Lall

UMNIITDEDDL EST DAITSTERS IDCITS TORFI CFLTO CROIUDRAT

TAMPA DIVISION

RAJESH LALL, M.D.,

Plaintiff,

v. Case No. 8:26-cv-00725-WFJ-NHA

PROFESSIONALS RESOURCE

NETWORK, INC., BOARDPREP LLC,

LAKELAND REGIONAL

HEALTH SYSTEMS, INC.,

MICHAEL J. SORNA, M.D.,

DEREK ROBBEN, M.D., and

KARMON SEARS, Psy.D.,

Defendants.

___________________________________/

ORDER

This cause comes before the Court upon sua sponte review. For the reasons

set forth below, Plaintiff Rajesh Lall’s Amended Complaint, Dkt. 28, is dismissed

without prejudice as a shotgun pleading.1

BACKGROUND2

This action arises out of an employment dispute following Plaintiff’s

termination by non-party BayCare Health System and Defendant Lakeland Regional

1 The Court notes that this matter has been raised by multiple defendants in their respective motions to dismiss. See

Dkt. 50 at 13–15; Dkt. 54 at 2. However, the Court addresses this matter sua sponte; therefore, this Order does not

rule upon those motions.

2 At this stage, all facts alleged by Plaintiff are taken as true, and the Court recounts the allegations contained in

Plaintiff’s Amended Complaint. Although Plaintiff references numerous exhibits, it appears that Plaintiff has yet to

file such. See Dkt. 28 at 210–15.

Health Systems, Inc. (“LRH”).3 See Dkt. 28. Plaintiff held clinical privileges as an

interventional cardiologist at Bartow Regional Medical Center, Winter Haven

Hospital, and BayCare Medical Group, which are affiliated with BayCare Health

System, as well as LRH. Id. ¶¶ 23–32. Plaintiff’s Florida medical license

(ME107070) remains active. Id. ¶ 1.

Plaintiff asserts that between September 2023, and January 2025, he

“repeatedly raised, in writing concerns regarding patient-care safety, governance

failures, bylaws noncompliance, conflicts of interest, and Code 15 / sentinel-event

reporting at [Bartow Regional Medical Center].” Id. ¶¶ 47–48. On January 23,

2025—for reasons not directly provided by Plaintiff—BayCare “terminated

Plaintiff’s employment effective immediately[.]” Id. ¶ 52. However, Plaintiff’s

clinical privileges were not yet revoked, as the severance process was still being

sorted out. See id. ¶¶ 52, 54, 57, 58.

On January 24, 2025, BayCare Safety and Security issued a system-wide “Be

On the Lookout” alert that labeled Plaintiff an “UNAUTHORIZED PERSON” and

instructed personnel to “facilitate a Trespass Warning from the site” if Plaintiff was

observed at any BayCare hospital. Id. ¶ 53. On January 24, 2025, communications

were sent from Plaintiff’s email address4 to various BayCare administrators, id. ¶

3 Plaintiff has additionally filed a related lawsuit against BayCare Health System, Inc., among a litany of other

defendants, including some that are included in the present action. See Lall v. BayCare Health System, Inc., No. 8:26-

cv-890 (M.D. Fla.).

4 Plaintiff avers that, “[t]hroughout [his] Complaint, where any communication is attributed to Plaintiff in writing,

Plaintiff neither admits nor denies authorship. Plaintiff recounts such communications as defendants and the

55, which were later utilized to justify an “adverse action” due to these

communications being perceived as a threat. Id. ¶¶ 55, 62. On February 20, 2025, a

Notice of Complaint was referred to Bartow Regional Medical Center’s Well-Being

Committee, which described Plaintiff’s behavior as “inappropriate and/or disruptive

to hospital operations.” Id. ¶ 63. On February 21, 2025, administrators at Bartow

Regional Medical Center contacted the Bartow Police Department to express

concern about perceived threatening communications they had received from

Plaintiff. Id. ¶ 64. When the Bartow Police Department closed its investigation, it

found that Plaintiff “did not commit a crime for written threat to kill or injury” and

that “[i]t seems the messages were directed towards the BayCare legal system and

not towards an individual.” Id.

