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2.7 38 Reviews

Laser Spine Institute Complaints Summary

16 Resolved
22 Unresolved
Our verdict: Dealing with Laser Spine Institute, which has an average resolution rate, requires some diligence. Research their service in depth and read a variety of customer reviews for a balanced view. Approach any customer service interactions with detailed and well-prepared queries to facilitate a better resolution process.
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Laser Spine Institute reviews & complaints 38

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Laser Spine Institute damage and cronic pain

Within 2 months I had Chronic pain and numbness, They said to wait a year or 2 and it should go away . Yeah right
I am worse than ever Numbness down both legs, feet and toes, Caused from damaged nerves from surgery.
I can hardly walk now at times and the pain is at its worst ever . I ended up closing my business and putting about 15 people out of work.
I need a good Florida lawyer In the LSI area who has dealt with them in the past and hopefully on contingency
Thanks, Peter

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adam landskowsky
Manhasset, US
Sep 25, 2013 4:24 pm EDT

Dr mottahedeh made me feel special she pull down my pants, give me massages help my back pain rub my shoulders I would say she is the ultimate wife I would marry her and I love her very much.

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Laser Spine Institute no complaint

I just had my surgery on December 21st 2012. I have had pain from an 8mm herniation on L5-S1 for 3 years. My herniation was protruding into my spinal canal. I was on the verge of paralysis.. I did my research, i saw the complaints, I saw A LOT. But in the end I weighed the pros and cons. I did have a minor complication with a spinal leak that was entirely because of ME not them. I was told before going in that this may happen because I have a naturally high spinal pressure. On January 2nd 013 i went in for the correction of the leak because it would not seal on its own.
Even with the complication I love LSI Oklahoma City. The facility was amazing, breakfast and lunch served every day of my visit. Staff was incredible. Dr Nees was my surgeon and he was awesome. He stay with my mother and I for 45 minutes going over the procedure and answered every one of my questions. I have never had a doctor do that.
Even when I had the complication he brought be in on New Years Day and even came to the hospital to see me and explain what happened. I was at Community Hospital in OKC for 4 days. I may not have had "textbook" outcome but I am still in a lot better state than when i went in.
I am a military wife and mother of 2 young children. Being disabled was not good for my family life or my husbands career. I 200% recommend LSI in OKC. I still have some swelling but my incision is healing great and I am in a lot less pain then when i began and getting better every day..
My mother even found Dr. Nees incredibly HOT!

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varn
Evansville, US
Feb 18, 2014 9:30 pm EST
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I have been a fellowship trained spinal surgeon for 15 years (I'm not sure if any of their docs have done accredited fellowships, the website doesn't list the surgeon's C.V.s as is customary, wonder why?) and I have never heard of "naturally high spinal pressure" as a factor in a spinal fluid leak. Dural leaks happen; they are known complications but are NEVER the patient's fault. Just sayin'. The only thing anyone need know about a place like LSI (and others like it) is the following. In a time when both patients and doctors agree that we are losing the most valuable component of our relationship (time spent together) due to changes in medical economics; how in the world could anyone expect good care to be delivered over the phone? Should people really be surprised if they don't do well if their initial "consultation" is a free MRI telephone evaluation? I can assure you that there is a bit more to the surgical decision-making process than merely looking at the MRI. These guys should be embarrassed, if not totally ashamed. Must be why I never see any of them at meetings.

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Sorry Now
Washington, US
Dec 02, 2013 8:50 am EST
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I had surgery at the Pennsylvania site. I met with a person who told me what I needed. I went ahead with itbecause my best friend drove a long way to help me. This was my very last hope. It has bee almost one month and i am in horriffic pain. The area that went down my left leg now goes ito my buttocks and down both legs. When they were discharging me the nurse wanted me to take my medication more often than my doctor prescribed. I tried to explain multiple times why I could not that Iwould run out of my medication. She said OH I NOW SEE RED FLAG... she accused me of trying to get extra medication. I am very upset at my treatment from the PA moreso the nurses. I have called to say that I am so much worse and the answer now is It can take up to a year to get really better. YOU ARE NOT TOLD THAT WHEN THEY WANT YOU TO HAVE SURGERY... They tell you most of our people get up right after surgery and feel so much better. I met one man that was reduced to a wheel chair. He stated he was no where near that condition before. They want ot do my neck no way in heck am setting foot in there again. RUN AWAY DO NOT GET SURGERY THERE.

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wilie
, US
Mar 02, 2013 4:13 pm EST

The paid lsi shills that come to this complaints site and post positive comments trying to hide the real horror stories have no shame. Don't see how they can sleep. Just shows that some people will do anything for money just like lsi.

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Laser Spine Institute - follow up

First and foremost anyone that leaves negative comments about any company or medical facility should be prepared for some back talk! First the negative is not applied to everyone, so you that are posting these opinions of LSI, really should do your homework just a little better. I totally understand if someone has has a bad experience .I myself have been...

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Laser Spine Institute lied about lawsuits

I attended one of their seminars and was given the impression they'd never been sued. However, they are named in lawsuits all over the Internet. There's an entire article in a major magazine dedicated to their lawsuits. They also gave the impression that one surgery could fix your horrible pain, but I've talked to patients and seen on the internet that you might need a whole bunch of procedures, but they won't tell you until after you're hooked. This company did not represent itself or its procedures fairly in its "educational seminar." And check out www.GlassDoor.com to see what its employees say about the company! Selling procedures. Shameless.

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Mechman2011
Watauga, US
Jun 14, 2015 1:12 pm EDT

I was also taken in by their lies, they "operated" on me and now I'm worse than ever.
When they called to "follow up", they would never let me talk with my doctor or anyone with medical training, then a year later I get a bill for three thousand more dollars.
I had paid up front over 29, 000.00. My insurance apparently refused to pay them, so now I "owe" them the amount they billed the Insuance.
If anyone knows a GOOD malpractice lawyer Please contact me. I got a follow up MRI and not only did they NOT do what they said they would do, I now have a cyst on my spine where they " operated" on me.DONT GO TO THEM I went to the Tampa FL. Location and had "Dr. Z", he "worked" on me (he was on their commercials) and now I can barley walk at all. With a wife and child to support at the age of 40 I'm now looking at total disability. Thank you so much for taking all our money, putting me in more pain than ever and ruining my life.

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john scot
Honor, US
Jan 19, 2013 10:31 am EST

A friend of mine had a procedure performed at the Laser Spine Institute in Tampa. It was nothing short of a total disaster. She was given false and misleading information prior to her visit, that being that she was a candidate for Laser Spine Surgery. Upon her arrival, she was then told that the doctors had not at that time reviewed her information and she may possibly not be a candidate. Confusing, conflicting and contradictory. In fact, they had tried to charge her more than double her out of pocket expenses than she had been initially quoted. Upon returning home, she had complications and became worse. There was no follow up by the Laser Spine Institute and they did not return phone calls when she was requesting their help. I have never in my life have known of a business to treat their clients so poorly, and would not recommend them to anyone due to their misinformation, lack of follow-up and total lack of care and concern for their patients. I have only written a very brief overview of the events and occurrences that my friend encountered.

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Laser Spine Institute poor results

Had their so called operation Nov 07. Worst experience of my life. They lied about what my ins would reimburse and cost me 26k out of pocket. The operation was a complete failure. Seemed to help for a while until their steriods and pain medicine wore off. Found a law firm that is willing to take cases on a contigent fee. The firm is Kline & Specter. Phone # is [protected] or you can go to their website. They specialize in personal injury and have several offices. They reference the recent Bloomberg story and seem anxious to help.

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Laser Spine Institute great company

I think you must be a shill for LSI. I had their so called operation Nov 07. What a nightmare. Took 30k out of my retirement and told them that I could not afford to lose it. They then told me not to worry my ins would pay everything. After over two years of fighting with ins received only 6k. LSI basically told me tough luck they would not refund anything even after their assurance. There are stories all over the internet like mine. What a scam. The operation was a complete failure had to be put on SSI disability shortly after their operation. They had assured me that I would be back on the golf course in two weeks. They will literally tell you anything to get your money. If you do your homework and review this and the other sites concerning all of the complaints you will understand how they operate. They have shills on all of the sites. Shame on them. I could go on and on about them but will leave it at this. Please do your homework and don't into buy this scam. If something sounds too good to be true it is. I know how it is to be desperate for relief and then be taken.

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Update by wilie
Aug 29, 2012 8:38 am EDT

Does anyone really believe that someone who had successful surgery would go to a complaints site to post their comments. The positive comments on these sites are obviously by the many LSI shills on their payroll. Please do your homework and don't let these quacks rape you like they did me and so many others.

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D/H
new fairfield, US
Mar 23, 2014 5:21 pm EDT

I scheduled my procedure this week but after reading all these complaints I am having second thoughts. My husband says he would hate to see me in worse shape then I am and have been for over 12 yrs. now. Any procedures other doctors want to do my insurance company will not pay for but LSI procedures they will. Can anyone tell me why this is? I have young children at home, I need to function in order to raise my kids. I don't know what to do now after reading all these and other sites complaints. I thought I did my research. I am scared to death now that I am going to wind up worse off them I am but desperate to get relief and get off these high doses of pain meds. Help!

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Not sure now
Colorado Springs, US
Feb 27, 2013 1:04 am EST

I was thinking about going to LSI, but decided to see if there were complaints. Ok...I do wonder why there would be anyone going to a complaint site if they were happy.

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Herbo
Big Pine Key, US
Feb 09, 2013 8:08 pm EST

It does seem odd that people who had great surgery outcomes would troll complaint sites to defend Laser Spine Institute. If LSI paying people to troll the internet and misrepresent outcomes and falsely defend LSI, then SOMETHING is very twisted. A real hospital doesn't act this way.

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MBREW88
Centerton, US
Jan 24, 2013 8:29 pm EST

I am not from LSI, I am a military wife and mother of 2. I recently had surgery with LSI in OKC. And my experience was amazing.. I did my homework. I did the surgery and I feel great. I had my surgery on December 21st. 2012 I also had a complication and ended up with a second surgery on Jan 2. 2013 but even with that complication that had me in the hospital for 5 days I still think LSI is great.

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hurtinunit
, US
Aug 02, 2012 9:03 am EDT

My aunt had laser spine surgery at the Fl LSI location in 2008 and she has referred me to them, she told me she had instant relief. I haven't slept more than 2 hours at a time in 2 weeks from a herniated disc. She told me about her long term pain prior to the surgery and that hers was a total success. I don't want to make a decision regarding my spine based on sleep deprived pain induced desperation but it must work for some people, I wonder if it is certain procedures have a greater success rate? I'm sorry to every one who had troubles. I also know that this type of site not only pads their own good reviews but also can be stricken with competeting industry persons making bogus negative comments as well. All I know is one person who I know and trust referred me because she had success. Other than that, I don't know what to believe...

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Laser Spine Institute back surgery

I originally had surgery for spinal stenosis in 2009. After surgery I experienced more pain than before. It took a year of complaining before anyone listened. Finally, in 2010
I had surgery again The results were no better. In 2011 I had conventional back surgery and asked the surgeon to give me an opinion on the previous surgeries. His comment was "they didn't do you any favors, it was pretty much a mess. I again wrote to Laser Spine and asked for a refund. In typical fashion they have chose to ignore me.
I haven't figured out my next step yet, but I am not done with my complaints.

