RX2U, LLC
3970 Peachtree Industrial Blvd. Unit 102
Berkeley Lake, GA 30096
(404) 387-2797
Insert Date
CT Corporation System, as Registered Agent of Humana Inc.
289 Culver Street,
Lawrenceville, GA 30046-4805
TO WHOM IT MAY CONCERN:
RE: RESPONSE TO ALLEGATIONS FRONTED BY HUMANA INC. AND NOTICE OF
INTENT TO SUE
Humana Inc. sent us a letter indicating its wish to terminate its relationship with RX2U,
LLC for nine unreasonable and unproven reasons. The letter of termination is hereby attached.
RX2U responds to the allegations brought against it as follows:
Allegation 01: Humana Inc. states that it has enough documents to prove some members
denied receiving prescription drug and/or supplies billed to Humana by pharmacy.
Allegation 02 : Humana Inc. states that it has enough documents to prove that Humana
members denied requesting prescription drugs and/or supplies billed to Humana by pharmacy.
Allegation 03: Pharmacy billed Humana Inc. for prescription drug and or supplies
dispensed to Humana Inc. members who denied knowing pharmacy.
RX2U has evidence to disprove the false allegations above including the names of the
related patients, recorded conversations with patients, and dates that the conversations took
place.
Allegation 04: Humana has reason to believe that pharmacy did not contact the members
to verify eligibility and consent prior to providing pharmacy services.
The above allegation is false and mere speculation at best. RX2U called all patients and
sent them welcome letters. RX2U has documents showing that each patient signed up for
prescription deliveries to their homes, call logs and sample letters duly signed and returned by
the patients.
Allegation 05: Pharmacy is an affiliated entity, of MED-4-YOU, LLC that was
previously terminated by Humana Inc.
MED-4-YOU, LLC and RX2U, LLC are two distinct companies that are not affiliated to
each other in any way whatsoever. MED-4-YOU is owned by Alizera Lavassani and RX2U,
LLC is owned by Seyed Lavassani. The allegation above seems to stem from the fact that Seyed
is Alizera’s father. There is no law that bars father and son from owning different companies.
There is no term in the contract which prevents Seyed and Alizera from owning different
companies.
Allegation 06 : Humana Inc. indicated that one of the reason to drop RX2U, LLC is
because at the time of contract, RX2U pharmacy indicated that pharmacy owner is Seyed
Lavassani.
Seyed Lavassani is indeed the sole owner of RX2U, LLC. That can be confirmed here
https://ecorp.sos.ga.gov/Account. It would only be discriminatory for Humana Inc. to terminate
the contract for this reason.
Allegation 07: Human indicated that one of the reason to drop RX2U, LLC is because
Mr. Alireza Lavassani was identified as the owner of the terminated pharmacy.
The foregoing is correct. There is no law that bars father and son from owning different
companies. There is no term in the contract which prevents Seyed and Alizera from owning
different companies.
Allegation 08: Human indicated that one of the reason to drop RX2U, LLC is because
based on filing with the Georgia secretary of State, Seyed Lavassani was an organizer of MED-
4-YOU, LLC.
The foregoing is correct. Seyed Lavassani is the registered agent of several companies
including MED-4-YOU, LLC; RX2U, LLC; The Glimpse of Heaven, LLC; A Glimpse of
Heaven on Earth Corp.; Hypnopsychology Institute; Government Health & Support Industries;
and Global Government Contractors. Others can be found here https://ecorp.sos.ga.gov/Account .
Accusation 09: Humana Inc. indicated that one of the reasons to drop RX2U LLC is
because upon their discovery and obtained information, they believe Seyed Lavassani and
Alireza Lavassani are related as a parent child family related.
The foregoing is correct. There is no law that bars father and son from owning different
companies. There is no term in the contract which prevents Seyed and Alizera from owning
different companies.
We have lots of evidence including documents, voice recordings, call logs patient
profiles, as well as files that show all activities between doctors and patients to disprove all false
allegations fronted by Humana Inc.
RX2U, LLC hereby demands that Humana Inc. sends over the documents it has to prove
its allegations. Upon receiving such documents, RX2U, LLC will compare the voice recordings
with the recordings in RX2U, LLC’s possession and present results to Humana Inc. If Humana
Inc. fails to comply with this demand within 20 days of the date on this letter, RX2U, LLC will
file a lawsuit against Humana Inc. at a court of appropriate jurisdiction for wrongful termination
of contract and loss of income. RX2U will pray for damages in excess of $500,000, excluding
illegal fees charged by Humana Inc. over the years, attorney fees, costs of the suit, and pre- and
post-judgment interests.
Thank you for taking the time to read this letter.
Yours Sincerely,
___________________________________
Seyed Lavassani
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