Aldaco Gender Modification Suit

FILED
TARRANT COUNTY
7/21/2023 12:47 PM
THOMAS A. WILDER
CAUSE NO. 067-343803-23 DISTRICT CLERK
§
SOREN ALDACO, §
Plaintiff, §
§
v. §
§
DEL SCOTT PERRY, SREENATH §
NEKKALAPU, BARBARA ROSE § IN THE DISTRICT COURT OF
WOOD, RICHARD SANTUCCI, §
ASHLEY DELEON, §
§ TARRANT COUNTY, TEXAS
and §
§
CRANE CLINIC, PLLC, TEXAS § _______ JUDICIAL DISTRICT
HEALTH PHYSICIANS GROUP, §
THREE OAKS COUNSELING §
GROUP, LLC, d/b/a THRIVEWORKS, §
MESA SPRINGS, LLC, §
§
Defendants. §
§
PLAINTIFF’S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES Plaintiff Soren Aldaco (“Plaintiff” or “Soren”) in the above-captioned and
numbered cause, and files this Original Petition, complaining of Defendants DEL SCOTT
PERRY, an individual, SREENATH NEKKALAPU, an individual, BARBARA ROSE WOOD,
an individual, RICHARD SANTUCCI, an individual, ASHLEY DELEON, an individual, CRANE
CLINIC, PLLC, a professional limited liability company, TEXAS HEALTH PHYSICIANS
GROUP, THREE OAKS COUNSELING GROUP, LLC, at times doing business as
“Thriveworks,” a limited liability company, and MESA SPRINGS, LLC, a limited liability
PLAINTIFF’S ORIGINAL PETITION PAGE 1
Copy from re:SearchTX

company (each a “Defendant” and together, the “Defendants”), and for her causes of action would
respectfully show the Court the following:
I. DISCOVERY CONTROL PLAN AND REQUEST FOR DISCLOSURES
1. Plaintiff intends to conduct discovery under Level 2 per Rule 190.3 of the Texas Rules
of Civil Procedure. Plaintiff requests that each Defendant provide initial disclosures as required under
Rule 194.2 within 30 days of filing an answer in this cause.
II. INTRODUCTION
2. This lawsuit details a chronology of wrongful acts committed by a collective of
medical providers who, in their pursuit of experimental “gender-affirming” medical therapies,
administered a series of ruinous procedures and treatments to Plaintiff Soren Aldaco, who was then a
vulnerable teenager struggling with a slew of mental health issues. Soren’s experiences with these
providers shock the conscious. The repercussions of these interventions have led to Soren’s
permanent disfigurement and profound psychological scarring. The Defendants’ breaches of their
fiduciary duties are only underscored by the fact that each Defendant met Soren and facilitated these
“therapies” at a pivotal juncture in Soren’s life—when she was grappling not only with the universal
challenges of adolescence and body image but also with a complex amalgamation of diagnosed
mental health comorbidities and other psychological and social disorders. Despite these telltale signs
demanding caution and therapeutic resolution, however, the Defendants deliberately and recklessly
propelled Soren down a path of permanent physical disfigurement and worsening psychological
distress.
3. Soren now seeks justice and compensation for the Defendants’ negligent and grossly
negligent actions, which have had, and will continue to have, a profound and lasting impact on her
physical and mental health and quality of life.

III. RULE 47 STATEMENT
4. Plaintiff affirmatively pleads that she is seeking monetary relief over $1,000,000.
Plaintiff also seeks judgment for all other relief to which she is entitled at equity or law.
IV. PARTIES
5. Plaintiff is an individual who resides in Tarrant County, TX.
6. Defendant Del Scott Perry (“Perry”), APRN, FNP-C is an individual who is believed
to reside in and provided medical services to Plaintiff in Tarrant County, Texas.
7. Defendant Sreenath Nekkalapu, M.D., (“Dr. Nekkalapu”) is an individual who is
believed to reside in and provided medical services to Plaintiff in Tarrant County, Texas.
8. Defendant Barbara Rose Wood, LCSW, LCDC (“Wood”) is an individual who is
believed to reside in Travis County and provided medical services to Plaintiff in Tarrant County,
Texas.
9. Defendant Richard Santucci, M.D., (“Dr. Santucci”) is an individual who is believed
to reside in and provided medical services to Plaintiff in Travis County and Tarrant County, Texas.
10. Defendant Ashley DeLeon, M.D., (“Dr. DeLeon”) is an individual who is believed to
reside in and provided medical services to Plaintiff in Travis County and Tarrant County, Texas.
11. Defendant Crane Clinic, PLLC (the “Crane Clinic”) is a professional limited liability
company registered in the State of Texas and whose principal place of business is located at 4407 Bee
Cave Road, Suite 612, Austin, Texas 78746.
12. Defendant Three Oaks Counseling Group, LLC (“Three Oaks”) is a limited liability
company registered in the State of Texas and whose principal place of business is located at 5524 Bee
Cave Road Suite K4 Austin, Texas 78746. At relevant times, Three Oaks has operated under the
assumed name “Thriveworks,” and so all references to “Three Oaks” shall refer to and include a

reference to “Thriveworks” and are to be considered interchangeable for the purposes of these
allegations.
13. Defendant Texas Health Physicians Group (“THPG”) is a corporation registered in
the State of Texas and whose principal place of business is located in Arlington, Texas.
14. Defendant Mesa Springs, LLC (“Mesa Springs”) is a limited liability company
registered in the State of Texas and whose principal place of business is located in Fort Worth, Texas.
15. Issuance of citations via Texas E-Serve System for all Defendants is requested.
V. VENUE & JURISDICTION
16. The damages sought and subject matter in controversy are within the jurisdictional
limits of this Court. Plaintiff is seeking monetary relief exceeding $1,000,000.00.
17. This Court has jurisdiction over the parties because both Plaintiff and Defendants are
residents of the State of Texas.
18. Venue is based on Texas Civ. Prac. & Rem. Code 15.002(a)(1) because a substantial
part of the events or omissions giving rise to the claims occurred within Tarrant County, Texas.
VI. OPEN COURTS
19. Under the Texas Constitution, a plaintiff in a medical negligence case can avoid the
two-year statute of limitation imposed by Texas Health and Safety Code § 74.251(a) when (1) the
plaintiff has a cognizable common-law cause of action, (2) the restriction of the claim is unreasonable
or arbitrary when balanced against the purpose of the open-courts provision, and (3) the claim was
filed within a reasonable time. Yancy v. United Surgical Partners Int’l, 236 S.W.3d 778, 783-84 (Tex.
2007).
20. Plaintiff alleges that Texas Health and Safety Code § 74.251(a), the standard medical
malpractice statute of limitations, is unconstitutional as applied to this case, where Plaintiff, at the

