Federal Defamation Complaint and Responses: Petrou v. Kazerooni (2019)
In April 2019, Dr. Myria Petrou filed a federal civil complaint against Dr. Ella Kazerooni in the United States District Court for the Southern District of New York. The matter was later transferred to the United States District Court for the Eastern District of Michigan.
At the time of the events described in the complaint, Dr. Kazerooni served as Division Director of Cardiothoracic Radiology at the University of Michigan and was Dr. Paul Cronin’s direct departmental supervisor. Dr. Kazerooni later became Interim Chair of the Department of Radiology in early 2018.
The complaint asserted causes of action against Dr. Kazerooni for defamation, intentional infliction of emotional distress, tortious interference with contract, wrongful death, and retaliation under the Sarbanes-Oxley Act. The excerpts reproduced below focus specifically on the defamation-related allegations and responses.
The complaint alleged that Dr. Kazerooni propagated, amplified, documented, repeated, or failed to correct allegedly defamatory statements concerning Dr. Petrou. According to the complaint, those statements were disseminated through emails, institutional reporting channels, annual review materials, and communications involving third parties, including allegations associated with an unidentified individual referred to as “Nick B.”
The unidentified individual using the name “Nick B.” allegedly claimed in communications forwarded to the University of Michigan Office of General Counsel that Dr. Ella Kazerooni was both his and Dr. Cronin’s “boss” within the University of Michigan Department of Radiology.
Additional allegations concerned statements relating to Dr. Petrou’s professional fitness, mental soundness, licensing, and communications involving law-enforcement and institutional reporting channels.
The excerpts below include allegations concerning defamatory emails and false sexual/criminal allegations, statements contained in Dr. Petrou’s August 31, 2018 annual review, the complaint’s formal “First Cause of Action — Defamation,” Dr. Kazerooni’s responses, and selected affirmative defenses concerning falsity, malice, recklessness, and publication.
The documents are presented in excerpted form for archival and reference purposes.
Federal Complaint
Federal Complaint Filed by Dr. Myria Petrou Against Dr. Ella Kazerooni (April 2019)
Complaint Allegations Concerning Reporting of “Nick B” Allegations to Drs. Reed Dunnick and Ashok Srinivasan
Complaint Allegations Concerning Defamatory Emails and “Nick B” Communications
Complaint Excerpts Concerning “Nick B,” Alleged False Criminal Allegations and Forwarding of “Nick” Recordings to Dr. Ella Kazerooni
Complaint Allegations Concerning August 31, 2018 Annual Review Statements
First Cause of Action — Defamation (Part I)
First Cause of Action — Defamation (Part II)
The response filed on behalf of Dr. Kazerooni admitted only that Dr. Petrou forwarded the "Nick B" recording(s) to Dr. Kazerooni in May 2018, while otherwise stating that Dr. Kazerooni lacked knowledge or information sufficient to form a belief concerning the remaining allegations relating to “Nick B.” The response further stated that “Nick B,” if such individual existed, was not Dr. Kazerooni’s agent and denied allegations relating to Dr. Kazerooni’s knowledge of “Nick B” or the underlying allegations.
Defendant’s Responses
Defendant Dr. Ella Kazerooni’s Responses to Complaint Allegations Concerning “Nick B” Recordings and Related Allegations
Defendant Dr. Ella Kazerooni’s Response Concerning August 31, 2018 Annual Review Statements
Defendant Dr. Ella Kazerooni’s Responses to Defamation Allegations (Part I)
Defendant Dr. Ella Kazerooni’s Responses to Defamation Allegations (Part II)
Selected Affirmative Defenses
Selected Affirmative Defenses Concerning Falsity and Defamatory Statements
Selected Affirmative Defenses Concerning Knowledge, Recklessness, and Negligence
The action was later dismissed without prejudice in September 2019 after Dr. Myria Petrou relocated with her family to Cyprus to secure employment and housing and did not continue pursuing the litigation at that time.
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Brad Foerster, MD PhD
Brad Foerster is a FOIA advocate documenting requests, transparency disputes, and accountability investigations involving public agencies, universities, police oversight, and Russia-Gate related inquiries. His work compiles original documents, timelines, and analysis of public records and institutional responses. Brad is also a board-certified radiologist, author of Town & Gown, and has published over 40 peer-reviewed articles. Brad lives in Potomac, Maryland with his family and is active in the Montgomery County Medical Society and the Takoma Park U.S. & World History Book Club.