TMZ broke the story -- Joe was gunning for AEG by filing complaints with the California Medical Board and another agency, alleging the concert promoter abused Jackson in a way that led to his death -- and he's just filed with the Medical Board.
Joe claims days before Jackson's death Murray had requested a heart resuscitation machine and a nurse in several e-mails making the request, but AEG never provided it.
According to the complaint, Joe is accusing AEG of co-opting Murray's medical judgment by enticing him with a huge salary -- in effect engaging in the "unlawful practice of corporate medicine."
Besides the CPR machine, Murray also asked for saline, catheters, needles and a gurney.
AEG and Murray had no comment.