The estate of Jeremy Parker last week sued the anti-vaccination, right-wing group America's Frontline Doctors for alleged wrongful death. Dr. Medina Culver, an osteopathic physician and Instagram influencer based in Henderson, Nevada, is also named in the case. The lawsuit alleges negligence by the group and Culver for the death of Parker last year. "Based on information provided by America's Frontline Doctors, Mr. Parker became convinced, along with several of his co-workers, that hydroxychloroquine was an effective treatment for COVID-19," the suit alleges. "On or about August 26, 2021, Mr. Parker had a telemedicine visit with Dr. Culver, at which time Dr. Culver prescribed Mr. Parker with hydroxychloroquine and/or ivermectin for COVID-19 treatment or 'preventative therapy.' Dr. Culver never performed a physical examination of Mr. Parker." According to the suit, Parker developed cold-like symptoms in late January of 2022. His body was found Feb. 3, 2022. The Washoe County coroner listed Parker's cause of death as "sudden in the setting of therapeutic use of hydroxychloroquine."

1. LUKE A. BUSBY, ESQ.
SBN 10319
316 California Ave.
Reno, Nevada 89509
775-453-0112
luke@lukeandrewbusbyltd.com
Attorney for the Plaintiffs
IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA,
IN AND FOR THE COUNTY OF WASHOE
* * *
ESTATE OF JEREMY PARKER, by and through
its Special Administrator JELENA HATFIELD,
JELENA HATFIELD, individually; TP, a minor, by
and through her parent and natural guardian
JELENA HATFIELD; GP, a minor, by and through
his parent and natural guardian JELENA
HATFIELD, and LP, a minor, by and through his
parent and natural guardian JELENA HATFIELD,
v.
MEDINA CULVER, D.O, individually, FREE
SPEECH FOUNDATION, INC. D/B/A/
AMERICA’S FRONTLINE DOCTORS, a foreign
nonprofit corporation, DOES I through X,
inclusive; and ROE CORPORATIONS I through
X, inclusive,
__________________________________________/
CASE NO:
DEPT NO:
Arbitration Exemption:
Medical Malpractice;
NAR 3(A) acton in
excess of $50,000
COMPLAINT
COME NOW, ESTATE OF JEREMY PARKER, by and through its Special
Administrator JELENA HATFIELD, JELENA HATFIELD, individually, TP, a minor, by
and through her parent and natural guardian JELENA HATFIELD; GP, a minor, by
and through his parent and natural guardian JELENA HATFIELD, LP, a minor, by and
through his parent and natural guardian JELENA HATFIELD (the “Plaintiffs”) by and
1
F I L E D
Electronically
CV23-00219
2023-02-03 11:41:35 AM
Alicia L. Lerud
Clerk of the Court
Transaction # 9491383 : yviloria

2. through the undersigned counsel, and hereby brings this action against MEDINA
CULVER, D.O., FREE SPEECH FOUNDATION, INC. D/B/A/ AMERICA’S FRONTLINE
DOCTORS, a foreign nonprofit corporation, DOE individuals 1-10 (inclusive), and
ROE corporations 1-10 (inclusive) (hereinafter, jointly and severally, also referred to
as, “Defendants” for damages to and for wrongful death resulting from the ingestion
of improperly prescribed hydroxychloroquine.
JURISDICTION
1. This Court has jurisdiction over this matter pursuant to Nev. Const. art.
VI, § 6, as this Court has original jurisdiction in all cases not assigned to the justices’
courts. This Court has subject matter jurisdiction over this matter pursuant to NRS
4.370, as the matter in controversy exceeds $15,000, exclusive of attorney’s fees,
interest, and costs.
2. This action is instituted for damages, attorneys’ fees, costs of suit and
pre-judgment interest pursuant to NRS 41.085 and 41.100.
3. Venue is properly in the above-captioned Court because: (a) the
Plaintiffs are located in and the Defendants do business in Washoe County; (b) the
transactions related to the same occurred in Washoe County; (c) the events and
omissions giving rise to the claims for relief detailed herein below occurred in
Washoe County; (d) it has personal jurisdiction over the Plaintiffs in this action; and
(e) it has personal jurisdiction over the Defendants.
PARTIES
4. That at all times relevant hereto decedent Jeremy Parker was a resident
of Washoe County, Nevada.
5. That at all times mentioned herein, Plaintiff Jelena Hatfield was and is a
resident of Washoe County, Nevada, and the wife of decedent Jeremy Parker.
Jelena is the Special Administrator of the Estate of Jeremy Parker pursuant to an
2

