P. O. BOX 183



February 24, 2003

Honorable Jerry Kilgore,

The Attorney General,

State of Virginia, (Commonwealth of Virginia)

900 E. Main Street,

Richmond, Virginia  23219.


Re: Our representations dated January 5, 16, 2003, and first Phase along with the Documents


Honorable Kilgore,


In continuation of our representations before your august offices, we further submit the details here under for your kind information and immediate necessary action thereon.


  1. In the year 1948, Council of the City of Petersburg felt the dire necessity of establishing a public hospital to meet the health and welfare requirements of the persons of low income in the City of Petersburg and surrounding areas.   With this sole motive THE HOSPITAL AUTHORITY OF CITY OF PETERSBURG CORPORATION has come into existence through a deed dated March 22, 1950.  The documents thereof are Exhibits “A1”, “A2, & A3” of dated September 7, 1948, September 16, 1948, & March 22, 1950 respectively, enclosed herewith for kind reference.


  1. On June 17, 1999, the chairman of Southside Regional Medical Center called a meeting of the planning committee.  In this meeting the process for a review and reunion of the Facilities Master Plan were discussed.  The Métis Associates, Ltd

was selected for this hospital planning, which is Exhibit “A4” herein .  Memorandum of Dr. Kenton, Vice-President/Administration addressed to the planning committee members is Exhibit “A5”.  Southside Regional Medical Center strategic plan June 1998 is Exhibit “A6”. Plan Confidentiality on page 3 of strategic plan is Exhibit “A7” and observation on financial condition of SRMC on page 6 is Exhibit “A8”.


  1. That SRMC Hospital Authority in their deliberations vide in the minutes on August 5, 1999 vide Exhibit “A9” herein resolved review and revision of the facilities master plan which would involve three phases.  The first phase would be an evaluation of existing facilities, the second phase would be an analysis of future needs and third phase would be development of a plan and a schedule implementation.  Paragraph 5, in the said minutes is Exhibit “A10” and that the President, Mr. David S. Dunham  through sub-para in para 9 in page 8 of Exhibit “A9”, vide  Exhibit “A11” reported that Métis Associates Ltd had already begun its work on master plan though the Metis Associates, Ltd by virtue of this motion  made only on August 5, 1999, was authorized to assist in review and revision of the facilities master plan.  It is therefore surprisingly obvious that Métis Associates Ltd began working on “Facilities Master Plan” before approval by SRMC, Hospital Authority itself.  This gives an understanding that the president has given permission to Métis Associates, Ltd, prior to being approved by the Hospital Authority, which amounts to abuse of authority vested in president.


  1. We herewith submit minutes dated September 2, 1999 of SRMC, Hospital Authority for kind perusal, which is Exhibit “A12” herein. The report of the president of conducting a review of departmental activities by the consultants of Métis Associates, Ltd in paragraph 8 on page 4 of these minutes is Exhibit “A13”.  Further it will be seen at page 8 of September 2, 1999 minutes that on Facilities Master Plan vide Exhibit “A14”, in which the concern about the availability of suitable locations is being expressed that, if it would be decided that the services provided at the main campus of the hospital should be located elsewhere.  This observation seems to be a pre-plan of the members of the hospital authority without any experts opinion as there being no report from Métis Associates, Ltd by this time and that the Métis Associates report was expected after about six months after they had started their work, probably that could be in and around March  2000.  Also, Surprisingly, it is found in the same minutes vide Exhibit “A14”, i.e. sub-Para 4 on page 8 of this motion that an Adhoc committee consisting of the chairman, Mr. James L. Thacker, Jr. and the President, Mr. David S. Dunham and legal counsel of the Hospital Authority, Mr. Samuel P. Johnson, III, were appointed, to investigate available locations in the city of Petersburg for the development of hospital facilities.  It is quite explicit that the decisions taken in these minutes are pre-planned without any expert’s opinions and with a plan to swindle amounts in purchase transactions.  It is also evident that the idea of shifting SRMC from the existing place is with unfounded grounds, without due deliberations and defeats the very purpose of establishment of SRMC in 1950’s, by the learned City Council of Petersburg.  Obviously the decision by the members of Hospital Authority appears to be of QUESTIONABLE BONAFIDES of the members of the Hospital Authority in general and of Mr. Dunham, the President; Mr. Johnson III, Esquire legal counsel and Mr. Thacker, Jr., chairman in particular.