On March 2, 2025, Plaintiff was notified that Bartow Regional Medical

Center’s Well-Being Committee had concluded that he was “an impaired physician”

and imposed a precautionary suspension of his clinical privileges, which was

conditioned on an evaluation and clearance for reinstatement from Defendant

Professionals Resource Network, Inc. (“PRN”). Id. ¶ 65. PRN is a “Florida private

not-for-profit corporation that, at all times relevant, participated in physician

institutional actors characterized them, without conceding the accuracy of those characterizations. Plaintiff further

alleges that none of the institutional actors who treated such communications as a predicate for adverse action

independently verified the authorship or afforded Plaintiff an opportunity to contextualize or clarify the content.” Dkt.

1 ¶ 34(f).

evaluation, monitoring, and referral activities that interface with the Florida

Department of Health[.]” Id. ¶ 17.

Plaintiff then began the intake process with PRN, which is led by their medical

director, Defendant Dr. Michael J. Sorna. Id. ¶¶ 69–72, 76. On March 18, 2025, PRN

provided Plaintiff with a selection of evaluators to perform an independent medical

evaluation, from which Plaintiff chose Defendant Dr. Derek Robben, who is

associated with Defendant BoardPrep LLC (“BoardPrep”). Id. ¶ 74. BoardPrep is a

“Florida limited liability company that provides medical evaluation services,

including evaluations performed in connection with PRN referrals and monitoring

determinations.” Id. ¶ 18. On April 3, 2025, Plaintiff completed the independent

medical evaluation with Dr. Robben. Id. ¶¶ 80, 82–83. Plaintiff then completed

neurocognitive testing with Defendant Dr. Karmon Sears on April 19, 2025. Id. ¶¶

86–91.

Plaintiff received written reports from Drs. Robben and Sears on May 7, 2025.

Id. ¶ 108. The reports both recommended continued treatment, among other

measures, id. ¶¶ 111, 113, while Dr. Robben specifically recommended a PRN

psychiatric monitoring agreement. Id. ¶ 111. The stated bases for Dr. Robben’s

report were his diagnostic impression and “the potential for recurrence of

problematic behaviors that could compromise safety.” Id. ¶ 112. In her report, Dr.

Sears mentioned “delusions (religious, paranoid, grandiose) as noted in [Plaintiff’s]

emails but not expressed during evaluation[,]” id. ¶ 114, and that “[a]t this time,

without further observation and weekly psychotherapy sessions, I cannot say that he

would be safe to return to BayCare Medical Group for those on the MEC or the

Wellness Committee.” Id.

Seemingly dissatisfied with the results, Plaintiff requested a second-opinion

evaluation, id. ¶ 124, which was later completed by non-party Acumen Assessments.

Id. ¶¶ 128, 135. On May 14, 2025, the PRN Clinical Team reviewed the results of

Dr. Robben’s independent medical evaluation and adopted his recommendation of a

psychiatric monitoring agreement. Id. ¶ 121. A draft of this agreement was

transmitted to Plaintiff on May 31, 2025. Id. ¶ 132.

On June 30, 2025, Dr. Sorna of PRN communicated to Plaintiff that the

second-opinion evaluation of Acumen Assessments yielded diagnoses of delusional

disorder (persecutory type) and autism spectrum disorder. Id. ¶ 143. Dr. Sorna told

Plaintiff that, “[b]ased on this report, I have no choice but to remove you from

clinical practice effective immediately. We do not feel it is safe for you to practice.”

Id. ¶ 144. Plaintiff was additionally informed that if he didn’t agree to PRN’s

psychiatric monitoring agreement, that PRN would have to report Plaintiff to the

Florida Department of Health (“DOH”) for the potential suspension of Plaintiff’s

license “on the grounds of safety concern.” Id. ¶ 145.

On June 30, 2025, PRN issued a written notice to Plaintiff to inform him that

he had been “refrained from practice,” and that the “refrainment will remain in force

until lifted by PRN in writing.” Id. ¶ 146. The notice further stated that this

refrainment was being imposed as a “condition of continued impaired practitioner

program participation.” Id. ¶ 147. This notice was transmitted to LRH, who then

informed Plaintiff on July 11, 2025, that “[b]ased on this formal notice from PRN,

you are not permitted to practice at LRH at this time.” Id. ¶¶ 176–78.

