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COMMONWEALTH OF MASSACHUSETTS
MIDDLESEX, ss. SUPERIOR COURT
CIVIL ACTION NO. \ S43 4
SUSAN CHEUNG, AND
CHRISTOPHER CHEUNG
A MINOR WHEN WAS
THOMAS B PUCHAK’S PATIENT
Plaintiff,
DLERK OURTS _
one uoul YY GF MIDDLESEX
DEC 80 2022
THOMAS B PUSCHAK
DENTIST AND OWNER
OF FAMILY DENTISTTRY
LEXINGTON MA
CAROL PUSCHAK
WIFE OF THOMAS PUSCHAK
& OFFICE MANAGER
OF FAMILY DENTISTTRY
LEXINGTON MA
Defendant.
Vee esr ww SSS SS een
VERIFIED COMPLAINT DEMAND DAMAGE COMPENSATION FROM THOMAS
AND CAROL PUACHAK FOR $250,000 AND JURY DEMAND
1. The plaintiff, Susan Cheung (“Susan”), is a natural person residing in Bedford,
Middlesex County, Massachusetts, She was seen Mr. Puschak for Dental care from Sep
2014 to Dec 2019 and is the mother of Christopher Cheung, a minor.
2. The plaintiff Christopher Cheung is the only son of Susan Cheung, and resides with
Susan in Bedford, Middlesex County, Massachusetts. He was a minor(15 years old) started to see
Mr. Puschak for dental care until 2020
3. The defendant, Thomas B Puschak is an individual dentist and owner of Family
Dentistry(Suite14.175 Bedford Street, Lexington MA 02420), Mr Puschak residing in 15 Saddle
Club Road, Lexington MA 024204. The defendant, Carol Puschak is an individual, wife of Thomas Puschak and office
manager of Family Dentistry (Suitel4.175 Bedford Street, Lexington MA 02420), residing in 15
Saddle Club Road, Lexington MA 02420
COUNT I
(Mal Practice to Christopher Cheung, abuse him and made his teeth missing; a Minor at the time)
5. Christopher saw Mr. Puschak for dental care between April 28" to Oct 27" 2020
6. Mr. Puschak performed Root Canal on Christopher’s lower left first molar tooth 19 on
April 28" 2016 when Christopher was minor, 15 years old, Then He did “Post and core” on May
2016, told us that He finished tooth 19 with permanent crown; Chris was done and all set for his
tooth 19 on May 27" 2016. As Mr. Puschak said the same way on May 27" 2016.
7. Mr. and Mrs. Puschak lied to Susan and Christopher, On May 17" 2016, after Mr. Puschak
spent 3+ hours on Christopher’s tooth 19, He told us that He did permanent crown, it was all set
for the tooth 19. But He filed the claim to Delta Dental for Post and Core, which claimed the
money for the permanent crown, It is a fraud money Mr. and Mrs. Puschak collected from Delta
Dental.
8. On Oct 27th Oct 2020, Chris had issues with the tooth 19 which Mr. Puschak finished four
and half years ago; Mr. Puschak told Chris that tooth 19 was missing as He put temporary crown
only at the time. He allegedly intended to extract the root of tooth 19 and wrote his procedure
treatment menu telling Chris to replace his tooth (All teeth) with implanting without Mom Susan
present and no knowledge,
On Oct 27" 2020, Mr. Puschak also at the 1 time told Susan that He only did temporary crown
on tooth 19 and the crown fell off, the tooth was missing. And Demand $10000+ money for
implanting procedure from Susan and Delta Dental (Christopher’s insurance company)
9. Mr. Puschak did the same procedure to Christopher’s tooth 10 on Aug 17" 2017 (Chris was
minor) for root canal only, and He finished with “Post and Core” Oct 3 2017 with a “temporary
crown”, Mr. Puschak did not do impression and did not plan to install permanent crown, This
time He was not interested in claim fraud money for Post and core, He demanded Patient to pay
him “the temporary crown for $541” . and the Insurance company would not pay his temporary
crown $541. So the Patient must pay him. When Susan asked him to install the permanent crown
for tooth 10 soon;He told the patient that it was too “expensive” to install permanent crown.
