License No.150206_ Boris Kirkun_ M.D

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License No.150206_ Boris Kirkun_ M.D Powered By Docstoc
					                                                   New York State Board for Professional Medical Conduct
                                                          433 River Street, Suite 303 Troy, New York 12180-2299    l   (518) 402-0863

Dennis P. Whalen                                                                                         William P. Dillon, M.D.
  Executive Deputy Commissionef of H&t;i                                                                          Chair
Anne F. Saile, Director                                                                                  Denise M. Bolan, R.P.A.
   Oifice of Professional Medical Conduct                                                                    Vice Chair
William J. Comiskey, Chief Counsel                                                                      An.4 R. Marks, M.D., J.D.
  Bureau of Professional Medical Conducl                                                                  Executive Secretary



                                                          April l&l999

   CERTIFIED MAIL-RETURN                      RECEIPT’ REQUESTED

  Boris Krikun, M.D.
   66-36 Yellowstone Boulevard
   Apt. 8A
   Forest Hills, New York 11375

                                                          RE:      License No. 150206

   Dear Dr. Krikun:

         Enclosed please find Order #BPMC 99-74 of the New York State Board for Professional
   Medical Conduct. This Order and any penalty provided therein goes into effect April 12,1999.

           If the penalty imposed by the Order is a surrender, revocation or suspension of this
   license, you are required to deliver to the Board the license and registration within five (5) days
   of receipt of the Order.

                                            Board for Professional M&lical Conduct
                                            New York State Department of Health
                                            Hedley Park Place, Suite 303
                                            433 River Street
                                            Troy, New York 12180

                                                          Sincerely,



                                                          Ansel R. Marks, M.D., J.D.
                                                          Executive Secretary
                                                          Board for Professional Medical Conduct

   Enclosure
   cc:    Amy Ku/b, Esq.
          Jacobsen & Goldberg, LLP
          585 Stewart Avenue
          Garden City, NY 11530

             Steven J. Masef
\       ‘.
    .



             NEW YORK STATE                         DEPARTMENT OF HEALTH
             STATE BOARD FOR PROFESSIONAL MEDICAL CONDUCT
              ~~~_____~________~~~-~~~~~~____‘--______~~~~~~~~~____________________,
               I                                                                    I
               I
               I                      IN THE MATTER                                 I
                                                                                    i   SURRENDER
               I
               I
                                                OF                                  I
               I                                                                    f       OF
               I                                                                    I
               I                    BORIS KRIKUN, M.D.                              I    LICENSE
               I
               L-~~~~~~-----~-~~----___________,___,___~~~~~~~~~~~~~~~~~~~~~~~~~~~~ i
                                                                                         BPMC #99-74

             STATE OF NEW YORK              )

             COUNTY OF QUEENS              )       “‘:

                    BORIS KRIKUN, M.D., being duly sworn, deposes and says:

                    On or about May 28, 1982, I was licensed to practice medicine as a physician
             in the State of New York having been issued License No. 150206 by the New York
             State Education Department.


                    My current address is 66-36 Yellowstone Boulevard, Apt. 8A, Forest Hills,
             N.Y. 11375, and I will advise the Director of the Office of Professional Medical
             Conduct of any change of my address.               .



                    I   understand that I have been charged with One Hundred Thirty Three        (133)

             specifications of professional misconduct as set forth in the Amended Statement of
             Charges, annexed hereto, made a part hereof, and marked as Exhibit “A”.
                                                       .


                    I   am applying to the State Board for Professional Medical Conduct for
             permission to surrender my license as a physician in the State of New York on the
             grounds that I do not contest specification 79 in full satisfaction of the Statement of
             Charges.


                     I hereby make this application to the State Board for Professional Medical
             Conduct and request that it be granted.
.



                I understand that, in the event that the application is not granted by the State
         Board for Professional Medical Conduct, nothing contained herein shall be binding
         upon me or construed to be an admission of any act of misconduct alleged or
         charged against me, such application shall not be used against me in any way, and
         shall be kept in strict confidence during the pendency of the professional misconduct
         disciplinary proceeding; and such denial by the State Board for Professional Medical
         Conduct shall be made without prejudice to the continuance of any disciplinary
         proceeding and the final determination by a Committee on Professional Medical
         Conduct pursuant to the provisions of the Public Health Law.


               I agree that, in the event the State Board for Professional Medical Conduct
         grants my application, an order shall be issued striking my name from the roster of
         physicians in the State of New York without further notice to me.     I agree that such
         order shall be effective upon issuance by the Board, which may be accomplished by
         mailing, by first class mail, a copy of the Surrender Order to me at the address set
         forth in this agreement, or to my attorney, or upon transmission via facsimile to me
         or my attorney, whichever is earliest.     *



               I am making this Application of my own free will and accord and not under
         duress, compulsion or restraint of any kind or manner. In consideration of the value
    i.   to me of the acceptance by the Board of this Application, allowing me to resolve this
         matter without the various risks and burdens of a hearing on the merits,        I knowingly
         waive any right I may have to contest the Surrender Order for which      I   hereby apply,
         whether administratively or judicially, and ask that the Application be granted.


                                                      .
                                                    a/4@q
         AFFIRMED:
                                                  BORISKRIKUN, M.D./
         DATED      03.2 6.49                     RESPONDENT


                                                        2
    The undersigned agree to the attached application of the Respondent to surrender
    his license.



                                          v4.muJ    d h%ur
                                         AMY
                                         Attorney for Respondent



    Date:    3 3/
            -&z-                         ~
                                         Bureau of Professional
                                          Medical Conduct




                                                                  edical Conduct




                                              3
.
NEW YORK STATE           DEPARTMENT OF HEALTH
STATE BOARD FOR PROFESSIONAL MEDICAL CONDUCT
  I                                                                    i
  I                      IN THE MATTER                                 I
                                                                           SURRENDER
                                                                       I
 II                                                                    I
                                  OF                                         ORDER
 i                                                                     i
  i                                                                    i
 I                    BORIS KRIKUN, M.D.                               I
 I                                                                     I
 ?_________________________________________________________________~


       Upon the proposed agreement of Boris Krikun, M.D. (Respondent) to
Surrender his license as a physician in the State of New York, which proposed
agreement is made a part hereof, it is agreed to and
       ORDERED, that the application and the provisions thereof are hereby
adopted; it is further
       ORDERED, that the name of Respondent be stricken from the roster of
physicians in the State of New York; it is further
       ORDERED, that this order shall be effective upon issuance by the Board,
which may be accomplished by mailing, by first class mail, a copy of the Surrender
Order to Respondent at the address set forth in this agreement or to Respondent’s
attorney by certified mail, or upon transmission via facsimile to Respondent or
Respondent’s attorney, whichever is earliest.


       SO ORDERED.




DATED:         q&/57
                                                     Chair
                                                     State Board for Professional
                                                       Medical Conduct
                                     EXHIBIT
                                     -~ "A"

  NEW YORK STATE                            DEPARTMENT OF HEALTH
 STATE BOARD FOR PROFESSIONAL MEDICAL CONDUCT
r-----------‘------‘““““‘-------~~~~~~~~~ ________________“‘____________~
I                                                                         I    AMENDED
                                 IN THE MATTER                                STATEMENT
i                                                                        i
                                   OF                                            OF
I                                                                        i
I                     BORIS KRIKUN, M.D.                                 I
                                                                         I    CHARGES
I__________________________--_-__________~~~~~~~~~~~~~~~~~~-~~~~~~__~



          BORIS KRIKUN, M.D., the Respondent, was authorized to practice medicine
    in New York State on or about May 28, 1982, by the issuance of license number
    150206 by the New York State Education Department.


                                    FACTUAL ALLEGATIONS
A.        Between on or about March 4, 1995 and March 30, 1997, Respondent treated
          Patient A, a 67 year old female, for chronic pancreatic cancer and other
          medical conditions at his office located at 62-60 108th Street, Forest Hills,
          New York.
          1.    Respondent repeatedly throughout the course of treatment
                a)      failed to conduct an adequate‘physical examination and/or other
                        necessary examinations/evaluations on Patient A or to note such
                        physical and other examination/evaluation if any;

                b)      failed to obtain an adequate medical history or note such history if
                                            I
                        any;
          2.    Respondent repeatedly throughout the course of treatment failed to
                adequately follow-up on Patient A’s medical condition or note such
                follow-up if any;
          3.    Respondent repeatedly throughout the course of treatment
                inappropriately prescribed Dilaudid, Percocet, controlled substances,
                and Zyban to Patient A;
            4      Respondent engaged in these prescribing practices for purposes
                   other than the good faith practice of medicine;
     4.     Respondent failed to maintain a record for Patient A which accurately
            reflects the care and treatment provided to Patient A.
     5.     Respondent failed to provide the Department of Health with Patient A’s
            medical record pursuant to its request received by Respondent on or
           about April 30, 1998.


B.   Between on or about April 28,1995 and October 17, 1996, Respondent
     treated Patient B, a 67 year old female, for arthritis and other medical
     conditions at his office
     1.     Respondent repeatedly throughout the course of treatment

            a)    failed to conduct an adequate physical examination and/or other
                   necessary examinations/evaluations on Patient B or to note such
                   physical and other examination/evaluation if any;
            b)     failed to obtain an adequate medical history or note such history if
                                           .
                   any;

     2.     Respondent repeatedly throughout the course of treatment failed to
            adequately follow-up on Patient B’s medical condition or note such
           follow up if any;
     3.     Respondent repeatedly throughout the course of treatment
            inappropriately prescribed. Dilaudid, Percocet, controlled substances
            and Zyban to Patient B;
            a)     Respondent engaged in these prescribing practices for purposes
                   other than the good faith practice of medicine;
     4.     Respondent failed to maintain a record for Patient B which accurately
            reflects the care and treatment provided to Patient B.
                                               3
                                               L
     5.     Respondent failed to provide the Department of Health with Patient B’s
            medical record pursuant to its request received by Respondent on or
            about April 30, 1998.