time of injury, was an autistic, depressed, confused, impressionable minor who was only able to
understand and comprehend her need for judicial redress after she reached the age of majority and the
influence of the wrongdoers had faded with her physical and psychological maturity and healing.
21. Plaintiff has a well-established common-law cause of action in medical negligence
against each Defendant in this case, and in the event where § 74.251(a) would bar a cause of action
against any Defendant in the below allegations, each of the elements of the Texas Open Court’s
provision would be satisfied so as to allow the claim to survive challenge.
VII. CHAPTER 74 NOTICE REQUIREMENTS HAVE BEEN SATISFIED
22. Pursuant to Texas Civil Practice & Remedies Code § 74.051(b), Plaintiff states that
she has fully complied with the provisions of § 74.051(a) (notice requirement) and § 74.052
(authorization form requirement).
VIII. FACTS
i. Soren struggled with her identity from an early age.
23. Soren has struggled with her identity from an early age. Due to a troubled family life,
the sudden loss of a beloved grandmother, peer ridicule, and a host of other stressors and troubles
plaguing her early years, Soren’s psychological health was poor from the start.
24. Making matters worse, Soren experienced an early puberty resulting in development
of her breasts beyond what was typical amongst her pre-teen peers. This early development invited
even more ridicule and, influenced by the “female” body images she saw on her social media, caused
her to deeply dislike her physical appearance.
25. Because of this dislike for her female physical appearance, coupled with her general
propensity to enjoy activities usually enjoyed by boys and the influence from some transgender online
friends, Soren began wondering if maybe she was transgender too.

26. Over the course of eighth and ninth grade, Soren flirted with identifying as a boy with
a small group of close friends and a couple of trusted teachers.
27. Over the next couple of years, Soren’s flirtation with and fluctuation between gender
identities began to stagnate, as Soren had become comfortable taking on a balanced gender identity
that reflected the nonbinary nature to which Soren felt most attuned. Gender identity aside, during
this time, Soren’s psychological troubles only worsened.
28. By the tenth grade, Soren’s depression and anxiety had become crippling. Once a
straight-A student, Soren now found herself falling behind both academically and socially. In addition
to depression, anxiety, and the social disorders she would later discover with the help of competent
counseling, Soren experienced the added psychological stress of meeting her biological father for the
first time in December of 2017. The next month, as a 15-year-old, these stresses and issues coalesced
and manifested into a manic episode that resulted in her psychiatric hospitalization at Mesa Springs
Psychiatric Hospital in Fort Worth, Texas.
ii. Dr. Nekkalapu betrays Soren’s doctor/patient confidentiality and pressures

Soren to pursue a transgender male identity.
29. As a result of her manic episode, Soren’s mother and stepfather checked her into Mesa
Springs on or about January 5, 2018. Mesa Springs placed her under the psychiatric care of Defendant
Dr. Sreenath Nekkalapu for a period of three days.
30. During those three days, and against Soren’s expressed wishes not to discuss her
gender identity, Dr. Nekkalapu relentlessly pressed her on the topic by prompting her with trans-
related questions and affirmations. In fact, Dr. Nekkalapu pressed so hard on the issue that Soren felt
as though the only way to cease the discussion was to agree with him and tell him that she did identify
as transgender. At the age of 15, this coerced “confession” from Soren would mark the first time

Soren had ever discussed her gender identity with anyone outside her close group of friends and the
first time ever speaking about it with a medical professional.
31. Notably, Dr. Nekkalapu did not do any meaningful or comprehensive
psychobehavioral examination, did not explore Soren’s existing mental and psychological issues, and
did not discuss or attempt to address her glaring comorbidities. Instead, he appeared to simply jump
to—and indeed encourage—the conclusion that the sole explanation for Soren’s psychotic break was
her needing to embrace a transgender identity, after only knowing her for mere minutes.
32. Dr. Nekkalapu’s persistence caused Soren to feel like she was being pressured or
coerced off the comfortable balance she had struck concerning her nonbinary gender identity, and this
caused her significant unease and caused her to once again wonder if she was, in fact, transgender.
33. Due to once again experiencing this gender uncertainty, Soren responded to Dr.
Nekkalapu’s forced identification by instructing him that under no circumstances was he allowed to
break their doctor–patient confidence by telling her mother the conclusion he reached about her being
transgender, and he comforted her that he would not.
34. Soren asked that this be kept from her parents because, among other reasons, including
the fact that Soren and her parents were not seeing eye-to-eye at the time, Soren was not entirely sure
that she agreed with Dr. Nekkalapu’s conclusion, as she still felt some sense of the nonbinary balance
she had previously achieved.
35. Just before being discharged from Mesa Springs, Soren learned that, despite her
wishes, Dr. Nekkalapu surreptitiously outed Soren to her mother and biological father, disclosing the
contents of Soren’s confidential conversations and that Soren had identified as transgender.
36. Not only did this unauthorized disclosure result in significant mental anguish for
Soren, it also amounted to an immense amount of psychological pressure on her to adapt to the

expectations of Dr. Nekkalapu, her mother, and her biological father, all of which were now of the
belief that she was a transgender boy, even if Soren was not entirely convinced herself.
37. As a result of this pressure, Soren then began to explore what it would be like to
actually live as a medicalized transgender boy by researching the various medicalization procedures
and expanding the group of people with whom she would adopt that persona and identity.
38. Three months after her manic episode and treatment at Mesa Springs, Soren began
treating with other therapist and psychologist who helped Soren discover that in addition to her Major
Depressive Disorder, ADHD, and other diagnoses, Soren also suffered from Autism Spectrum
Disorder. Soren’s autism was never discussed or even considered by Dr. Nekkalapu.
39. It was not until several years later that Soren had enough maturity and awareness to
look back on these events with Dr. Nekkalapu and realize that not only was Dr. Nekkalapu’s coercion
undue and improper, but that his coercion, when coupled with his violation of Soren’s confidences to
her mother, combined to create an incessant psychological pressure on her to travel down this path of
physiological and psychological harm. Similarly, Soren then also learned that not only did Dr.
Nekkalapu’s disclosure of her confidences to her mother breach his duty owed to her, it was also a
violation of Texas statutory law.
iii. Soren meets Del Scott Perry and is immediately put on cross-sex hormones.
40. In 2019, Soren visited a transgender “support group” in Fort Worth, Texas called
Trans-Cendence International (“TCI”). This group hosts meetings for transgender children and their
supporters. TCI would pair transgender children and adolescents with “elders” to purportedly help
guide them in their “gender journey.”
41. It was through word of mouth within this group that Soren learned that Defendant Del
Scott Perry was “the guy” who prescribes testosterone upon request. Perry attended most meetings—

