witnesses using the files (File 303, MRI reports, PDMP) that refuted his claims.
- Objective Provability: Falsity is proven by the government’s own diagnostic and pharmacy records.
- Undermining of the Impartial Function: The court’s absolute reliance on the prosecutor in this vacuum was exploited to secure a denial of acquittal.
This was not a series of isolated errors, but a four-quadrant blackout of the record. The fabrications regarding the Glasgow testimony (Conspiracy), the T.G. dispensing record (Quid Pro Quo), the retail fills (Medical Necessity), and the diagnostic proofs (Medical Basis) worked in tandem to systematically deceive the court. This “deliberately planned and carefully executed scheme” necessitates the exercise of the court’s inherent authority to preserve the integrity of the judicial machinery for appellate review.
MUST STEP DOWN AND RESIGN
THE INTENT TO TREAT
ORDER DOCUMENT 818
ecf 813 denied
🔓 🔓 🔓
ALL WATCHED OVER BY MACHINES OF LOVING GRACE
ALL WATCHED OVER BY MACHINES OF LOVING GRACE
BE SURE TO DONATE TO THE MARK IBSEN GOFUNDME DEFENSE FUND, WHERE THE SON ALWAYS RISES!!!
FOR NOW, YOU ARE WITHIN
THE NORMs
references:
the attempted railroading of dr. norman j. clement, rph, dds
TRIBUTES
Guest Book
Daysi M
Rest in peace Dr Tennant. You were an angel im my life, you saved me from a wheelchair and I will always be greatful and will always remember you! Rest eternally in the Lord’s arms.
Bob Kalish
Thank you for always having a willingness to go against mainstream theory. Medical history will prove him right. But, most importantly, to his wife of many years, I know that you may have been a major driving force in his life. Truly, very sorry for your loss
effective medical device sterilization
