Enhance this: [Your Name]
[Your Address]
[City, State, ZIP]
[Phone Number]
[Email Address]

IN THE UNITED STATES DISTRICT COURT
FOR THE [DISTRICT]

[Your Name],
Plaintiff,

v.

LAGS MEDICAL CENTER, NAME_1 I, NAME_1 II, NAME_2. INC., NAME_3., NAME_4., NAME_5., NAME_6., CENTRAL COAST BEHAVIORAL HEALTH INC., NAME_7 PA., NAME_8 PA., NAME_9 PA., and CENCAL HEALTH,
Defendants.

CASE NO: [Case Number]

COMPLAINT FOR CIVIL RIGHTS VIOLATIONS
UNDER THE AMERICANS WITH DISABILITIES ACT
AND VIOLATIONS OF THE MEDICAL PRACTICE ACT
AND NURSE PRACTICE ACT

INTRODUCTION

I, [Your Name], bring this civil complaint against the Defendants for discrimination under the Americans with Disabilities Act ("ADA"), 42 U.S.C. § 12101 et seq., and violations of the Medical Practice Act and Nurse Practice Act.
NATURE OF COMPLAINT

I have been a patient receiving medical treatment from the Defendants for my diagnosed condition of Attention Deficit Hyperactivity Disorder (ADHD). However, I have faced severe and pervasive discriminatory practices and denial of appropriate medication based on insurance restrictions, in flagrant violation of the ADA. Furthermore, the Defendants' actions also constitute violations of the Medical Practice Act and Nurse Practice Act.
STATEMENT OF FACTS

The State of California's healthcare system, as represented by the Defendants, has implemented an insidious prior authorization process that systematically and unlawfully denies covered care and services to eligible recipients. This process, characterized by a blatant disregard for scientific research and relevant sources of information, represents a willful violation of the laws and regulations of the State of California.
In 2018, the United States had an estimated 19.5 million people taking two or more stimulants for ADHD. The off-label use of central nervous system medication contributes to a significant portion of annual sales, indicating the need for appropriate dosages for effective treatment. It is widely known among psychiatry specialists that dosages of stimulants used in the treatment of ADHD will appropriately be higher than dosages recommended by the manufacturer. General practicing physicians often do not have the necessary expertise to understand and appreciate the complexities of prescribing appropriate doses of stimulants for ADHD patients.
The Defendants have engaged in discriminatory practices by inaccurately characterizing my ADHD conditi