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Update by J Gaul
May 26, 2012 9:27 am EDT

I did because I was in pain for a very long time and was hopeful they had the answer.

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Emma Barela
leve, US
Sep 15, 2014 9:49 am EDT
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I have been scheduled for back surgery in Arizona. I am concerned that they are not affiliated with a hospital?

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CommonsenseIMHO1
Denver, US
May 26, 2012 5:06 am EDT
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You let these yo yo's do surgery on you?

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Laser Spine Institute insurance billing, and no relief from pain

I've been a back pain sufferer for over 25 years with increased pain in the legs. I had tried everything from hot pools to accupuncture, Physical Therepy to pain pills.Nothing worked. Then I talked to the folks at the Laser Spine Institute in Arizona. My hopes soared and visions of being pain free and sleeping at night filled my imagination.
I was told by the Laser Spine Folks that I would need to pay a deductible of $2000.00 from my insurance company (United). I paid the deductible, of which I could not afford because I hadn't worked for 6 months prior, due to pain. After the surgery I found out from my Insurance Company that I don't have a deductible of $2000.00. According to my Insurance Company, I'm supposed to pay 10% of medical cost not to exceed $2000.00 a year. I've never receives a billing statement from Laser Spine Institute. As I try to deal with them in an effort to find out what my charges were for I'm transferred to different departments in Tampa Florida. Nobody has been able to help me so far.
As far as my procedure goes, the story gets worse. I'm still plaged by pain, that during thenfirst week or two after my procedure seemed to go away. But as the days went by the pain returned even more intense than it was to begin with. Now I take Morphine and Methadone for pain. I don't sleep at night because leg my leg pain is so intense. I don't have regular bowell movements and find it very difficult to urinate.The procedure I had at LSI only cost me money I didn't have and made my family's financial situation more hopeless.I don't see how I can ever work again or enjoy the things in life that I used to do in my spare time. I fell like I was lied to and taken advantage of because of my pain and hopelessness.

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Laser Spine Institute dr. stephen david watson

If you've ever thought about having laser spine surgery, please research all your options very carefully and by all means stay away from Innovative Pain Solutions and Dr. Stephen Watson. Dr. Watson is an anesthesiologist and pain management physician, NOT a spine surgeon.

Dr. Watson utilizes a minimally invasive procedure called Accurascope or DND (Discectomy and Neural Decompression), pioneered by Lawrence B. Rothstein, M.D., who is also the founder of North American Spine. Dr. Rothstein has had 19 medical malpractice lawsuits brought against him with regard to this procedure, and many of his former patients have been left permanently maimed and injured. Dr. Rothstein has since claimed bankruptcy. Complications of this experimental surgery (which includes the use of a very powerful laser) include nerve damage, pain, weakness, numbness, paralysis and incontinence.

Dr. Watson states in his physician bio on his websites that he is currently working with Dr. Rothstein at the Riverview Health Institute in Dayton, Ohio, and performing the Accurascope/DND procedure. This is a complete untruth! Dr. Watson is not employed at the Riverview Health Institute and does NOT work hand in hand with Dr. Rothstein; however, Dr. Watson was supposedly trained to perform the Accurascope/DND first hand from Dr. Rothstein, the very doctor who has been sued for millions due to medical negligence.

Dr. Watson has also changed business names in the state of Ohio on an least one occasion, has licenses to practice medicine in several different states, and is NOT to be trusted. Dr. Watson also operates in Florida performing this same procedure, operating under the name of Innovative Spine Care.

You won't find very much information on Dr. Watson on the Internet, as he has no established reputation, other than being associated with Dr. Lawrence Rothstein, a pain management anesthesiologist who pioneered a minimally invasive spine surgery which has resulted in many innocent people suffering a permanent disability for life.

Please think TWICE before having laser surgery of any kind, and please keep your distance from Dr. Stephen Watson, whatever state you may reside in.

Please see the following links for further information:

http://www.innovativepainsolutions.com/watson.html
http://www.innovativepainsolutions.com/index.html
http://www.florida-spine-care.com
http://www.daytondailynews.com/news/crime/federal-suit-filed-against-georgia-company-1055778.html
http://www.zoominfo.com/#!search/profile/person?personId=422113610&targetid=profile

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Rita-Jo
Inverness, US
Mar 22, 2015 2:39 pm EDT

My son has had 2 procedures from Dr. Watson. The first one was for neck pain and constant headaches due to a car accident. When the procedure was over he was headache and neck pain free. He had a second procedure for mid and lower back pain and is very satisfied with the outcome. He is now going for physical therapy. Dr Watson is professional, compassionate, knowledgeable and highly skilled. I would recommend Dr Watson to anyone with neck or back pain. He also has a very wonderful staff, who are always willing to help.

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Lawrence V
, US
Sep 07, 2014 10:40 am EDT

I had headaches, numbness in hands, and pain inside the bones in my neck where all types of medication could not reach...Dr Watson and his crew were polite and honest...by the end of my neck surgery the pain in the bones of my neck were gone and the headaches were too...the numbness remained...he explained well in detail what he could do and I'm very happy I found him

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Tampa Norman
, US
May 04, 2013 6:14 am EDT

I had Dr. Watson perform this surgery in Tampa in 6/13. I had two herniated discs in my neck, found it difficult to sleep and was limited in many activities...constant pain was horrible. Although the first two months post op were much more painful than I had anticipated, within five months pain was reduced by 90% and now, almost a year after surgery, I can say that I am almost completely pain free. Dr. Watson is a caring and skillful surgeon. What you are reading about is Doctor that trained Dr. Watson in this procedure, not Dr. Watson.

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Laser Spine Institute misrepresentation

I went to the Phoenix facility in hopes of some relief by thermal ablasion. I checked in on Monday as directed. They waited until the morning of my procedure (Thur) to perform a nerve block, not the two days prior as they should have. They did a block at L4, that was in-sufficient for the proper diagnoses. It should have been L3, L4 & L5. I returned home after being denied treatment (which turned out to be a blessing) and go proper diagnosis from UCSD of CA. They performed a thermal ablasion bi-latterly at L3-L5 with great success. AND IT WAS COVERED BY INSURANCE co-pay only, not thousands of dollars! They are innept and not worth the effort. I now have proof of what did work and what LSI didn't do. No way around the physical proof. When you cause people with emotional issues related to pain and give them false hope, you are negligent as a healthcare provider.

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Raiderwin1
Pittsburg, US
Feb 01, 2013 11:01 pm EST
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I did send my MRI to LSI for a free review & asked to speak to a doctor to see if I was a good candidate. Instead of speaking to a doctor the receptionist put through to some sales guy. He said I was a good candidate w/o even looking at the MRI( WOW).

After this I decided to more research on LSI because a potential patient should not be talking to a sales guy about a serious medical procedure.

I did an intense backround check on LSI and decided not to be treated by them after reading all the negative comments on the net. Plus I also found too many lawsuits against them on the internet which turned totally me off. In all fairnness to LSI I did find some comments that were positive but the negatives far outweighed the positives. I eventually found a great doctor close to home here in California and had my surgery done w/ no complications.

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Maria L Stremmel
Manchester, US
Oct 20, 2012 1:52 pm EDT

They did pretty much the same thing to me just last wk. I booked a rm at doubletree on Aug 14, 2012 for 2 days. During that time an MRI was performed and several sets of
X-rays I brought with me were reviewed. It was determined at this time 2 surgeries would be performed, cervical and lumbar. My insurance was to cover all but $1000. I was told to book a rm at doubletree for
10 days, Oct 9-19, 2012. I did that. The rm was pre-paid and non refundable. I got there, they got an EMG on day 2 which made the sx that had been scheduled on day 3(Thurs) needed to be moved to Monday. On day 3(Thurs) I was told sorry we can't help u. The Dr was rude, obnoxious, condescending, unprofessional and appeared inept. I informed the pt rep I had done just what I was told and booked the room when and where they requested but was unable to get any of my hotel costs refunded. I was informed that was my problem and I knew the risks when I came for the evaluation. Nowhere in the new patient packet does it state I may at anytime during the 3 day "preop" period be deemed not a good candidate. After 5 days of getting jerked around, yrs of severe chronic pain and almost $1000 cost for nothing, I am now going to go to REAL neurosurgeons next week for real pt care not greed and misrepresentation.

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unenlightened
Saint Robert, US
Jun 04, 2012 5:20 pm EDT

Stay away from Laser Spine Institute

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wilie
, US
Mar 11, 2012 7:22 pm EDT

I had their so called surgery in Nov 07. Total nightmare. Not only was the surgery a complete failure but had to put up 30k and was assured that I would be fully reimbursed. After over two years of fighting with ins co received only 6k. LSI refused to reimburse anything even after their assurance. Hard to believe that a co like this is allowed to continue. I could go on and about my experience but will leave it at this. Please take my advice and stay away from this place all of the complaints on this site and many other sites aren't there for no reason. Also might want to go to the bloomberg news site and read their story on them.

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Laser Spine Institute overcharge / underservice

I was a chronic pain sufferer (neck pain) and traveled from Texas to Tampa in March 2009 for surgery at LSI. The treatment I received was less than acceptable and the only thing I gained was debt for having this surgery. I had to take $15, 000 out of my (early retirement) because I am only 40! I learned later that the healthcare services could have been performed for a fraction of the cost that LSI charged, in my local hometown! Their surgery did NOTHING to improve my condition and I left with the same pain, I entered their facility with. My surgeon didn't even have the bedside manner or a minute to come and speak with my Mom after my surgery, as she requested. LSI wanted payment in full BEFORE the surgery ($15k) then, overbilled my insurance with inflated prices that exceeded reasonable and customary charges. In my own personal opinion, LSI doesn't care about their patients. They only care about making money and growing their bottom line. Thank God, I am nearly pain free now with a new product that I found. I no longer have to take prescription pain medications and have had 2 major neck surgeries. Alice [protected]@yahoo.com [protected]

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jy3
Bayside, US
Feb 19, 2013 6:41 pm EST
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trying to get in touch with GeoNOregon about pcg. How did you do a qwr if they say I only have an internal number, no acct number?I'm in foreclosure & chap 13. how do I fight them?

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unenlightened
Saint Robert, US
Jun 04, 2012 5:16 pm EDT

Alice, my surgery was a completed failure and I now have new, unbearable pains. There is no reason for the kind of negligent care that LSI provides.

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GeoNOregon
Lake Oswego, US
May 13, 2012 6:59 am EDT
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I tried your email address, but it didn't work. I'd like to talk with you. I have advanced cervical stenosis, and was wondering what is causing your neck problems, and what kind of success you've had with surgery. If you read this, please up date your email address so we can talk. I'll check back now and then..

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wilie
, US
Mar 11, 2012 7:33 pm EDT

To Alice in Texas I also had their so called surgery in Nov 07. My experience was very similar to yours except that I had to put up 30k and was assured that ins would completely reimburse. After over two years of fighting only received about 6k. My operation was also a complete failure except to pad their pocketbook. Hard to believe a co like this is allowed to take advantage of people so desperate for help.

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Laser Spine Institute - careful! scam!

Be VERY Careful. First find out if this is the standard of care for treatment of your condition. Look up published literature on this! Then, check out the doctors. The "honors" they list are not any major true honors that are recognized by other doctors in the community. Some are random webbased honors that have not been created by official medical...

