Complaint - Cyrus Hoseyni, Ira Spector, Greg Zhou, Stephen Kopko, Robert Moyer

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
8. Greg Zhou
9. Stephen Kopko
10. Robert Moyer
11. Valerie Williams
Defendants
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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
N O T I C E
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within
twenty (20) days after this complaint and notice are served, by
entering a written appearance personally or by attorney and filing in
writing with the court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the case
may proceed without you and a judgment may be entered against
you by the court without further notice for any money claimed in
the complaint or for any other claim or relief requested by the
Plaintiff. You may lose money or property or other rights important
to you.
You should take this paper to your lawyer at once. If you do not
have a lawyer, go to or telephone the office set forth below. This
office can provide you with information about hiring a Lawyer. If
you cannot afford to hire a lawyer, this office may be able to
provide you with information about agencies that may offer legal
services to eligible persons at a reduced fee or no fee.
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Lawyer Referral and Information Services
One Reading Center
Philadelphia, Pennsylvania 19107
(215) 238-6333
TTY (215) 451-6197
A V I S O
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse
de las demandas que se presentan más adelante en las siguientes
páginas, debe tomar acción dentro de los próximos veinte (20) días
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personalmente o por medio de un abogado una comparecencia escrita
y radicando en la corte por escrito sus defensas de, y objecciones a, las
demandas presentadas aquí en contra suya. Se le advierte de que
Si usted falla de tomar acción como se describe anteriormente, el caso
puede proceder sin usted y un fallo por cualquier suma de dinero
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TTY (215) 451-6197

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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.

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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.

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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.

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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.

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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

Complaint - Cyrus Hoseyni, Ira Spector, Greg Zhou, Stephen Kopko, Robert Moyer

Complaint - Cyrus Hoseyni, Ira Spector, Greg Zhou, Stephen Kopko, Robert Moyer

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