despite not being a transgender individual—and was the cross-sex hormone provider for most of the
children and adolescents who frequented the group. Perry had apparently built this list of clientele
from the group over a period of months or years of attending these meetings with another member of
the group.
42. Upon Soren’s first casual encounter with Perry at a TCI meeting, Perry immediately
confirmed to her that, as with the other young girls and boys in the group, he could and would
prescribe Soren with the testosterone she wanted if and when she visited his office.
43. On January 28, 2020, at Soren’s first ever appointment at Perry’s office—a visit
lasting only approximately 30 minutes—Perry wrote Soren a prescription for her first round of cross-
sex hormones, anastrozole (an estrogen blocker) and testosterone cypionate (together with the
anastrozole, the “cross-sex hormones”), at an outrageously large, off-label dosage. Perry gave her
instructions on how to inject herself with the drugs and sent her on her way. Notably, to this day, it
is still clinically uncertain what the long-term consequences are for the use of these cross-sex
hormones in minors, but certain grotesque risks are well known within the medical literature
including, for women, infertility, vaginal atrophy, bone density and growth complications, and many
other disfiguring side-effects.
44. During this short, initial visit, and as further detailed below, Perry failed to discuss
with Soren the full extent of the risks posed by the cross-sex hormones and the irreversible
consequences that use of the cross-sex hormones would cause. Perry also failed to discuss any
potential alternatives to the cross-sex hormones, instead deferring to Soren’s wishes to take
testosterone like the other kids at TCI. Perry also failed to discuss or address any of Soren’s numerous
mental health issues and existing comorbidities and conducted no psychobehavioral mental health
analysis before providing Soren’s first injection of life-altering cross-sex hormones. Soren was, at

the time, only 17 years old, and Perry never sought or obtained any written parental consent from
Soren’s parents to guide her down this path.
45. When these cross-sex hormones eventually started causing severe complications in
Soren’s body, rather than reduce her dosage or take her off the cross-sex hormones completely, Perry
simply referred Soren out to various medical specialists who could treat the specific symptoms that
arose while continuing to prescribe and administer the cross-sex hormones. In fact, at this point in
time, Soren was so sufficiently gaslit by Perry that she dismissed at least one of these medical
specialist’s advice to discontinue use of the cross-sex hormones because they were likely the source
of her side effects. When she heard that cautionary advice, as compared to the immediate certainty
and unqualified affirmation coming from Perry that continued cross-sex hormones were the proper
course, Soren ironically wrote off the doctor as being a bigot who was behind the times and merely
pushing an agenda without Soren’s best interest at heart. To Soren, the advice coming from the
doctors seemed less certain, less emphatic, and thus less persuasive than the “gender-affirming”
medicalization course Perry had laid out for her. So she stuck with Perry’s plan despite the fact that
a more cautious approach was being suggested by an actual medical doctor, as opposed to Perry’s
advice, which was only that of a nurse practitioner. Nevertheless, Soren continued taking the cross-
sex hormones pursuant to Perry’s prescription until November of 2021, when Soren realized and
discovered Perry’s egregious breach of care.
46. At all relevant times, Perry practiced under the guidance and supervision of Defendant
Texas Health Physicians Group. Moreover, at all relevant times, THPG facilitated, allowed, and
acquiesced in Perry’s reckless prescription of cross-sex hormone to minors. While facilitating Perry’s
practice, THPG failed to ensure that Perry’s practice complied with any recognized standard of care
by, among other things, failing to enact a protocol requiring Perry to conduct a comprehensive

psychological assessment, a comprehensive prior medical history review, or to otherwise properly
pre-qualify Soren for the course of treatment he so readily prescribed. THPG’s lack of such
responsible oversight enabled Perry’s reckless treatment and created a dangerous environment that
directly contributed to and caused Soren’s injuries.
iv. Soren’s relationship therapist, Barbara Wood, authors a recommendation letter

qualifying Soren to receive a double mastectomy shortly after her 19th birthday.
47. Soren began treating with defendant Barbara Wood on or around July 24, 2020, for
certain relationship and co-dependency issues Soren was then experiencing with her partner, and
continued therapy with Wood until May 10, 2021.
48. All appointments with Wood were telehealth visits.
49. Wood’s treatment of Soren focused almost exclusively on the co-dependency and
relationship issues she was experiencing with her partner; their sessions never focused on or attempted
to fully assess or resolve the question of Soren’s gender identity. To the extent that the topic did come
up, Soren discussed with Wood that she was still exploring her gender expression and that Soren was
becoming more comfortable with a non-masculine (or nonbinary) expression.
50. Wood never conducted any type of social assessment of how or whether Soren was
publicly living as a transgender man or of what kind of impact that lifestyle was or was not having on
Soren’s day-to-day mental health. Put simply, Wood had little to no insight into Soren’s transgender
perspective and experience.
51. Notably, over the entire course of Soren’s treatment with Wood, COVID-19
restrictions were in place, and Soren had little to no normal social experiences. Even her high school
experience was entirely online and by video during this time. Therefore, not even Soren was aware,
nor could she have been aware, of what it would be like to live a full social life as a transgender male.