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Laser Spine Institute terrible

Am now worse than before the surgery---took $30, 000 and ran (insurance did not cover)---no follow up, nothing ---still fighting to get an answer and I now have developed severe sciatica which i never had before. Long story but DO NOT DO IT. Find a real doctor.

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KAAlbury
Fort Lauderdale, US
Jul 06, 2011 11:00 pm EDT
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Can you reveal your issue with your back? My husband is looking to LSI for help with spinal stenosis, but I sure as heck don't want him worse when he exits the hospital!

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Laser Spine Institute lawsuit filed in florida

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF
THE STATE OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY

CIVIL DIVISION

JOE SAMUEL BAILEY, individually;
LASERSCOPIC SPINAL CENTERS OF AMERICA, INC.
a Nevada corporation; LASERSCOPIC MEDICAL CLINIC, LLC,
a Florida limited liability company; LASERSCOPIC
SURGERY CENTER OF FLORIDA, LLC, a Florida limited
liability company; LASERSCOPIC DIAGNOSTIC IMAGING
AND PHYSICAL THERAPY, LLC, a Florida limited liability
Company; LASERSCOPIC SPINAL CENTER OF FLORIDA, LLC,
A Florida limited liability company, and LASERSCOPIC SPINE
CENTERS OF AMERICA, INC., a Nevada corporation,

Plaintiffs,
vs. Case No. 06-08498 Division L

JAMES S. ST. LOUIS, D.O., individually; MICHAEL W. PERRY, M.D.,
Individually; E.F.O. HOLDINGS, LP, a Texas Limited Partnership; EFO
GENPAR, INC., a Texas corporation; EFO LASER SPINE INSTITUTE,
LTD, a Florida limited liability company; LASER SPINE INSTITUTE, LLC,
a Florida limited liability company; LASER SPINE MEDICAL
CLINIC, LLC, a Florida limited liability company; LASER SPINE
PHYSICAL THERAPY, LLC, a Florida limited liability company, and
LASER SPINE SURGICAL CENTER, LLC, a
Florida limited liability company,

Defendants.
_______________________ /

FOURTH AMENDED COMPLAINT
Plaintiffs JOE SAMUEL BAILEY, LASERSCOPIC SPINAL CENTERS OF AMERICA, INC., LASERSCOPIC MEDICAL CLINIC, LLC, LASERSCOPIC SURGERY CENTER OF FLORIDA, LLC, LASERSCOPIC DIAGNOSTIC IMAGING AND PHYSICAL THERAPY, LLC, LASERSCOPIC SPINAL CENTER OF FLORIDA, LLC, and LASERSCOPIC SPINE CENTERS OF AMERICA, INC., by and through their undersigned attorneys, sue Defendants JAMES S. ST. LOUIS, D.O., MICHAEL W. PERRY, M.D., E.F.O. HOLDINGS LP, EFO GENPAR, INC., EFO LASER SPINE INSTITUTE, LTD., LASER SPINE INSTITUTE, LLC, LASER SPINE MEDICAL CLINIC, LLC., LASER SPINE PHYSICAL THERAPY, LLC., LASER SPINE SURGICAL CENTER, LLC, and allege:
I. INTRODUCTION
1. This action seeks damages as a result of the complete destruction (and theft) of Plaintiffs’ business by Defendants, each of whom were either (i) employed by and acted as directors of Spinal and the Spinal Operating Companies (defined below); or, (ii) occupied a position of trust and confidence relative to Plaintiffs that created fiduciary duties on behalf of Defendants to Plaintiffs. In their positions, Defendants each obtained confidential, proprietary and trade secret information, which they used to form a competing business.
2. Spinal and the Spinal Operating Companies (defined below) were formed for and engaged in the business of owning and operating free-standing, self contained diagnostic and treatment centers for diseases of the spine and, in particular, to engage in minimally invasive spine surgery on an outpatient basis. At the heart of Spinal and the Spinal Operating Companies’ (defined below) business plan was the development and operation of multiple surgical centers that would be developed across the United States. Upon the successful development and operation those centers, Spinal planned to commence an Initial Public Offering (“IPO”) of Spinal’s stock.
3. The claims brought against Defendants arise out of their conspiracy to steal (and actual theft of) Plaintiffs’ business. Defendants took the plan, the people and, ultimately, the patients and opened a competing surgery center engaged in the very same business (minimally invasive spine surgery), using the business plan created by Plaintiffs and copying the identical business structure. As more fully set forth below, Defendants conduct was intentional, willful and wanton and resulted in significant damages including the demise of what would have otherwise been a multi-million dollar enterprise.
II. JURISDICTION AND VENUE
4. This is an action for damages that in excess of One Hundred and Fifty Thousand Dollars ($150, 000.00), exclusive of interest and costs. This Court has subject matter jurisdiction over this case pursuant to Article V, Section 5 of the Florida Constitution, Florida Statutes, Section 26.012, and in accordance with Florida common law.
5. Jurisdiction is proper in Hillsborough County because Defendant Laser Spine Institute, LLC’s principal place of business is in Hillsborough County. In addition, the improper use and disclosure of confidential information occurred in Hillsborough County, the theft of trade secrets occurred in Hillsborough County as did Defendants other tortious conduct. Finally, Defendants each conducted and continue to conduct business in Hillsborough County, Florida.
6. Venue is proper in this Court pursuant to §47.011, Florida Statutes, et seq. because, among other things, many of the claims and causes of action accrued in Hillsborough County.
III. PARTIES

