The ArchAngel Michael

ArchAngel Michael Division Litigation

The historic teaching on the nature of the ArchAngel Michael moves the Institute to focus upon defending those advancing the Culture of Life while opposing those advancing the Culture of Death.
Many litigation projects have been undertaken through the Institute, most famously the Supreme Court case spilling out of former Attorney General Phill Klines legal pursuant of the late, late term abortionist George Tiller for performing illegal abortions. Here is a post on that project and Tillers demise and a tie to the Obama administration.
We also had to threaten litigation against the IRS to launch the Institute they told us were were too hard on the policies of the newly-elected President back in 2008, and thus too biased to be granted 501 C3 status. We let them know we were willing to test that theory of the constitution in federal court and they holstered their proverbial pistols. We are currently fully approved as a 501 C 3 nonprofit. Here is our letter back to the IRS. Here is our post calling the IRS out. Here is a post on that victory.
We also advised Kansans for Life (the state NRTL affiliate over Kansas) during the turbulent period that began with the 2006 attorney general election and ended when when Kathleen Sebelius hand-picked abortion industry tool Attorney General Steve Six was defeated 2010. (Attorney Six is now up for appointment to the federal bench by the Obama Administration and KFL is leading the charge against that. Six is a study in how the Left rewards those who do their bidding Brown a study on just the opposite phenomena on the Right.)
Those were a few of our smaller litigation projects. Here are the three really big shows that have defined much of the ArchAngel Institute since its birth in May, 2007:

DEFINING LITIGATION PROJECT #1: A victory 18 years in the making

In 1991 the federal court in the Northern District of Indiana, through the Honorable William C. Lee, issued an injunction and ancillary orders against Bryan J. Brown (and two others), restraining them from again engaging in civil disobedience toward the goal of ending child killing at 827 Webster Street (Indianas most notorious abortuary). In 2007 , John Brown (Bryans father) bought that same location to establish the ArchAngel Institute in the very Webster Street location used to kill local children from 1978 2006. Given that George Klopfer and Susan Hill were no longer killing children at 827 Webster Street, the injunction had become unworkable. It was scrapped, along with the abortionists abandoned claims to attorneys fees for the original action, by order of the Honorable William C. Lee on August 6, 2009 18 years after the 1991 life-changing order. Here is a post on that victory.

DEFINING LITIGATION PROJECT #2: Not in this bar, you dont!

Bryan J. Browns 2007-filed motion to join the Indiana bar ended with what seemed to be a NEVER! in 2010. Brown is the Executive Director of the ArchAngel Institute. Brown has been an attorney licensed in Kansas in 1996 (even serving that state as the Deputy Attorney General over Consumer Protection and Antitrust litigation) between 2003 2007). Brown is admitted to the Seventh Circuit Court of Appeals (since 1999), admitted to the United States Supreme Court (since 2001), and cleared as to moral character and fitness to practice law by the National Board of Law Examiners in 2005 (to which about all states defer but not Indiana , at least not as to Brown). Missouri, after an extensive background check and four hour hearing, cleared Bryan as to good moral character and fitness in 2006. Bryan has practiced law across the nation, arguing before half the federal appellate courts and even winning a very controversial case before then-Judge (now Justice) Samuel Alito. (Indeed, Brown may now be paying for that sin against postmodernity as well as such sins as working for the AFAs Don Wildmon as a constitional litigator and being on Attorney General Phill Klines management team and being a rescue leader in Indiana and Kansas twenty years ago.) Yet the Supreme Court of Indiana refused to license Bryan, citing no statutes, no case law, no law at all but denying him good moral character and fitness status based upon his religious beliefs and propensity to act in conformity with the same. Bryan appealed that case to the United States Supreme Court who failed to grant him a hearing on the denial. Note in the federal courts recitation of facts (below) that Bryan has been banished for five years when the statute allows only two. Bryan has documented and is documenting still political correctness on steriods through his interactions with the bureaucrats at the Indiana Board of Law Examiners and Judges and Lawyers Assistance Program. Here is one of many posts on this miscarriage of justice. Here is the link to the verified complaint (affidavit) filed on December 8:

  • http://www.scribd.com/doc/23961843/Brown-v-Bowman-complaint-12-09

Here is the category gathering all posts on Brown v. Board of Law Examiners.