52. In February of 2021, still not feeling entirely comfortable with her gender identity, but
still disliking the way her breasts looked on her body, Soren began exploring the possibility of
undergoing a double mastectomy (a.k.a. “top surgery”), even if just for the purpose of removing the
breasts she disliked.
53. That exploration led to Soren contacting the Crane Clinic in Austin, Texas, a notorious
surgical center recently relocated from California to Texas to perform “gender-affirming” surgeries,
including mastectomies, and other “gender-affirming” treatments. The Crane Clinic informed Soren
that to get the double mastectomy, she needed to obtain a letter from a practitioner recommending her
for the procedure.
54. The Crane Clinic provided Soren with a template for what the letter needed to say and
a list of individual practitioners who would sign the letter upon her request, if needed.
55. Rather than use one of the practitioners on the Clinic’s list to obtain the letter and
signature, Soren first checked with Wood and asked her to sign the recommendation letter. Wood
immediately responded, “No problem,” despite never having conducted a comprehensive assessment
of Soren’s gender struggles or mental health and having no real insight into that part of Soren’s life.
56. A few days later, Wood signed a letter containing several false or otherwise
misleading prerequisite statements to appease Soren’s request and satisfy Crane’s requirements.
57. That letter included the following material falsehoods or misrepresentations:
a. that Wood had been treating Soren for Gender Dysphoria “since 7-24-2020,” when in
fact, Wood had never assessed or treated Soren for Gender Dysphoria;
b. that Soren’s “diagnosis is persistent and well documented in his medical record,”
when in fact, Soren’s diagnosis for Gender Dysphoria was neither persistent nor well
documented in her medical record;
c. that Soren’s “transgender identity has been persent [sic] persistently for at least two
years,” when in fact, Soren’s gender identity had been in a state of fluctuation over
that course of time;

d. that Soren’s “disorder is not a symptom of another mental disorder,” when in fact,
Wood performed no diagnostic tests or assessments to rule out this possibility;
e. that Soren “has documentation that he has completed a minimum of 12 continuous

months of living in a gender role that is congruent with his gender identity across a
wide range of life experience and events,” when in fact, Soren had not completed any
months in such a gender role across a wide range of life experiences or events;
f. that Soren “confirmed to [Wood] that he does not drink, nor does he use illegal drugs
for recreational purposes,” when in fact, Soren had previously disclosed to Wood that
she drank and smoked marijuana socially at the time.
58. Wood’s authoring of this falsified letter and enabling, encouraging, and
recommending Soren for a “gender-affirming” double mastectomy without first investigating and
comprehensively assessing Soren’s suitability for such a procedure represents an egregious departure
from the standard of care and a reckless disregard for Soren’s health and safety. These grossly
negligent actions directly and proximately caused and/or contributed to Soren’s significant emotional,
psychological, and physical injuries.
v. Defendants Dr. DeLeon and Dr. Santucci negligently approve and perform a double
mastectomy on Soren and then negligently fail to provide post-surgical care.
59. Once Soren received the signed letter from Wood, she submitted the letter to the Crane
Clinic and paid the Crane Clinic’s fee to schedule her “initial consultation” appointment. The initial
consultation was a brief phone call, lasting only minutes. This visit consisted of a short, preliminary
background inquiry to which Soren disclosed her comorbidities and the numerous medications she
was taking to treat them. Despite these red-flag disclosures, the Crane Clinic surgeons concluded that
initial visit by scheduling her double mastectomy for June 11, 2021.
60. Not once during the intake process or the pre-operative visits did Dr. DeLeon or any
other Crane Clinic practitioner assess or review Soren’s suitability for an elective double mastectomy.
Not once did anyone from the Crane Clinic ask for comprehensive medical records from any of
Soren’s prior medical providers or current therapists. And despite having actual knowledge of

Soren’s long history of and current struggle with Major Depressive Disorder, autism, and other mental
health disorders, no Crane Clinic practitioner gave Soren a psychological assessment to ensure she
had the capacity to consent or the proper motivations for wanting the surgery. The Crane Clinic
surgeons simply accepted the recommendation letter at face value, conducted no independent medical
assessment of their own, ignored the red flags, and put Soren under the knife, permanently and
irreversibly disfiguring and disabling her. Because of Soren’s comorbidities, age, and other similar
red flags, simply approving Soren for the double mastectomy and agreeing to perform it was itself a
gross breach of the medical standard of care.
61. But making matters worse, Dr. DeLeon, the Crane Clinic surgeon, negligently
performed the double mastectomy and Dr. Santucci negligently supervised Soren’s problematic
recovery, leaving Soren with horrible post-surgical complications and resulting disfigurement that
continue to affect Soren to this day. When her emergency post-surgical complications arose, Soren
immediately reached out to Dr. Santucci, who downplayed her horrible complications and insisted to
her that the complications were “normal.” Despite Soren sending graphic pictures of the pools of
blood forming subcutaneously within her torso, her nipples literally peeling off of her chest, and
explaining the immense pain she was experiencing, Dr. Santucci seemed as though he could not be
bothered to see her and did not even advise her to seek emergency care. The most Soren managed to
get from Dr. Santucci was a reluctant agreement that he would check to see if he could get her in the
following day. Dr. DeLeon’s and Dr. Santucci’s combined breaches forced Soren to seek out
emergency treatment at the University of Texas Southwestern hospital in Dallas, Texas. There, the
emergency surgeons diagnosed Soren with “massive bilateral hematomas” (16cm on the left flank,
and 17cm on the right), re-opened the Crane Clinic incisions, and stitched in drains (which should
have been included in the original surgery) and drained significant amounts of accrued blood and

other bodily fluids. In addition to undergoing the pain and suffering this caused, Soren was then
forced to continue draining blood and fluids from her chest cavity for the following week. These
complications were never disclosed to Soren as a possibility, and indeed, when Dr. DeLeon informed
Soren of the details of the surgery, she provided materials showing surgeries that included drains and
was shown videos and pictures of other patients who had the surgery with drains. Soren was unaware
that the “drainless” surgery actually performed was a risky procedure rarely used by competent
practitioners.
62. Having had to pay out of pocket for her emergency treatment in Dallas, Soren sought
reimbursement from the Crane Clinic, whose practitioners botched the surgery and should have
treated her post-operative problems but refused to. The Crane Clinic initially failed to respond. After
repeated attempts, Soren finally got a response from the clinic. The CEO agreed to reimburse Soren
for the $421.31 she incurred in out-of-pocket expenses, but only on the condition that she quickly
sign a substantial, four-page agreement that included a punitive non-disparagement clause and other
complicated legal provisions, including a forfeiture of all her possible claims against the Crane Clinic.
After asking the Crane Clinic CEO to confirm that the Clinic would take measures to ensure similar
treatment never happened to future patients like her, and upon getting no response, Soren refused to
sign the agreement or to accept Crane Clinic’s payment.
vi. Soren starts questioning her treatments and discovers how her doctors had failed
her.
63. Following her problematic recovery from the Crane Clinic surgery, Soren began to
realize that neither the testosterone nor the double mastectomy had helped her feel entirely
comfortable in her body.
64. Discouraged by this realization, Soren began looking for and discovered a successful
alternative to resolve the issues with her gender identity through the simple practice of meditation and