10. Mr. Puschak did the same procedure to Chrsitopher’s tooth 7 on Feb 1% 2018(Chris was
minor) for root canal only, and He finished with “Post and Core” Oct 3 2018 with a temporary
crown, Mr. Puschak did not do impression and did not plan to install permanent crown, this time
He was not interested in claim fraud money for Post and core, He demanded Patient to pay him
the temporary crown for $541. When Susan asked him to install the permanent crown for tooth 7
soon; He told the patient that it was too “expensive” to install permanent crown. He madeinsulting gesture and body language, and moved his mouth with hands wrapped around, told
Sudan Cheung that all Christopher’s teeth were rotten, cannot be saved!
11 After Feb 1 2018 tooth 7 root canal; Feb 23"! 2016; Christopher came in to finish up tooth 7,
Mr. Puschak was looking for other root canal opportunities to ruin Christopher’s teeth, to dig out
“implanting opportunities”, Without patients and patient’s parents knowledge, He left the tooth 7
with all nerves pulled out and “ temporary crown” and searching to do some unknown work in
other teeth without any patients’ knowledge and instruction, Mr. Puschak was performing
nonstandard dental work to purposely to make Christopher’s teeth missing( A minor at the time)
and destroy Christopher’s health.(Body and Mental)
12. Mr. Puschak first noticed Chris’s tooth 3 cavity on April 28" 2016, He never mentioned to
the patient and the patient’s parents; his negligent work to Christopher’s tooth 3 at the beginning
directly led his tooth 3 missing! now Mr. Puschak made Christopher’s tooth 3 missing as well!
He planned to extract the tooth 3 for bigger money. (His treatment note)
COUNT II
(Malpractice and Sexual Assault to Susan Cheung)
12. Without considering the health situation of Susan Cheung, Mr. Puschak performed low
quality “deep cleaning”, caused patient’s effecting and bleeding gum on health.
“If your gums or an area of gum feels painful, tender, swollen, or you notice a strange taste,
plus or blood in your mouth, it increased my blood pressure, cholesterol and sugar level.
Mr. and Mrs. Puschak do this for money. Mrs. Puschak disturbed Susan Cheung in every
occasion with deep cleaning text reminder.
13. Dental care is out of standard care, Mr. and Mrs. Puschak cheated on money illegally from
both Delta Dental and Patients and used the way lure Susan bring her son there. Mr. Puschak
knew children’s psychology, as Mr. Puschak’s father was pediatrician. so, he was taking
advantage of Christopher as Christopher was a minor and just lost his father with sudden heart
attack. Mr. Puschak knew how to cheat on children to make their teeth missing, abuse children
and destroy their life when they are just children or teenagers.
14. After Susan fired Mr. Puschak in 2019, for 3 years; Susan’s health recovered back, she has
Export opinion that Susan Cheung’s teeth only require regular cleaning, it is within limit without
gum problem nor disease.
15. On April 28th 2016 and Jan 17th 2017, Thomas Puschak worked on Susan Cheung’s teeth,
Thomas Puschak worked on Susan’s teeth, fill cavities and deep cleaning, do a cap. During the
anesthesia. He took advantage of putting his hands into Susan’s cloths, improperly brush my
neck, back, front, breasts and my body, told Susan relax, sexual assaulted Susan. Thomas
Puschak later shifted his abusive and sexual assault to my son, who was a minor (15 years old) at
the time.16. Mr. Puschak ordered Susan to do deep cleaning as other dentists said that Susan’s teeth
condition does not need deep cleaning, Susan does not have gum disease. The reason that Mr.
Puschak did this is because He wanted to sexual harass and insult Susan, at the same time, abuse
my son, to remove his teeth illegally for money!!!
17. Mr. Puschak also asked his wife Carol to text Susan multiple times before each visit, they
loved Susan to go there frequently, so that they can harass and insult Susan; also Mr. Puschak
loves to abuse my son physically and mentally, sexual harass Christopher when he was minor.
18. Every time, Susan came to Mr. Puschak’s office to do dental work, Mr. Puschak seemed
already ready and waited there, Always When Susan just came in. Mr. Puschak would be chasing
and Stalking, inappropriate touching Susan, and asking Susan for money, He also threatens me
that He knew everything of me, Mrs. Puschak told me that they have guns in their office, and
that I must pay him money right away. Sometimes, the way that His gesture to talk to me was
also very insulting. He always lowers down his back, and use his ass to face me, and talk about
"the dental procedure, dental needs and money I owed him". And something like” Your son
should come to see me every week”. And He also turn his tone in the mouth, and use his hands
wrap in front his face, everything that Susan talked to Mr. Puschak about the treatment of
Christopher’s teeth, He said that all the teeth were rotten, and laugh at me, this made me very
uncomfortable and confused!!!