7. At all times material hereto, Plaintiff Laserscopic Spinal Centers of America Inc. (“Spinal”), was and is a Nevada corporation (closely held) doing business in Florida through its affiliates/subsidiaries. Spinal was formed as a holding company to own 100% of the interests in Plaintiffs Laserscopic Medical Clinic, LLC, Laserscopic Surgery Center of Florida, LLC, Laserscopic Diagnostic Imaging and Physical Therapy, LLC, and Laserscopic Spinal Center of Florida, LLC, each of which is a single member limited liability company (collectively, the “Spinal Operating Companies”).
8. Spinal and the Spinal Operating Companies were formed for the purpose of owning and operating multiple free-standing, self-contained diagnostic and treatment centers for diseases of the spine and, in particular, to engage in minimally invasive spine surgery on an outpatient basis and to provide other medically necessary treatments including pain management and physical therapy.
9. At all times material hereto, the Spinal Operating Companies were and are Florida limited liability companies, each of which was engaged in business in Pinellas County, Florida, under the parent company Spinal from June 3, 2004 to March 4, 2005.
10. Spinal was initially owned by Plaintiff Joe Samuel Bailey (27%); Defendant James S. St. Louis, D.O. (34%), Defendant Michael Perry, M.D. (5%) and Ted Suhl (34%) (“Suhl”). Each of the shareholders of Spinal was a director of the company. In the Fall of 2004, Suhl sold his interest in Spinal to Mark Miller (“Miller”). Miller then sold 17% of his 34% to Dr. Tim Langford (“Langford”) in early 2005.
11. For the reasons more fully discussed below, the majority shareholders of Spinal formed Plaintiff Laserscopic Spine Centers of America Inc. (“Spine”) in December of 2004. Like Spinal, Spine was and is a Nevada corporation (closely held) doing business in Florida through certain of the operating entities whose assets and liabilities were transferred from the Spinal Operating Companies (collectively the “Spine Operating Entities”). Laserscopic Surgery Center of Florida, LLC and Laserscopic Medical Clinic, LLC were sold to Spine. Laserscopic Spinal Center of Florida, LLC and Laserscopic Diagnostic Imaging and Physical Therapy, LLC were each assigned to Spine. Spine operated from March 4, 2005 until it ceased doing business in late 2006. Both Spinal and Spine are corporations in good standing.
12. At all times material hereto, Plaintiff Joe Samuel Bailey (“Bailey”), was a resident of the State of Arkansas; but also owned property in Florida. Bailey was and is a shareholder, officer and director in both Spinal and Spine. Specifically, Bailey was the Chief Executive Officer and President of both entities.
13. At all times material hereto, Defendant James S. St. Louis, D.O. (“St. Louis”) was and is a resident of Pinellas County, Florida, and is a shareholder and director of Spinal. He was also employed as an orthopedic surgeon performing medical services at Spinal, was its Medical Director, and was heavily involved in marketing the Spinal brand. Defendant St. Louis was Spinal’s Chief of Surgery and was listed as such in Spinal’s submissions to the ACHA licensing board. Defendant St. Louis resigned without notice on or about November 15, 2004 to establish a competing venture with the other named defendants. Although Defendant St. Louis still owns a 34% interest in Spinal and is a director, he is also a shareholder and, upon information and belief, an officer and director of certain of the defendant entities. Defendant St. Louis is employed by certain defendant entities as an orthopedic surgeon performing the same minimally invasive spine surgeries that he performed on behalf of Spinal and the Spinal Operating Companies.
14. At all times material hereto, Defendant Michael Perry, M.D. (“Perry”), was and is a resident of Pinellas County, Florida, and is a shareholder and director of Spinal. Defendant Perry was the internist who performed medical clearance and other professional services on behalf of patients and prospective patients at Spinal and the Spinal Operating Companies and was also involved in marketing the Spinal brand. Once Bailey learned of Defendants’ conspiracy to steal the business of Spinal and the Spinal Operating Companies and their intentional interference in its ongoing operations, Defendant Perry was terminated. Although Defendant Perry still owns 5% of Spinal and is a shareholder, he is also, upon information and belief, an officer and director of certain of the defendant entities. Defendant Perry is currently employed by certain of the defendant entities performing the identical professional services he performed for Spinal and the Spinal Operating Companies.
15. Defendants St. Louis and Perry formed Spinal and the Spinal Operating Companies in conjunction with Plaintiff Bailey in 2004 and were engaged in that business until approximately November of 2004, at which time Defendants St. Louis and Perry abandoned the business and formed Defendant EFO Laser Spine, Ltd and its subsidiaries and operating entities to engage in the identical minimally invasive spine surgery business.
16. Defendant EFO Holdings, L.P. was at all times a foreign limited partnership doing business in Florida. “EFO” is an acronym for “Esping Family Office”; EFO is headed by manager and principal of the manager, non-party William Esping. (“Esping”). EFO Holdings, L.P. holds itself out as being, among things, in the business of financing, lending and investing in largely non-medical ventures.
17. Defendant EFO Genpar, Inc. was at all times relevant a Texas Domestic Business Corporation with its principal places of business in Texas. EFO Genpar, Inc. was at all times relevant a General Partner of EFO and, as such, is liable for the debts, obligations, and tortious acts of EFO Holdings, L.P.
18. Defendant EFO Holdings, L.P. and EFO Genpar, Inc. will collectively be referred to as “Defendant EFO” or “EFO.”
19. Defendant EFO purposefully availed itself of the privilege of conducting activities within Florida and thus invoked the benefits, liabilities, and protections of Florida law.
20. At all times material, Defendant EFO by and through various agents, including but not limited to Esping, Robert Grammen (“Grammen”), and Michael Surgen (“Surgen”), purposefully availed themselves of Florida’s jurisdiction by engaging in and investing in Florida businesses from which Defendant EFO derived substantial profits resulting in continuous and meaningful contacts with the State of Florida and its citizens.
21. Further, upon information and belief, Defendant EFO Laser Spine Institute, Ltd., discussed below, is owned in whole or in part by Defendant EFO and, as a result, Defendant EFO is liable for the tortious acts of its subsidiary and/or affiliate.
22. Upon information and belief, Defendant Laser Spine Institute, LLC, discussed below, is owned in whole or in part by Defendant EFO and, as a result, Defendant EFO is liable for the tortious acts of its subsidiary and/or affiliate.
23. At all times material hereto, Defendant EFO Laser Spine Institute, Ltd. (“LSI”) was and is a Florida corporation, authorized to do business in Florida. Defendant LSI maintains its principal place of business in Hillsborough County, Florida.
24. At all times material hereto, Defendant Laser Spine Institute, LLC, and its related defendant affiliates Laser Spine Medical Clinic, LLC, Laser Spine Physical Therapy, LLC and Laser Spine Surgical Center, LLC (collectively, the “LSI Operating Companies”) were and are Florida limited liability companies, authorized to do business and doing business in Hillsborough County, Florida.
25. Upon information and belief, non-party Grammen was and is the Senior Partner of Cypress Lending Group Ltd., a wholly owned subsidiary of Defendant EFO, and was and is a partner of Defendant EFO and Manager of EFO’s Florida operations.
26. Upon information and belief, among others, non-parties Esping and Grammen and Defendants St. Louis and Perry, among others, are each a shareholder, officer and director of Defendant LSI.
IV. GENERAL ALLEGATIONS
27. Minimally invasive spine surgery is a less traumatic, less invasive, micro-spine laser surgery using a tiny incision and laser-assisted arthroscopic, endoscopic, and microspinal surgical techniques to relieve back and neck pain. As late as 2004, there were only a dozen or so physicians trained in this technique throughout the entire United States. It was a highly specialized surgical procedure and, even today, the ability to perform this unique surgery is limited.
28. Advanced minimally invasive spine surgery is performed at an outpatient surgery center with local or light, general anesthesia, involving a tiny incision. The entire procedure is performed through a small sleeve using micro spinal instruments; the actual operating time is approximately 30 to 90 minutes per nerve root, maximizing patient satisfaction with a reduction in residual symptoms.
29. The distinguishing characteristic of these advanced procedures over more common minimally invasive spine surgeries or traditional open spine surgery is the ability to not only remove soft tissue, such as a bulging disc by the use of a laser, but also the ability to effectively correct symptoms of spinal stenosis created by bone spurs or bony overgrowth of the spinal column.
30. From about 1996 through 2001, Bailey managed the marketing efforts for a surgery center engaged in a similar business to Spinal and the Spinal Operating Companies, to wit: a surgery center engaged in minimally invasive spine surgery located initially in Hudson, Florida. In that capacity, Bailey was successful in generating tens of millions of dollars in revenues in just a three year period.
31. Bailey met Defendant Perry in about 1994, and later worked with him at the same surgical center from approximately 1996 to 2001. Neither Bailey nor Defendants St. Louis or Perry had an ownership interest in that surgical center. Bailey left the company in 2001 to concentrate on other business ventures, but Defendant Perry continued his employment for another three years or so. Bailey met Defendant St. Louis after Bailey left that surgical center.
A. Formation of Spinal and the Spinal Operating Companies.
32. In 2003, Defendant St. Louis contacted Bailey asking whether Bailey would be interested in forming surgical center engaged in minimally invasive spine surgery. Although the suggestion was initially an aspiration in nature, when the facility where Defendants St. Louis and Perry worked was relocated from Hudson, Florida, to Port St. Joe, Florida, Defendants St. Louis and Perry were increasingly upset about being forced to travel a significant distance from their respective homes and families, among other things. As a result, the frequency and seriousness of Defendant St. Louis’ requests increased.
33. In his conversations with Bailey, Defendant St. Louis assured Bailey that if he would join with Defendant St. Louis and Perry—neither of whom had the ability to raise capital to start such a venture—to form the company, the venture would be extremely profitable given the unique nature of the procedure. As part of those discussions, it was always understood and agreed that Defendant St. Louis would act as the surgeon performing the surgery; Defendant Perry would review the films and MRI’s to determine whether a patient was a good candidate for surgery and otherwise ensure that the patient was cleared for surgery; and Bailey would oversee the marketing and other operational aspects of the company, although Defendants St. Louis and Perry would also have responsibility to market the facility and assist with branding the company. In early Winter of 2004, Bailey finally agreed and the three of them set about to form what became Spinal and the Spinal Operating Companies.
34. On February 16, 2004, Defendant St. Louis resigned from his then employer to work with Bailey, taking one of the first major steps in effectuating their plan to open a surgery center specializing in minimally invasive spine surgery. At the time, Defendant St. Louis was one of only a dozen or so surgeons in the United States who could perform the advanced techniques of minimally invasive spine surgery, using laser-assisted arthroscopic, endoscopic, and microspinal surgical techniques.
35. Bailey and Defendants St. Louis and Perry agreed that they were going to work jointly to obtain the necessary funding, find an appropriate site for a surgery center, market the new facility, obtain patients and take all other necessary steps to make their new venture a success. They then set about to make their dream of owning their own surgical center a reality. The plan was, as more fully codified and detailed in the confidential business plan, to open one surgical center and then follow up with multiple surgical centers once the initial center was up and running. As noted above, ultimately, the goal of Bailey and Defendants St. Louis and Perry was to take Spinal and the Spinal Operating Companies public.
36. During the period while the surgery center was being developed and the ground work for the business established, Defendant St. Louis was paid Seventy-Three Thousand Dollars ($73, 000.00) per month. He received this compensation notwithstanding the fact that the surgery center was not yet opened and no revenue was being generated or collected. By agreement of the parties, Defendant Perry remained working at his job with the understanding that he would resign closer to the time their surgery center was ready to begin operations. Bailey did not receive a salary or other compensation, although he was reimbursed for certain out-of-pocket expenses.
37. Among other things, between February of 2004 and the end of July of 2004, the following steps were taken by Bailey and Defendants St. Louis and Perry on behalf of Spinal and the Spinal Operating Companies: (1) the companies were formed; (2) an expert in the area of surgery center development and operations was retained to develop a strategic business plan and to consult on healthcare and operational issues; (3) the strategic business plan was prepared and then finalized; (4) numerous sites for the possible surgical center were toured and ultimately a site was selected; (5) a lease was executed on behalf of Spinal for approximately 15, 000 square feet, which lease was guaranteed personally by Bailey; (6) significant capital was raised and possible additional investors were solicited including Defendant EFO; (7) many marketing seminars were conducted that resulted in dozens of candidates for surgery once the center was operational; (8) necessary equipment was purchased and installed; (9) the surgery center was built out and efforts were well underway to obtain an ACA license; and (10) a competent surgical team was hired so that once the facility was operational, Spinal and the Spinal Operating Companies could hit the ground running.
38. At significant expense, Bailey located (and Spinal retained) Larry Unger (“Unger”), an expert in the area of developing and operating ambulatory surgical facilities, to prepare a confidential business plan for Spinal and the Spinal Operating Companies. A draft of the business plan was finished by March of 2004 and the final version was completed by June of 2004. Among other things, the confidential business plan was to be used to establish the business and to provide information confidentially to potential investors. The business plan and consulting fees to implement the plan for Spinal and the Spinal Operating Companies was more than Sixty-Seven Thousand Dollars ($67, 000.00) excluding any cost associated with the time devoted by Bailey and Defendants St. Louis and Perry.
39. The Spinal and Spinal Operating Companies business plan is clearly marked “Confidential” on the cover page at the top; at the bottom of the cover page the following legend appears: “Confidentiality Statement: This document is not to be copied in whole or in part, distributed, emailed, faxed or discussed with individuals other than those authorized by the authors.”
40. The business plan contains the marketing strategy, financial projections, pro formas and details regarding the business model of Spinal and the Spinal Operating Companies, as well as other important confidential and proprietary information regarding the companies.
41. Various operating documents were also created including the Shareholders’ Agreement for Spinal, the limited liability company agreements for the Spinal Operating Companies and a Physician Services Agreement for Defendants St. Louis and Perry. Drafts of the agreements were exchanged between the parties for the purpose of codifying the terms of the parties’ oral understanding as to how the business would operate.
42. In June of 2004, the Articles of Incorporation of Spinal were filed with the Secretary of State of Nevada as were the Corporate Bylaws. By agreement of the parties, Bailey, Defendant St. Louis, Defendant Perry and Suhl (another investor) were elected as the four directors comprising the Board of Directors of Spinal. Bailey was elected as the Chief Executive Officer and the Secretary of Spinal. Defendant St. Louis was the Medical Director and Defendant Perry was the Chief of Internal Medicine.
43. At the time that Bailey and Defendants St. Louis and Perry agreed to form Spinal and the Spinal Operating Companies, Defendant St. Louis was one of the few surgeons qualified to perform the surgical procedure that Spinal and the Spinal Operating Companies’ business model was based on. As a result, Defendant St. Louis was an integral part of the strategic business plan and was a necessary component to the success of Spinal and Spinal Operating Companies. Were it not for Defendant St. Louis’ solicitation of Bailey and his repeated commitment to Spinal and Spinal Operating Companies, Bailey never would have agreed to move forward with the proposed venture or to invest significant capital and time in the company. Without a surgeon and surgical team, the business model could not succeed. It was precisely because of this fact that Defendants St. Louis and Perry’s commitment to the business was critical.
44. Having known each other for several years and based on their prior professional and personal relationships, a relationship of trust and mutual respect existed between Bailey and Defendants St. Louis and Perry. Based upon this relationship and the representations of Defendants St. Louis and Perry, Bailey agreed to move forward with Spinal and Spinal Operating Companies.
45. A professional service agreement was prepared for each of the key Spinal and Spinal Operating Companies’ principals (Bailey and Defendants St. Louis and Perry). Those agreements each contained non-competition and confidentiality provisions.
46. The Physician Services Agreement was executed by Defendant Perry in about August 2004. Defendant St. Louis and Spinal were solidifying his agreement and, based upon Defendant St. Louis’ representations, an agreement was to be signed by him in short order.
47. Among other relevant terms, Perry’s Physician Services Agreement (as well as the draft presented to St. Louis) contained the following terms:
This Agreement is made pursuant to Florida Statute Section 542.335. The Associate hereby acknowledges that the Association’s engagement with the clinic will enable Perry to gain skill in Perry’s medical specialty and will provide access to certain trade secrets and proprietary information of the Clinic and will enable Perry to form certain relationships with individuals and entities within the geographical area in which Perry performs his services. In consideration of the above and including but not limited to the consideration set forth herein for this covenant, and the additional benefits to which the Association and Perry is entitled under this agreement and from engagement with the Clinic, and other valuable consideration the sufficiency and receipt of which are hereby acknowledged, the Association and Perry specifically agree that the Association and Perry shall not, directly or indirectly for the Association’s or Perry’s own benefit or on behalf of others during the Term and for a period of twenty-four (24) months immediately following the termination of this agreement, engage in the practice of internal medicine from a medical office established within the Service Area or provide any marketing or administrative services to any company or person engaged in a business competitive with the practice and business of the Clinic.

Attached as Exhibit “A” is a copy of Defendant Perry’s Physician Services Agreement.