mindfulness. Through this practice, Soren learned that her body was not the problem at all; the
problem was with her perception and expectation of her body that society and social media had all
but forced upon her.
65. In or around November 2021, after experiencing the almost immediate benefits of this
meditative approach to her issues, Soren began to wonder why each of the Defendants had so strongly
and quickly ushered her down this path of irreversible medicalization by way of cross-sex hormones
and physical mutilation to her body without ever considering, let alone attempting and ruling out, a
psychological resolution to her distress. The meditation practice allowed her to, for the first time,
clear her mind from the cloud of misguided influence each of these practitioners had been holding
over her for the prior years and to finally see their actions with clear, discerning eyes. This question
of why her doctors had fast-tracked her medicalization over taking a cautious, therapy-guided
approach plagued her and led her to ask other questions that began to open her eyes to the
wrongdoings of the Defendants.
66. After considerable thought and research, around November of 2021, Soren discovered
that the “gender-affirming care” she received from these Defendants was a controversial and
experimental practice with little reputable research or science supporting it.1 She realized that each
of these Defendants, reaching back to Dr. Nekkalapu, had recklessly, if not intentionally, overlooked
or ignored her sordid psychological history to justify the approach they had pre-determined to be right
for anyone similarly confused about their gender identity. She learned that others existed in the
transgender community who had, like her, been taken advantage of by their practitioners and led down
similar paths. She learned that certain organizations in the medical community published purported
1
Indeed, multiple European countries, including England, Sweden, Finland, and Norway, have all but banned
“gender-affirming” medicalization of minors after conducting systematic reviews of the available body of evidence
and concluding that there is low certainty of any benefits but high likelihood of numerous risks. See, e.g., Europe
Adopts A Cautious Approach To Gender-Affirming Care For Minors (forbes.com)

“standards of care” that required much more, even if still not enough, from practitioners prescribing
these kinds of treatments.2
67. Ultimately, what Soren realized is that over the rocky course of her adolescence, what
she needed was an unbiased doctor, not an idealogue. And upon these realizations, she immediately
felt and understood the wrongs she had suffered at the hands of the Defendants. With this lawsuit,
Soren now seeks redress for those wrongs.
2
WPATH described itself in its “Standards of Care, 7th Version” (hereinafter, “SOC 7”) as “an international,
multidisciplinary, professional association whose mission is to promote evidence-based care, education, research,
advocacy, public policy, and respect for transgender health.” While dubbed “Standards of Care,” WPATH clarified
that the goal of the publication is to provide “clinical guidance” and WPATH emphasized its role in promoting
public policy “advocacy.” Accordingly, WPATH’s “Standards of Care” are WPATH’s own self-professed guidance
and cannot be said to be equivalent to the applicable standard of care for legal purposes in this or any other case. See
also, e.g., New standards of transgender health care raise eyebrows: Controversial recommendations on everything
from transition to castration, The Economist, Sept. 22, 2022 (“[T]he public launch of the latest standards of care by
the World Professional Association for Transgender Health (WPATH) on September 15th was a mess. Known as
SOC8, they originally included a list of minimum ages for treatments—14 for cross-sex hormones, 15 for removal
of breasts, 17 for testicles. Hours later, a ‘correction’ eliminated the age limits.”) (emphasis added), available at
https://www.economist.com/united-states/2022/09/22/new-standards-of-transgenderhealth-care-raise-eyebrows. In
fact, at the WPATH annual conference in September 2022, Amy Tishelman, the lead author of SOC 8’s chapter on
adolescent treatment, explained that the very reason for the “correction” eliminating the age recommendations was
to address “the potential uses of the chapter for legal and insurance contexts . . . . What we didn’t want to do was
create a chapter that would make it more likely that practitioners would be sued because they weren’t following
exactly what we said.” Tishelman further explained that the change was to mitigate the “risk for being held in court
for not sticking completely to these standards” with the goal to “not face malpractice lawsuits.”

IX. CAUSES OF ACTION
Count 1. - Medical Negligence against Defendant Sreenath Nekkalapu
68. Plaintiff refers to and incorporates paragraphs 1 – 67 as if fully restated herein.
69. Plaintiff was a patient of Defendant Dr. Sreenath Nekkalapu, and as such, Dr.
Nekkalapu owed Soren a duty of care.
70. Dr. Nekkalapu breached that duty of care by, among other things, improperly
assessing, diagnosing, and/or counseling Soren concerning her gender identity, improperly coercing
Soren to adopt a gender identity she was not ready to adopt, and causing Soren to experience
psychological pressure to explore and travel a path towards transgender medicalization.
71. Dr. Nekkalapu further breached the duty he owed to Soren by violating her patient–
doctor confidentiality in disclosing Soren’s communications concerning her gender identity to
Soren’s parents and thus violated Texas Occupations Code § 159.009.
72. Defendant Nekkalapu’s negligence proximately caused and contributed to Soren’s
numerous economic, physical, and psychological injuries.
Count 2. - Respondeat Superior against Defendant Mesa Springs Hospital
74. At all times relevant, Defendant Dr. Nekkalapu was an agent, principal, employee, or
borrowed servant of Defendant Mesa Springs. Mesa Springs exercised control and/or supervision
over Dr. Nekkalapu’s ability to practice under the Mesa Springs name and within their facilities.
While within the course and scope of his duties or employment with Mesa Springs, Dr. Nekkalapu
committed numerous acts of negligence that proximately caused injury to Soren. Therefore, Mesa
Springs is vicariously responsible for the injuries caused by Dr. Nekkalapu’s negligence under the
doctrine of Respondeat Superior.