C.   Between on or about March 4, 1995 and March 30, 1997, Respondent treated
     Patient C, a 48 year old male, for bladder cancer and other medical conditions
     at his office
     1.     Respondent repeatedly and throughout the course of treatment
            a)       failed to conduct an adequate physical examination and/or other
                     necessary examinations/evaluations on Patient C or to note such
                     physical and other examination/evaluation if any;

            b)       failed to obtain an adequate medical history or note such history
                     if any;
     2.     Respondent repeatedly throughout the course of treatment failed to
            adequately follow-up on Patient A’s medical condition or note such
            follow-up if any;
     3.     Respondent repeatedly throughout the course of treatment
            inappropriately prescribed Percocet, a controlled substance, and Zyban,
            to Patient C;
            a)       Respondent engaged in these prescribing practices for purposes
                     other than the good faith practice of medicine;
                                     I
     4.     Respondent failed to maintain a record for Patient C which accurately
            reflects the care and treatment provided to Patient C.
     5.     Respondent failed to provide the Department of Health with Patient C’s
            medical record pursuant to its request received by Respondent on or
            about April 30, 1998.


                                             3
D.   Between on or about December 30,1996 and May 5,1997, Respondent
     treated patient D, a 37 year old male, for abdominal pain and other medical
     conditions at his office
     1.       Respondent repeatedly and throughout the course of treatment
              a)    failed to conduct an adequate physical examination and/or other
                    necessary examinations/evaluations on Patient D or to note such
                    physical and other examination/evaluation if any;

              b)    failed to obtain an adequate medical history or note such history if
                    any;
     2.       Respondent repeatedly and throughout the course of treatment failed to
              adequately follow-up on Patient D’s medical condition;
     3.       Respondent repeatedly throughout the course of treatment
              inappropriately prescribed Dolophine, a controlled substance, and
              Zyban to Patient D;
              a)    Respondent engaged in these prescribing practices for purposes         /

                    other than the good faith practice of medicine;
     4.       Respondent failed to maintaih a record for Patient D which accurately
              reflects the care and treatment provided to Patient D.
     5.       Respondent failed to provide the Department of Health with Patient D’s           1

              medical record pursuant to its request received by Respondent on or              I
              about April 30,1998.                                                             /
                                     .                                                         /


E.   Between on or about June 24,1996 and May 24,1997, Respondent treated
     Patient E, a 76 year old male, for leg pain and other medical conditions at his
     office
     1.       Respondent repeatedly throughout the course of treatment
              a)    failed to conduct an adequate physical examination and/& other

                                            4
                 necessary eXaminatiOnS/eVahatiOnS on Patient E or to note such
                 physical and other examination/evaluation if any;
          b)     failed to obtain an adequate medical history or note such history if
                 any;
    2.    Respondent repeatedly throughout the course of treatment failed to
          adequately follow-up on Patient E’s medical condition or note such
          follow-up if any;
    3.    Respondent repeatedly throughout the course of treatment
          inappropriately prescribed Percocet, a controlled substance, and Zyban,
          to Patient E;

          a)     Respondent engaged in these prescribing practices for purposes
                 other than the good faith practice of medicine;
    4.    Respondent failed to maintain a record for Patient E which accurately
          reflects the care and treatment provided to Patient E.
    5.    Respondent failed to provide the Department of Health with Patient E’s
          medical record pursuant to its request received by Respondent on or
          about April 30, 1998.          *



F   Between on or about February 21,1995 and April 21,1997, Respondent
    treated Patient F, a 75 year old female, for Causalgia, breast cancer and other
    medical conditions at his office
                                   .
    1.    Respondent repeatedly and throughout the course of treatment
          4      failed to conduct an adequate physical examination and/or other
                 necessary examinations/evaluations on Patient F or to note such
                 physical and other examination/evaluation if any;
          b)     failed to obtain an adequate medical history or note such history if
                 any;
                                         5
     2.    Respondent repeatedly throughout the course of treatment failed to
           adequately follow-up on Patient F’s medical condition or note such
           follow-up if any;
     3.    Respondent repeatedly throughout the course of treatment
           inappropriately prescribed Dilaudid, a controlled substance, and Zyban
           to Patient F;

           a)      Respondent engaged in these prescribing practices for purposes
                   other than the good faith practice of medicine;
     4.     Respondent failed to maintain a record for Patient F which accurately
            reflects the care and treatment provided to Patient F.
     5.     Respondent failed to provide the Department of Health with Patient F’s
            medical record pursuant to its request received by Respondent on or
           about April 30, 1998.


G.   Between on or about March 16, 1995 and April 1, 1997, Respondent treated
     Patient G, a 38 year old female, for ovarian cancer and other medical
     conditions at his office
     1.     Respondent repeatedly throughout the course of treatment

            a)     failed to conduct an adequate physical examination and/or other
                   necessary examinations/evaluations on Patient G or to note such
                   physical and other examination/evaluation if any;
                                   .
            b)     failed to obtain an adequate medical history or note such history if
                   any;
     2.     Respondent repeatedly and throughout the course of treatment failed to
            adequately follow-up on Patient G’s medical condition or note such
            follow-up, if any;
     3.     Respondent repeatedly throughout the course of treatment

                                           6
                inappropriately prescribed Dilaudid, Percocet, controlled substances
                and Wellbutrin to Patient G;

                a)     Respondent engaged in these prescribing practices for purposes
                      other than the good faith practice of medicine;
         4.     Respondent failed to maintain a record for Patient G which accurately
                reflects the care and treatment provided to Patient G.
         5.     Respondent failed to provide the Department of Health with Patient G’s
                medical record pursuant to its request received by Respondent on or
                about April 30, 1998.


    H.   Between on or about January lo,1997 and May 12,1997, Respondent
         treated Patient H, a 32 year old female, for radiculitis and other medical
         conditions at his office
         1.     Respondent repeatedly throughout the course of treatment
                a)    failed to conduct an adequate physical examination and/or other
                      necessary examinations/evaluations on Patient H or to note such
                       physical and other exainination/evaluation if any;
                b)    failed to obtain an adequate medical history or note such history if
                      any;
         2.     Respondent repeatedly throughout the course of treatment failed to

i               adequately follow-up on Patient H’s medical condition or note such
                                      .
               follow up if any;
         3.     Respondent repeatedly throughout the course of treatment
                inappropriately prescribed Dolophine, a controlled substance and
                Wellbutrin to Patient H;
                a)     Respondent engaged in these prescribing practices for purposes
                       other than the good faith practice of medicine;

                                               7
     4.       Respondent failed to maintain a record for Patient l-l which accurately
              reflects the care and treatment provided to Patient H.
     5.       Respondent failed to provide the Department of Health with Patient H’s
              medical record pursuant to its request received by Respondent on or
              about April 30, 1998.


I.   Between on or about February 3, 1995 and March 28, 1997, Respondent
     treated Patient I, a 31 year old male, for abdominal pain and other medical
     conditions at his office
     1.       Respondent repeatedly throughout the course of treatment
              a)    failed to conduct an adequate physical examination and/or other
                    necessary examinations/evaluations on Patient I or to note such
                    physical and other examination/evaluation if any;
              b)    failed to obtain an adequate medical history or note such history if
                    any;
     2.       Respondent repeatedly throughout the course of treatment failed to
              adequately follow-up on Patient I’s medical condition or note such
              follow-up if any;
     3.       Respondent repeatedly throughout the course of treatment
              inappropriately prescribed Dilaudid, Percocet, controlled substances
              and Wellbutrin to Patient I;
                                    a

              a)     Respondent engaged in these prescribing practices for purposes
                     other than the good faith practice of medicine;
     4.   _   Respondent failed to maintain a record for Patient I which accurately
              reflects the care and treatment provided to Patient I.
     5.       Respondent failed to provide the Department of Health with Patient I’s
              medical record pursuant to its request received by Respondent on or

                                             8
           about April 30, 1998.


J.   Between on or about March 2, 1995 and March 23, 1997, Respondent
     treated Patient J, a 29 year old male, for an unspecified pain and/or
     malignancy and other medical conditions at his office
     1.    Respondent repeatedly and throughout the course of treatment
           a)     failed to conduct an adequate physical examination and/or other
                  necessary examinations/evaluations on Patient J or to note such
                  physical and other examination/evaluation if any;
           b)     failed to obtain an adequate medical history or note such history if
                  any;
     2.    Respondent repeatedly and throughout the course of treatment failed to
           adequately follow-up on Patient J’s medical condition;
     3.    Respondent repeatedly throughout the course of treatment
           inappropriately prescribed Dilaudid, a controlled substance and
           Wellbutrin to Patient J;

           a>     Respondent engaged in these prescribing practices for purposes
                  other than the good faith practice of medicine;
     4.    Respondent failed to maintain a record for Patient J which accurately
           reflects the care and treatment provided to Patient J.
     5.    Respondent failed to provide the Department of Health with Patient J’s
           medical record pursuant to its request received by Respondent on or
           about April 30, 1998.