At this point, Plaintiff began transmitting written communications to PRN

describing his intent to pursue legal action for: “tortious interference; defamation

and character assassination; abuse and overreach of authority under delegated

license; violation of constitutional rights under the First and Fifth Amendments; and

violation of civil rights under the Americans with Disabilities Act[.]” See id. ¶¶ 150,

151, 154; see also id. ¶ 157 (describing a letter entitled “Formal Rebuttal and FINAL

Legal Warning — PRN Overreach, Constitutional Violations, and Ethical

Misconduct”). Plaintiff specifically sent correspondence to Dr. Sorna demanding

that he “cease and desist from any further defamatory diagnosis or

mischaracterization,” among other demands. Id. ¶ 151.

On July 16, 2025, Plaintiff formally rejected PRN’s psychiatric monitoring

agreement via written communication. Id. ¶ 156. Accordingly, on August 7, 2025,

PRN issued a letter to Plaintiff stating, “[b]ecause you have declined to enter into an

impaired practitioner program contract, PRN has closed your program file and sent

it to the Florida Department of Health as required.” Id. ¶ 158. On August 11, 2025,

the DOH issued Plaintiff a Notification of Investigation. Id. ¶ 159.

On September 19, 2025, Plaintiff was arrested and charged with unidentified

felony offenses, and on October 8, 2025, was subsequently arrested and charged with

unidentified misdemeanor offenses. Id. ¶ 189. Following these arrests and charges,

on December 3, 2025, LRH sent Plaintiff a notice stating, “[p]lease consider this as

formal notice of your automatic voluntary resignation from the LRH Medical Staff,

effective immediately.” Id. This notice additionally cited “Section 11.E of the

Medical Staff Bylaws,” which maintains that “an individual’s appointment and

clinical privileges shall be automatically relinquished if the individual is arrested,

charged, or indicted for any felony[.]” Id. ¶ 212. On January 26, 2026, the Board of

Directors of LRH informed Plaintiff by letter that it had approved the automatic

voluntary resignation. Id. ¶ 193.

On March 18, 2026, Plaintiff filed his initial Complaint, initiating the present

action. See Dkt. 1. On April 10, 2026, the Probable Cause Panel of the Florida Board

of Medicine determined that no probable cause of a violation existed on PRN’s

August 7, 2025, disciplinary referral to the DOH, and on April 15, 2026, the DOH

closed the disciplinary file. Dkt. 28 ¶¶ 162, 186. On April 20, 2026, Plaintiff sent

PRN’s legal counsel a written request for PRN to withdraw the refrainment from

practice dated June 30, 2025, but PRN responded the following day that it was “not

in a position [to] withdraw” the refrainment. Id. ¶¶ 163–64.

On May 18, 2026, Plaintiff filed the operative Amended Complaint, alleging:

breach of contract against Defendant LRH (Count I); violation of the Rehabilitation

Act (discrimination on the basis of perceived disability) against Defendant LRH

(Count II); violation of the ADA (discrimination on the basis of perceived disability)

against Defendant LRH (Count III); violation of 42 U.S.C. § 1983 for deprivation of

procedural due process under the Fourteenth Amendment against Defendants PRN

and Sorna (Count IV); violation of 42 U.S.C. § 1983 for unreasonable search and

seizure under the Fourth Amendment against Defendants PRN and Dr. Sorna (Count

V); defamation under Florida law against Defendants PRN and Dr. Sorna (Count

VI); tortious interference with business relationship under Florida law against

Defendants PRN, BoardPrep, Dr. Sorna, Dr. Robben, and Dr. Sears (Count VII);

violation of RICO, 18 U.S.C. § 1962(c), against Defendants PRN and Dr. Sorna

(Count VIII); violation of RICO, 18 U.S.C. § 1962(d), against Defendants PRN,

BoardPrep, Dr. Sorna, Dr. Robben, and Dr. Sears (Count IX); civil conspiracy under

Florida law against Defendants PRN, BoardPrep, Dr. Sorna, Dr. Robben, and Dr.

Sears (Count X); and defamation under Florida law against Defendants PRN,

BoardPrep, Dr. Sorna, Dr. Robben, and Dr. Sears (Count XI). Id. ¶¶ 205–444.