19. | am afraid the force and He attracted my son to only see him for dental work, I am afraid
that He would hurt my son if I did not pay him money immediately, not listen to him.
Mr. Puschak harassed and assaulted me multiple times. ( Note: I is Susan Cheung )
COUNT III
(Child Pedophiles, Abuse and Damage Christopher Cheung’s life)
20. Christopher went to see Mr. Puschak for dental care from April 28" 2016 to Oct
.27 2020. Mr. Puschak knew that Chrsitopher lost his dad when He was 13 years
old. Mr. Puschak pretended to be very nice to Christopher, and very concerned
about Christopher without Dad situation, but Mr. Puschak settled down
Christopher with a Child is a child abuser, molester and sex offender. Mr. Puschak
showed unusual interest and skills to children. Mr. Puschak’s father was a
pediatrician, so Mr. Puschak had plenty of experience to dela with under age
children to hurt their life.
Mr. Puschak noticed the cavity of Christopher’s tooth 3, He never mentioned to
Christopher’s Mom, and He already decided to do negligent to make Christopher’s
tooth 3 missing, He already planned to destroy Christopher’s heath, making
advantage of minors.
21. He made use of the opportunity to abuse Christopher, instructed wrong way
by his wife carol (She is not licensed with anything) to make Christopher’s gumbleeding, Mr. Puschak does not have dental practice standard, Puschak told me” As
long as you brushed your teeth, your gum is bleeding, that is the right way to
keep your oral hygiene good, satisfy his expectation!” He and his wife run his
dirty dental clinic, they discriminated and abused Christopher, sexual harassed
Christopher in his dental practice. Then they cheated to Susan and told her
differently.
22. Puschak criticizes Christopher’s oral hygiene as Mr. Puschak knew that
Christopher lost his dad and Mr. Puschak can cheat on Christopher and Susan. Mr.
Puschak planned and was intending to do Root Canal for every tooth of
Christopher, then not install permanent crowns, waited until they were missing,
Puschak’s logic and plan is as long as he made notes about, Christopher did not
brush teeth, that would cause teeth cavity, every time Christopher visited Mr.
Puschak, Mr. Puschak acted as He had fished a big fish for money (AS Chris was a
minor), He spent 3, 4+ hours, root canal and root canal again, He improperly
touched me and abused me. Mr. Puschak was proudly to say that They liked” his
skills”, it meant that Puschak did not do anything wrong, out of standard care.
He can extract it later and implant for money! Puschak is very good at abusing
and sexual assault, harassing children under age, like me when I was 15 years
old!!! Especially we have delta dental PPO benefit, I personally had become a fat
and vulnerable target for Puschaks to prey and abuse.
23. When Puschak did the root canal, Puschak did anesthesia and put rubber dam
on me, He started his hand to go underneath my cloths, to touch me improperly,
and groped me at some point when only he was with me.
At the beginning, when He did root canal on Christopher’s tooth 19, Susan
spotted Mr. Puschak groped Christopher (like intentionally when he did x ray on
Christopher etc.), and Later Mr. and Mrs. Puschak strictly refused Susan to go to
closing to the Christopher’s dental chair, they restricted Susan to wait at the front
desk, or tell her that they did not allow her to stay at their dental office.
This cause serious damage to Christopher’s life, it made him depressed, and
had problems to social friends and studied in school.
24, Mr. Puschak never did impression after each root canal, He never ordered a
permanent crown, so He was never intended to fix the cavity, he is intended to use
root canal as a powerful tool to make all my teeth missing, the tooth after root
canal is very fragile without nerves, it needs to be installed permanent crown as
soon as possible, Another way is playing negligent, like he found that my tooth 3
has cavity in 2016, He just ignored it until it became missing, then Puschak in histreatment plan to write that it needs to be extracted and implanted for big money
for him! Puschak is malpractice and abusive, sex offender to children!
