NOTICE OF INTENT TO INITIATE LITIGATION UNDER §766.106, FLORIDA STATUTES
Date: October 09, 2025
To:
HCA Florida Healthcare
Legal Department / Registered Agent
4500 San Pablo Road
Jacksonville, FL 32224
and
Joseph A. Alvarez, Esq.
Sussman, Johnson & Alvarez Family Law
1200 Riverplace Blvd, Suite 850
Jacksonville, FL 32207
Dear HCA Florida Healthcare and Mr. Alvarez:
Please take notice that I, Ali Eslami, intend to initiate litigation against HCA Florida Healthcare and Dr. Andrew Freeth, M.D., pursuant to Chapter 766, Florida Statutes, for unauthorized prescribing, medical negligence, emotional distress, and related torts.
Dr. Freeth, an emergency-room physician with no behavioral-health specialization or credentialing, unlawfully used his prescribing authority to issue psychotropic or behavioral-health medications to his ex-wife despite the absence of any legitimate physician–patient relationship. These prescriptions were issued outside any authorized clinical context, without consent, evaluation, or medical justification.
Even representatives from the Florida Department of Children and Families (DCF), upon learning of the circumstances during the false-positive incident, expressed concern that a licensed physician had prescribed medication to his ex-wife. When DCF inquired who her doctor was and learned it was her ex-husband, they explicitly noted that such conduct was highly inappropriate and represented a clear conflict of interest.
Those unauthorized actions resulted in a false-positive fentanyl test during a DCF screening, triggering public humiliation, loss of family connection, emotional trauma, and reputational injury to me as her partner. Despite multiple clean DCF and independent toxicology tests, I was falsely accused of substance use and subjected to severe public and online harassment.
The misuse of a medical license for personal or retaliatory purposes, coupled with coordinated efforts with his ex-wife’s family to disseminate private and sensitive content online, demonstrates willful and malicious conduct. Dr. Freeth has also used the DCF incident — which resulted directly from his own improper prescribing — as a weapon in his ongoing custody litigation, attempting to portray others negatively while concealing his own misconduct.
Having worked in healthcare information technology for over fourteen years, I am familiar with the standard business-intelligence, compliance, and quality-of-care monitoring systems that hospitals use to detect irregular prescribing. Such systems should have identified and flagged Dr. Freeth’s unauthorized activity, making the continuation of these practices a failure of oversight and compliance within HCA Florida Healthcare.
Given his continued affiliation with HCA Florida Healthcare, your institution bears potential vicarious liability for negligent supervision, credentialing, and failure to monitor misuse of prescribing privileges.
Pursuant to §766.106, Florida Statutes, you are hereby notified to conduct a presuit investigation and provide a written response within ninety (90) days of receipt of this notice. This notice is served in good faith and in full compliance with Florida law.