48. Further, the Physician Services Agreement contains a confidentiality provision that states:
Confidentiality of Information. Immediately upon execution of this Agreement and at all times hereunder the Clinic will provide the Association and/or Perry with Confidential Information (as defined herein). The Association and Perry agree to keep confidential and not to disclose to others at any time the Confidential Information, except (i) with the written consent of the Clinic, (ii) if such Confidential Information is generally known to the public (other than through breach of this Section 2.11), or (iii) as expressly required by law. Confidential Information shall include, but shall not be limited to, the following: (a) the data bases of the Clinic including, but not limited to, patient names, addresses and telephone numbers; (b) the clinical and research protocols of the Clinic; (c) contractual arrangements between the Clinic and insurers or managed care associations or other payors and all marketing materials or ideas; (d) the hiring needs, salary levels and skills of employees of the Clinic; (e) the referral sources of the Clinic; end (f) any secrets, propriety or financial information, confidential technology, patient lists or trade secrets of the Clinic or its other physician employees, or any matter or information ascertained by the Association or Perry through their relationship with the Clinic, the use or disclosure of which might be construed to be contrary to the best interests of the Clinic, its shareholders, officers, directors, employees, affiliates, and other physicians (the "Confidential Information"). Immediately upon the execution of this Agreement and at all times thereafter, the Association and Perry further agrees that during the Term and as of the date termination of this Agreement, neither will take or retain, without the prior written consent of the Clinic, any papers, slides, data (electronic or otherwise), records, patient lists, files, computer diskettes, research data, business plans and marketing studies or other demographic analysis, information regarding payor contracts entered or under consideration by the Clinic, or other documents or copies thereof or other Confidential Information of any kind belonging to the Clinic pertaining to its business, payers, customers, patients, financial condition, or activities. The Association and Perry acknowledge that a remedy at law for any breach by the Association and/or Perry of this provision will be inadequate, and the Association and Perry hereby agrees that the Clinic shall be entitled to seek injunctive relief in case of any such breach in addition to all other relief that may be available to the Clinic.

49. Although Defendant St. Louis was presented with the same agreement, he suggested certain minor changes and modifications to the document. Counsel for Spinal and the Spinal Operating Companies and counsel for Defendant St. Louis were working to finalize the agreement, but, for the reasons set forth below, Defendant St. Louis did not ultimately sign the agreement.
50. After significant expense and effort, the surgery center and related medical operations of Spinal and Spinal Operating Companies began operations in August of 2004. In the first month of operation, Spinal and Spinal Operating Companies performed numerous surgeries and regularly saw prospective patients; this activity continued in September, October, and part of November of 2004. It was expected that Spinal and Spinal Operating Companies would be in the black consistent with projections in the business plan.
51. Within a month after the surgery center opened, through significant time and expense of Spinal and the Spinal Operating Companies, a prospective patient list (persons interested in receiving the advanced surgeries performed by Spinal and the Spinal Operating Companies) was created. The list was comprised of potential patients obtained through the seminars conducted by Spinal and the Spinal Operating Companies as well as from other marketing efforts initiated by the companies. The list of patients was confidential, proprietary and trade secret information of Spinal and the Spinal Operating Companies.
52. Spinal and the Spinal Operating Companies created their business plan, patient lists and patient leads and other confidential business information (the “Spinal Confidential Information”) at considerable time and expense. The Spinal Confidential Information was extremely valuable to Spinal and the Spinal Operating Company and, as a result, Spinal and the Spinal Operating Companies took steps to protect the Spinal Confidential Information from dissemination to the public at large.
53. As more fully discussed below, in contravention of their fiduciary obligations to Spinal and Spinal Operating Companies, Defendants St. Louis and Perry abandoned Spinal and Spinal Operating Companies to form a competing surgical center with Defendant EFO.

B. The relationship between Spinal, Spinal Operating Companies and Defendant EFO formed.

54. In April of 2004, Bailey contacted Robert Grammen (“Grammen”) at EFO to discuss Spinal and Spinal Operating Companies and determine whether Defendant EFO was interested in investing and/financing in the companies. Bailey generally described to Grammen the business model and concepts of Spinal and Spinal Operating Companies. Defendant EFO (through its principals, non-parties Esping and Grammen) expressed interest in making a significant investment in the companies.
55. Several meetings and numerous telephone conversations occurred between Bailey, Defendants St. Louis and Perry and Defendant EFO (through its non-party principals Esping and Grammen) between April of 2004 and May of 2004 including, without limitation, meetings where the parties jointly toured possible locations suitable for a surgery center in various cities.
56. After becoming more familiar with the nature of the business, Defendant EFO represented that it was excited and interested in the possibility of investing in Spinal and Spinal Operating Companies and began extensive discussions with Bailey relating to such an investment. Defendants St. Louis and Perry were part of these discussions.
57. As part of the due diligence, Bailey and Defendants St. Louis and Perry provided Defendant EFO with a copy of the confidential business plan of Spinal and the Spinal Operating Companies. At the time that this confidential, proprietary and trade secret information was provided to Defendant EFO (through its non-party principals Esping and Grammen), they were advised that the business plan was to be kept in the strictest confidence and was only being provided for the purpose of allowing them to evaluate whether to invest in the companies. Defendant EFO (through its non-party principals Esping and Grammen) agreed to maintain the business plan and any other documents in the strictest confidence. Larry Unger was involved in these conversations as well.
58. In April of 2004, Defendant EFO submitted an initial offer to Bailey and Defendants St. Louis and Perry for investment in Spinal and the Spinal Operating Companies. Bailey and Defendants St. Louis and Perry rejected the initial proposal, but the parties continued to engage in discussions and negotiations in hopes that an agreement could be reached. Negotiations broke off for a time period and then were renewed in or about September of 2004.
C. The conspiracy to form LSI and the LSI Operating Companies commenced.
59. As noted above, Bailey and Defendants St. Louis and Perry met and had numerous discussions with Defendant EFO on behalf of Spinal and the Spinal Operating Companies on numerous occasions for the express purpose of having Defendant EFO invest in the companies.
60. During those meetings, Bailey and Defendants St. Louis and Perry provided Defendant EFO with the Spinal Confidential Information and discussed in detail with Defendant EFO the business model. Among other things, Defendant EFO was advised that there were only a handful of surgeons trained in this procedure and, accordingly, Defendant St. Louis was integral to the business plan.
61. At all times material, Defendant EFO (and thereafter Defendants LSI and the LSI Operating Companies) knew that Defendants St. Louis and Perry were directors in Spinal and the Spinal Operating Companies and were critical employees as well.
62. From April of 2004 through early November of 2004, Defendant EFO repeatedly and continually represented to Bailey, Spinal and the Spinal Operating Companies that they were interested in making a multi-million dollar investment. As late as October of 2004, EFO (through its non-party principal Esping) advised Bailey to “stop looking for other funding” because EFO was without question investing in Spinal and the Spinal Operating Companies.
63. It was as a result of these repeated assurances and representations that Bailey, Spinal and the Spinal Operating Companies provided Defendant EFO with the Spinal Confidential Information and opened up the companies’ books and financial records.
64. Specifically, based upon the relationship of trust and confidence that developed between Bailey, Spinal and the Spinal Operating Companies, on the one hand, and Defendant EFO, on the other hand, as well as the repeated assurances of Defendant EFO with respect to its investment in Spinal and the Spinal Operating Companies, which assurances were relied upon by Bailey, Spinal and the Spinal Operating Companies, Surgen (a representative of Defendant EFO) and Grammen were provided unfettered access to the financial books and records of Spinal and the Spinal Operating Companies.
65. Under the guise of conducting “due diligence, ” Defendant EFO requested and Spinal and the Spinal Operating Companies supplied the Spinal Confidential Information as well as other confidential and proprietary information including the companies’ then current ownership interests, lease agreements, operating agreements, and financial statements, so that Defendant EFO could provide a revised term sheet.
66. At the time this information was provided, Defendants EFO, St. Louis and Perry concealed from Bailey, Spinal and the Spinal Operating Companies that they were secretly having discussions as to how they could undermine and destroy Spinal and the Spinal Operating Companies and open a competing surgical facility. Had Defendants made such a disclosure, obviously Bailey, Spinal and the Spinal Operating Companies could have taken necessary steps to protect themselves and the Spinal Confidential Information.
67. Thereafter, in October 2004, Defendant EFO (through its non-party principal Esping) communicated to Bailey to “stop looking elsewhere for funding, ” and that Defendant EFO would meet the financing/capital needs of the company through a loan. Further, because Defendant EFO knew the other deal points that were unacceptable to Bailey, Spinal and the Spinal Operating Companies, it made clear that it would present a proposal that would be acceptable to all.
68. Defendant EFO knew that Bailey, Spinal and the Spinal Operating Companies would rely on those representations including, without limitation, that it would cease efforts to obtain alternative financing because Defendant EFO was committed to Spinal and the Spinal Operating Companies. Indeed, the representations of Defendant EFO were expressly designed to cause Bailey, Spinal and the Spinal Operating Companies not to close with any of the other financing options, which Defendant EFO hoped would place Bailey, Spinal and the Spinal Operating Companies into a precarious financial position. This would enable Defendant EFO to acquire a substantial interest in Spinal for pennies on the dollar.
69. On October 27, 2004, Defendant EFO faxed a second proposed term sheet for financing to Bailey. Contrary to Defendant EFO’s prior commitments and representations, the second term sheet proposed Defendant EFO as the majority shareholder and controlling interest:
Bailey 10%
Defendant Perry 5% (paid in capital)
Defendant Perry 5% (vested interest)
Defendant St. Louis 25% (vested interest)
Defendant EFO Holdings 55%