DEFINING LITIGATION PROJECT #3: Standing up for the Civil Rights of all right wing nutjobs everywhere

Three, because the bureaucrats of the Indiana Judges and Lawyers Assistance Program and their mental health hatchetmen violated Bryans constitutional, civil and property rights repeatedly while processing him in a neo-marxist (i.e. politically correct) fashion, Bryan filed a civil rights lawsuit against them in federal court on December 8, 2009. After more than 16 months during which time a file exceeding 1000 pages of facs and legal briefing was generated the federal court finally ruled on March 31, 2011. In that ruling the court dismissed Bryans civil rights lawsuit for failure to state a clam that the federal court could remedy. Here is a post on why this lawsuit was filed (the public interest ramifications). Here is a post on the misuse of programs such as JLAP to persecute religious persons that the state dislikes (i.e, right wing nutjobs). Here is a post on what Brown did wrong (gasp). Here is the category gathering all posts on Bryan J. Brown v. Elizabeth S. Bowman, M.D, Dr. Stephen G. Ross, social worker Tim Sudrovech, and government attorney Terry Harrell (all associated with the Judges and Lawyers Assistance Program).

ONWARD CHRISTIAN SOLDIER marching into uncertainty on almost every front

On July 18, 2011, Bryan filed his appellate brief with the Seventh Circuit Court of Appeals. The Defendants must file their brief within 30 days. Find below the federal courts factual recitation followed by additional facts placed before the Seventh Circuit in Bryans brief. What follows tells most all of the story of legal projects two and three. First through a selection from the Honorable Theresa Springmans March 31, 2011 order that sent the case up to the Seventh Circuit Court of Appeals. Second, by presentation of Browns factual recital from his July 18-filed brief. (Note the theme of unconstitutional processing and anti-Christian bias.)

FROM BROWNs APPELLATE BRIEF:

Appellant adopts in whole the District Court’s Procedural Background and further tenders the following of which this Honorable Court can take judicial notice:

  • 1. Defendant Elizabeth Bowman filed an amended answer to the complaint on February 3, 2010 (ECF 32), two weeks before she filed her February 24, 2009-dated motion to dismiss (ECF 42).
  • 2. No other Defendants filed answers to the verified complaint.
  • 3. Plaintiff claimed (in a short and plain statement) to bring the instant litigation against Defendants Sudrovech and Harrell in both their individual and official capacities. See, i.e. Complaint (ECF No. 1) at style and parties, ¶¶ 12, 13.
  • 4. Plaintiff filed an affidavit placing the reports of Defendants Sudrovech, Bowman and Ross as well as Dr. William Alexy into the record via ECF 57 and ECF 57-1. That affidavit contains much detail supporting the witness immunity argument. See Appendix B of ECF 57, pp 37 – 40.
  • 5. On May 19, 2011 Appellant filed a timely notice of appeal from the District Court order of April 20, 2011. This appeal places only a subset of the pled claims and only a subset of the named Defendants on this Honorable Court’s docket. ECF 66.
  • 6. Defendants Ross and Bowman filed a motion for an appellate bond on June 1, 2011. ECF 70 & 71. Appellant filed a response brief. ECF 72. Appellees filed a reply brief. ECF No. 74 The District Court ruled the motion moot by action of the Appellant. ECF 76
  • 7. Plaintiff was placed upon the role of the Kansas Supreme Court in 1996 and has enjoyed good standing in that bar since. Plaintiff was admitted to the bar of this Honorable Court in 1999 and admitted to the bar of the United States Supreme Court in 2001, having never been disciplined by any bar.
  • 8. Plaintiff was certified as to good moral character and fitness to practice law by the National Conference of Bar Examiners in 2007. ECF 1, ¶ 217.
  • 9. Under operation of Indiana law Plaintiff at bar is currently unable to practice law in any court located in the State of Indiana for anyone other than himself. This includes the federal courts for the Northern and Southern Districts of Indiana. Plaintiff brings the instant appeal pro se.