Count 3. - Medical Negligence and Gross Medical Negligence Against Defendant Del Scott
Perry
76. Plaintiff was a patient of Defendant Perry, and as such, Perry owed Plaintiff a duty of
care.
77. By providing Soren with cross-sex hormone injections during her first visit and
rushing her into this “gender affirming” treatment protocol, Perry was negligent and grossly negligent
in numerous ways. Given the severity of the risks inherent in prescribing an ongoing course of
experimental “gender-affirming” cross-sex hormone treatment, Perry recklessly disregarded the
safety and well-being of Soren where, among other things, prior to prescribing and administering
cross-sex hormones to Soren, Perry failed to:
a. thoroughly assess and consider Soren’s then-current and previous history of psychological
health comorbidities, including Soren’s diagnoses of major depressive disorder, ADHD,
autism spectrum disorder, obsessive compulsive disorder, social exclusion and rejection
disorder, and others (the “comorbidities”);
b. assess, consider, and rule out Soren’s other, diagnosed psychological comorbidities and
neurodivergences as a source of or contributing cause of her then-current gender
incongruence;
c. consult with or review treatment records from Soren’s previous mental health and other
medical providers;
d. to refer Soren to a licensed mental health professional with training and expertise in
treating gender dysphoric adolescents with complex psychological comorbidities and/or
neurodivergences or otherwise engage the help and consultation of such a mental health
expert;
e. undertake a comprehensive biopsychosocial assessment to rule out potential alternative

sources of Soren’s gender incongruence;
f. consider or discuss with Soren alternative, non-medicinal therapies available to address

her gender incongruence;
g. assess and consider the duration and/or degree of consistency of Soren’s experience of
gender incongruence;

h. consider Soren’s inability to understand and comprehend the risks and benefits and
provide informed consent for hormonal treatments due to her comorbidities;
i. inform Soren of all reproductive effects of the cross-sex hormones, including the potential
loss of fertility, and available options to preserve fertility;
j. obtain specialized training in treating gender dysphoric adolescents with complex

psychological comorbidities and neurodivergences;
k. consider the long-term best interest of Soren.
78. Perry’s intentional or reckless disregard for Soren’s safety and well-being is further
demonstrated by his failure to stop Soren’s cross-sex hormone treatments and conduct any of the
above comprehensive assessments when Soren began experiencing the numerous side effects and
complications arising from her use of the cross-sex hormones. Rather than evaluate whether the cross-
sex hormones were still appropriate for Soren given the complications she was experiencing, Perry
chose instead to continue the course of “gender-affirming” treatment and merely refer Soren out to
practitioners who could treat her symptoms as they arose.
79. Perry’s negligence and gross negligence proximately caused and contributed to
Soren’s numerous economic, physical, and psychological injuries.
Count 4. - Respondeat Superior against Defendant Texas Health Physicians Group
81. At all times relevant, Defendant Perry was an agent, principal, employee, or borrowed
servant of Defendant Texas Health Physicians Group. THPG exercised control and/or supervision
over Perry’s ability to practice under the THPG name and within their facilities. While within the
course and scope of his duties or employment with THPG, Perry committed numerous acts of
negligence and gross negligence that caused injury to Soren. Therefore, THPG is vicariously
responsible for the injuries caused by Perry’s negligence and gross negligence under the doctrine of
Respondeat Superior.

Count 5. - Negligence and Gross Negligence Against Defendant Texas Health Physicians
Group
83. Soren was a registered patient of THPG and Perry, a THPG practitioner. Because
Soren was a THPG patient receiving medical services at THPG facilities by a THPG practitioner,
THPG owed Soren a duty of care.
84. THPG breached that duty of care by, among other things, failing to enact and enforce
policies and procedures to properly train, supervise, oversee, audit, or control the provision of
“gender-affirming” treatments by THPG practitioners and to ensure all proper precautions are
followed before beginning a medicalized cross-sex hormone treatment plan for one of its patients.
85. Given the extreme risk of irreversible physical and psychological harm that could
befall, and in Soren’s case did befall, a patient who was put on a cross-sex hormone treatment plan
without first pre-assessing that patient for suitability, THPG’s failure to implement controls over its
practitioners prescription of such treatment plans and its failure to require comprehensive
psychological assessments prior to administering such treatment represent a reckless deviation from
the standard of care and a conscious indifference to the safety and welfare of its patients, like Soren.
86. THPG’s gross negligence in this respect, specifically its reckless disregard for the
safety and welfare of patients seeking or being prescribed cross-sex hormone therapies for “gender
affirming” purposes, proximately caused and contributed to Soren’s numerous economic, physical,
and psychological injuries.
Count 6. -Medical Negligence and Gross Medical Negligence against Defendant Barbara
Wood

88. Plaintiff was a patient of Defendant Wood, and as such, Wood owed Plaintiff a duty
of care.
89. Defendant Wood breached that duty of care and thus committed negligence and gross
negligence in numerous ways, including but not limited to authoring and signing a deceptive letter
containing numerous material falsehoods for the purpose of recommending and enabling Soren to
receive a double mastectomy. Given the irreversible nature of such a procedure and extreme risk to
Soren’s future livelihood if the surgery proved not to be appropriate for her in resolving her gender
incongruence issues, Wood’s cavalier approach to simply giving Soren the letter she wanted upon her
request demonstrates a severe departure from any recognized standard of care, an egregious lack of
required diligence before recommending such a procedure, and an overall reckless disregard for
Soren’s health, safety, and welfare.
90. In addition to preparing the falsified letter, Wood’s gross negligence is further
exemplified where, prior to authoring a letter in support of such a procedure and recommending the
procedure for Soren, Wood failed to:
a. thoroughly assess and consider Soren’s then-current and previous history of psychological
health comorbidities, including Soren’s diagnoses of major depressive disorder, ADHD,
autism spectrum disorder, obsessive compulsive disorder, social exclusion and rejection
disorder, and others in the context of assessing whether a double mastectomy would be
appropriate for Soren;
b. assess, consider, and rule out Soren’s other, diagnosed psychological comorbidities and
neurodivergences as a source of or contributing cause of her then-current gender
incongruence;
c. consult with or review treatment records from Soren’s previous mental health and other
medical providers;
d. undertake a comprehensive biopsychosocial assessment to rule out potential alternative

sources of Soren’s gender incongruence;
e. consider or discuss with Soren alternative, non-medicinal therapies available to address


f. assess and consider the duration and/or degree of consistency of Soren’s experience of
g. consider Soren’s inability to understand and comprehend the risks and benefits and
provide informed consent for a double mastectomy due to her comorbidities;
h. obtain specialized training in treating gender dysphoric adolescents with complex