K.   Between on or about October 21, 1996 and May 26, 1998, Respondent
     treated Patient K, a 45 year old male, for pain and nephrolithiasis and other
     medical conditions at his office

                                          9
     1.       Respondent repeatedly throughout the course of treatment

              a)     failed to conduct an adequate physical examination and/or other          1

                     necessary examinations/evaluations on Patient K or to note such
                     physical and other examination/evaluation if any;
              b)     failed to obtain an adequate medical history or note such history   if
                     any;
     2.       Respondent repeatedly throughout the course of treatment failed to
              adequately follow-up on Patient K’s medical condition or note such
              follow-up if any;
     3.       Respondent repeatedly throughout the course of treatment
              inappropriately prescribed Methadone, a controlled substance, and
              Zyban to Patient K;

              a)     Respondent engaged in these prescribing practices for purposes
                     other than the good faith practice of medicine;
     4.       Respondent failed to maintain a record for Patient K which accurately
              reflects the care and treatment provided to Patient K.
     5.       Respondent failed to provide the Department of Health with Patient K’s
              medical record pursuant to its request received by Respondent on or
              about April 30, 1998.


L.   Between on or about February 9, 1995 and March 20,1997, Respondent
     treated Patient L, a 38 year old male for unspecified pain and malignancy
     and other medical conditions at his office
     1.   -   Respondent repeatedly and throughout the course of treatment
              a)     failed to conduct an adequate physical examination and/or other          ,

                     necessary examinations/evaluations on Patient L or to note such              1

                     physical and other examination/evaluation if any;

                                            10
          b)     failed to obtain an adequate medical history or note such history if
                 any;
    2.    Respondent repeatedly throughout the course of treatment failed to
          adequately follow-up on Patient L’s medical condition or note such
          follow-up if any;
    3.    Respondent repeatedly throughout the course of treatment
          inappropriately prescribed Dilaudid, Percocet, controlled substances
          and Wellbuttin to Patient L;
          a)     Respondent engaged in these prescribing practices for purposes
                 other than the good faith practice of medicine;
    4.    Respondent failed to maintain a record for Patient L which accurately
          reflects the care and treatment provided to Patient L.
    5.    Respondent failed to provide the Department of Health with Patient L’s
          medical record pursuant to its request received by Respondent on or
          about April 30, 1998.


M   Between on or about February 21,1995 and May 23, 1997, Respondent
    treated Patient M, a 74 year old female, for breast cancer, phantom pain and
    other medical conditions at his office
    1.    Respondent repeatedly and throughout the course of treatment
          a)     failed to conduct an adequate physical examination and/or other
                 necessary examinations/evaluations on Patient M or to note such
                 physical and other examination/evaluation if any;
          b)     failed to obtain an adequate medical history or note such history if
                 any;
    2.    Respondent repeatedly and throughout the course of treatment failed to
          adequately follow-up on Patient M’s medical condition or note such

                                         11
           follow-up if any;
     3.    Respondent repeatedly throughout the course of treatment
           inappropriately prescribed Dilaudid, a controlled substance and Zyban
           to Patient M;
           a)     Respondent engaged in these prescribing practices for purposes
                  other than the good faith practice of medicine;
     4.    Respondent failed to maintain a record for Patient M which accurately
           reflects the care and treatment provided to Patient M.
     5.    Respondent failed to provide the Department of Health with Patient M’s
           medical record pursuant to its request received by Respondent on or
           about April 30, 1998.


N.   Between on or about February 21, 1995 and May 14, 1997, Respondent
     treated patient N, a 63 year old female for multiple sclerosis, neuralgia and
     other medical conditions at his office
     1.    Respondent repeatedly throughout the course of treatment
           a)     failed to conduct an adequate physical examination and/or other
                  necessary examinations/evaluations on Patient N or to note such
                  physical and other examination/evaluation if any;
           b)     failed to obtain an adequate medical history or note such history if
                  any;             .

     2.    Respondent repeatedly throughout the course of treatment failed to
           adequately follow-up on Patient N’s medical condition or note such
           follow up if any;
     3.     Respondent repeatedly throughout the course of treatment
            inappropriately prescribed Dilaudid, a controlled substance, Zyban and
            Atarax to Patient N;

                                              12
           a>     Respondent engaged in these prescribing practices for purposes
                  other than the good faith practice of medicine;
    4.     Respondent failed to maintain a record for Patient N which accurately
           reflects the care and treatment provided to Patient N.
    5.     Respondent failed to provide the Department of Health with Patient N’s
           medical record pursuant to its request received by Respondent on or
           about April 30, 1998.


0   Between on or about February 3, 1995 and March 27,1997, Respondent
    treated Patient 0, a 36 year old female for abdominal pain and other medical
    conditions at his office
    1.     Respondent repeatedly and throughout the course of treatment
           a)     failed to conduct an adequate physical examination and/or other
                  necessary examinations/evaluations on Patient 0 or to note such
                  physical and other examination/evaluation if any;

           b)     failed to obtain an adequate medical history or note such history if
                  any;
    2.     Respondent repeatedly throughout the course of treatment failed to
           adequately follow-up on Patient O’s medical condition or note such
           follow-up if any;
    3.     Respondent repeatedly throughout the course of treatment
                               s
           inappropriately prescribed Dilaudid, Percocet, controlled substances
           and Wellbutrin to Patient 0;
           a)     Respondent engaged in these prescribing practices for purposes
                  other than the good faith practice of medicine;
    4.     Respondent failed to maintain a record for Patient 0 which accurately
           reflects the care and treatment provided to Patient 0.

                                          13
    5.    Respondent failed to provide the Department of Health with Patient O’s
          medical record pursuant to its request received by Respondent on or
          about April 30, 1998.


    Between on or about March 7,1995 and March 23,1997, Respondent treated
    Patient P, a 34 year old female for phantom pain from an unspecified
    malignancy and other medical conditions at his office
    1.    Respondent repeatedly and throughout the course of treatment
          a)    failed to conduct an adequate physical examination and/or other
                 necessary examinations/evaluations on Patient P or to note such
                 physical and other examination/evaluation if any;
          b)    failed to obtain an adequate medical history or note such history if
                 any;
    2.    Respondent repeatedly and throughout the course of treatment failed to
          adequately follow-up on Patient P’s medical condition or note such
          follow-up if any;
    3.    Respondent repeatedly throughout the course of treatment
          inappropriately prescribed Dilaudid, a controlled substance and Atarax
          all controlled to Patient P;
          a)     Respondent engaged in these prescribing practices for purposes
i                other than the good faith practice of medicine;
    4.    Respondent failed to maintain a record for Patient P which accurately
          reflects the care and treatment provided to Patient P.
    5.    Respondent failed to provide the Department of Health with Patient P’s
          medical record pursuant to its request received by Respondent on or
          about April 30, 1998.


                                         14
Q.   Between on or about February 19, 1995 and March 26, 1997, Respondent
     treated Patient Q, a 56 year old female, for phantom pain and other medical
     conditions at his office
     1.     Respondent repeatedly and throughout the course of treatment
            a)       failed to conduct an adequate physical examination and/or other
                     necessary examinations/evaluations on Patient Q or to note such
                     physical and other examination/evaluation if any;

            b)       failed to obtain an adequate medical history or note such history if
                     any;
     2.     Respondent repeatedly throughout the course of treatment failed to
            adequately follow-up on Patient Q’s medical condition or note such
            follow up if any;
     3.     Respondent repeatedly throughout the course of treatment
            inappropriately prescribed Dilaudid, a controlled substance, and Zyban
            to Patient Q;
            a)       Respondent engaged in these prescribing practices for purposes
                     other than the good faith practice of medicine;
     4.     Respondent failed to maintain a record for Patient Q which accurately
            reflects the care and treatment provided to Patient Q.
     5.     Respondent failed to provide the Department of Health with Patient Q’s
            medical record pursuant to its request received by Respondent on or
                                 .
            about April 30, 1998.


R.   Between on or about January 7,1997 and May 12,1997, Respondent treated
     Patient R, a 48 year old male for abdominal pain and other medical conditions
     at his office
     1.     Respondent repeatedly throughout the course of treatment

                                             15
            a>    failed to conduct an adequate physical examination and/or other
                  necessary examinations/evaluations on Patient R or to note such
                  physical and other examination/evaluation if any;

            b)    failed to obtain an adequate medical history or note such history if
                  any;
     2.     Respondent repeatedly throughout the course of treatment failed to
           adequately follow-up on Patient R’s medical condition or note such
           follow-up if any;
     3.    Respondent repeatedly throughout the course of treatment
           inappropriately prescribed Dolophine, a controlled substance and
           Zyban to Patient R;
           a)     Respondent engaged in these prescribing practices for purposes
                  other than the good faith practice of medicine;
     4.    Respondent failed to maintain a record for Patient R which accurately
           reflects the care and treatment provided to Patient R.
     5.    Respondent failed to provide the Department of Health with Patient R’s
           medical record pursuant to its request received by Respondent on or
           about April 30, 1998.


S.   Between on or about February 13, 1995 and March 28, 1997,
     Respondent treated Patient S, a 67 year old male, for bladder cancer and
                                 .
     other medical conditions at his office
     1.    Respondent repeatedly throughout the course of treatment
           a)     failed to conduct an adequate physical examination and/or other
                  necessary examinations/evaluations on Patient S or to note such
                  physical and other examination/evaluation if any;
           b)     failed to obtain an adequate medical history or note such history if

                                          16
              any;
     2.       Respondent repeatedly throughout the course of treatment failed to
              adequately follow-up on Patient S’s medical condition;
     3.       Respondent repeatedly throughout the course of treatment
              inappropriately prescribed Dilaudid and Dolophine, controlled
              substances to Patient S;

              a)     Respondent engaged in these prescribing practices for purposes
                     other than the good faith practice of medicine;
     4.       Respondent failed to maintain a record for Patient S which accurately
              reflects the care and treatment provided to Patient S.
     5.       Respondent failed to provide the Department of Health with Patient S’s
              medical record pursuant to its request received by Respondent on or
              about April 30, 1998.