25, Christopher went here and got severe damaged in life was proven that
Puschak was eager to do root canal for every tooth of mine, but not do impression,
install permanent crowns afterwards for all my teeth: All the dentists do root canal
once thoroughly, otherwise the nerve still there, Patients would not able to eat or
sleep, but Puschak did my root canal teeth multiple times for temporary crown!;
He made me expose to X ray radiation, He used rubber dam to make me chock, not
breath without my mother’s knowledge and consent when I was 15 years old and
later on. He touched my body improperly, sexual harassed and assaulted me. He
contacted me, recorded my phones number without My mom and my consent He
asked his no licensed wife to show how to brush teeth to me all the time, Puschak
never showed me nor did to me by himself! then He tried to make my gum
bleeding and sexual harassed me and abused me!
(Note: I is Christopher)
COUNT IV
(Fraud Claim to Insurance company, disturb our Insurance, Collect Fraud money and refuse to
correct to Delta Dental Insurance Company. Also Cheated on Health Advocate)
26 Mr. Puschak and Mrs. Puschak filed 3+ time to Delta Dental to claim fraud money by
exchanging the invalid code for Root Canal procedures for both tooth 10 and tooth 7, He never
did the impression, nor ordered permanent crown, Mr. Puscak was intended to make
Christopher’s tooth missing (Chris was a minor at all the time when Mr. Puschak did it! , Mr.
Puschak did this fraud skim in almost every work to Christopher at the time He was a minor)
27. As Mr. Puschak did the root canal only to Christopher’s tooth 7 on Feb 1% 2018, Mr. and
Mrs. Puschak filed multiple claims for Root canal for tooth 7, after they collected root canal
money, and then their fake code got declined by Delta Dental, they filed another fraud claim on
Oct 19" 2018, claimed the Mr. Puschak did Tanium and Tanium alloyed crown on Feb 1* 2018
for Christopher’s tooth 7, and collected both fraud money from Delta Dental and patient.
28. As Mr. Puschak was informed his fraud claim, Delta Dental requested him to use ADA form
to correct the fraud claim, and return fraud money to Delta Dental, Mr. Puschak refused violently
to attack Susan by filing harassment prevention order in Concord district court.; and disturbed
our Delta Dental PPO high end insurance.29. WHEREFORE, the plaintiff requests that the Court order the defendant to use “ADA” form
to correct his fraud claim EOB# 201830280524000 and resubmit to Delta Dental to refund the
fraud money to all the parties.
COUNT V
(Intend to Direct Wrong Way to Use Fluoride toothpaste, Poison Christopher)
30. During the time Christopher saw Thomas Puschak, from 04/28/2016 to 10/25/2019;
3 years, Puschak sold Christopher 14 Sodium Fluoride 1.1% toothpaste, and charged
$15 each time, Puschak told Christopher and emphasized to only use his fluoride 1.1%
toothpaste exclusively, do not use any other toothpastes, but use it not following the
direction on the label instruction on the toothpaste box, use 10,20 times more than the
label instructed, and leave the toothpaste on teeth, not rinse. Doctor ChuanJun Wu, as
well as Children’s poison control hotline also told Susan that it is very dangerous if you
do not follow the directions on the label of the toothpaste box and can get poisoned!
Especially for children it is restricted. As we all know Fluorite is a poison element, it can
cause bone cancer and cancers, and heart diseases! a little amount into the body could
cause serious health concerns and problems for a long lifetime! Thinking about the time
when | was 15 years old only, it was a poisonous control issue! This is especially true to
children (Poison control problems); The time Thomas Puschak instructed me to leave
fluoride on my teeth just contradict with poison control guidelines for children. Puschak
never told me about the health issue even when | was 15 years old, irresponsible and
negligent,
When | just turned 13 years old, | lost my dad, He suddenly left us with heart attack,
when | first saw Thomas Puschak on April 28" 2016, He asked, so | told him about my
dad. Thomas Puschak thought that this was a wonderful opportunity for hurting me, so
that He intended to make my teeth missing, even when the temporary crown on my
tooth 19 fell, | went to see him on Oct 27" 2020, He wrote the prescription and was
going to extract Christopher's teeth, and implanting them with big 5 digits money!
Thomas Puschak is a Malpractice Dentist, as well as a fraud criminal!
JURY DEMAND 4 gl bo -1 To
The plaintiff hereby claims trial by jury on all matters so triable.