VII. Statement of the Facts

Appellant adopts in whole the District Court’s Factual Background, with the addition of the following:

A. The Relationship to the Bar Admission Motion

  • 10. The following is excerpted from Plaintiff’s lengthy verified complaint (ECF 1) as to the relationship of the instant litigation to In Re Applicant 24128. a. Plaintiff does not ask this Honorable Court to reverse or even review the ultimate outcome of his bid to become a licensed Indiana attorney. As precedent makes clear, that case will be heard, if at all, by the United States Supreme Court. This court simply lacks the subject matter jurisdiction to relieve the instant Plaintiff of the order that he not be admitted to the Indiana bar and not even seek admission again until 2014. [¶21]
    • b. This suit is not focused upon the inaction of the Indiana Supreme Court or the action of the Indiana Board of Law Examiners. This suit is instead focused upon the actions of the staff of the Judges and Lawyers Assistance Program and the small cadre of hand-picked providers with whom they collaborate. As such this case has applicability far beyond bar admission issues. [¶22]
    • c. The actions alleged herein and the remedies sought herein are not the type that can be brought to the United States Supreme Court in an action seeking a reversal of the Indiana Supreme Court’s denial of Plaintiff’s admission to its bar. If the claims brought herein are not heard by this Honorable Court, the claims brought herein are unlikely to be heard in any court of law. [¶23]
    • d. Plaintiff had communicated his intent to bring this litigation long before the Indiana Supreme Court issued its five sentence, law-free ruling on his 31 month application to add Indiana to the list of multiple jurisdictions that had found him of sufficient moral character and mental fitness to practice law. [¶24]
    • e. Plaintiff had intended to bring this litigation whether Indiana found him possessed of such moral character and mental fitness or not. Thus the fact that Indiana did not should not enter into the calculus of whether this case is rightly before the court. [¶25]
    • e. Plaintiff had intended to bring this litigation whether Indiana found him possessed of such moral character and mental fitness or not. Thus the fact that Indiana did not should not enter into the calculus of whether this case is rightly before the court. [¶25]
    • e. Plaintiff had intended to bring this litigation whether Indiana found him possessed of such moral character and mental fitness or not. Thus the fact that Indiana did not should not enter into the calculus of whether this case is rightly before the court. [¶25]
  • 11. Plaintiff’s prayers for relief in the instant litigation arise out of torts independent of the final order issued on November 16, 2009 disposing of his bar application motion. (In re Applicant 24128) ECF 1, Legal Claims
  • 12. Plaintiff threatened to file litigation based upon these torts more than a year prior to the issuance of the final order of In re Applicant 24128. ECF 1, ¶¶ 84, 92 – 94.

B. Collusion in High Places and Fears of Ongoing Harm

  • 13. Plaintiff alleges that Dr. Bowman, Dr. Ross, social worker Sudrovech and government attorney Harrell were involved in collusion toward the goal of violating Plaintiff’s rights under the state and federal constitutions. ECF 1, Legal Claims 4-13, 21 – 23.
  • 14. Plaintiff alleges that social worker Sudrovech engaged in the independent tort of interfering with his contract with Dr. Bowman. ECF 1, Legal Claim 20.
  • 15. Plaintiff fears that the reports of Drs. Bowman and Ross will be communicated to authorities outside of the State of Indiana, thereby negatively impacting his professional options in the future. ECF 1, ¶¶ 209 – 212
  • 16. Plaintiff fears that publishing the details of his processing through the Indiana JLAP system in book form may result in disciplinary actions against him. ECF 1, ¶¶ 213 – 216