T.   Between on or about March 3, 1995 and March 22, 1997, Respondent treated
     Patient T, a 73 year old female, for phantom pain and other medical conditions
                                            I
     at his office
     1.       Respondent repeatedly throughout the course of treatment
              a)     failed to conduct an adequate physical examination and/or other
                     necessary examinations/evaluations on Patient T or to note such
                     physical and other examination/evaluation if any;
                                    s
              W      failed to obtain an adequate medical history or note such history if
                     any;
     2.   -   Respondent repeatedly throughout the course of treatment failed to
              adequately follow-up on Patient Ts medical condition or note such
              follow up if any;
     3.       Respondent repeatedly throughout the course of treatment

                                                17
            inappropriately prescribed Dilaudid, a controlled substance and Zyban,
           to Patient T;
            a)     Respondent engaged in these prescribing practices for purposes
           other than the good faith practice of medicine;
     4.     Respondent failed to maintain a record for Patient T which accurately
           reflects the care and treatment provided to Patient T.
     5.     Respondent failed to provide the Department of Health with Patient T’s
           medical record pursuant to its request received by Respondent on or
            about April 30, 1998.


U.   Between on or about March 4, 1995 and March 21, 1997, Respondent treated
     Patient U, a 35 year old male for testicular cancer and other medical
     conditions at his office
     1.     Respondent repeatedly throughout the course of treatment
           a)     failed to conduct an adequate physical examination and/or other
                  necessary examinations/evaluations on Patient U or to note such
                  physical and other examination/evaluation if any;
            b)    failed to obtain an adequate medical history or note such history if
                  any;
     2.     Respondent repeatedly throughout the course of treatment failed to
            adequately follow-up on Patient U’s medical condition or note such
                                 .
           follow-up if any;
     3.     Respondent repeatedly throughout the course of treatment
            inappropriately prescribed Dilaudid, Percocet, controlled substances
            and Wellbutrin to Patient U;
            a)     Respondent engaged in these prescribing practices for purposes
                  other than the good faith practice of medicine;

                                           18
     4.     Respondent failed to maintain a record for Patient U which accurately
            reflects the care and treatment provided to Patient U.
     5.     Respondent failed to provide the Department of Health with Patient U’s
           medical record pursuant to its request received by Respondent on or
           about April 30, 1998.


V.   Between on or about November 5, 1996 and May 26, 1997, Respondent
     treated Patient V, a 35 year old male, for abdominal pain and other medical
     conditions at his office
     1.     Respondent repeatedly throughout the course of treatment
           a)     failed to conduct an adequate physical examination and/or other
                   necessary examinations/evaluations on Patient V or to note such
                   physical and other examination/evaluation if any;

            b)    failed to obtain an adequate medical history or note such history if
                   any;
     2.     Respondent repeatedly throughout the course of treatment failed to
            adequately follow-up on Patient V’s medical condition;
     3.     Respondent repeatedly throughout the course of treatment
            inappropriately prescribed Dilaudid, a controlled substance and Zyban,
            all controlled to Patient V;
            a>     Respondent engaged in these prescribing practices for purposes
                   other than the good .faith practice of medicine;
     4.     Respondent failed to maintain a record for Patient V which accurately
            reflects the care and treatment provided to Patient V.
     5.     Respondent failed to provide the Department of Health with Patient V’s
            medical record pursuant to its request received by Respondent on or
            about April 30, 1998.

                                           19
W.   Between on or about June 22, 1996 and February Respondent treated Patient
     W,a 63 year old female for abdominal pain, ovarian cancer and other medical
     conditions at his office
     1.     Respondent repeatedly throughout the course of treatment
           a)     failed to conduct an adequate physical examination and/or other
                   necessary examinations/evaluations on Patient W or to note such
                   physical and other examination/evaluation if any;
            b)    failed to obtain an adequate medical history or note such history if
                  any;
     2.     Respondent repeatedly throughout the course of treatment failed to
            adequately follow-up on Patient W’s medical condition or note such
           follow up if any;
     3.     Respondent repeatedly throughout the course of treatment
            inappropriately prescribed Dilaudid, Percocet, controlled substances
            and Wellbutrin to Patient W;

            a)     Respondent engaged in these prescribing practices for purposes
                   other than the good faith practice of medicine;
     4.     Respondent failed to maintain a record for Patient W which accurately
            reflects the care and treatment provided to Patient W
     5.     Respondent failed to provide the Department of Health with Patient W’S
            medical record pursuant to its request received by Respondent on or
                                     .
            about April 30, 1998..


X.   Between on or about March 4, 1995 and March 29, 1997, Respondent treated
     Patient X, a 76 year old female, for abdominal pain, pancreatitus and other
     medical conditions
     1.     Respondent repeatedly throughout the course of treatment

                                           20
          4      failed to conduct an adequate physical examination and/or other
                 necessary examinations/evaluations on Patient X or to note such
                 physical and other examination/evaluation if any;
          b)     failed to obtain an adequate medical history or note such history if
                 any;
    2.    Respondent repeatedly throughout the course of treatment failed to
          adequately follow-up on Patient X’s medical condition or note such
          follow-up if any;
    3.    Respondent repeatedly throughout the course of treatment
          inappropriately prescribed Dilaudid, a controlled substance and
          Wellbutrin to Patient X;
          a)     Respondent engaged in these prescribing practices for purposes
                 other than the good faith practice of medicine;
    4.    Respondent failed to maintain a record for Patient X which accurately
          reflects the care and treatment provided to Patient X.
    5.    Respondent failed to provide the Department of Health with Patient X’s
          medical record pursuant to its request received by Respondent on or
          about April 30, 1998.


Y   Between on or about March 2, 1995 and May 5, 1997, Respondent treated
    Patient Y, an 84 year old female for insomnia, arthritis and other medical
                                  _
    conditions
    1.    Respondent repeatedly throughout the course of treatment
          a)     failed to conduct an adequate physical examination and/or other
                 necessary examinations/evaluations on Patient A or to note such
                 physical and other examination/evaluation if any;
          b)     failed to obtain an adequate medical history or note such history if

                                         21
                  any;
     2.    Respondent repeatedly throughout the course of treatment failed to
           adequately follow-up on Patient Y’s medical condition or note such
           follow up if any;
     3.    Respondent repeatedly throughout the course of treatment
           inappropriately prescribed Ativan, a controlled substance, Wellbutrin
           and Atarax to Patient Y;
           a)     Respondent engaged in these prescribing practices for purposes
                  other than the good faith practice of medicine;
     4.    Respondent failed to maintain a record for Patient Y which accurately
           reflects the care and treatment provided to Patient Y.
     5.    Respondent failed to provide the Department of Health with Patient Y’s
           medical record pursuant to its request received by Respondent on or
           about April 30, 1998.


Z.   Between on or about February 20, 1995 and April 28, 1997 Respondent
     treated Patient Z, a 48 year old female, for abdominal pain, cervical cancer
     and other medical conditions at his office
     1.    Respondent repeatedly throughout the course of treatment
           a)     failed to conduct an adequate physical examination and/or other
                  necessary examinations/evaluations on Patient Z or to note such
                                _
                  physical and other examination/evaluation if any;
           b)     failed to obtain an adequate medical history or note such history if
                  any;
     2.    Respondent repeatedly throughout the course of treatment failed to
           adequately follow-up on Patient Z’s medical condition or note such
           follow-up if any;

                                         22
          3.     Respondent repeatedly throughout the course of treatment
                 inappropriately prescribed Dilaudid, a controlled substance and
                 Wellbutrin to Patient Z;
                 a)     Respondent engaged in these prescribing practices for purposes
                        other than the good faith practice of medicine;
          4.     Respondent failed to maintain a record for Patient Z which accurately
                 reflects the care and treatment provided to Patient Z.
          5.     Respondent failed to provide the Department of Health with Patient Z’s
                 medical record pursuant to its request received by Respondent on or
                 about April 30, 1998.




                               SPECIFICATION OF CHARGES




                      FIRST THROUGH TWENTY SIXTH SPECIFICATIONS                           I


i
                                  FRAUDULENT PRACTICE


          Respondent is charged with committing professional misconduct as defined by     I
    N.Y. Educ[ Law §6530(2)(McKinney Supp. 1999) by practicing the profession of
    medicine fraudulently as alleged in the facts of the following:
           1.    Paragraphs A and A(3) and A(3)a.
          2.     Paragraphs B and B(3) and B(3)a.