Plaintiff, Ko awchy
Susan Cheung,
Christopher Cheung, was Minor when
he was Mr. Puschak’s patient,VERIFICATION
I, Susan Cheung, do hereby declare that I have read the foregoing Verified Complaint
and know the contents thereof. I declare under penalty of perjury that the foregoing is true
and correct, that no material facts have been omitted therefrom, that this declaration was
executed on this Satay of December in Middlesex County, Massachusetts.
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COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, ss. SUPERIOR COURT CIVIL ACTION NO. \ S43 4 SUSAN CHEUNG, AND CHRISTOPHER CHEUNG A MINOR WHEN WAS THOMAS B PUCHAK’S PATIENT Plaintiff, DLERK OURTS _ one uoul YY GF MIDDLESEX DEC 80 2022 THOMAS B PUSCHAK DENTIST AND OWNER OF FAMILY DENTISTTRY LEXINGTON MA CAROL PUSCHAK WIFE OF THOMAS PUSCHAK & OFFICE MANAGER OF FAMILY DENTISTTRY LEXINGTON MA Defendant. Vee esr ww SSS SS een VERIFIED COMPLAINT DEMAND DAMAGE COMPENSATION FROM THOMAS AND CAROL PUACHAK FOR $250,000 AND JURY DEMAND 1. The plaintiff, Susan Cheung (“Susan”), is a natural person residing in Bedford, Middlesex County, Massachusetts, She was seen Mr. Puschak for Dental care from Sep 2014 to Dec 2019 and is the mother of Christopher Cheung, a minor. 2. The plaintiff Christopher Cheung is the only son of Susan Cheung, and resides with Susan in Bedford, Middlesex County, Massachusetts. He was a minor(15 years old) started to see Mr. Puschak for dental care until 2020 3. The defendant, Thomas B Puschak is an individual dentist and owner of Family Dentistry(Suite14.175 Bedford Street, Lexington MA 02420), Mr Puschak residing in 15 Saddle Club Road, Lexington MA 024204. The defendant, Carol Puschak is an individual, wife of Thomas Puschak and office manager of Family Dentistry (Suitel4.175 Bedford Street, Lexington MA 02420), residing in 15 Saddle Club Road, Lexington MA 02420 COUNT I (Mal Practice to Christopher Cheung, abuse him and made his teeth missing; a Minor at the time) 5. Christopher saw Mr. Puschak for dental care between April 28" to Oct 27" 2020 6. Mr. Puschak performed Root Canal on Christopher’s lower left first molar tooth 19 on April 28" 2016 when Christopher was minor, 15 years old, Then He did “Post and core” on May 2016, told us that He finished tooth 19 with permanent crown; Chris was done and all set for his tooth 19 on May 27" 2016. As Mr. Puschak said the same way on May 27" 2016. 7. Mr. and Mrs. Puschak lied to Susan and Christopher, On May 17" 2016, after Mr. Puschak spent 3+ hours on Christopher’s tooth 19, He told us that He did permanent crown, it was all set for the tooth 19. But He filed the claim to Delta Dental for Post and Core, which claimed the money for the permanent crown, It is a fraud money Mr. and Mrs. Puschak collected from Delta Dental. 8. On Oct 27th Oct 2020, Chris had issues with the tooth 19 which Mr. Puschak finished four and half years ago; Mr. Puschak told Chris that tooth 19 was missing as He put temporary crown only at the time. He allegedly intended to extract the root of tooth 19 and wrote his procedure treatment menu telling Chris to replace his tooth (All teeth) with implanting without Mom Susan present and no knowledge, On Oct 27" 2020, Mr. Puschak also at the 1 time told Susan that He only did temporary crown on tooth 19 and the crown fell off, the tooth was missing. And Demand $10000+ money for implanting procedure from Susan and Delta Dental (Christopher’s insurance company) 9. Mr. Puschak did the same procedure to Christopher’s tooth 10 on Aug 17" 2017 (Chris was minor) for root canal only, and He finished with “Post and Core” Oct 3 2017 with a “temporary crown”, Mr. Puschak did not do impression and did not plan to install permanent crown, This time He was not interested in claim fraud money for Post and core, He demanded Patient to pay him “the temporary crown for $541” . and the Insurance company would not pay his temporary crown $541. So the Patient must pay him. When Susan asked him to install the permanent crown for tooth 10 soon;He told the patient that it was too “expensive” to install permanent crown. 10. Mr. Puschak did the same procedure to Chrsitopher’s tooth 7 on Feb 1% 2018(Chris was minor) for root canal only, and He finished with “Post and Core” Oct 3 2018 with a temporary crown, Mr. Puschak did not do impression and did not plan to install permanent crown, this time He was not interested in claim fraud money for Post and core, He demanded Patient to pay him the temporary crown for $541. When Susan asked him to install the permanent crown for tooth 7 soon; He told the patient that it was too “expensive” to install permanent crown. He madeinsulting gesture and body language, and moved his mouth with hands wrapped around, told Sudan Cheung that all Christopher’s teeth were rotten, cannot be saved! 