3. Order Appointing Special Administrator issued by this Court in Docket No.
PR23-00071 on February 3, 2023.
6. TP, a minor aged 17, by and through her parent and natural guardian
JELENA HATFIELD was and is a resident of Washoe County, Nevada, and the
daughter of decedent Jeremy Parker.
7. GP, a minor aged 14, by and through his parent and natural guardian
JELENA HATFIELD was and is a resident of Washoe County, Nevada, and the son
of decedent Jeremy Parker.
8. LP, a minor aged 8, by and through his parent and natural guardian
JELENA HATFIELD was and is a resident of Washoe County, Nevada, and the son
of decedent Jeremy Parker.
9. That Plaintiffs are informed and believe and thereupon allege that at all
times mentioned herein, MEDINA CULVER, D.O. (hereinafter “Dr. Culver”), is a
resident of Nevada and was and is a doctor of osteopathic medicine licensed to
practice in the State of Nevada. The particular county in which Dr. Culver resides is
unknown to the Plaintiff.
10. That Plaintiffs are informed and believe and thereupon allege that at all
times mentioned herein, FREE SPEECH FOUNDATION, INC. D/B/A/ AMERICA’S
FRONTLINE DOCTORS (hereinafter “America’s Frontline Doctors”), is a foreign
nonprofit corporation with its principal place of business in Nevada located in
Washoe County.
11. The true names and capacities, whether individual, corporate,
associate, or otherwise, Defendants Roe Corporations I through X are unknown to
Plaintiffs, who therefore sue said Defendants by such fictitious names. Plaintiffs are
informed and believe and thereon allege that each of the Defendants designated
herein as a Roe Corporation is negligently responsible in some manner for the
events and happenings herein referred to and negligently caused injury and
3

4. damages proximately thereby to Plaintiffs as herein alleged. Plaintiffs will ask leave
of court to amend this Complaint to insert the true names and capacities of said
Roe Corporation Defendants when the same have been ascertained by Plaintiffs,
together with the appropriate charging allegations, and to join such Defendants to
this action.
12. Plaintiffs reserve the right to amend and supplement this Complaint as
to claims and the true names, official capacities and/or degree of involvement of
said Defendants.
13. At all times herein mentioned, each Defendant was the co-conspirator,
agent, servant, employee, assignee and/or joint venturer of each of the other
Defendants and was acting within the course and scope of said conspiracy, agency,
employment, assignment and/or joint venture and with the permission and consent
of each of the other Defendants. Plaintiffs are informed and believe, and thereon
allege, that Defendants,and each of them, at all material times relevant to this
Complaint, performed the acts alleged herein. Plaintiffs are informed and believe,
and thereon allege, that at all times mentioned herein, Defendants, and each of
them, including without limitation those.
14. Defendants herein sued as DOES or ROES, were acting in concert or
participation with each other, or were joint participants and collaborators in the acts
complained of, or were the agents or employees of the others in doing the acts
complained of herein, each and all of them acting within the course and scope of
said agency and/or employment by the others, each and all of them acting in
concert one with the other and all together.
15. Attached to this Complaint as Exhibit 1 is the Declaration of Dr.
Bannister, provided per NRS 41A.071, and are attached as if fully rewritten herein.
///
///
4