C. The Work of the Authorities at Bar (Dr. Stephen Ross)

  • 17. Dr. Stephen Ross, psychologist (“Dr. Ross”) was retained by Plaintiff/Appellant, who paid in full for Ross’ services, on the order of Defendant Sudrovech. ECF 1, ¶¶ 33, 206
  • 18. Defendant Ross’s report was in letter form, written to Defendant Tim Sudrovech, and closed with the following pledge: “Should you [Tim Sudrovech] or Mr. Brown notice any errors in this report, please contact me. I am open to a revised version of this report. If you or Mr. Brown have any specific questions, please do not hesitate to contact me. As always, I appreciate having the opportunity to be of assistance to JLAP.” ECF 57-1, p.9
  • 19. Plaintiff/Appellate contacted Dr. Ross about his concerns as to the content of his report, and in specific:
    • a. Ross’ “nondiagnosis” that Plaintiff/Appellant’s social affect “suggests to me the possibility of a sub-clinical bipolar disorder of a hypomanic type.” (Emp. in original) ECF 57-1, p.9; ECF 1, ¶¶ 48 – 53, 80 – 82, 92 – 98; Legal Claims 8, 23.
    • b. Ross’ seizure of Brown’s handwritten work product preserving Brown’s contemporaneous concerns regarding the content of the test questions asked of him by Dr. Ross. ECF 1, ¶¶ 36 – 39, Legal Claims 11, 14.
    • c. Dr. Ross’ weighing of Brown’s weltanschauung through religious and political questioning in a government evaluation process that culminated in the following report by Ross: “It is important for me to note, however, that I am not making these statements purely based upon the fervor of Mr. Brown’s religious beliefs and convictions. “ ECF 57-1, p.9. (emp. added); ECF 1, ¶¶ ¶¶ 64 – 79, Legal Claims 12, 13; see Plaintiff’s concerns at ECF 1, ¶¶ 56-57.
    • 20. The Ross report did not contain a jurat or any other indicia of testimonial intent. ECF 57-1, pp.2 9.
    • 21. The Ross report was not submitted as evidence per any written rules of procedure. ECF 57-1, pp. 1-2; ECF 57, pp. 37 40.
    • 22. The Ross report was not subjected to cross-examination. Id.
    • 23. Dr. Ross never took to the witness stand or otherwise offered testimony at a hearing incident to In re 24128. Id.
    • 24. The Ross report was not the subject of any stipulations rendering it testimonial or evidentiary. Id.
    • 25. No change was made to the Ross report in response to Brown’s requests. The authorities at the IBLE [Indiana Board of Law Examiners] were given information by unknown persons that caused them to conclude the following: “[Brown] picked a fight early with JLAP, a coordinate agency of the Judicial Branch that the Applicant never bothered to understand (he often referenced to JLAP as if its employees worked for the Board of Law Examiners), and his attitude toward its dedicated professional employees and cooperating clinicians was often rude and curt. While these behaviors are not disqualifying, they are notable.” ECF 52-2 (September 25, 2009 Findings of Face, Conclusions of Law and Recommendations of the Indiana Board of Law Examiners, at p. 29)
    • 26. The Ross report was tendered, without notice of Appellant’s concerns, to the IBLE by Social Worker Sudrovech on June 3, 2008. ECF 57-1, pp. 1-2.
  • 23. Dr. Ross never took to the witness stand or otherwise offered testimony at a hearing incident to In re 24128. Id.
  • 24. The Ross report was not the subject of any stipulations rendering it testimonial or evidentiary. Id.
  • 25. No change was made to the Ross report in response to Brown’s requests. The authorities at the IBLE [Indiana Board of Law Examiners] were given information by unknown persons that caused them to conclude the following: “[Brown] picked a fight early with JLAP, a coordinate agency of the Judicial Branch that the Applicant never bothered to understand (he often referenced to JLAP as if its employees worked for the Board of Law Examiners), and his attitude toward its dedicated professional employees and cooperating clinicians was often rude and curt. While these behaviors are not disqualifying, they are notable.” ECF 52-2 (September 25, 2009 Findings of Face, Conclusions of Law and Recommendations of the Indiana Board of Law Examiners, at p. 29)
  • 26. The Ross report was tendered, without notice of Appellant’s concerns, to the IBLE by Social Worker Sudrovech on June 3, 2008. ECF 57-1, pp. 1-2.
  • 23. Dr. Ross never took to the witness stand or otherwise offered testimony at a hearing incident to In re 24128. Id.