                                                23
     3.    Paragraphs C and C(3) and C(3)a.
     4.    Paragraphs D and D(3) and D(3)a.
     5.    Paragraphs E and E(3) and E(3)a.
     6.    Paragraphs F and F(3) and F(3)a.
     7.    Paragraphs G and G(3) and G(3)a.
     8.    Paragraphs H and H(3) and H(3)a..
     9.    Paragraphs I and l(3) and l(3)a.
     10.   Paragraphs J and J(3)and J(3)a.
     11.   Paragraphs K and K(3) and K(3)a.
     12.   Paragraphs L and L (3) and L(3)a.
     13.   Paragraphs M and M(3) and M(3)a.
     14.   Paragraphs N and N(3) and N(3)a.
     15.   Paragraphs 0 and O(3) and O(3)a.
     16.   Paragraphs P and P(3) and P(3)a..
     17.   Paragraphs Q and Q(3) and Q(3)a.
     18.   Paragraphs R and R(3) and R(3)a.
     19.   Paragraphs S and S(3) and S(3)a.
     20.   Paragraphs T and T(3) and T(3)a.
     21.   Paragraphs U and U(3) and U(3)a.
     22.   Paragraphs V and V(3) and V(3)a.

j,   23.   Paragraphs W and W(3) and W(3)a.
                              .
     24.   Paragraphs X and X(3) and X(3)a.
     25:   Paragraphs Y and Y(3) and Y(3)a.
     26.   Paragraphs Z and Z(3) and Z(3)a.




                                        24
        TWENTY SEVENTH THROUGH FIFTY SECOND SPECIFICATIONS
                                GROSS NEGLIGENCE
      Respondent is charged with committing professional misconduct as defined in
N.Y. Educ. Law §6530(4)(McKinney Supp. 1999) by practicing the profession of
medicine with gross negligence as alleged in the facts of the following:


      27.    Paragraphs A and A(l), A(l A(l)(b), A(2), A(3) and A(3)a
             and/or A(4).
      28.    Paragraphs B and B(l), B(l)a, B(l)b, B(2), B(3) and      B(3)a
             and/or B(4).
      29.    Paragraphs C and C(l), C(l)a, C(l)b, C(2), C(3) and C(3)a
             and/or C(4).
      30.    Paragraphs D and D(l), D(l)a, D(l)b, D(2), D(3) and D(3)a
             and/or D(4).
      31.    Paragraphs E and E(l), E(l)a, E(l)b, E(2), E(3) and      E(3)a
             and/or E(4).
      32.    Paragraphs F and F(l), F(l)a, F(l)b, F(2), F(3) and F(3)a
                                a
             and/or F(4).
      33.    Paragraphs G and G(l), G(l)a, G(l)b, G(2), G(3) and G(3)a
             and/or G(4).
      34.    Paragraphs H and H(l), H(l)a, H(l)b, H(2), H(3) and H(3)a
             and/or H(4).
      35.    Paragraphs I and l(l), I(l I(l)b, l(2), l(3) and l(3)a and/or l(4).

                                           25
36.   Paragraphs J and J(l), J(l>a, J(2)b, J(2), J(3)and J(3)a and/or
      JW
37.   Paragraphs K and K(l), K(l)a, K(l)b, K(2), K(3) and K(3)a and/or
      K(4) *
38.   Paragraphs L and L(l), L(l)a, Ll(b), L(2), L (3) andL(3)a and/or
      L(4).
39.   Paragraphs M and M(l), M(l)a, M(l)b, M(2), M(3) and     M(3)a
      and/or M(4).
40.   Paragraphs N and N(l), N(l)a, N(l)b, N(2), N(3) and N(3)a
      and/or N(4).
41.   Paragraphs 0 and O(l), O(l)a, O(l)b, O(2), O(3) and O(3)a
      and/or O(4).
42.   Paragraphs P and P(l), P(l)a, P(l)b, P(2), P(3) and P(3)a and/or
      P(4).
43.   Paragraphs Q and Q(l), Q (l)a, Q(l)b, Q(2), Q(3) and Q(3)a
      and/or Q(4).
44.   Paragraphs R and R(l), R(l)& R(l)b, R(2), R(3) and R(3)a
      and/or R(4).
45.   Paragraphs S and S(l), S(l)a, S(l)b, S(2), S(3) and S(3)a and/or
      S(4).
46.   Paragraphs T and T(l), T(l)a, T(l)b, T(2), T(3) and T(3)a and/or
                         .
      -44) *

47.   Paragraphs U and U(l), U(l)a, U(l)b, U(2), U(3) and U(3)a
      and/or U(4).
48.   Paragraphs V and V(l), V(l)a, V(l)b, V(2), V(3) and V(3)a and/or
      V(4).
49.   Paragraphs W and W(l), W(l)a, W(l)b, W(2), W(3) and W(3)a

                                  26
              and/or W(4).
      50.     Paragraphs ‘X and X(l), X(l)a, X(l)b, X(2), X(3) and X(3)a and/or

              X(4).
      51.     Paragraphs Y and Y(l), Y(l)a, Y(l)b, Y(2), Y(3) and Y(3)a andjor
              Y(4).
      52.     Paragraphs Z and Z(l), Z(l)a, Z( l)b, Z(2), Z(3) and Z(3)a and/or
              Z(4).




            FIFTY THIRD THROUGH SEVENTY EIGHTH SPECIFICATIONS
                              GROSS INCOMPETENCE


      Respondent is charged with committing professional misconduct as defined in
N.Y. Educ. Law §6530(6)(McKinney Supp. 1999) by practicing the profession of
medicine with gross incompetence as alleged in the facts of the following:


      53.     Paragraphs A and A(l), A(l A(l)(b), A(2), A(3) and A(3)a
              and/or A(4).
      54.     Paragraphs B and B(l), B(l)a, Bl(b), B(2), (B(3) and B(3)a
              and/or B(4).
      55.     Paragraphs C and C(l), C(l)a, C(l)b, C(2), C(3) and    C(3)a
                                 _
              and/or C(4).
      56.     Paragraphs D and D(l), D(l)a, D(l)b, D(2), D(3) and     D(3)a
              and/or D(4).
      57.     Paragraphs E and E(l), E(l)a, E(l)b, E(2), E(3) and E(3)a
              and/or E(4).
      58.     Paragraphs F and F(l), F(l)a, F(l)b, F(2), F(3) and F(3)a

                                           27
      and/or F(4).
59.   Paragraphs G and G(l), G(l)a, G(l)b, G(2), G(3) and G(3)a
      and/or G(4).
60.   Paragraphs H and H(l), H(l)a, H(l)b, H(2), H(3) and H(3)a
      and/or H(4).
61.   Paragraphs I and l(l), l(l)a, I(l)b, l(2), l(3) and l(3)a and/or l(4).
62.   Paragraphs J and J(l), J(l)a, J(2)b, J(2), J(3)and J(3)a and/or
      JW
63.   Paragraphs K and K(l), K(l)a, K(l)b, K(2), K(3) and K(3)a and/or
      K(4) *
64.   Paragraphs L and L(l), L(l)a, L(l)b, L(2), L (3) andL(3)a and/or

      L(4).
65.   Paragraphs M and M(l), M( l)a, M( l)b, M(2), M(3) and M(3)a
      and/or M(4).
66.   Paragraphs N and N(l), N(l)a, N(l)b, N(2), N(3) and N(3)a
      and/or N(4).
67.   Paragraphs 0 and O(l), O(lra, O(l)b, O(2), O(3) and O(3)a
      and/or O(4).
68.   Paragraphs P and P(l), P(l)a, P(l)b, P(2), P(3) and P(3)a and/or
      P(4).
69.   Paragraphs Q and Q(q), Q (?)a, Q(l)b, Q(2), Q(3) and Q(3)a
      and/or Q(4).
70.   Paragraphs R and R(l), R(l)a, R(l)b, R(2), R(3) and R(3)a
      and/or R(4).
71.   Paragraphs S and S(l), S(l)a, S(l)b, S(2), S(3) and S(3)a and/or
       S(4).
72.   Paragraphs T and T(l), T(l)a, T(l)b, T(2), T(3) and T(3)a and/or

                                      28
      -WV
73.   Paragraphs U and U(l), U(l)a, U(l)b, U(2), U(3) and U(3)a
      and/or U(4).
74.   Paragraphs V and V(l), V(l)a, V(l)b, V(2), V(3) and V(3)a and/or
      V(4).
75.   Paragraphs Wand W(l), W(l)a, W(l)b, W(2), W(3) and W(3)a
      and/or W(4).
76.   Paragraphs X and X(l), X(l)a, X(l)b, X(2), X(3) and X(3)a and/or
      X(4).
77.   Paragraphs Y and Y(l), Y(l)a, Y(l)b, Y(2), Y(3) and Y(3)a and/or

      Y(4).
78.   Paragraphs Z and Z(l), Z(l)a, Z(l)b, Z(2), Z(3) and Z(3)a and/or

      Z(4) *




                                  29
                             SEVENTY NINTH SPECIFICATION
                    NEGLIGENCE ON MORE THAN ONE OCCASION
      Respondent is charged with committing professional misconduct as defined in
N.Y. Educ. Law §6530(3)(McKinney Supp. 1999) by practicing the profession of
medicine with negligence on more than one occasion as alleged in the facts of two
or more of the following:
      79.       Paragraphs A and A(l), A(l A(l)b, A(2), A(3) and A(3)a and/or
                A(4), B and B(l), B(l)a, B(l)b, B(2), B(3) and         B(3)a and/or
                B(4), C and C(l), C(l)a, C(l)b, C(2), C(3) and C(3)a and/or
                C(4), D and D(l), D(l)a, D(l)b, D(2), D(3) and D(3)a and/or
                D(4), E and E(l), E(l)a, E(l)b, E(2), E(3) and        E(3)a and/or
                E(4),F and F(l), F(l)a, F(l)b, F(2), F(3) and       F(3)a and/or F(4),
                G and G(l), G(l)a, G(l)b, G(2), G(3) and G(3)a and/or G(4),H
                and H(l), H(l)a, H(l)b, H(2), H(3) and H(3)a and/or H(4), I and
                l(l), l(l)a, I(l)b, l(2), l(3) and l(3)a and/or l(4), J and J(l), J(l)a,
                J(2)b J(2), J(3)and J(3)a and/or J(4), K and K(l), K(l)a, K( l)b,
                K(2), K(3) and K(3)a and/or K(4), L and L(l), L(l)a, Ll (b), L(2), L
                (3) and L(3)a and/or L(4),M and M(l), M(l)a, M(l)b, M(2), M(3)
                and M(3)a and/or M(4),N and N(l), N(l)a, N(l)b, N(2), N(3) and
                N(3)a and/or N(4), O-and O(l), O(l)a, O(l)b, O(2), O(3) and
                O(3)a and/or O(4), P and P(l), P(l)a, Pi(b), P(2), P(3) and P(3)a
            _   and/or P(4),Q and Q(l), Q(l)a, Q(l)b, Q(2), Q(3) and Q(3)a
                and/or Q(4), R and R(l), R(l)a, R(l)b, R(2), R(3) and R(3)a
                and/or R(4), S and S(l), S(l)a, S(l)b, S(2), S(3) and S(3)a and/or
                S(4), T and T(l), T(l)a, T(l)b, T(2), T(3) and T(3)a and/or T(4), U