5. ALLEGATIONS OF FACT
16. Jeremy Parker died on February 3, 2022. He left behind a wife who is
disabled, and three minor children, “TP” age 17, “GP” age 14, and “LP” age 8. He
also left behind many other family members and friends. He was 52 years old. His
death was caused by the negligence of Dr. Culver and by falsehoods spread by
America’s Frontline Doctors.
17. Based on information provided by America’s Frontline Doctors, Mr.
Parker became convinced, along with several of his co-workers, that
hydroxychloroquine was an effective treatment for COVID-19.
18. America’s Frontline Doctors promoted falsehoods about the COVID-19
pandemic and COVID-19 vaccines.
19. America’s Frontline Doctors made false claims about COVID-19
vaccines efficacy and safety, and promoted paid telehealth consultations with
"AFLDS-trained" physicians that would prescribe medications claimed to be
COVID-19 treatments.
20. On June 15, 2020, the U.S. Food & Drug Administration (FDA) revoked
an Emergency Use Authorization for hydroxychloroquine. The FDA concluded, “it is
no longer reasonable to believe that oral formulations of HCQ and CQ may be
effective in treating COVID-19, nor is it reasonable to believe that the known and
potential benefits of these products outweigh their known and potential risks.”
21. On March 24, 2020, Nevada Governor Steve Sissolak signed an
emergency regulation promulgated by the Nevada State Board of Pharmacy that
prohibited the prescribing and dispensing of hydroxychloroquine for a COVID-19
diagnosis.
22. Believing what he had heard from America’s Frontline Doctors, in early
to mid-August of 2021, Mr. Parker reached out to America’s Frontline Doctors
seeking a prescription for hydroxychloroquine in case he contracted COVID-19.
5

6. 23. On or around August 26, 2021, Mr. Parker was connected with Dr.
Culver through America’s Frontline Doctors.
24. On or about August 26, 2021, Mr. Parker had a telemedicine visit with
Dr. Culver, at which time Dr. Culver prescribed Mr. Parker with hydroxychloroquine
and/or ivermectin for COVID-19 treatment or “preventative therapy.”
25. Soon thereafter, Mr. Parker received a prescription for
hydroxychloroquine 200 mg from “Ravkoo,” in the mail, which was arranged by
America’s Frontline Doctors.
26. Dr. Culver never performed a physical examination of Mr. Parker.
27. In late January of 2022, Mr. Parker began to have cold-like symptoms.
On the night of February 1st and 2nd, 2022, Mr. Parker spent the night with a family
friend, Ron Pevny, at Mr. Pevny’s home on Royal Drive in Reno, Nevada. At around
12 p.m. on February 1, 2022, Mr. Parker called Jelena and informed her that he was
feeling ill with cold symptoms and that he would be staying the night at Mr. Pevny’s
house, and that he was afraid that he had COVID-19. On February 2, 2022, at
around 9 p.m. Mr. Parker called and spoke to his children, but not to Jelena Hatfield.
28. On the morning of February 3, 2022, Mr. Parker’s body was discovered
by Mr. Pevny.
29. An autopsy was performed on Mr. Parker by the Washoe County
Coroner’s office. A copy of the Certificate of Death of Mr. Parker is attached hereto
as Exhibit 2. Therein, the coroner concluded that Mr. Parker’s immediate cause of
death was “Sudden Death In The Setting of Therapeutic Use of
Hydroxychloroquine.”
30. According to the Declaration of R. Bruce Bannister, D.O. attached
hereto as Exhibit 1, Dr. Culver breached the standard of care by prescribing
hydroxychloroquine to Mr. Parker because “[a] physical examination was not
performed, diagnostic tests, most importantly an electrocardiogram, were not
6

7. performed to evaluate Mr. Parker’s cardiac rhythm, to ensure that the
hydroxychloroquine could be safely prescribed.”
31. According to the Declaration of Dr. Bannister, to a reasonable degree of
medical probability, ingestion of hydroxychloroquine prescribed by Dr. Culver
caused Mr. Parker’s death.
CLAIMS FOR RELIEF
FIRST CAUSE OF ACTION
WRONGFUL DEATH
32. Plaintiffs hereby re-allege those allegations contained herein and
incorporate same by reference as though fully set forth herein.
33. Mr. Parker passed away on February 3, 2022, as a direct and proximate
result of the negligence of Defendants.
34. As a direct and proximate result of Defendants’ actions and/or
omissions as herein alleged, Plaintiffs have incurred expenses expenses incidental
thereto, funeral expenses, all to their damage in a sum according to proof at trial and
request all damages available pursuant to NRS 41.085.
35. Defendants, and each of them, had a duty to care for and treat their
patients in a reasonable, prudent and appropriate manner.
36. Defendants, and each of them, breached said duty and, as a proximate
result thereof, decedent died.
37. Plaintiffs have attached the Declaration of R. Bruce Bannister, D.O.
hereto as Exhibit 1 (attached in full as if fully rewritten herein). Dr. Bannister testifies
about the standard of care that Defendants had, that Defendants fell below the
standard of care and that such breach, to a reasonable degree of medical
probability, was the cause of the death of Dr. Parker.
7