D. The Work of The Authorities at Bar (Dr. Elizabeth Bowman)

  • 27. Dr. Elizabeth Bowman, psychiatrist (“Dr. Bowman”) was retained by Plaintiff/Appellant, who paid in full for Bowman’s services, on the order of Defendant Terry Harrell. ECF 1, ¶¶ 123 – 129.
  • 28. Dr. Bowman tendered a report on Brown that again weighed his ideology to opine on his worthiness as to a government license. ECF 1, ¶¶ 133 – 169.
  • 29. Brown challenged the Bowman report for, inter alia, the following reasons:
    • a. Bowman cited as evidence of mental illness Brown’s conservative ideology: “[Petitioner] showed lack of empathy for women whose pregnancies may be the result of rape or incest, for the [abortion providing] plaintiffs in the federal civil lawsuit against him who were left with their attorneys fees to pay, for this [psychiatrist] whose profession and presumed religious beliefs he repeatedly devalued” ECF 57-1, pp. 20 – 21. See also ECF 32 (Bowman answer) at ¶¶ 144, 157; ECF 1, Legal Claims 4 13
    • b. Bowman cited as evidence of mental illness Brown’s actions in conformance with his religious beliefs: “[Brown’s] conscience has been shaped by his Roman Catholic beliefs.” “[Brown’s] moral integrity has been expressed in a manner that has led to principled civil disobedience based upon his religious beliefs.” “[Brown’s] past arrests are related to his religious beliefs …” “I find his personality disorder has caused him to lose perspective on the ethics of his behaviors and to be arrested for civil disobedience [between 1988 – 1992].” ECF 57-1, pp. 23 ; ECF 1, Legal Claims 4 13
    • c. Bowman grossly misrepresented the conclusions of Dr. William Alexy as to Brown’s mental health, which Dr. Alexy found sufficient to justify licensure. See answers, infra; ECF 1, Legal Claims 16 – 19.
  • 30. No change was made to the Bowman report in response to Brown’s concerns, but rather the authorities at the IBLE were given information by Sudrovech that caused them to conclude the following: “Dr. Bowman diagnosed [Petitioner] as having a Personality Disorder NOS [Not Otherwise Specified]” and noted that this is what “led to his arrests [some eighteen years ago].” ECF 57-1, p. 13
  • 31. The Bowman report did not contain a jurat or any other indicia of testimonial intent. ECF 57-1, pp. 15 – 24.
  • 32. The Bowman report was not submitted as evidence per any written rules of procedure. ECF 57-1, pp. 13-14, ECF 57, pp. 37 40.
  • 33. The Bowman report was not subjected to cross examination. Id.
  • 34. Dr. Bowman never took to the witness stand or otherwise offered testimony at a hearing. Id.
  • 35. The Bowman report was not the subject of any stipulations rendering it testimonial or evidentiary. Id.
  • 36. The Bowman report misspelled Defendant Sudrovech’s name, grossly misrepresented the analysis of Dr. William Alexy and contained myriad additional factual errors and misstatements of the record, as well as a strong rebuke of Plaintiff for his attempts to clarify his own history. ECF 57-1, pp. 30 – 39.
  • 37. Dr. Bowman admits to including hearsay in her ostensible expert opinion report in her answer to the complaint. See ECF 32, ¶¶ 172-177.
  • 38. The Bowman report was tendered to the IBLE by Social Worker Sudrovech on January 22, 2009. ECF 57-1, pp. 13-14.

E. The Work of The Authorities at Bar (JLAP Management)

  • 39. Defendant Sudrovech “interpreted”, weighed and adopted the report of the psychiatrist Dr. Bowman in his report to the IBLE, stating “JLAP concurs with Dr. Bowman’s evaluation and diagnosis …. [noting among other items that Brown] ‘showed lack of empathy’ about issues associated with his beliefs.” ECF 57-1, p. 13.
  • 40. Defendant Sudrovech further wrote that “JLAP agrees to some degree with Dr. Bowman’s conclusion ‘that Mr. Brown’s success would be enhanced by individual psychotherapy”, as anyone who would actively involve themselves in a therapeutic process would. However JLAP questions how much Mr. Brown would value the experience of psychotherapy, how appropriately engaged in a therapeutic process would be.” ECF 57-1, p. 14 (emp.added).
  • 41. Sudrovech similarly “interpreted” the report of the psychologist Dr. Ross in his report to the IBLE. ECF 57-1, pp. 1-2.
  • 42. Neither the Sudrovech-Ross report (i.e. Sudrovech’s report attached to the Ross report and filing both with the IBLE, ECF 57-1, pp. 1-2) nor the Sudrovech-Bowman (i.e. Sudrovech’s report attached to the Bowman report and filing both with the IBLE, ECF 57-1, pp. 13-14) report contained a jurat or any other indicia of testimonial intent by Social Worker Sudrovech. See also ECF 57, pp. 37-40.
  • 43. Neither the Sudrovech-Ross report nor the Sudrovech-Bowman report were submitted as evidence per any written rules of procedure. ECF 57-1, pp. 1-2, 13-14, ECF 57, pp. 37-40.
  • 44. Neither the Sudrovech-Ross report nor the Sudrovech-Bowman report were subjected to cross examination. Id.
  • 45. Social Worker Sudrovech never took to the witness stand or otherwise offered testimony at a hearing. Id.
  • 46. Neither the Sudrovech-Ross report nor the Sudrovech-Bowman report were the subject of any stipulations rendering it testimonial or evidentiary. Id.
  • 47. According to Indiana Supreme Court Admis. Disc. R. 31, § 10, Defendants Sudrovech and Harrell are immune from civil suit for “official acts done in good faith in furtherance of the Committee’s work.”
  • 47. According to Indiana Supreme Court Admis. Disc. R. 31, § 10, Defendants Sudrovech and Harrell are immune from civil suit for “official acts done in good faith in furtherance of the Committee’s work.”
  • 48. Plaintiff alleges bad faith on the part of Defendants Harrell and Sudrovech. ¶¶ 17, 55, 103, 151, 165, 204, 207, 265.
  • 49. Plaintiff alleges both official and individual (unofficial) acts on the part of Harrell and Sudrovech. ECF 1, at ¶¶ 12 – 13.
  • 50. Plaintiff notified Defendant Harrell of his concerns regarding the unconstitutional and unprofessional manner in which she, Sudrovech and the Judges and Lawyers Assistance Program had processed the referral from the IBLE prior to the final ruling of the Indiana Court. ECF 57-1, pp. 38 – 41.
  • 51. Plaintiff notified the Hearing Panel incident to In re Applicant 24128 of his concerns to no avail, as that the Court did not deign to address any of Plaintiff’’s concerns or prayers for legal or equitable relief incident to that motion hearing. ECF 57, p. 39.