  1. We submit SRMC, is a non-profit public institution and financially quite viable and its income in the year 1999 was over ten million dollars.  According to the Audit and Budget committee reports vide Exhibit “A15” submitted herewith that the net income was $10,187,721.00.  That obviously an institution, which is earning profits and serving the cause of poor citizens, ought not to be disturbed and that the management of the Hospital Authority if not capable to further improve the existing institution, at least its sound and viable existence should not be disturbed under these circumstances.  Hence the sale proposal by management of the Hospital authority is neither in the interest of the hospital for the purpose it was founded nor with any aim of providing health care to the needy poor people.  It appears the management of Hospital Authority has its own vested interest better known to them.  A public institution which is earning profits, to put for sale is unthinkable on the part of the management.  The institution, which is serving for the health care and welfare of the poor citizens, if kept under sale without proper alternative provision, appears to be with an ulterior motive, probably for selfish gains of the proposes for shifting and thereby causing disservice to the people


  1. (a) We submit herewith the minutes of the Hospital Authority dated May 4, 2000, which is Exhibit “A16” herein.  At page 10 of these minutes in paragraph 11 & 12, vide Exhibit “A17” herein through a motion, Hospital Authority authorized, the administration to obtain on two parcels of land and authorized the president Mr. Dunham to sign the option agreements on behalf of Authority.  Incidentally, it may please be noticed that this meeting on May 4th, 2000 had been called at 3:00 p.m. by the chairman of the Authority, Mr. Thacker, Jr. but on the same day on May 4, 2000, itself Mr. Dunham had entered into two option agreements, one with Roslyn Farm Corporation, a Virginia corporation, which is Exhibit “A18” herein.  That Roslyn Farm Corporation is represented by its president, Mr. Robert C. Walker.  This agreement consists of the property described in first parcel admeasuring to area of 26.88 acres is also designated as “Parcel B”.  The second parcel is admeasuring to an area of 10.00 acres, thus Roslyn Farm Corporation to this option agreement agreed to sell 36.88 acres for a purchase price of $1,266,870.00.  ($1.2669 million)  Incidentally, it can be seen that this property mentioned in supra has been purchased by Roslyn Farm Corporation, through a deed dated 5th January 2000 from Joseph E. Chudoba and Emily S. Chudoba, Trustees under the Emily S. Chudoba living trust for a purchase price of $381,900.00 itself vide instrument #000000065, Record in the Clerk’s Office of Prince George on January 6, 2000 at 2:52 pm., the copy of the said deed in Exhibit “A19”.  It is quite evident that Roslyn Corporation has purchased two plats, Parcel “A” of 40.274 acres and Parcel “B” 26.88 acres for a purchased price of $381,900.00; whereas Hospital Authority purchased only 36.88 acres from Roslyn Farm Corporation out of the said parcels of land for a purchase price of  $1,266,870.00.  The said sale transactions have been dealt by Mr. Samuel P. Johnson, III, Attorney at Law, who is the counsel for Roslyn Farm Corporation as well as the Hospital Authority.  Apparently it is obvious fact, that there is a collusive acts of transactions, on the part of members of Hospital Authority and president of Roslyn Farm Corporation to subject the Hospital Authority to substantial financial losses in hundreds of thousands of dollars.  For all these acts, the president of Authority, Mr. David S. Dunham, and Mr. Samuel P. Johnson, III, Attorney At Law, and Mr. James L. Thacker, Jr. chairman are primarily responsible.  We submit a thorough and detailed probe and investigation on these sale transactions disclose the volume of fraud played by the members of the Hospital Authority and sellers of the real estate properties in collusion with each other, in a planned way to swindle large amounts of the hospital for their inherent and selfish gains.  Obviously it is evident from the paras supra that shifting the Hospital, a public institution to a new place is not based on sound principles of administration.  But it is only an organized way to meet the selfish gains of the persons involved in such transactions. That Roslyn Farm Corporation got also executed on the aforementioned real estate property through another Deed of Bargain and sale on 6th January 2000; which is Exhibit “A20” herein.  That Exhibit “A20” was executed by one Mr. George F. Brasfield and Ms. Evans B. Brasfield.  The executers of Roslyn Farm Corporation, has to explain the necessity of this deed Exhibit “A20” herein.   Immediate investigation on these real estate properties would disclose fraudulent acts of the persons involved in these transactions.