8. 38. As a direct and proximate result of Defendants’ actions and/or
omissions, Plaintiff Estate of Mr. Parker has suffered special damages, including
economic loss in an amount in excess of Fifteen Thousand Dollars ($15,000.00).
39. As a further proximate result of Defendants’ actions and/or omissions,
Plaintiffs have suffered general damages including, but not limited to loss of
consortium, society, love, support and companionship, emotional distress and pain
and suffering as a result of the untimely death of Mr. Parker in an amount in excess
of Fifteen Thousand Dollars ($15,000.00).
40. The actions above constitute wrongful death by Defendants against
decedent and, as such, Plaintiffs hereby respectfully request all damages available
to them, individually, pursuant to NRS 41.085, NRS 41.100, NRS 41A et seq. and/or
any other available statutory and/or common law remedies.
41. Plaintiffs have been required to retain the services of an attorney to
prosecute this action, and Plaintiffs are therefore entitled to attorney's fees and
costs of suit.
SECOND CAUSE OF ACTION
PROFESSIONAL NEGLIGENCE
42. Plaintiffs hereby re-allege those allegations contained herein and
incorporate same by reference as though fully set forth herein.
43. Defendants Dr. Culver is a physician and/or provider of health care as
set forth in NRS 41A.017.
44. Defendants owed Plaintiff a duty to use the care and skill ordinarily
exercised by physicians under like or similar circumstances, and to use reasonable
diligence and best judgment in the exercise of skill and the application of learning in
an effort to accomplish the purpose for which they were employed.
45. At all times mentioned herein, Defendants knew, or in the exercise of
reasonable care, should have known, that the providing of medical care and
8

9. treatment was of such a nature that if not properly given, is likely to injure the person
to whom it is given.
46. That Defendants fell below the standard of care by improperly
prescribing hydroxychloroquine to Mr. Parker.
47. Plaintiffs have attached the Declaration of R. Bruce Bannister, D.O.
hereto as Exhibit 1 (attached in full as if fully rewritten herein). Dr. Bannister testifies
about the standard of care that Defendants had, that Defendants fell below the
standard of care and that such breach, to a reasonable degree of medical
probability, was the cause of the death of Dr. Parker.
48. As a direct and proximate result of Defendants’ actions and/or
omissions as herein alleged, Mr. Parker died.
49. As a direct and proximate result of the negligent actions, omissions and
breaches of duty of Defendants and each one of them as described herein, Plaintiffs
suffered general and special damages in an amount in excess of $15,000.00.
50. It has become necessary for Plaintiffs to retain the services of an
attorney to prosecute this action, and Plaintiffs are therefore entitled to attorney's
fees and costs of suit.
THIRD CAUSE OF ACTION
EXEMPLARY DAMAGES
51. Plaintiffs hereby re-allege those allegations contained herein and
incorporate same by reference as though fully set forth herein.
52. The Defendants acted with knowledge of the probable harmful
consequences of the wrongful act and a willful and deliberate failure to act to avoid
those consequences of the probable harmful consequences of prescribing
hydroxychloroquine to Mr. Parker.
53. The Defendants conduct was malicious and oppressive and showed a
conscious disregard of Mr. Parker’s rights protected under law;
9

10. 54. As such, the Plaintiffs seek an award of exemplary and punitive
damages against the Defendants.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of
them, jointly and severally, as set forth below:
1. For general damages in excess of Fifteen Thousand Dollars
($15,000.00);
2. For special damages, as set hereinabove, in excess of Fifteen Thousand
Dollars ($15,000.00);
3. For exemplary damages;
4. For attorney’s fees and costs;
5. For pre-judgment and post-judgment interest; and
6. For such other and further relief as the Court deems just and proper.
NRS 239B.030(4) AFFIRMATION
Pursuant to NRS 239B.030 the undersigned hereby affirms that this
document does not contain the social security number of any person.
DATED this Feb 3, 2023
By: /s/ Luke Busby, Esq.___________
LUKE A. BUSBY, ESQ.
Nevada Bar No. 10319
316 California Ave.
Reno, Nevada 89509
775-453-0112
luke@lukeandrewbusbyltd.com
Attorneys for the Petitioner
10

11. Exhibit List
1. Declaration or R. Bruce Bannister.
2. Redacted Death Certificate of Jeremy Parker
11