70. Bailey, Spinal and the Spinal Operating Companies rejected the October 27, 2004, term sheet since it contradicted Defendant EFO’s representations and because it was not in the companies’ best interest, despite Defendant St. Louis’ urging that Bailey, Spinal and the Spinal Operating Companies accept the deal.
71. Unbeknownst to Bailey, Spinal and the Spinal Operating Companies, only a short time after the surgery center opened its doors in August of 2004, Defendant EFO (through non-party principals Esping, Grammen, and Surgen) and Defendants St. Louis and Perry actually began a conspiracy to: (1) form Defendant LSI and the LSI Operating Companies, a competing surgery center specializing in minimally invasive spine surgery; (2) misappropriate the confidential, proprietary and trade secret information of Spinal and the Spinal Operating Companies including the Spinal Confidential Information; (3) improperly solicit virtually all of Spinal and the Spinal Operating Companies key surgical and other employees; (4) look for locations for a competing surgical facility in the event that they could not usurp the leased premises of Spinal and the Spinal Operating Companies; (5) undermine and defame Bailey with employees of Spinal and the Spinal Operating Companies by, among other things, make defamatory and slanderous statements about Bailey; (6) conduct secret meetings at the Vinoy Hotel in St. Petersburg (where Defendant St. Louis resided) and elsewhere in an effort to further their conspiracy by discussing plans to open their competing venture.
72. Defendants St. Louis and Perry began canceling patients scheduled for surgery or would otherwise no show up for scheduled surgeries so that such patients could ultimately be diverted to their soon to be open competing center. Defendants LSI and the LSI Operating Companies would benefit from such wrongful condcut even in event that Defendant EFO could not force Spinal and the Spinal Operating Companies to accept their term sheet. Defendant St. Louis also delayed signing a professional services agreement as he conspired with the other co-defendants to destroy Spinal.
73. Behind Bailey, Spinal and the Spinal Operating Companies’ proverbial back, Defendant EFO (who knew that Defendants St. Louis and Perry were shareholders, employees, and directors of Spinal), held secret meetings for the purpose of interfering in the relationship between Spinal and the Spinal Operating Companies and Defendants St. Louis and Perry.
74. Because Defendants St. Louis and Perry were employees of Spinal and the Spinal Operating Companies, they each had a duty of loyalty to the companies. They were also directors, and as such each had a fiduciary duty to Spinal and the Spinal Operating Companies. These duties include: duty of good faith, duty of loyalty, duty to refrain from self-dealing, duty of full disclosure, and the duty to use the amount of care that an ordinary careful and prudent director would use in managing a corporation’s affairs. These duties precluded them from, among other things, opening a competing facility and stealing Spinal and the Spinal Operating Companies’ employees and confidential, proprietary and trade secret information.
75. Notwithstanding their duties to Spinal and the Spinal Operating Companies, Defendants St. Louis and Perry engaged in numerous meetings and conversations with Defendant EFO (through its non-party principals Esping and Grammen and also through Surgen) for the purpose of soliciting them to sever their relationship with Spinal and the Spinal Operating Companies and forming Defendants LSI and the LSI Operating Companies.
76. Defendant EFO (including its non-party principals Esping and Grammen and also Surgeon) knew that Defendants St. Louis and Perry were employees, shareholders and directors of Spinal and the Spinal Operating Companies. Without Bailey, Spinal and the Spinal Operating Companies’ knowledge, Defendants EFO, St. Louis and Perry interfered with the advantageous business relationships with the employees of Spinal and the Spinal Operating Companies by, among other things, (1) using these employees—during regular business hours as well as after hours—to help Defendants EFO, St. Louis and Perry locate a property at which to open their competing surgical center; (2) soliciting them to join their soon to be opened competing facility—Defendants LSI and the LSI Operating Companies; (3) making defamatory and slanderous statements about Bailey in an effort to undermine Bailey and question the security of remaining as an employee of Spinal and the Spinal Operating Companies; (4) making defamatory and slanderous statements about Bailey, Spinal and the Spinal Operating Companies to third parties including Spinal’s landlord and its third party vendors; (5) interfering with the patient relationships with Spinal and the Spinal Operating Companies including, without limitation, as discussed below, the theft of approximately 200 patient leads that were taken to use at Defendants LSI and the LSI Operating Companies; and (6) interfering with Spinal and the Spinal Operating Companies’ retention of a new physician to replace Defendant St. Louis.
77. Defendants’ meetings and discussions occurred over approximately a two month period beginning in or about September of 2004. Through their discussions and inspection of numerous possible locations, Defendants learned that it was not going to be as easy as they suspected to find a location suitable to open a competing surgical center. Unless Defendants were lucky enough to find a vacant surgical center with an ACHA license, they were going to lose a significant amount of time in building their own surgery center, a fate that they wanted to avoid at all costs. Defendants coveted the Spinal surgery center because it was built for ACHA approval at substantial time and expense, which, if they could obtain the center, would be a significant benefit.
78. Other alternatives, and the course that Defendants chose, was to either force Spinal and the Spinal Operating Companies to sell the company for pennies on the dollar, or if that did not succeed, Defendants would simply force Spinal and the Spinal Operating Companies out of business by committing the tortious acts described below. If either effort succeeded, Defendants expected to end up with the surgery center operated by Spinal and the Spinal Operating Companies.
79. Beginning at least as early as October of 2004, and upon information and belief even as early as August of 2004, Defendants St. Louis and Perry began to undermine Bailey and Spinal by representing to the employees of Spinal and the Spinal Operating Companies that Bailey is a convicted felon, that he uses 13 aliases; that Bailey is bankrupt; that Bailey was stealing money from Spinal and the Spinal Operating Companies and that Spinal and the Spinal Operating Companies are going to fail. Defendants St. Louis, Perry and non-party Dr. Hamburg (the anesthesiologist brought by Defendants St. Louis and Perry to Spinal and the Spinal Operating Companies) made the statements to not just employees, but also to third party vendors. At the time these statements were made, Defendants St. Louis and Perry knew or should have known that the statements were false.
80. The timing of the statements was not accidental, but was in fact deliberate. Because Defendants desperately needed to either acquire Spinal and the Spinal Operating Companies or at least get its surgery center with its ACHA built out infrastructure, the statements were deliberately designed to help Defendants to achieve their goals.
81. In the beginning of November of 2004, Defendant EFO (through its non-party principals Esping and Grammen), without disclosing to Bailey, Spinal or the Spinal Operating Companies their clandestine plan to open a competing center with Defendants St. Louis and Perry (both of whom were employees, shareholders and directors of Spinal), tried to coerce Bailey to strike a deal with Defendant EFO regardless of whether it was in the best interests of Spinal or the Spinal Operating Companies. Defendants EFO, St. Louis and Perry effectively attempted a hostile takeover of Spinal and the Spinal Operating Companies and Defendant EFO used Defendants St. Louis and Perry to help accomplish its goal.
82. Among other things, the proposed deal required that Defendant EFO would control the board of directors and it would result in a significant reduction in Bailey’s ownership which would have went from 27% to 10%. The proposed transaction would have only reduced Defendant St. Louis’ interest from 34% to 25%. In other words, Bailey would be reduced by a substantial 63% of his ownership interest under EFO’s proposal; Defendant St. Louis would have been reduced by only 26.5%. This, despite the fact that it was Bailey, Spinal and the Spinal Operating Companies that developed the Spinal Confidential Information, furnished the seed capital used to get the business off the ground, assembled a surgical team that was clearly talented (otherwise Defendants EFO, LSI and the LSI Operating Companies would not have raided it), equipped and licensed a surgery center, and spent at a minimum 2000 hours of time (at no salary) in getting the business going.
83. Spinal rejected the proposal. Because EFO’s efforts to acquire a controlling interest in Spinal failed, Defendants collectively moved forward with their joint plan to open the competing center. However, they still hoped to get the surgical center developed by Spinal and the Spinal Operating Companies by driving the companies out of business.
84. After Defendants St. Louis and Perry literally went to the bank and cashed their November paychecks (as opposed to deposit them in the bank for processing as they had historically done), Defendant St. Louis announced his resignation. At the time this happened, Defendants’ plan quickly unfolded as roughly half of Spinal and the Spinal Operating Companies’ staff resigned with him including the main members of the surgical team. The staff that resigned included, without limitation, Defendant St. Louis, Defendant Perry, Dr. Glen Hamburg (anesthesiologist), Jim Stafford (scrub tech), Guy Lepine (Marketing Director), Stacy Danahy (charge nurse), Roy Leathem (business manager), Roxanne Wendt (billing, coding collections), Carl Erisman (Xray technician), Colin Pick (certified nurse anesthetist), and Cheryl Pierson (Defendant Perry’s nurse).
85. Defendants asked Defendant Perry to stay behind at Spinal to act as a mole and gather more of Spinal’s Confidential Information; however, as soon as Spinal and the Spinal Operating Companies learned that Defendant Perry was part of the conspiracy, he was terminated.
86. Spinal and the Spinal Operating Companies were on the ropes given that the center only opened three (3) months earlier. Bailey, Spinal and the Spinal Operating Companies had expended significant time and money to develop the Spinal Confidential Information, form the companies and make them operational. As a result, losing the entire surgical team was quite a blow given that few doctors were qualified to perform the minimally invasive technique and the importance of the surgical team to Spinal and the Spinal Operating Companies business model. Further, significant capital was expended in development of the surgical center and paying Defendant St. Louis during the start-up period while the center was not opened and generating revenue.
87. Defendants did not just open a competing facility, however. They recruited Guy Lepine (“Lepine”), who was responsible for marketing and his relationship with vendors at Spinal and the Spinal Operating Companies. Lepine wrongfully took all of Spinal and the Spinal Operating Companies patient leads with him to start Defendant LSI and the LSI Operating Companies. Further, Lepine and others took with them Spinal’s Confidential Information including its business plan.
88. Lepine was also responsible, in part, for setting up the surgery center of Spinal and the Spinal Operating Companies. Defendants were able to recruit Lepine because they, among other things, told him that that: Bailey is a convicted felon, he has 13 aliases, he was stealing money from Spinal and the Spinal Operating Companies and the companies were going to fail. Given Defendants St. Louis and Perry’s position with the companies, Lepine believed the statements about Bailey at the time and grew concerned about his position with Spinal and the Spinal Operating Companies.
89. These same false statements were made to each of the other employees of Spinal and the Spinal Operating Companies that resigned including Defendant Perry, Dr. Glen Hamburg (anesthesiologist), Jim Stafford (scrub tech), Guy Lepine (Marketing Director), Stacy Danahy (charge nurse), Roy Leathem (business manager), Roxanne Wendt (billing, coding collections), Carl Erisman (X-ray technician), Colin Pick (certified nurse anesthetist), and Cheryl Pierson (Perry’s nurse). Other employees that heard the false statements but elected to stay with Spinal include but are not limited Robert McNalley, Florence Barbie, Fred Weaver, Diane Mears, Candace Cummings, Aaron Plumb and Kim McCown.
90. These individuals, including Defendant St. Louis, Defendant Perry, Dr. Glen Hamburg (anesthesiologist), Jim Stafford (scrub tech), Stacy Danahy (charge nurse), , Roxanne Wendt (billing, coding collections), Carl Erisman (Xray technician), Colin Pick (certified nurse anesthetist), and Cheryl Pierson (Perry’s nurse), comprised the bulk of the surgical team at Spinal and the Spinal Operating Companies.
91. At all times material, Defendant EFO knew that Defendants St. Louis and Perry were employees, shareholders and directors of Spinal, but nonetheless used wrongful means and further encouraged Defendants St. Louis and Perry to sever their employment with and loyalty to Spinal and the Spinal Operating Companies and enter into a similar competing business financed and/or controlled by Defendant EFO.
92. Further, Defendants EFO, St. Louis and Perry knew that the employees that they solicited to resign and join forces with them at Defendants LSI and the LSI Operating Companies were employees of Spinal and the Spinal Operating Companies and that these individuals had an advantageous business relationship with Spinal and the Spinal Operating Companies.
93. At least as early as the date that Defendant St. Louis resigned, each of the Defendants began making defamatory and slanderous statements to third parties including the vendors Prism Physical Therapy, GE Healthcare, Ultra Open MRI, Alsco, and Mercury Medical amongst others that serviced Spinal and the Spinal Operating Companies and its landlord. Those statements included those mentioned above, e.g., that Bailey is a convicted felon, he has 13 aliases, he is bankrupt, he was stealing money from Spinal and the Spinal Operating Companies and that the companies were going to fail.
94. Spinal and the Spinal Operating Companies had advantageous business relationships with its vendors and its landlord. Defendants knew or should have known of the advantageous relationships with these vendors at the time the false and defamatory statements were made, but made such statements anyway.
95. Indeed, Defendant EFO and, thereafter, Defendants LSI and the LSI Operating Companies contacted the landlord of Spinal and the Spinal Operating Companies in an effort to encourage and solicit the landlord, Kevin McCallum, into severing his company’s relationship with Spinal and the Spinal Operating Companies. Among other things, Defendant EFO and, thereafter Defendants LSI and the LSI Operating Companies told the landlord that if the landlord would refuse to accept rent from Spinal and the Spinal Operating Companies, Defendants LSI and the LSI Operating Companies would lease the entire facility (as opposed to approximately half, which is what Spinal and the Spinal Operating Companies was leasing). Further, Defendant EFO and, thereafter, LSI and the LSI Operating Companies told the landlord that if these terms were not accepted, that Spinal and the Spinal Operating Companies would fail, that no rent would be forthcoming and that the landlord would be left with no tenant.
96. Further, after October 27, 2004 and continuing through to November 2004, Defendants EFO, St. Louis, Perry, LSI and the LSI Operating companies contacted Miller, Suhl, and other business relations of Spinal and the Spinal Operating Companies, and told them false and defamatory statements concerning Bailey, Spinal and the Spinal Operating Companies, including and without limitation, (1) that Bailey, Spinal and the Spinal Operating Companies could not obtain financing; (2) that foreclosure on Spinal and the Spinal Operating Companies’ lease of its surgery center was impending; (3) that GE Capital was about to foreclose on Spinal and the Spinal Operating Companies’ equipment; (4) that Bailey had stolen from the company and had spent time in jail (5) that Bailey was operating under assumed names including even female names; (6) that Bailey had filed for bankruptcy; and (7) that Bailey had improperly organized Spinal and the Spinal Operating Companies, thus making financing and operations difficult. At all times material hereto, Ted Suhl and Mark Miller were investors in Spinal.
97. At times throughout November 2004, Defendant EFO contacted Miller and Suhl and informed them that if they did not cooperate with Defendant EFO, then Defendant EFO would take the doctors and start their own competing business, leaving Spinal and the Spinal Operating Companies with no surgeon, physicians or staff. At the time these statements were made, Defendant EFO knew that Miller had entered into a contract to make a significant capital contribution to the company. Defendant EFO knew or should have known that the statements made were false.
98. The same defamatory statements were made by Defendants EFO (by its employees, agents, or representatives), St. Louis, Perry, LSI and the LSI Operating Companies to other business relationships including those both in Florida and those out-of-state including the landlord Kevin McCallum in St. Petersburg, Fred Bergman of Ultra Open MRI, and Ron Chism of Prism Health.
99. Defendants St. Louis and Perry, while serving on the Board of Directors of Spinal, wrongfully participated along with Defendant EFO to launch a competing spine surgery clinic (Defendants LSI and the LSI Operating Companies) that was financed by Defendant EFO.
100. On November 9, 2004, Andrew N. Meyercord, corporate counsel to Spinal, sent a letter to Esping at Defendant EFO, advising that Defendants St. Louis and Perry were directors of Spinal and as such owed a series of fiduciary duties to Spinal and the Spinal Operating Companies. Mr. Meyercord demanded that there be no further contact between EFO and Defendants St. Louis and Perry regarding the sale of their ownership interests in Spinal or any other matter related to the operation of a minimally invasive surgery center.
101. In that same letter, Mr. Meyercord further demanded the immediate return of all confidential information provided to Defendant EFO in connection with its proposed investment in Spinal and instructed that such materials should not be used by EFO for any purpose. Mr. Meyercord clearly advised Defendant EFO, at that time, that Spinal and the Spinal Operating Companies had undertaken efforts to maintain the confidentiality of such materials and that Defendant EFO’s continued possession and any use of those materials was not permitted.
102. Defendant LSI and the LSI Operating Companies were formed using the Spinal Confidential Information including, without limitation, its business plan and the patient lists and leads, each of which was created at a significant expense to Spinal and the Spinal Operating Companies. This information was maintained confidential by Spinal and the Spinal Operating Companies.
103. Defendants LSI and the LSI Operating Companies were formed by effectively taking more than half of Spinal and the Spinal Operating Companies’ team (including the entire surgical team) and transplanting them at Defendant LSI and the LSI Operating Companies. Defendants also took the Spinal Confidential Information including its list of prospective patients and business plan, the later of which it copied virtually verbatim. Defendants also copied and used various other forms of Spinal and the Spinal Operating Companies and structured Defendants LSI and the LSI Operating Companies in the identical manner. Defendants even purchased the identical equipment, used the same surgical supplies from the same vendors. Thus, when it opened, LSI and the LSI Operating Companies had the benefit of the tremendous effort of Bailey, Spinal and the Spinal Operating Companies.
104. These egregious acts were accomplished with the assistance of the improper conduct of Defendants St. Louis and Perry as well as agents for Defendant EFO such as Grammen and Surgen. On November 15, 2004, on the date of Defendant St. Louis’ resignation, while still members of the board of directors, Defendants St. Louis and Perry engaged in activities to interrupt, disrupt, interfere, disturb, and/or destroy Spinal and the Spinal Operating Companies by attempting to enter the restricted and confidential business office (storing Bailey’s files) in Spinal and the Spinal Operating Companies’ clinic in St. Petersburg, Florida. Defendants St. Louis and Perry threatened to break down the door if they were not given a key, and again defamed Bailey by telling employees that Bailey had stolen from the company but that “everything would be fine once Bailey is removed.”
105. Moreover, on November 16, 2004, Defendant James St. Louis left the clinic with a metal briefcase containing approximately $30, 000 worth of surgical equipment, whereupon being informed that the police were called and a police report was being filed, he later returned all or part of the equipment.
106. Although Defendants were conspiring for several months, on November 18, 2004 agents for Defendant EFO filed for corporate status with the state of Florida for Defendants LSI and the LSI Operating Companies.
107. Approximately ten days after Defendant St. Louis’ resignation, on November 24, 2004, Spinal and the Spinal Operating Companies discharged Defendant Perry as an employee for a) engaging in activities that were interrupting, disrupting, interfering, disturbing, destroying, and/or usurping the business opportunities of Spinal and the Spinal Operating Companies; b) using proprietary and confidential information for his own purposes including the Spinal Confidential Information; and, c) canceling patients that were scheduled to come to the St. Petersburg clinic (over the course of several days before Defendant St. Louis resigned) for the benefit of Defendants.
D. Spinal and the Spinal Operating Companies attempted to mitigate its damage by hiring Dr. Wolff but Defendants’ conspiracy to destroy the company continued.