(b) That another option agreement entered between Hospital Authority of Petersburg and Roland Specter and Geralde S. Specter is Exhibit “A21”.  This is an agreement executed for purchase of two parcels of land, that Parcel ONE comprised  of 35.9 acres and Parcel TWO comprised of 8.066 acres, and that the purchase price for these being $1,200,000.00 as per the Exhibit “A21”. It is quite interesting to observe that these parcels of land belong to the aforementioned Mr. I. Roland Specter, who was a former member of this Hospital Authority and that at present, his son Mr. Mark B. Specter, is the current member of the Hospital Authority.  That out of this total of  43.966 acres, Mr. Roland Specter, on 4.721 acres of this particular parcel, maintains a house, which is assessed at $248.000.00, and 39.245 acres are assessed for $5,998.00 per acre by City of Petersburg Assessors’ office.  The entire first parcel is assessed for $483,391.00.  But through the agreement, with the involvement and negotiation of Mr. Dunham and Mr. Johnson, the purchase price has been fixed at the rate of $27,273.00 per acre.  All this goes to say that the entire land dealing is an obvious fraud. From the above submissions, we bring to your kind urgent and immediate intervention for conducting a probe on sale transactions of real estate land, parcels and that there is also no necessity to enter into such sale transactions.  Further to our knowledge, we understand that the said land is of black water SWAMP, which is a FEDERAL PROTECTED area.


  1. We submit that it is not out of place to bring to your kind knowledge that there are quite many instances of the cases of patients that at the intervention of the president of the quorum , the patients who were admitted into hospital were discharged without completing the treatment and again readmitted to extract Medicare and Medicaid funds.  We submit to bring these instances to your knowledge, through express evidence provided the Hospital Authority is restrained from destroying such medical records of the patients from their medical records department. 


  1. There were also unwanted procedures which were conducted

by some of the doctors. When complained on these matters peer review committee did not examine the complaints because of biased attitude and being discriminatory and prejudiced. The evidence of such events would be disclosed, provided protection is rendered to complainants.  There are also instances of physicians being harassed with vindictive accusations.  We further submit that operating rooms were used for indulgence of sexual acts by Mr. Dunham and some doctors. That on January 15, 2003, the Hospital Authority caused paid advertisement quoting the reasons for sale, is quite evident that the very purpose for which the institution was established to serve the cause of poor people is completely ignored and with a calculative motive to grab hospital funds the sale of the hospital is being negotiated and thus once for all vanishing a public institution from the citizens of Petersburg.  The said advertisement is Exhibit “A22” herein. We are herewith submitting a representation of a patient, which is Exhibit

“A23” herein, who was denied treatment because she has no health insurance coverage.  The Hospital, being a non-profit organization should not have denied treatment to the patient.


Under the aforementioned facts and circumstances we pray:


1.      The sale of the hospital by the Hospital Authority is to be stopped henceforth.

2.      Thorough investigation is to be conducted on purchase of land plots from Roslyn Farm Corporation and from Mr. J. Roland Specter, former member of the Hospital Authority.

3.      Thorough investigation on the functioning of Mr. David B. Dunham, as president of the Hospital Authority, and Mr. Samuel P. Johnson, III, legal counsel of the Hospital on purchase of land parcels by the Hospital Authority.

4.      Order for investigation on sexual harassment.

5.      Investigation of unlawful termination of employees.

6.      Gravely misusing the operation rooms for indulging in sexual acts.


We request to provide immunity from Federal and State governments to reveal such unlawful; acts committed at Southside Regional Medical Center. 



We are looking forward for your help to rescue this city from these Thugs looting a public property and it is at your mercy for the survival of this great medical institution.



Very truly yours,



George Brown              Lloyd Hines                  Lokesh B. Vuyyuru



Emma Whitehead         Christopher White        Dorothy Taylor


Victoria Gray-Adams               Alzena Mayfield


Enclosures: Along with the documents “A1” to “A23”



             Copies: Honorable President George W. Bush

                           Hon. Governor of Virginia

                           All senators

                           All congressmen

                           All legislators

                           All sate senators

                     Commonwealth attorney

                            U.S. District attorney

                            Hon. John Ashcroft

                            Circuit court Judge