psychological comorbidities and neurodivergences or refer Soren to a practitioner who
had such specialized training; and
i. consider the long-term best interest of Soren.
91. Wood’s negligence and gross negligence proximately caused and contributed to
Count 7. -Respondeat Superior against Defendant Three Oaks Counseling Group, LLC
93. At all times relevant, Defendant Wood was an agent, principal, employee, or
borrowed servant of Defendant Three Oaks. Three Oaks exercised control and/or supervision over
Wood’s ability to practice under the Three Oaks name and within its facilities. While within the course
and scope of her duties or employment with Three Oaks, Wood committed numerous acts of
negligence and gross negligence that caused injury to Soren. Therefore, Three Oaks is vicariously
responsible for the injuries caused by Wood’s negligence and gross negligence under the doctrine of
Respondeat Superior.
Count 8. - Negligence and Gross Negligence Against Defendant Three Oaks Counseling
Group, LLC
95. Soren was a registered patient of Three Oaks and Wood, a Three Oaks practitioner.
Because Soren was a Three Oaks patient receiving medical services at Three Oaks’ facilities by a
Three Oaks practitioner, Three Oaks owed Soren a duty of care.

96. Three Oaks breached that duty of care by, among other things, failing to enact and
enforce policies and procedures to properly train, supervise, oversee, audit, or control the provision
of “gender-affirming” therapy treatments by Three Oaks practitioners and to ensure all proper
precautions are followed before diagnosing a patient with gender dysphoria or authoring and signing
a recommendation letter for a double mastectomy or other “gender-affirming” medicalization for one
of its patients.
97. Given the permanent and lifelong psychological damage and physical disfigurement
that could befall a patient who underwent an ill-advised double mastectomy without first pre-
assessing that patient for suitability, Three Oaks’ failure to implement controls over its practitioner’s
recommendation and endorsement of such a treatment plan represent a reckless deviation from the
standard of care and a conscious indifference to the safety and welfare of its patients, like Soren.
98. Three Oaks’ gross negligence in this respect, specifically its reckless disregard for the
safety and welfare of patients seeking a recommendation letter for a double mastectomy for “gender
affirming” purposes, proximately caused and contributed to Soren’s numerous economic, physical,
and psychological injuries.
Count 9. -Medical Negligence and Gross Medical Negligence against Defendant Dr. DeLeon
100. Plaintiff was a patient of Defendant Dr. DeLeon, and as such, Dr. DeLeon owed
Plaintiff a duty of care.
101. Dr. DeLeon was negligent and grossly negligent in numerous ways including but not
limited to negligently approving and performing surgery on Soren and failing to provide any of the
necessary follow-up treatment that Soren required due to the complications arising from the
negligently performed surgery. Given the severity of the risks inherent in providing an irreversible

surgery on a patient struggling with mental health issues, Dr. DeLeon recklessly disregarded the safety
and welfare of Soren where, among other things, prior to performing that surgery on Soren, Dr.
DeLeon failed to:
a. talk at length with Soren or gain any meaningful insight into Soren’s complicated and
extensive mental and psychological health, as Dr. DeLeon approved her for surgery after a
single, brief telephone visit;
b. perform an independent psychological assessment or form an evidence-based, independent

judgment that the proposed surgical procedure was necessary and appropriate despite Soren’s
mental health issues;
c. contact or interact with any of the other health professionals who had previously provided
care to Soren;
d. establish or gain confidence that the referring mental health professionals were competent in
the assessment and treatment of gender dysphoria;
e. procure comprehensive medical records from any of Soren’s prior medical providers or
current therapists;
f. have a robust discussion with Soren covering: the limitations of a procedure to achieve “ideal”
results and provide a full range of before-and-after photographs of the clinic’s patients,
including both successful and unsuccessful outcomes; the inherent risks and possible
complications of a radical double mastectomy; inform Soren of the clinic’s own complication
rates with each procedure;
g. establish that Soren had persistent, well-documented diagnosis of gender dysphoria;
h. establish that Soren had the capacity at that time to make a fully informed decision;
i. attempt to make sure that Soren’s significant mental health concerns were reasonably well
controlled.
102. By failing to discuss these matters with Soren and confirm her capacity to comprehend
and understand them, Dr. DeLeon failed to give Soren the necessary information to enable Soren to
give informed consent.
103. Dr. DeLeon’s negligence and gross negligence continued by (1) failing to perform the
surgery to the appropriate standards, as evidenced by Soren’s need for emergency medical procedures
to fix her significant complications arising immediately after the surgery; and (2) failing to provide

any post-operative care, despite Soren pleading to be seen and informing Dr. DeLeon and her
colleagues of her significant complications.
104. Dr. DeLeon’s negligence and gross negligence proximately caused and contributed to
Count 10. -Medical Negligence and Gross Medical Negligence against Defendant Dr. Santucci
106. Plaintiff was a patient of Defendant Richard Santucci, and as such, Dr. Santucci owed
Plaintiff a duty of care.
107. Dr. Santucci was negligent in that when Soren contacted him as the on-call, Crane
Clinic physician when her emergency complications arose, Dr. Santucci breached his standard of care
by conducting little to no diligence to investigate Soren’s complications and dismissed or disregarded
all of her expressions of pain and concern. By immediately concluding, over the phone, that Soren’s
grotesque complications “were normal,” Dr. Santucci failed Soren as a doctor and abandoned Soren
to her own devices on seeking and obtaining emergency care. Given the severity of the risks inherent
in the possible complications arising post-surgery from a double mastectomy, and Dr. Santucci’s lack
of any discernable care for his patient experiencing those complications, Dr. Santucci was negligent
or grossly negligent and proximately caused Soren numerous economic, physical, and psychological
injuries.
Count 11. -Respondeat Superior against Crane Clinic, PLLC
109. At all relevant times, Defendants Dr. DeLeon and Dr. Santucci were agents,
principals, employees, or borrowed servants of Defendant Crane Clinic, PLLC. The Crane Clinic
exercised control and/or supervision over Dr. DeLeon’s and Dr. Santucci’s abilities to practice under