                                                 30
             and U(l), U(1 >a, U(l)b, U(2), U(3) and U(3)a and/or U(4), V
             and V(l), V(l>a, V(l)b, V(2), V(3) and V(3)a and/or V(4), W
             and W(l), W( l)a, WI(b), W(2), W(3) and W(3)a and/or
             W(4), X and X(l), X(l)a, X(l)b, X(2), X(3) and X(3)a and/or
             X(4), Y and Y(l), Y(l)a, Y(l)b, Y(2), Y(3) and Y(3)a and/or
             Y(4), Z and Z(l), Z( l)a, Z(l)b, Z(2), Z(3) and Z(3)a and/or
             Z(4).




                                EIGHTIETH SPECIFICATION
                INCOMPETENCE ON MORE THAN ONE OCCASION
      Respondent is charged with committing professional misconduct as defined in
N.Y. Educ. Law §6530(5)(McKinney Supp. 1999) by practicing the profession of
medicine with incompetence on more than one occasion as alleged in the facts of
two or more of the following:
      80.    Paragraphs A and A(l), A(l A(l)b, A(2), A(3) and A(3)a and/or
             A(4), B and B(l), B(l)a, B?(b), B(2), B(3) and B(3)a and/or B(4),
             C and C(l), C(l)a, C(l)b, C(2), C(3) and C(3)a and/or C(4), D
             and D(l), D(l)a, D(l)b, D(2), D(3) and D(3)a and/or D(4), E and
             E(l), E(l)a, E(l)b, E(2), E(3) and E(3)a and/or E(4),F and F(l),
             F(l)a, F(l)b, F(2), F(3) and F(3)a and/or F(4), G and G(l),
             G(l)a, G(l)b, G(2), G(3) and G(3)a and/or G(4),H and H(l),
             H(l)a, H(l)b, H(2), H(3) and H(3)a and/or H(4), I and l(l), l(l)a,
             I(l)b, l(2), l(3) and l(3)a and/or l(4), J and J(l), J(l)a, J(2)b, J(2),
             J(3)and J(3)a and/or J(4), K and K(l), K(l)a, K(l)b, K(2), K(3)
             and K(3)a and/or K(4), L and L(l), L(l)a, Ll(b), L(2), L (3)
              andL(3)a and/or L(4)M and M(l), M(l)a, M(l)b, M(2), M(3)
              and M(3)a and/or M(4),N and N(l), N(l)a, N(l)b, N(2), N(3)
             and N(3)a and/or N(4), 0 and O(l), O(l)a, O(l)b, O(2),
              O(3) and O(3)a and/or O(4), P and P(l), P(l)a, Pl (b), P(2),
              P(3) and P(3)a and/or P(4), Q and Q(l), Q(l)a, Q(l)b,
              Q(2), Q(3) and Q(3)a and/or Q(4), R and R(l), R(l)a,
              R(l)b, R(2), R(3) and R(3)a and/or R(4), S and S(l), S(l)a,
              S(l)b, S(2), S(3) and S(3)a and/or S(4), T and T(l), T(l)a,
              T(l)b, T(2), T(3) and T(3)a and/orT(4), U and U(l), U(l)a,
              U(l)b, U(2), U(3) and U(3)a and/or U(4), V and V(l), V(l)a,
              V(l)b, V(2), V(3) and V(3)a and/or V(4), W and W(l),
              W(l)a, WI(b), W(2), W(3) and W(3)a and/or W(4), X and
              X(l), X(l)a, X(l)b, X(2), X(3) and X(3)a and/or X(4),Y and
              Y(l), Y(l)a, Y(l)b, Y(2), Y(3) and Y(3)a and/or Y(4), Z and
              Z(l), Z(l)a, Z(l)b, Z(2), Z(3) and Z(3)a and/or Z(4).




       EIGHTY FIRST THROUGH ONE HUNDRED FIFTH SPECIFICATIONS
                           FAILURE TO MAINTAIN RECORDS
                                    _
       Respondent is charged with committing professional misconduct as defined in
N.Y. Educ. Law §6530(32)(McKinney Supp. 1999) by failing to maintain a record for
each patient which accurately reflects the care and treatment of the patient, as
alleged in the facts of:


       81.    Paragraphs A and A(l), A(l A(l)b, A(2), and/or A(4).
82.    Paragraphs B and B(l), B(l)a, B(l)b, B(2), and/or B(4).
83.    Paragraphs C and C(l), A(l C(l)b, C(2), and/or C(4).
84.    Paragraphs D and D(l), D(l)a, D(l)b, D(2), and/or E(4).
85.    Paragraphs F and F(l), F(l)a, F(l)b, F(2), and/or F(4).
86.    Paragraphs G and G(l), G(l)a, G(l)b, G(2), and/or G(4).
87.    Paragraphs H and H(l), H(l)a, H(l)b, H(2), and/or H(4).
88.    Paragraphs I and l(l), I(l I( l)b, l(2), and/or l(4).
89.    Paragraphs J and J(l), J(l)a, J(l)b, J(2), and/or J(4).
90.    Paragraphs K and K(l), K(l)a, K(l)b, K(2), and/or K(4).
91.    Paragraphs L and L(1), L(l)a, L(l)b, L(2), and/or L(4).
92.    Paragraphs M and M(l), M(l)a, M(l)b, M(2), and/or M(4).
93.    Paragraphs N and N(l), N(l)a, N(l)b, N(2), and/or N(4).
94.    Paragraphs 0 and O(l), O(l)a, O(l)b, O(2), and/or O(4).
95.    Paragraphs P and P(l), P(l)a, P(l)b, P(2), and/or P(4).
96.    Paragraphs Q and Q(l), Q(l)a, Q(l)b, Q(2), and/or Q(4).
97.    Paragraphs R and R(l), R(l)a, R(l)b, R(2), and/or R(4).
98.    Paragraphs S and S(l), S(l)a, S(l)b, S(2), and/or S(4).
99.    Paragraphs T and T(l), T(l)a, T(l)b, T(2), and/or T(4).
100.   Paragraphs U and U(l), U(l)a, U(l)b, U(2), and/or U(4).
101.   Paragraphs V and V(l), V(l)a, V(l)b, V(2), and/or V(4).
102. Paragraphs Wand W(l), W(l)a, W(l)b, W(2), and/or W(4).
103.   Paragraphs X and X(i), X(l)a, X(l)b, X(2), and/or X(4).
104.   Paragraphs Y and Y(l), Y(l)a, Y(l)b, Y(2), and/or Y(4).
105.   Paragraphs Z and Z(l), Z(l)a, Z(l)b, Z(2), and/or Z(4).
                             ONE HUNDRED SIXTH THROUGH
                  ONE HUNDRED THIRTY FIRST SPECIFICATIONS
                                   MORAL UNFITNESS


       Respondent is charged with committing professional misconduct as defined in
N.Y. Educ. Law §6530(20)(McKinney Supp. 1999) by engaging in conduct in the
practice of the profession of medicine that evidences moral unfitness to practice as
alleged in the facts of the following:
       106. Paragraphs A and A(l), A(l A(l)(b), A(2), A(3) and A(3)a
              and/or A(4).
       107. Paragraphs B and B(l), B(l)a, Bl(b), B(2), B(3) and           B(3)a
              and/or B(4).
       108. Paragraphs C and C(l), C(l)a, C(l)b, C(2), C(3) and C(3)a
              and/or C(4).
       109.   Paragraphs D and D(l), D(l)a, D(l)b, D(2), D(3) and         D(3)a
              and/or D(4).
       110. Paragraphs E and E(l), E(l)a, E(l)b, E(2), E(3) and          E(3)a
              and/or E(4).
       111. Paragraphs F and F(l), F(l)a, F(l)b, F(2), F(3) and F(3)a
              and/or F(4).
       112. Paragraphs G and G(l), G(l)a, G(l)b, G(2), G(3) and G(3)a
              and/or G(4).               -