108. After Defendants’ wrongful conduct, Spinal and the Spinal Operating Companies had no surgeon to perform the procedures and, hence, it was effectively out of business unless it could quickly find another qualified surgeon to perform the unique surgery that was at the heart of its business plan.
109. It was not as simple as just replacing a surgeon or surgery team, however. Because of the false statements made by Defendants to vendors, the landlord and other third parties, even if Spinal and the Spinal Operating Companies could replace the surgeon, it would take much more to right the ship. Because the marketing efforts of Spinal and the Spinal Operating Companies focused on the expertise and experience of Defendant St. Louis, rebuilding Spinal and the Spinal Operating Companies would require it to rebrand itself and market a new surgeon at a time when Spinal and the Spinal Operating Companies had already expended significant sums to market and develop the center based on the expertise its shareholder, employee and directors, Defendants St. Louis and Perry.
110. In addition to staging a collective “walk out” of the entire surgical team, Defendants maliciously disseminated defamatory statements about Bailey, misappropriated Spinal Confidential Information, and stole the list of approximately 200 prospective patient that were generated by Spinal and the Spinal Operating Company at great expense and effort. Lepine, on behalf of Defendants subsequently contacted each one of them, soliciting them to come to the new competing facility. A public notice was also published in an alleged effort to mislead potential and former patients of Spinal. A substantial number of the patients ultimately had surgery at Defendants LSI and the LSI Operating Companies. This list of prospective patients was not readily available to the public and was generated by Spinal and the Spinal Operating Companies through its significant marketing efforts.
111. The conduct of Defendants significantly harmed Bailey, Spinal and the Spinal Operating Companies business and goodwill within the medical community, with third party vendors, the landlord, as well as with patients and prospective patients. Defendants’ conduct also increased the risk to potential investors associated with the venture, hence limiting Plaintiffs’ access to the capital markets to which they turned, in part, to keep the venture afloat after Defendants tortious conduct.
112. In an effort to salvage Spinal and the Spinal Operating Companies from financial ruin (due to lack of a qualified surgeon or surgical team), Bailey, on behalf of Spinal and the Spinal Operating Companies, began conve

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JimCent
, US
Sep 16, 2016 5:41 pm EDT

They record everything then throw it in your face. They say they will send itemized bill and never do. One lie. Thay have a doctor talk to you for two minutes, then they use a D.O. for the operation. When you leave they don't know you. The guy you set up payment with is arrogant and smart ###. You waste a week for a 30 minute operation. They dope you up so that when you leave you feel good and tell them so. When the faulty work shows up they throw it in your face that you said you felt good. They are liars, con men and crooks. I had 8 things wrong with my back they "fixed" one. Really they fixed nothing. They said I had to come back for each thing that was wrong with me. I figured it out that with motel I would spend $101, 500 and nothing would be accomplished. As if I would fall for they lies twice.

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lon nie
, US
Jul 09, 2014 6:50 pm EDT

These people, LASER SPINE INSTITUTE are heartless liars, , , They will use fear or what ever it takes to get your money... I had surgery back on Jan 31, 2009... Was in more pain after than before... Called and said the doctor is going to want to see me... The young lady say's, But why would the doctor want to see you?... Because I'm in more pain than before my surgury... Again she say's... But why would the doctor want to see you?... I went in to get the stitches out and he still would come to see me... Useless ###... They even tried to over bill my insurance company...

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kennybgood2me
Chenango Forks, US
Dec 06, 2012 12:15 pm EST
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I had laser spine surgery on Aug 22, 2012, not one follow up with surgeons or staff, the only time they called is when I called so much and threatened further action, I am in worst 24/7 pain than I ever was before surgery and the back surgery was suppose to be in preperation for my neck surgery which is worst, this was done at the Wayne, PA facility near Philidelphia!
I am looking for an attorny/ies who may have already dealt with this company, as stated I am in severe 24/7 pain as a result of surgery and I want results! I need another surgery on lower back and then on my cervical, I will not go back to The laser Spine Institute I fear for my saftey using them! They destroyed my career and life!
Please attorneys feel free to call, I reside in NY State! [protected] leave message if need be!

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Tired Of Pain
, US
May 15, 2012 3:06 pm EDT

I have seen their ads on TV & have been considering contacting them. I have degenerative disk disease (ddd) and, though my current pain management team has the pain more under control than it ever was, I was hoping to be able to do something to really get my life back. I have lived with this since 2004 and actually considered suicide in the beginning. I was living in Phoenix AZ at that time. I had all kinds of therapy, injections, radio-frequency ablation; name it - I had it - short of surgery! That's the main problem: no doctor in Phoenix or in Tyler TX will operate on my back. As of my most recent MRI, I had four disks that were shot. Sometimes I actually go for several weeks with no oral pain meds (I have a morphine pump implanted & the catheter runs direct to my spine). However, when the pain hits, IT HITS! I could go Germany & have the surgery but my insurance won't pay a penny. I'm gathering this outfit isn't what I want touching me either. Does anyone have a suggestion? Thanks. southerngirl1949@yahoo.com

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SusieQ55
Nashville, US
May 14, 2012 3:13 am EDT

My mother died from complications of surgery from LSI. And since they don't take insurance, they robbed her blind!