F. The Admissions of Dr. Elizabeth S. Bowman

  • 52. Admissions contained in the Amended Answer filed by Defendant Dr. Bowman:
    • a. Dr. Bowman admitted that she knew of Plaintiff’s identity as a pro-life Christian even before he initially contacted her or signed any releases allowing the government to brief her. ECF 32, ¶128
    • b. Dr. Bowman admitted that she refused to answer questions about her practice, associations and beliefs at the onset of her evaluation of Plaintiff. ECF 32, ¶136
    • c. Dr. Bowman admitted that Plaintiff informed her of his belief that constitutional law circumscribed the proper focus of government examinations. ECF 32, ¶142
    • d. Dr. Bowman admitted ordering Plaintiff to quote no such constitutional law to her. ECF 32, ¶143
    • e. Dr. Bowman admitted that Plaintiff informed her of his belief that Dr. Ross’ seizure of his work product violated Plaintiff’s civil rights. ECF 32, ¶142
    • f. Dr. Bowman admitted that Plaintiff informed her of his belief that Dr. Ross’ test questions violated Plaintiff’s civil rights. Id.
    • g. Dr. Bowman’s diagnosis of Plaintiff as one suffering from mental illness was predicated upon her conclusion that Plaintiff “expressed devaluing attitudes toward pharmacologic or psychotherapeutic mental health treatment and made sarcastic remarks devaluing authority of all types, especially mental health authority and the abortion industry.” ECF 32, ¶162
    • h. Plaintiff posted that “Dr. Bowman asserted in her final report that Dr. Alexy ‘felt Mr. Brown would benefit from individual psychotherapy with a woman therapist.’ This statement is nowhere found in Dr. Alexys report.” Dr. Bowman answered: “While the allegations in this paragraph are technically correct, Dr. Bowman did speak with Dr. Alexy [insert hearsay allegations after this point].” ECF 32, ¶174
    • i. Plaintiff posited that “Dr. Bowman asserts in her final report that ‘Dr. Alexys testing concluded that Mr. Brown likely has Personality Disorder Not Otherwise Specified.’ This statement is nowhere found in Dr. Alexys report. Dr. Alexy instead offers no diagnosis as to a mental illness or ‘personality disorder’ in his report. Dr. Alexy, like Dr. Flueckiger, found no label from the DSM IV applicable to Plaintiff.” Dr. Bowman answered “ While the first four sentences of this paragraph are technically correct, [insert hearsay allegations after this point].” ECF 32, ¶177.
    • j. Plaintiff posited that “Defendant Bowman told Plaintiff that during the [pre]-briefing Defendant Sudrovech had instructed her to not record a final conclusion as to Plaintiff’s ability to pass [Indiana Admission] Rule 12 analysis as both Dr. Ross and Dr. Flueckiger had done. Defendant Sudrovech rather ordered Defendant Bowman to leave the question open to be addressed by his final report.” Dr. Bowman answered “ It is admitted that Tim Sudrovech did request that Dr. Bowman not include in her written report a conclusion as to whether the Plaintiff should be admitted to the bar [insert hearsay allegations after this point].” ECF 32, ¶165