Case no:

17-15217

IN THE UNITED STATES APPELLATE COURT

FOR THE NINTH CIRCUIT

Madhuri Trivedi vs. U.S. DEPARTMENT OF HOMELAND SECURITY, John F. Kelly, in his
Official Capacity as Secretary of Homeland Security, U.S. CITIZENSHIP AND
IMMIGRATION SERVICES, Lori Scialabba in her Official Capacity as Director- U.S.
Citizenship and Immigration Services,
Donald Neufeld -director USCIS service center in his individual capacity,
Greggory Richardson- director TSC - in his individual capacity,
Mark Hazuda- Director NSC - in his individual capacity,
John Roth, OIG - in his individual capacity,
Maria Odom-DHS- in her individual capacity

Letter detailing GE issues, deposition, arbitration, 600 defects on 100,000 medical

devices for several years, wrongful /illegal termination and loss of immigration
and wages as a retaliation of not participating in GEs fraud scheme

_________________________________________________________________
Appellant MADHURI TRIVEDI March 4th 2017

Founder, CEO OrangeHealth( start up)

P.O. Box 8359, Fremont, CA 94537
Madhuri.orangehc@gmail.com Phone: 650-242-5135 Fax: 708-774-4859

Copy to: Patrick Hale (He just retired)

Email : pat_hale@mit.edu
Director System Design and Management (SDM) and SDM Sloan Fellow program
Massachusetts Institute of Technology and MIT Sloan school of Management
Case 17-15217 Madhuri Trivedi Page 1 of 7
 Hon. Circuit Judge Clanby and Clifton,

Department of Justice needs to be renamed as Department of Injustice.

I wrote a short motion for injunctive relief upon this court and appellate
court and both judges have shown no respect, empathy and sympathy. DHS has
done TORT, intentional infliction of emotional distress and hardship. GE despite
my stellar performance to cover up their fraud illegally and wrongfully terminated
me ; along with my wages and immigration.
Judges could have looked at whole record and try to resolve..I am surprised
how tax payers money are used and how talented, honest people for doing right,
lawful thing get such treatment

Exhibit 3..all 600 defects were closed in one day without doing anything during
last few months I was there..GE argument was that they will be addressed/closed when
existing product is replaced with new product. But when defects were closed there was
no new product in existence. And GE was replacing back office software and not medical
device software. Replacing medical device software on 100,000 devices requires
RECALL from GE or FDA.

1) Deposition of Genera Eletric architect William Barbiaux taken by Madhuri

Trivedi
2) Exhibits of Deposition of GE architect William Barbiaux
3) Description of GE document
GE document describing 496 design non conformances(defects) in
PRODUCTION for several years and worst performance on medical devices
side, 100,000 medical devices including MRI, CT scan, ultrasound, LCS and
more
4) GE document describing 496 design non conformances(defects) in
PRODUCTION for several years and worst performance on medical devices

Case 17-15217 Madhuri Trivedi Page 2 of 7

 side, 100,000 medical devices including MRI, CT scan, ultrasound, LCS and
more
5) Immigration email with Dave and Nate before joining GEHC
6) After I raised serious concerns and issues in GEs performance ranking
system during my arbitration with GE, GE ended it as per new article blow.

General Electric is ending annual performance reviews

7) AAA 51 160 01260 13 Subpoena witness
Where GE CEO Mike Swinford, GE CTO Mike Harsh came to testify
8) AAA 51 160 01260 13 Subpoena document
Those male engineers who were responsible for GE product Insite Exc despite
having uncompetitive, below acceptable standards were treated favourably.
9) Security Issue in production Insite2
10) pointing out contravention of codelaw. HIPPAHITECH law
11) Medical device product didnt have audit trail and logging as confirmed by
GE architect
12) Customer internal customer Missy's complaint, where she was not able to
connect to medical devices for two months
(hence unable to do her job, unable to meet service contract obligation that GE
signs with hospitals when they buy a medical device and also purchase a
service contract worth $50k, $100k or more) and madhuri fixed immediately
within 24 hoursIt was Madhuris second week at work..Being brand new I
fixed itGEs uncompetitive staff who were not able to fix it..their EGO was
on FLAME.
13) After fixing as shown in Exhibit 13, Email was sent by GE representative
to all
regional service leaders in canada and USA.
14) Which Fortune 500 Boards of Directors are taking security seriously
This article states that after I left GE issued cyber security warning on their
products to all share holders dated back to 2010..2010 was a year when I
started working for GE first time