       113. Paragraphs H and H(l), H(l)a, H(l)b, H(2), H(3) and H(3)a
              and/or H(4).
       114.   Paragraphs I and l(l), l(l)a, I(l)b, l(2), l(3) and l(3)a and/or l(4).
       115.   Paragraphs J and J(l), J(l)a, J(2)b, J(2), J(3)and J(3)a and/or
              JW
                                             34
     116.   Paragraphs K and K(l), K(l)a, K(l)b, K(2), K(3) and K(3)a and/or
            K(4) *
     117.   Paragraphs L and L(l), L(l)a, Ll (b), L(2), L (3) and L(3)a and/or
            L(4).
     118.   Paragraphs M and M(l), M(l)a, M(l)b, M(2), M(3) and     M(3)a
            and/or M(4).
     119.   Paragraphs N and N(l), N(l)a, N(l)b, N(2), N(3) and N(3)a
            and/or N(4).
     120.   Paragraphs 0 and O(l), O(l)a, O(l)b, O(2), O(3) and O(3)a
            and/or O(4).
     121.   Paragraphs P and P(l), P(l)a, Pi(b), P(2), P(3) and P(3)a and/or
            P(4).
     122.   Paragraphs Q and Q(l), Q (l)a, Q(l)b, Q(2), Q(3) and Q(3)a
            and/or Q(4).
     123.   Paragraphs R and R(l), R(l)a, R(l)b, R(2), R(3) and R(3)a
            and/or R(4).
     124.   Paragraphs S and S(l), S(l]a, S(l)b, S(2), S(3) and S(3)a and/or
            S(4).
     125.   Paragraphs T and T(l), T(l)a, T(l)b, T(2), T(3) and T(3)a and/or
            T(4).
     126.   Paragraphs U and U(l), U( l)a, U( l)b, U(2), U(3) and U(3)a
            and/or U(4).         s

     127.   Paragraphs V and V(l), V(l)a, V(l)b, V(2), V(3) and V(3)a and/or
II
            V(4).
     128.   Paragraphs W and W(l), W( l)a, W(l)b, W(2), W(3) and W(3)a
            and/or W(4).
     129.   Paragraphs X and X(l), X(l)a, X(l)b, X(2), X(3) and X(3)a and/or
/I
                                         35
              X(4)-
       130.   Paragraphs Y and Y(l), Y(l)a, Y(l)b, Y(2), Y(3) and Y(3)a and/or
              Y(4)-
       131.   Paragraphs Z and Z(l), Z(l)a, Z(l)b, Z(2), Z(3) and Z(3)a and/or




                 ONE HUNDRED THIRTY SECOND SPECIFICATION
                      FAILURE TO PROVIDE MEDICAL RECORDS
       Respondent is charged with committing professional misconduct as defined in
N.Y. Educ. Law §6530(28)(McKinney        Supp. 1999)   by failing to make available
relevant medical records with respect to an inquiry or complaint about the licensee’s
professional misconduct, as alleged in the facts of:


       132.   Paragraphs A and A(5), B and B(5), C and C(5), D and D(5), E and
              E(5), F and F(5), G and G(5), H and H(5), I and l(5), J and J(5), K and
              K(5), L and L(5), M and M(5), N and N(5), 0 and       O(5), P and P(5), Q
              and Q(5), R and R(5), S andS(5), T and T(5), U and U(5), V and V(5)
              W and W(5), X and X(5), Y and Y(5), Z and Z(5).




                  ONE HUNDRED-THIRTY THIRD SPECIFICATION
    WILLFUL OR GROSS FAILURE TO COMPLY WITH FEDERAL, STATE OR
                      LOCAL LAWS, RULES OR REGULATIONS
       Respondent is charged with committing professional misconduct as defined in
N.Y. Educ. Law §6530(16)(McKinney Supp. 1999) by failing to comply with
substantial provisions of federal, state or local laws, rules, or regulations governing

                                             36
the practice of medicine, as alleged in the facts of:
       133.   Paragraphs A and A(5), B and B(5), C and C(5), D and D(5), E and
              E(5), F and F(5), G and G(5), H and H(5), I and l(5), J and J(5), K and
              K(5), L and L(5), M and M(5), N and N(5), 0 and O(5), P and P(5), Q
              and Q(5), R and R(5), S and S(5), T and T(5), U and U(5), V and V(5)
              W and W(5), X and X(5), Y and Y(5), Z and Z(5).




DATED:        March
              New York: f%?York


                                                        ROY NEMERSON
                                                        Deputy Counsel
                                                        Bureau of Professional
                                                         Medical Conduct




                                            37
                                                                i
      and/or F(4).
59.   Paragraphs G and G(l), G(l)a, G(l)b, G(2), G(3) and G(3)a
      and/or G(4).
60.   Paragraphs H and H(l), H(l)a, H(l)b, H(2), H(3) and H(3)a
      and/or H(4).
61.   Paragraphs I and l(l), I(l I(l)b, l(2), l(3) and l(3)a and/or l(4).
62.   Paragraphs J and J(l), J(l)a, J(2)b, J(2), J(3)and J(3)a and/or
      J(4).
63.   Paragraphs K and K(l), K(l)a, K(l)b, K(2), K(3) and K(3)a and/or
      K(4).
64.   Paragraphs L and L(l), L(l)a, L(l)b, L(2), L (3) andL(3)a and/or
      L(4).
65.   Paragraphs M and M(l), M(l)a, M(l)b, M(2), M(3) and           M(3)a
      and/or M(4).
66.   Paragraphs N and N(l), N(l)a, N(l)ti, N(2), N(3) and N(3)a
      and/or N(4).
67.   Paragraphs 0 and O(l), O(l)a, O(l)b, O(2), O(3) and O(3)a
      and/or O(4).
68.   Paragraphs P and P(l), P(l)a, P(l)b, P(2), P(3) and P(3)a and/or
      P(4).
69.   Paragraphs Q and Q(l), Q (l)a, Q(l)b, Q(2), Q(3) and Q(3)a
      and/or Q(4).           *

70.   Paragraphs R and R(l), R(l)a, R(l)b, R(2), R(3) and R(3)a
      and/or R(4).
71.   Paragraphs S and S(l), S(l)a, S(l)b, S(2), S(3) and S(3)a and/or
       S(4).
72.   Paragraphs T and T(l), T(l)a, T(l)b, T(2), T(3) and T(3)a and/or

                                    28
                                                            i

      T(4) *
73.   Paragraphs U and U(l), U(l)a, U(l)b, U(2), U(3) and U(3)a
      and/or U(4).
74.   Paragraphs V and V(l), V(l)a, V(l)b, V(2), V(3) and V(3)a and/or
      V(4) *
75.   Paragraphs W and W(l), W(l)a, W(l)b, W(2), W(3) and       W(3)a
      and/or W(4).
76.   Paragraphs X and X(l), X(l)a, X(l)b, X(2), X(3) and X(3)a and/or
      X(4).
77.   Paragraphs Y and Y(l), Y(l)a, Y(l)b, Y(2), Y(3) and Y(3)a and/or
      Y(4) *
78.   Paragraphs Z and Z(l), Z(l)a, Z(l)b, Z(2), Z(3) and Z(3)a and/or
      Z(4).




                                  29
                            SEVENTY NINTH SPECIFICATION
                 NEGLIGENCE ON MORE THAN ONE OCCASION
      Respondent is charged with committing professional misconduct as defined             in
N.Y. Educ. Law §6530(3)(McKinney Supp. 1999) by practicing the profession of
medicine with negligence on more than one occasion as alleged in the facts of        two
or more of the following:
      79.    Paragraphs A and A(l), A(l A(l)b, A(2), A(3) and A(3)a and/or
             A(4), B and B(l), B(l)a, B(l)b, B(2), B(3) and B(3)a and/or
             B(4), C and C(l), C(l)a, C(l)b, C(2), C(3) and C(3)a and/or
             C(4), D and D(l), D(l)a, D(l)b, D(2), D(3) and D(3)a and/or
             D(4), E and E(l), E(l)a, E(l)b, E(2), E(3) and E(3)a and/or
             E(4),F and F(l), F(l)a, F(l)b, F(2), F(3) and F(3)a and/or F(4),
             G and G(l), G(l)a, G(l)b, G(2), G(3) and G(3)a and/or G(4),H
             and H(l), H(l)a, H( l)b, H(2), H(3) and H(3)a and/or H(4), I and
             l(l), I(l I(l)b, l(2), l(3) and.l(3)a and/or l(4), J and J(l), J(l)a,
             J(2)b, J(2), J(3)and J(3)a and/or J(4), K and K(l), K(l)a, K(l)b,
             K(2), K(3) and K(3)a and/or K(4), L and L(l), L(l)a, Ll(b), L(2), L
             (3) and L(3)a and/or L(4),M and M(l), M(l)a, M(l)b, M(2), M(3)
             and M(3)a and/or M(4),N and N(l), N(l)a, N(l)b, N(2), N(3) and
             N(3)a and/or N(4), Oand O(l), O(l)a, O(l)b, O(2), O(3) and
             O(3)a and/or O(4), P and P(l), P(l)a, PI(b), P(2), P(3) and P(3)a
             and/or   P(4),Q and Q(l), Q(l)a, Q(l)b, Q(2), Q(3) and Q(3)a
             and/or Q(4), R and R(l), R(l)a, R(l)b, R(2), R(3) and R(3)a
             and/or R(4), S and S(l), S(l)a, S(l)b, S(2), S(3) and S(3)a and/or
             S(4), T and T(l), T(l)a, T(l)b, T(2), T(3) and T(3)a and/or T(4), U

                                            30
                and U(l), U(l)a, U(l)b, U(2), U(3) and U(3)a and/or U(4), V
                and V(l), V(l)a, V(l)b, V(2), V(3) and V(3)a and/or V(4), W
                and W(l), W(l)a, WI(b), W(2), W(3) and        W(3)a and/or
                W(4), X and X(l), X(l)a, X(l)b, X(2), X(3) and X(3)a and/or
                X(4), Y and Y(l), Y(l)a, Y(l)b, Y(2), Y(3) and Y(3)a and/or
                Y(4), Z and Z(l), Z(l)a, Z(l)b, Z(2), Z(3) and Z(3)a and/or
                Z(4).