11 After Feb 1 2018 tooth 7 root canal; Feb 23"! 2016; Christopher came in to finish up tooth 7, Mr. Puschak was looking for other root canal opportunities to ruin Christopher’s teeth, to dig out “implanting opportunities”, Without patients and patient’s parents knowledge, He left the tooth 7 with all nerves pulled out and “ temporary crown” and searching to do some unknown work in other teeth without any patients’ knowledge and instruction, Mr. Puschak was performing nonstandard dental work to purposely to make Christopher’s teeth missing( A minor at the time) and destroy Christopher’s health.(Body and Mental) 12. Mr. Puschak first noticed Chris’s tooth 3 cavity on April 28" 2016, He never mentioned to the patient and the patient’s parents; his negligent work to Christopher’s tooth 3 at the beginning directly led his tooth 3 missing! now Mr. Puschak made Christopher’s tooth 3 missing as well! He planned to extract the tooth 3 for bigger money. (His treatment note) COUNT II (Malpractice and Sexual Assault to Susan Cheung) 12. Without considering the health situation of Susan Cheung, Mr. Puschak performed low quality “deep cleaning”, caused patient’s effecting and bleeding gum on health. “If your gums or an area of gum feels painful, tender, swollen, or you notice a strange taste, plus or blood in your mouth, it increased my blood pressure, cholesterol and sugar level. Mr. and Mrs. Puschak do this for money. Mrs. Puschak disturbed Susan Cheung in every occasion with deep cleaning text reminder. 13. Dental care is out of standard care, Mr. and Mrs. Puschak cheated on money illegally from both Delta Dental and Patients and used the way lure Susan bring her son there. Mr. Puschak knew children’s psychology, as Mr. Puschak’s father was pediatrician. so, he was taking advantage of Christopher as Christopher was a minor and just lost his father with sudden heart attack. Mr. Puschak knew how to cheat on children to make their teeth missing, abuse children and destroy their life when they are just children or teenagers. 14. After Susan fired Mr. Puschak in 2019, for 3 years; Susan’s health recovered back, she has Export opinion that Susan Cheung’s teeth only require regular cleaning, it is within limit without gum problem nor disease. 15. On April 28th 2016 and Jan 17th 2017, Thomas Puschak worked on Susan Cheung’s teeth, Thomas Puschak worked on Susan’s teeth, fill cavities and deep cleaning, do a cap. During the anesthesia. He took advantage of putting his hands into Susan’s cloths, improperly brush my neck, back, front, breasts and my body, told Susan relax, sexual assaulted Susan. Thomas Puschak later shifted his abusive and sexual assault to my son, who was a minor (15 years old) at the time.16. Mr. Puschak ordered Susan to do deep cleaning as other dentists said that Susan’s teeth condition does not need deep cleaning, Susan does not have gum disease. The reason that Mr. Puschak did this is because He wanted to sexual harass and insult Susan, at the same time, abuse my son, to remove his teeth illegally for money!!! 17. Mr. Puschak also asked his wife Carol to text Susan multiple times before each visit, they loved Susan to go there frequently, so that they can harass and insult Susan; also Mr. Puschak loves to abuse my son physically and mentally, sexual harass Christopher when he was minor. 18. Every time, Susan came to Mr. Puschak’s office to do dental work, Mr. Puschak seemed already ready and waited there, Always When Susan just came in. Mr. Puschak would be chasing and Stalking, inappropriate touching Susan, and asking Susan for money, He also threatens me that He knew everything of me, Mrs. Puschak told me that they have guns in their office, and that I must pay him money right away. Sometimes, the way that His gesture to talk to me was also very insulting. He always lowers down his back, and use his ass to face me, and talk about "the dental procedure, dental needs and money I owed him". And something like” Your son should come to see me every week”. And He also turn his tone in the mouth, and use his hands wrap in front his face, everything that Susan talked to Mr. Puschak about the treatment of Christopher’s teeth, He said that all the teeth were rotten, and laugh at me, this made me very uncomfortable and confused!!! 