DISCUSSION

Federal Rule of Civil Procedure 8 requires that a complaint include “a short

and plain statement of the claim showing that the pleader is entitled to relief,” and

that “[e]ach allegation must be simple, concise, and direct.” Fed. R. Civ. P. 8(a)(2),

(e).5 In light of Rule 8, courts in the Middle District of Florida have made it clear

that a complaint is an “improper and impermissible place for the tedious and

burdensome aggregation of prospective evidence, for the rehearsal of tendentious

arguments, or for the protracted recitation and explanation of legal authority

putatively supporting the pleader’s claim for relief.” Trump v. N.Y. Times Co., 800

F. Supp. 3d 1297, 1298 (M.D. Fla. 2025).

These well-established pleading principles are violated by “shotgun”

pleadings. Weiland v. Palm Beach Cnty. Sheriff’s Off., 792 F.3d 1313, 1320 (11th

Cir. 2015). There are four categories of shotgun pleadings:

The most common type—by a long shot—is a complaint containing

multiple counts where each count adopts the allegations of all preceding

counts, causing each successive count to carry all that came before and

the last count to be a combination of the entire complaint. The next most

common type . . . is a complaint that . . . is guilty of the venial sin of

being replete with conclusory, vague, and immaterial facts not

obviously connected to any particular cause of action. The third type of

shotgun pleading is one that commits the sin of not separating into a

different count each cause of action or claim for relief. Fourth, and

finally, there is the relatively rare sin of asserting multiple claims

against multiple defendants without specifying which of the defendants

are responsible for which acts or omissions, or which of the defendants

the claim is brought against. The unifying characteristic of all types of

shotgun pleadings is that they fail to one degree or another, and in one

way or another, to give the defendants adequate notice of the claims

against them and the grounds upon which each claim rests.

5 Although pro se litigants should be shown a certain level of leniency, see GJR Invs. v. Cnty. of Escambia, 132 F.3d

1359, 1369 (11th Cir. 1998) (citation omitted), the Eleventh Circuit recognizes that “once a pro se . . . litigant is in

court, he is subject to the relevant law and rules of court, including the Federal Rules of Civil Procedure.” Moon v.

Newsome, 863 F.2d 835, 837 (11th Cir. 1989). “There is no ‘pro se plaintiff’ standard. There is only the standard set

by the Federal Rules of Civil Procedure, which all litigants—counseled or not—must follow.” Herbozo v.

Fernandez, No. 8:26-cv-436-KKM-TGW, 2026 WL 706678, at *3 (M.D. Fla. Mar. 13, 2026).

Id. at 1321–23.

Such pleadings are “flatly forbidden by the spirit, if not the letter, of these

rules because they are calculated to confuse the ‘enemy,’ and the court, so that

theories for relief not provided by law and which can prejudice an opponent’s case,

especially before the jury, can be masked.” Barmapov v. Amuial, 986 F.3d 1321,

1324 (11th Cir. 2021) (citation modified) (quoting Weiland, 792 F.3d at 1320).

Further, shotgun pleadings “waste scarce judicial resources, inexorably broaden the

scope of discovery, wreak havoc on appellate court dockets, and undermine the

public’s respect for the courts.” Id. (quoting Vibe Micro, Inc. v. Shabanets, 878 F.3d

1291, 1295 (11th Cir. 2018)). “When presented with a shotgun complaint, the district

court should order repleading sua sponte.” Ferrell v. Durbin, 311 F. App’x 253, 259

n.8 (11th Cir. 2009) (per curiam) (citing Wagner v. First Horizon Pharm. Corp., 464

F.3d 1273, 1280 (11th Cir. 2006)). The Court does so here.

The Amended Complaint contains 444 numbered paragraphs—some split into

multiple subsections, see, e.g., Dkt. 28 ¶ 344 (including one paragraph that spans six

pages)—totaling a voluminous 221 pages. See id. Over these hundreds of pages,

Plaintiff divides his allegations into dozens of separately labeled sections and

subsections, which repeatedly cross-reference prior allegations, unattached exhibits,

and other portions of the Amended Complaint. See id. The result is a pleading so

sprawling that discerning the nature of Plaintiff’s claims and the factual allegations

underlying each requires substantial effort by the Court. See Herbozo v. Fernandez,

No. 8:26-cv-436-KKM-TGW, 2026 WL 706678, at *3 (M.D. Fla. Mar. 13, 2026)

(“Judges are not like pigs, hunting for truffles buried in briefs.” (quoting Chavez v.

Sec’y Fla. Dep’t of Corr., 647 F.3d 1057, 1061 (11th Cir. 2011)). Overall, the Court

finds this to be far from the “short and plain statement” required by Rule 8(a)(2).

As to the first category of shotgun pleading concerning the adoption of

preceding counts, Plaintiff begins each listed claim with a re-incorporation

consisting of a cluttered assembly of paragraphs and factual sections. See Dkt. 28.