the Crane Clinic name and within their facilities. While within the course and scope of their duties
or employment with the Crane Clinic, Drs. DeLeon and Santucci committed numerous acts of
negligence and gross negligence that caused injury to Soren. Therefore, the Crane Clinic is
vicariously responsible for the injuries caused by Drs. DeLeon and Santucci’s negligence and gross
negligence under the doctrine of Respondeat Superior.
Count 12. - Negligence and Gross Negligence Against Crane Clinic, PLLC
111. Soren was a registered patient of the Crane Clinic, Dr. DeLeon, and Dr. Santucci, both
Crane Clinic surgeons. Because Soren was a Crane Clinic patient receiving medical services at Crane
Clinic’s facilities by Crane Clinic surgeons, Crane Clinic owed Soren a duty of care.
112. Crane Clinic breached that duty of care by, among other things, failing to enact and
enforce policies and procedures to properly train, supervise, oversee, audit, control, or prevent the
performance of “gender-affirming” surgeries by Crane Clinic surgeons so as to ensure all proper
precautions are followed to confirm the necessity for and appropriateness of the surgery for each
individual patient.
113. Crane Clinic’s gross negligence in this respect is further evidenced by the fact that
Crane Clinic offered Soren pre-selected medical providers who would provide Soren the necessary
recommendation letter simply upon her request if she so desired.
114. Given the extraordinary risks and significant probability of lifelong psychological
damage and physical disfigurement that could result for a patient who underwent an ill-advised double
mastectomy without first pre-assessing that patient for suitability, Crane Clinic’s failure to implement
such controls and safety measures over its surgeons pre-surgical diligence represent a reckless

deviation from the standard of care and a conscious indifference to the safety and welfare of its
patients, like Soren.
115. Further, Crane Clinic was negligent in failing to enact and/or enforce proper
procedures and protocols to ensure that adequate post-operative care was available and accessible by
post-surgical patients during their recovery.
116. Crane Clinic’s negligence and gross negligence, specifically its reckless disregard for
the safety and welfare of patients seeking a double mastectomy for “gender-affirming” purposes,
proximately caused Soren numerous economic, physical, and psychological injuries.
X. CONCLUSION AND PRAYER FOR DAMAGES
WHEREFORE, PREMISES CONSIDERED, Plaintiff Soren Aldaco respectfully prays that
upon final trial in this matter, the Court grant her a judgment for the following:
a) compensatory damages in an amount sufficient to fully compensate Plaintiff for all

physical pain and suffering, emotional distress, medical expenses, loss of income, loss of
consortium, physical disfigurement, and mental anguish suffered.
b) exemplary damages to punish the Defendants for their gross negligence and to deter
others in the medical profession from engaging in similar conduct in the future.
c) prejudgment and post-judgment interest as allowed by law.
d) and for all such other and further relief, both general and special, at law and in equity, to
which Plaintiff may show to be justly entitled.
XI. JURY DEMAND
Plaintiff respectfully demands a trial by jury on all issues so triable as a matter of right.
Respectfully submitted,
Ronald L. Miller
State Bar No. 24095424
[email protected]
Jordan Campbell

[email protected]
Daniel Sepulveda
[email protected]
CAMPBELL MILLER PAYNE, PLLC

5955 Alpha Rd #1491
Dallas, Texas 75240
Telephone: (214) 316-7156

Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Ron Miller on behalf of Ron Miller

Bar No. 24095424
[email protected]
Envelope ID: 77762081
Filing Code Description: Petition
Filing Description: Plaintiff's Original Petition
Status as of 7/21/2023 1:07 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Ron Miller [email protected] 7/21/2023 12:47:44 PM SENT
Jordan Campbell [email protected] 7/21/2023 12:47:44 PM SENT
Daniel Sepulveda [email protected] 7/21/2023 12:47:44 PM SENT

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FILED

PLAINTIFF’S ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

PERRY, an individual, SREENATH NEKKALAPU, an individual, BARBARA ROSE WOOD,

an individual, RICHARD SANTUCCI, an individual, ASHLEY DELEON, an individual, CRANE

CLINIC, PLLC, a professional limited liability company, TEXAS HEALTH PHYSICIANS

GROUP, THREE OAKS COUNSELING GROUP, LLC, at times doing business as

PLAINTIFF’S ORIGINAL PETITION PAGE 1

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respectfully show the Court the following:

I. DISCOVERY CONTROL PLAN AND REQUEST FOR DISCLOSURES

Rule 194.2 within 30 days of filing an answer in this cause.

2. This lawsuit details a chronology of wrongful acts committed by a collective of

medical providers who, in their pursuit of experimental “gender-affirming” medical therapies,

physical and mental health and quality of life.

PLAINTIFF’S ORIGINAL PETITION PAGE 2

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5. Plaintiff is an individual who resides in Tarrant County, TX.

to reside in and provided medical services to Plaintiff in Tarrant County, Texas.

7. Defendant Sreenath Nekkalapu, M.D., (“Dr. Nekkalapu”) is an individual who is

8. Defendant Barbara Rose Wood, LCSW, LCDC (“Wood”) is an individual who is

9. Defendant Richard Santucci, M.D., (“Dr. Santucci”) is an individual who is believed

Cave Road, Suite 612, Austin, Texas 78746.

PLAINTIFF’S ORIGINAL PETITION PAGE 3

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13. Defendant Texas Health Physicians Group (“THPG”) is a corporation registered in

V. VENUE & JURISDICTION

limits of this Court. Plaintiff is seeking monetary relief exceeding $1,000,000.00.

residents of the State of Texas.

VI. OPEN COURTS

PLAINTIFF’S ORIGINAL PETITION PAGE 4

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21. Plaintiff has a well-established common-law cause of action in medical negligence

provision would be satisfied so as to allow the claim to survive challenge.

VII. CHAPTER 74 NOTICE REQUIREMENTS HAVE BEEN SATISFIED

(authorization form requirement).

i. Soren struggled with her identity from an early age.

her to deeply dislike her physical appearance.

friends, Soren began wondering if maybe she was transgender too.

PLAINTIFF’S ORIGINAL PETITION PAGE 5

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a small group of close friends and a couple of trusted teachers.

this time, Soren’s psychological troubles only worsened.

Psychiatric Hospital in Fort Worth, Texas.

ii. Dr. Nekkalapu betrays Soren’s doctor/patient confidentiality and pressures

Dr. Sreenath Nekkalapu for a period of three days.

PLAINTIFF’S ORIGINAL PETITION PAGE 6

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first time ever speaking about it with a medical professional.

31. Notably, Dr. Nekkalapu did not do any meaningful or comprehensive

transgender, and he comforted her that he would not.

she had previously achieved.

PLAINTIFF’S ORIGINAL PETITION PAGE 7

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violation of Texas statutory law.