Case 17-15217 Madhuri Trivedi Page 3 of 7

15) Surgery device port hacking page 1
I was able to hack product on OEC C arm surgical medical device while
testing. As William Barbuiax testified in exhibit 1 (attached here)..this was
critical and it would have been a seious issue in filed/hospitals if I would not
have raised it.
16) Surgery port hacking page 2
17) Surgery OEC C arm had several missing libraries for networking,
communicationsWhile my manager/team lead were harassing me and was
in rush to release this productbecause of me and my investigation .this
was put on hold. Without networking and connectivity libraries; Insite EXC
product cant exist as it was the core and main function of product. After that
several teams had to spent two months fixing this issues and developing
libraries..My role was to TEST this product. Develop automated /scripts
/software test plans .

In 2007, GE Healthcare entered a consent decree with the FDA which prohibited
the manufacture or distribution of surgery OEC C arms medical imaging devices
(
https://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/2007/ucm108
828.htm) . Ms. Trivedis first project for GE Healthcare was to work on finally
bringing a related product back to market. Being aware of the checkered history, I
was putting highest standards; but was punished for following quality processes.
18) Insite Production issue screen

Case 17-15217 Madhuri Trivedi Page 4 of 7

19) As per exhibit 19 above Centicity medical product as GE used Insite Exc
and this exhibit shows Veterans hospitals signed a contract worth multi
million.
20) I was told to develop 1000 page test in 23 days that works on linux and
widows both..including developing/writing software.
21) 1000 page test document
22) My communication with GE managers about surgery hack, quality, no
networkingthis was important internal whistleblowing and I suffered more
and more retaliation and discrimination
23) My Email to General manager Dave Elario..raising and reporting concerns
and again they harassed me more and delayed my immigration.
24) Dipti Patel team/project lead at GE developed a test plans which was used on
thousands of devices
Test plan captured network traffic( life sniffing data transferred over the
internet because internet uses HTTP hyper text transfer protocol..in Diptis
test network analyzer compared screenshots (INSTEAD of comparing binary
data..this shows how poor her technical depth , knowledge and understanding

Case 17-15217 Madhuri Trivedi Page 5 of 7

 wasAnd How GE quality system, managers allowed it for years.. GE
managers also had no clue and time to know how to do it in a right technical
way)..of ideal network packet with the network packet that is under test..(For
example someone from court sends a message over internet..standards
message versus actual message)
25) GE manger perjury Lying under Oath
26) Email from Principal engineers that defect required fixing whole software, not
bandaid
27) Insite product was accessible on multiple ports which is hacking security
vulnerability. A product MUST be accessible via one PORT but it was
randomly opening multiple ports..It is like having random doors open into
your house and you have no clue who getting in/out of doors and which doors
are open because it is randomly open..This was a Hackers paradise..
28) Static code analyzer is a software that analyzes and code reviews software
against 1000 rules. FDA recommends/for some requires that for medical
devices and software for medical devices to use static code analyzer. Insite
Exc product never used static code analyzer..While writing software , they
used manual review where one person will ead code and reviewWhile being
new to team, I wrote to My manager Dave Mehring that we use static code
analyzer as it is recommended. Given Insite Exc used 15 programming
languages-.NET, C#, java, PERL, C, C++, python, and moreDave mehring
replied via email that for ten years we havent been using any quality
analyzer/static code analyzer for Insite Exc and we dont have time. It was my
third month at GE-new to GE when I ran into this. Dave Mehring was mad
and looking for ways to revenge and make me look bad.
29) GenderSpeak Email Mike Harsh- CTO of GE Healthcare about gender
sensitivity i.e. communicating with female engineers
30) I reported my concerns to GE global services CEO Mike Swinford ..But no
result came out..At arbitration hearing he said that whatever I sent to him to
report issues..He forwarded that to senior HR manager reporting to him Adam

Case 17-15217 Madhuri Trivedi Page 6 of 7

 Holton..And he testified that Adam Holton has left GE a month before my
arbitration hearing.
Given my immigration was at stake, I was doing best to have GE address it.

Appellant
MADHURI TRIVEDI
P.O. Box 8359
Fremont, CA 94537
Madhuri.orangehc@gmail.com
Phone: 650-242-5135
Fax: 708-774-4859
March 4th 2017
CERTIFICATE OF SERVICE

I hereby certify that on this date, I caused a true and correct copy of this statement
delivered electronically to Gisela Westwater.

Dated: March 4th 2017 Respectfully submitted,

Madhuri Trivedi
__________________________________________________________________

Case 17-15217 Madhuri Trivedi Page 7 of 7