For example, under Count XI for defamation, the Amended Complaint states the

following:

Plaintiff incorporates by reference, as if fully set forth herein, only the

following paragraphs of this Complaint: paragraphs 1 through 10

(Nature of Action), paragraphs 11 through 15 ( Jurisdiction and Venue),

paragraph 16 (Plaintiff), paragraph 18 (BoardPrep), paragraph 21 (Dr.

Robben), paragraph 22 (Dr. Sears), paragraph 322 (Section B of Count

VI - Elements of Defamation Under Florida Law), paragraphs 330 and

331 (Section D of Count VI - Factual Basis for Falsity and Defamatory

Implication), the sub-items of paragraph 344 labeled (h) through (k)

solely to the extent they identify the methodological defects, disregard

of exculpatory collateral records, and pathologizing of protected

professional concerns relevant to falsity, fault, and privilege defeat in

this Count XI, and the factual allegations in Section G (BoardPrep

Evaluation Process) of this Complaint.

Id. ¶ 403. Similarly convoluted re-incorporations precede each claim. See id. ¶¶ 206,

239, 262, 285, 303, 321, 340, 350, 383, 394, 403. Although Plaintiff here does not

specifically reallege “the allegations of all preceding counts”—as described in

Weiland—the Court nonetheless finds that Plaintiff’s method of re-incorporation

likewise frustrates the purpose of Rule 8, which is “to give the defendants adequate

notice of the claims against them and the grounds upon which each claim rests.”

Weiland, 792 F.3d at 1323.

Furthermore, the Amended Complaint is “guilty of the venial sin of being

replete with conclusory, vague, and immaterial facts not obviously connected to any

particular cause of action.” Id. at 1322. Included therein are exhaustive and

unnecessary details about the myriad interactions between Plaintiff and both parties

and nonparties alike. See generally Dkt. 28 ¶¶ 23–204 (covering merely the

Statement of Facts). Specifically, Plaintiff repeatedly provides in-depth details

regarding the immaterial substance of these interactions. See id. ¶¶ 71, 77, 92–107,

119, 122, 131, 141, 155, 181, 183, 195. Additionally, Plaintiff uses 46 paragraphs to

describe his employment history with the non-party BayCare and its affiliated

entities.6 See id. ¶¶ 23–68.

In light of the foregoing, the Court finds that “[e]ven under the most generous

and lenient application of Rule 8, the complaint is decidedly improper and

impermissible.” Trump, 800 F. Supp. 3d at 1298; see Whispering Pines Mobile

Homeowners’ Ass’n v. Wallach, No. 6:19-cv-487-Orl-41EJK, 2020 WL 9455604, at

*2, (M.D. Fla. Apr. 7, 2020) (“The Amended Complaint is clearly not a ‘short and

plain statement of the claim’ as it contains over seventy pages and more than two

6 These facts seem more pertinent to the aforementioned ongoing lawsuit in Lall v. BayCare Health System, Inc., No.

8:26-cv-890 (M.D. Fla.).

hundred numbered paragraphs; it is also full of long block quotes from statutes, and

long lists that fall under one paragraph number.” (citation modified)).

CONCLUSION

Accordingly, it is hereby ORDERED and ADJUDGED that:

1. Plaintiff Rajesh Lall’s Amended Complaint, Dkt. 28, is DISMISSED without

prejudice, with leave to amend within twenty-eight (28) days. Any second

amended complaint must not exceed fifty pages, excluding only the caption,

the signature, and any attachments. Failure to timely file the same will result

in dismissal of this action without further notice.

2. After review of the Amended Complaint, the Court also finds that some of the

claims may not be clearly cognizable as currently pleaded. Plaintiff Rajesh

Lall is cautioned against frivolous claims, and the Court notes that all claims

must be adequately and plausibly alleged to survive the pleadings stage.

3. Plaintiff should further ensure that this action is brought against the correct

parties. See Dkt. 54 at 2–3 (alleging that the correct party is Lakeland Regional

Medical Center, Inc., not Lakeland Regional Health Systems, Inc.).

DONE AND ORDERED at Tampa, Florida, on June 19, 2026.

/s/ William F. Jung

WILLIAM F. JUNG

UNITED STATES DISTRICT JUDGE

COPIES FURNISHED TO:

Counsel of Record