19. | am afraid the force and He attracted my son to only see him for dental work, I am afraid that He would hurt my son if I did not pay him money immediately, not listen to him. Mr. Puschak harassed and assaulted me multiple times. ( Note: I is Susan Cheung ) COUNT III (Child Pedophiles, Abuse and Damage Christopher Cheung’s life) 20. Christopher went to see Mr. Puschak for dental care from April 28" 2016 to Oct .27 2020. Mr. Puschak knew that Chrsitopher lost his dad when He was 13 years old. Mr. Puschak pretended to be very nice to Christopher, and very concerned about Christopher without Dad situation, but Mr. Puschak settled down Christopher with a Child is a child abuser, molester and sex offender. Mr. Puschak showed unusual interest and skills to children. Mr. Puschak’s father was a pediatrician, so Mr. Puschak had plenty of experience to dela with under age children to hurt their life. Mr. Puschak noticed the cavity of Christopher’s tooth 3, He never mentioned to Christopher’s Mom, and He already decided to do negligent to make Christopher’s tooth 3 missing, He already planned to destroy Christopher’s heath, making advantage of minors. 21. He made use of the opportunity to abuse Christopher, instructed wrong way by his wife carol (She is not licensed with anything) to make Christopher’s gumbleeding, Mr. Puschak does not have dental practice standard, Puschak told me” As long as you brushed your teeth, your gum is bleeding, that is the right way to keep your oral hygiene good, satisfy his expectation!” He and his wife run his dirty dental clinic, they discriminated and abused Christopher, sexual harassed Christopher in his dental practice. Then they cheated to Susan and told her differently. 22. Puschak criticizes Christopher’s oral hygiene as Mr. Puschak knew that Christopher lost his dad and Mr. Puschak can cheat on Christopher and Susan. Mr. Puschak planned and was intending to do Root Canal for every tooth of Christopher, then not install permanent crowns, waited until they were missing, Puschak’s logic and plan is as long as he made notes about, Christopher did not brush teeth, that would cause teeth cavity, every time Christopher visited Mr. Puschak, Mr. Puschak acted as He had fished a big fish for money (AS Chris was a minor), He spent 3, 4+ hours, root canal and root canal again, He improperly touched me and abused me. Mr. Puschak was proudly to say that They liked” his skills”, it meant that Puschak did not do anything wrong, out of standard care. He can extract it later and implant for money! Puschak is very good at abusing and sexual assault, harassing children under age, like me when I was 15 years old!!! Especially we have delta dental PPO benefit, I personally had become a fat and vulnerable target for Puschaks to prey and abuse. 23. When Puschak did the root canal, Puschak did anesthesia and put rubber dam on me, He started his hand to go underneath my cloths, to touch me improperly, and groped me at some point when only he was with me. At the beginning, when He did root canal on Christopher’s tooth 19, Susan spotted Mr. Puschak groped Christopher (like intentionally when he did x ray on Christopher etc.), and Later Mr. and Mrs. Puschak strictly refused Susan to go to closing to the Christopher’s dental chair, they restricted Susan to wait at the front desk, or tell her that they did not allow her to stay at their dental office. This cause serious damage to Christopher’s life, it made him depressed, and had problems to social friends and studied in school. 24, Mr. Puschak never did impression after each root canal, He never ordered a permanent crown, so He was never intended to fix the cavity, he is intended to use root canal as a powerful tool to make all my teeth missing, the tooth after root canal is very fragile without nerves, it needs to be installed permanent crown as soon as possible, Another way is playing negligent, like he found that my tooth 3 has cavity in 2016, He just ignored it until it became missing, then Puschak in histreatment plan to write that it needs to be extracted and implanted for big money for him! Puschak is malpractice and abusive, sex offender to children! 