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ray dushey
Liberty Lake, US
Mar 15, 2012 7:57 pm EDT
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Need an attorney asap. I had surgery in 2009/2010 at LSI Florida & Arizona and ended up with multiple complications (dural leak, left unattended for 1.5 months). Dr. Wolff performed the first surgery followed by Dr. Weiss (Arizona) who repaired the dural leak and removed bone fragments from Dr. Wolff. I suffer daily. The pain is mentally destroying me...lost everything. Who can help? I'm on fetanyl, percocet, etc. for unbearable pain. need help [protected]

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rodutah
Logan, US
Jun 28, 2011 3:35 am EDT

Did you have any luck whether or not there was a class action suit against LSI. I had very unsuccessful surgery at the Scottsdale in March 2011. Please contact me at [protected]. Rod

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Pgfoley2
Scottsdale, US
Jun 09, 2011 7:24 am EDT

Does anyone have any knowledge of a possible class action suit against LSI? Anyone have unsuccessful surgery at their Scottsdale facility? For $20, 751 my husband and I got six "so so sandwiches, water and small dessert!

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Mrs Cleaver
Atlanta, US
May 04, 2011 6:01 pm EDT

http://www.bloomberg.com/news/2011-05-04/laser-spine-surgery-more-profitable-than-google-sees-surge-in-complaints.html

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Alice in Texas
AUSTIN, US
Dec 02, 2010 6:18 pm EST

I am seeking an attorney in Florida who has knowledge of The Laser Spine Institute their practices or malpractices. Please contact me as soon as possible. Thank You! Alice in Texas [protected]

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Laser Spine Institute - no morals

I have been in the medical field for well over 17 years, and this is the first company I have ever worked for that did nothing buy lie to their employees and their patients. LSI was something that I was hoping to have a career with. During their presentation they give to all new hires, this is a company that speaks highly of family, integrity, their...

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Laser Spine Institute - lsi treats their employees like garbage

I worked for Laser Spine Institute in Scottsdale, AZ. I held a very important and pivotal position within the company and surgery center. When I first began my employment, I thought this was going to be the opportunity of a lifetime…I quickly learned that was not the case. Let me start off by saying that Laser Spine Institute was started by surgeon Jame...

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Laser Spine Institute you are just a dollar sign

I have read many complaints about Laser Spine Institute all over the internet and agree with all the various complaints. I am a former employee of Laser Spine Institute. No, I am not sour grapes. I am very educated and well respected in the medical field.

I have worked for a very long time in the medical field in real surgeon's offices before going to work for LSI. I was not prepared for what Laser Spine Institute really is. I strongly believe that this is a company that is NOT about helping patients get their life back. I strongly believe that this is a company that is about selling as many surgeries as possible. My job was to call people that submitted a request for information about the laser surgery. Really, my job was to call and hound people about getting the surgery. My job was to push the potential patient to sign up. If LSI got a last minute cancellation for surgery they would scramble to find another patient to fill the spot. They did not like losing the money from that time slot.

The folks that have blogged that after their surgery they could not get call backs from Laser Spine Institute is also valid. I dealt with many complaints from people that had issues after surgery and could not get anyone to call them back.

I felt like a used car salesperson. Laser Spine Institute actually has a sales department. In my long career in medicine I have never worked in ANY medical facility that had a sales department. I despised my job. I am now unemployed which I would prefer to trying to sell people a surgery. I did not have the stomach to push and push a person into having such a major surgery. When I was let go I was told, among other things, that my sales were not high enough. I am a legitimate medical professional and would have to say that I took that as a compliment! Oh well, at least I can sleep at night.

Do your homework they only have one real spine surgeon. Do you want someone operating on your spine that hasn't had specialized training in spine surgery? IT IS A SCAM. THEIR DAYS ARE NUMBERED!

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stizmo
Atlanta, US
Apr 11, 2019 8:39 pm EDT

Was told before I began that they needed to check my insurance and when they called me back, after 3 weeks of waiting, they said I was covered. Now, Laser Spine keeps sending me a bill for remaining $15000+ but I also received a bill statement from Melissa Cantrell stating I have a $0 balance. Can't get in touch with a billing person to take care of this much less would Dr. Puppala call me back! I have never had a Dr hide behind the employees & not tell the billing office that I (in front of my husband in the waiting rm) would not be responsible for any remaining bill not covered by insurance that he writes it off! Yeah, that's why I'm getting a letter from billing in Maine threatening collection! HAH! LOL! REALLY! I w/be glad to file a countersuit since I have made numerous attempts to discuss this to billing or Dr. Puppala TO NO AVAIL! I have proof from insurance and the bill faxed from your company saying I owe nothing. I want this cleared up immediately. I'm being treated by an Orthopedic Surgeon for the work performed didn't even fix the problem and now have more issues. STAY AWAY OR PAY BIG!

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lindadak
, US
Feb 23, 2018 7:38 pm EST
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I have spondyolisthesis and was told I need surgery. I phoned LSI this morning to determine if they would be an option for me. I wanted to know about insurance; how many trips I'd have to make to Phoenix (I'm from Alaska. It's expensive to fly down there and then add hotel, meals, transportation, etc.); what I can expect; etc. The woman I spoke with asked for my name first. I told her that wasn't important right now, I'm basically interviewing them to determine if they are an option. She then asked for my phone number. When I asked why she needed that, she hung up on me. I felt they would begin a hard-sell pressure campaign to get me into their facility. If hanging up on potential patients with legitimate questions is an example of their customer service and patient care, I want no part of it. They are not an option for me.

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Fortin
Opelika, US
Jan 23, 2014 10:29 am EST

- LSI has established a very efficient production line. Day 1 consists of MRI and CT scans. Day 2 consists of meeting with a doctor, not your surgeon because LSI deems their surgeon’s time too important to waste on the patients. The doctor reviewing my MRI was board certified in physical medicine. My surgery was performed on by Dr. Wolff, whose patient approval rating according to some web sites maxes at 54%. His surgery on my back (L4/5) on 31 January of 2013 resulted in an herniated disk, which I had to have a real neurosurgeon repair. LSI's post op care support is atrocious...I suffered terribly for five weeks after the LSI surgery. Dr. Wolff never spoke to me again after the surgery and his nurse only twice in four weeks despite my many calls to them asking for their help...asking for an MRI to see what was going on. LSI will have successes...maybe as high as 75%. But can you take the risk of failure? Get a real neurosurgeon, someone who will speak to you before and after the surgery! This is now a year later and I still cannot walk properly.

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maimed
Big Pine Key, US
Feb 25, 2013 2:51 am EST
Verified customer This comment was posted by a verified customer. Learn more

AVOID For-profit clinics for a quick fix for your back. I wish I did. I went to Laser Spine Institute to have surgery. They offered to cut their regular cash price from $30, 000 to only $5, 000 cash, but it was no bargain. I am now on disability and in unspeakable pain. When my surgeon, Dr. Craig Wolff. did not return to work after my surgery, I did some checking. Turns out, he was arrested for DUI. At the trial, the LSI surgeon pleaded "no contest" to the charges. his earlier DUI was later reduced to a "Reckless Driving" charge, so he was unable to hide the second DUI charge. The state of Arizona learned about Dr. Wolff's DUI troubles and made him surrender his medical license in Arizona. You can google "Craig Wolff" and "Arizona medical board" to see for yourself.

Even worse, LSI works hard to remove posts from it's real patients like me and they reportedly pay people to post positive bogus reviews to "bury" the truth about this company that preys upon people desperate for help.

AVOID Laser Spine Institute; go to a real hospital and get a real neurosurgeon.

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LSIFan
Boise, US
Feb 22, 2013 11:01 pm EST

All of these claims are ### my wife had surgery with lsi and is cured now her neck pain is gone. I too read these blogs and comments before her surgery and almost stopped her from going to Tampa but I was smart enough to ask myself if the were all bad they would be out of business by now. I believe those on this page are the few and far between who didn't find relief at lsi. Trust me take the chance. You will see how many patients get wheeled in and walk out, just seeing this before my wife went in the OR made us know we were in the right place. They have performed over 30, 000 surgeries with 90% success so sorry for the ten percent but why don't you go ask your local surgeon what success chance you are looking at. The truth is its about 50 50 chance with fusion that's what my wife was offered... Thank you Laser Spine Institute you gav me my wife back!

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screwedbypumpagents
, US
Jun 09, 2012 3:29 pm EDT

I agree with the other complaints. They shipped me the wrong parts and I tried to contact them many times by email with no success. No phone and no address RIP OFF!

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unenlightened
Saint Robert, US
Jun 04, 2012 5:18 pm EDT

I have irreversible damage from their surgeries. I have nothing more to say.

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wilie
, US
Mar 11, 2012 11:40 pm EDT

I also had surgery there in Nov 07. What a rip off. This place is truly a joke. Needless to say the operation was a complete failure. Had to put up 30k and was assured that my ins would completely reimburse the 30k. After over two years of fighting with ins received only 6k. When I asked them about their assurance they basically said tough luck. The 30k was my retirement fund and informed them of this prior to my deposit. Bloomberg news recently did a story on them and hopefully will help expose them for what they are. You can go to their website to read the story, its a real eye opener. I hope anyone that reads this will take my advice and stay far away from this place. I now understand why there are hundreds of complaints on this and other sites conerning them.

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Not allowed to speak
Tampa, US
Oct 05, 2010 6:12 pm EDT

the company itself is a scam. yes they have "doctors" but the doctors do not go to a fellowship to be certified spine surgeon. they do their training for the procedure by dr. st louis himself, at the tampa facility. they just opened the facility in PA.

they have beautiful offices, nice decor, breakfast and lunch provided for the patients - big deal.

please do your homework, please know that it is a numbers game. the big wigs all bonus when they hit the magical monthly number.

you see a doctor, he gives you his opinion and then you are led to the "patient coordinator". that is where the number game begins. this is where the patient coordinator gives you their price of a whopping $30k, because after you add in the surgery center, anesthesia, doctors fee, nursing staff, supplies, bandages, blah blah they actually bill out over $60-$80 to the insurance. So your $30k pays them and they still collect from the insurance.

patients after surgery could experience problems, and they are given an 800 number to call, which is routed to the "tampa" office. and most of the time you dont' get a prompt call back, that is why they tell you to go to the emergency room if you are not feeling right.

the doctor who did your surgery, you won't even see him at the post operative appointment. you see a nurse if you are lucky, otherwise you see the MA.

they have you sign the longest form ever indicating if you get money from your insurance, that you will sign it over to them and not keep it.

none of the doctors are board certified. as a matter of fact, this procedure that they do, is involved in a lawsuit in florida, because dr. st louis, stole the idea from his former employer who was a real spine surgeon. that should tell you something.

good luck and read, read read. there are far better choices for care, that actually do care.

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gftodd
Sewell, US
Aug 30, 2010 12:26 pm EDT

I am sorry to hear about everyones experiences and i am just reading up on this stuff becaues for once i am actually considering surgery. I was told at least 18 yrs ago i needed to have spinal fusion. I said i would not ever get surgery until i was on the floor and could not get up, until i found LSI. Now having said that i am just looking into this surgery and trying to find information about it.I did go to a seminar they have located in Wayne PA and they where very knowledgable from what i have seen. I have not made up my mind yet but with your complaints i now know i have to look into this alot further

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Laser Spine Institute - buyer beware

Around March of 2006 I developed a Herniated Disc at the level L5--S1 causeing pain from my low back though my hip and all the way down the right leg to my toes, From a very mild to a make you cry pain. no fun. 7/18/2006 I paid a down payment I let LSI operate on me and a day later I told them, I still hurt, but they said it's was in my head. I Asked for an...

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