25, Christopher went here and got severe damaged in life was proven that Puschak was eager to do root canal for every tooth of mine, but not do impression, install permanent crowns afterwards for all my teeth: All the dentists do root canal once thoroughly, otherwise the nerve still there, Patients would not able to eat or sleep, but Puschak did my root canal teeth multiple times for temporary crown!; He made me expose to X ray radiation, He used rubber dam to make me chock, not breath without my mother’s knowledge and consent when I was 15 years old and later on. He touched my body improperly, sexual harassed and assaulted me. He contacted me, recorded my phones number without My mom and my consent He asked his no licensed wife to show how to brush teeth to me all the time, Puschak never showed me nor did to me by himself! then He tried to make my gum bleeding and sexual harassed me and abused me! (Note: I is Christopher) COUNT IV (Fraud Claim to Insurance company, disturb our Insurance, Collect Fraud money and refuse to correct to Delta Dental Insurance Company. Also Cheated on Health Advocate) 26 Mr. Puschak and Mrs. Puschak filed 3+ time to Delta Dental to claim fraud money by exchanging the invalid code for Root Canal procedures for both tooth 10 and tooth 7, He never did the impression, nor ordered permanent crown, Mr. Puscak was intended to make Christopher’s tooth missing (Chris was a minor at all the time when Mr. Puschak did it! , Mr. Puschak did this fraud skim in almost every work to Christopher at the time He was a minor) 27. As Mr. Puschak did the root canal only to Christopher’s tooth 7 on Feb 1% 2018, Mr. and Mrs. Puschak filed multiple claims for Root canal for tooth 7, after they collected root canal money, and then their fake code got declined by Delta Dental, they filed another fraud claim on Oct 19" 2018, claimed the Mr. Puschak did Tanium and Tanium alloyed crown on Feb 1* 2018 for Christopher’s tooth 7, and collected both fraud money from Delta Dental and patient. 28. As Mr. Puschak was informed his fraud claim, Delta Dental requested him to use ADA form to correct the fraud claim, and return fraud money to Delta Dental, Mr. Puschak refused violently to attack Susan by filing harassment prevention order in Concord district court.; and disturbed our Delta Dental PPO high end insurance.29. WHEREFORE, the plaintiff requests that the Court order the defendant to use “ADA” form to correct his fraud claim EOB# 201830280524000 and resubmit to Delta Dental to refund the fraud money to all the parties. COUNT V (Intend to Direct Wrong Way to Use Fluoride toothpaste, Poison Christopher) 30. During the time Christopher saw Thomas Puschak, from 04/28/2016 to 10/25/2019; 3 years, Puschak sold Christopher 14 Sodium Fluoride 1.1% toothpaste, and charged $15 each time, Puschak told Christopher and emphasized to only use his fluoride 1.1% toothpaste exclusively, do not use any other toothpastes, but use it not following the direction on the label instruction on the toothpaste box, use 10,20 times more than the label instructed, and leave the toothpaste on teeth, not rinse. Doctor ChuanJun Wu, as well as Children’s poison control hotline also told Susan that it is very dangerous if you do not follow the directions on the label of the toothpaste box and can get poisoned! Especially for children it is restricted. As we all know Fluorite is a poison element, it can cause bone cancer and cancers, and heart diseases! a little amount into the body could cause serious health concerns and problems for a long lifetime! Thinking about the time when | was 15 years old only, it was a poisonous control issue! This is especially true to children (Poison control problems); The time Thomas Puschak instructed me to leave fluoride on my teeth just contradict with poison control guidelines for children. Puschak never told me about the health issue even when | was 15 years old, irresponsible and negligent, When | just turned 13 years old, | lost my dad, He suddenly left us with heart attack, when | first saw Thomas Puschak on April 28" 2016, He asked, so | told him about my dad. Thomas Puschak thought that this was a wonderful opportunity for hurting me, so that He intended to make my teeth missing, even when the temporary crown on my tooth 19 fell, | went to see him on Oct 27" 2020, He wrote the prescription and was going to extract Christopher's teeth, and implanting them with big 5 digits money! Thomas Puschak is a Malpractice Dentist, as well as a fraud criminal! JURY DEMAND 4 gl bo -1 To The plaintiff hereby claims trial by jury on all matters so triable. Plaintiff, Ko awchy Susan Cheung, Christopher Cheung, was Minor when he was Mr. Puschak’s patient,VERIFICATION I, Susan Cheung, do hereby declare that I have read the foregoing Verified Complaint and know the contents thereof. I declare under penalty of perjury that the foregoing is true and correct, that no material facts have been omitted therefrom, that this declaration was executed on this Satay of December in Middlesex County, Massachusetts.