                                EIGHTIETH SPECIFICATION
                   INCOMPETENCE ON MORE THAN ONE OCCASION
      Respondent is charged with committing professional misconduct as defined             in
N.Y. Educ. Law §6530(5)(McKinney Supp. 1999) by practicing the profession of
medicine with incompetence on more than one occasion as alleged in the facts of
                                                .
two or more of the following:
      80.       Paragraphs A and A(l), A(l A(l)b, A(2), A(3) and A(3)a and/or
                A(4), B and B(l), B(l)a, Bl (b), B(2), B(3) and B(3)a and/or B(4),
                C and C(l), C(l)a, C(l)b, C(2), C(3) and C(3)a and/or C(4), D
                and D(l), D(l)a, D(l)b, D(2), D(3) and D(3)a and/or D(4), E and
                E(l), E(l)a, E(l)b, E(2), E(3) and    E(3)a and/or E(4),F and F(l),
                F(l)a, F(l)b, F(2), F(3) and F(3)a and/or F(4), G and G(l),
            _   G(l)a, G(l)b, G(2), G(3) and G(3)a and/or G(4),H and H(l),
                H(l)a, H(l)b, H(2), H(3) and H(3)a and/or H(4), I and l(l), I( l)a,
                I(l)b, l(2), l(3) and l(3)a and/or l(4), J and J(l), J(l)a, J(2)b, J(2),
                J(3)and J(3)a and/or J(4), K and K(l), K(l)a, K(l)b, K(2), K(3)

                                                31
                                                                        i
             and K(3)a and/or K(4), L and L(l), L(l)a, L!(b), L(2),    L    (3)
             andL(3)a and/or L(4),M and M(l), M(l)a, M(l)b, M(2), M(3)
              and M(3)a    and/or M(4),N and N(l), N(l)a, N(l)b, N(2), N(3)
              and N(3)a and/or N(4), 0 and O(l), O(l)a, O(l)b,     O(2),
              O(3) and O(3)a and/or O(4), P and P(l), P(l)a, PI(b), P(2),
              P(3) and P(3)a and/or P(4), Q and Q(l), Q(l)a, Q(l)b,
              Q(2), Q(3) and Q(3)a and/or Q(4), R and R(l), R(l)a,
              R(l)b, R(2), R(3) and R(3)a and/or R(4), S and S(l), S(l)a,
              S(l)b, S(2), S(3) and S(3)a and/or S(4), T and T(l), T(l)a,         .

              T(l)b, T(2), T(3) and T(3)a and/or T(4), U and U(l), U(l)a,
              U(l)b, U(2), U(3) and U(3)a and/or U(4), V and V(l), V(l)a,
              V(l)b, V(2), V(3) and V(3)a and/or V(4), W and W(l),
              W(l)a, WI(b), W(2), W(3) and W(3)a and/or W(4), X and
              X(l), X(l)a, X(l)b, X(2), X(3) and X(3)a and/or X(4),Y and
              Y(l), Y(l)a, Y(l)b, Y(2), Y(3) and Y(3)a and/or Y(4), Z and
              Z(l), Z(l)a, Z(l)b, Z(2), Z(3) and Z(3)a and/or Z(4).




       EIGHTY FIRST THROUGH ONE HUNDRED FIFTH SPECIFICATIONS
                        FAILURE TO MAINTAIN RECORDS
                                  m
       Respondent is charged with committing professional misconduct as defined in
N.Y. Educ. Law §6530(32)(McKinney Supp. 1999) by failing to maintain a record for
each patient which accurately reflects the care and treatment of the patient, as
alleged in the facts of:


       81.    Paragraphs A and A(l), A(l A(l)b, A(2), and/or A(4).

                                              32
                                                                 i
82.    Paragraphs B and B(l), B(l)a, B(l)b, B(2), and/or B(4).
83.    Paragraphs C and C(l), A(l C(l)b’, C(2), and/or C(4).
84.    Paragraphs D and D(l), D(l)a, D(l)b, D(2), and/or E(4).
85.    Paragraphs F and F(l), F(l)a, F(l)b, F(2), and/or F(4).
86.    Paragraphs G and G(l), G(l)a, G(l)b, G(2), and/or G(4).
87.    Paragraphs H and H(l), H(l)a, H(l)b, H(2), and/or H(4).
88.    Paragraphs I and l(l), l(l)a, I(l)b, l(2), and/or l(4).
89.    Paragraphs J and J(l), J(l)a, J(l)b, J(2), and/or J(4).
90.    Paragraphs K and K(l), K(l)a, K(l)b, K(2), and/or K(4).
91.    Paragraphs L and L(l), L(l)a, L(l)b, L(2), and/or L(4).
92.    Paragraphs M and M(l), M(l)a, M(l)b, M(2), and/or M(4).
93.    Paragraphs N and N(l), N(l)a, N(l)b, N(2), and/or N(4).
94.    Paragraphs 0 and O(l), O(l)a, O(l)b, O(2), and/or O(4).
95.    Paragraphs P and P(l), P(l)a, P(l)b, P(2), and/or P(4).
96.    Paragraphs Q and Q(l), Q(l)a, Q(l)b, Q(2), and/or Q(4).
97.    Paragraphs R and R(l), R(l)a, R(l)b, R(2), and/or R(4).
98.    Paragraphs S and S(l), S(l)a, S(l)b, S(2), and/or S(4).
99.    Paragraphs T and T(l), T(l)a, T(l)b, T(2), and/or T(4).
100.   Paragraphs U and U(l), U(l)a, U(l)b, U(2), and/or U(4).
101.   Paragraphs V and V(l), V(l)a, V(l)b, V(2), and/or V(4).
102.   Paragraphs Wand W(l), W(l)a, W(l)b, W(2), and/or W(4).
103.   Paragraphs X and X(l), X(l)a, X(l)b, X(2), and/orX(4).
104.   Paragraphs Y and Y(l), Y(l)a, Y(l)b, Y(2), and/or Y(4).
105:   Paragraphs Z and Z(l), Z(l)a, Z(l)b, Z(2), and/or Z(4).




                                       33
                             ONE HUNDRED SIXTH THROUGH
                  ONE HUNDRED THIRTY FIRST SPECIFICATIONS
                                   MORAL UNFITNESS


       Respondent is charged with committing professional misconduct as defined in
N.Y. Educ. Law §6530(20)(McKinney Supp. 1999) by engaging in conduct in the
practice of the profession of medicine that evidences moral unfitness to practice as
alleged in the facts of the following:
       106.   Paragraphs A and A(l), A(l A(l)(b), A(2), A(3) and A(3)a
              and/or A(4).
       107. Paragraphs B and B(l), B(l)a, Bl(b), B(2), B(3) and B(3)a
              and/or B(4).
       108. Paragraphs C and C(l), C(l)a, C(l)b, C(2), C(3) and C(3)a
              and/or C(4).
       109. Paragraphs D and D(l), D(l)a, D(l)b, D(2), D(3) and       D(3)a
              and/or D(4).
       110. Paragraphs E and E(l), E(l)a, E(l)b, E(2), E(3) and E(3)a
              and/or E(4).
       111. Paragraphs F and F(l), F(l)a, F(l)b, F(2), F(3) and F(3)a
              and/or F(4).
       112. Paragraphs G and G(l), G(l)a, G(l)b, G(2), G(3) and G(3)a
              and/or G(4).               _

       113. Paragraphs H and H(l), H(l)a, H(l)b, H(2), H(3) and H(3)a
              and/or H(4).
       114. Paragraphs I and l(l), I(l I(l)b, l(2), l(3) and l(3)a and/or l(4).
       115.   Paragraphs J and J(l), J(l)a, J(2)b, J(2), J(3)and J(3)a and/or
              JW
                                             34
                                                                i
116.    Paragraphs     K and K(l), K(l)a, K(l)b, K(2), K(3) and K(3)a and/or
        K(4).
117.    Paragraphs L and L(l), L(l)a, Ll(b), L(2), L (3) and L(3)a and/or
        L(4).
118.    Paragraphs M and M(l), M(l)a, M(l)b, M(2), M(3) and M(3)a
        and/or M(4).
119.    Paragraphs N and N(l), N(l)a, N(l)b, N(2), N(3) and N(3)a
        and/or N(4).
120.    Paragraphs 0 and O(l), O(l)a, O(l)b,     O(2), O(3) and O(3)a
        and/or O(4).
121.    Paragraphs P and P(l), P(l)a, Pi(b), P(2), P(3) and P(3)a and/or
        P(4).
122.    Paragraphs Q and Q(l), Q (l)a, Q(l)b, Q(2), Q(3) and Q(3)a
        and/or Q(4).
123.    Paragraphs R and R(l), R(l)a, R(l)b, R(2), R(3) and R(3)a
        and/or R(4).
124.    Paragraphs S and S(l), S(l)a, S(l)b, S(2), S(3) and S(3)a and/or
         S(4)*
125.     Paragraphs T and T(l), T(l)a, T(l)b, T(2), T(3) and T(3)a and/or


126.     Paragraphs U and U(l), U(l)a, U(l)b, U(2), U(3) and U(3)a
                            .
         and/or U(4).
127.     Paragraphs V and V(l), V( l)a, V( l)b, V(2), V(3) and V(3)a and/or
       V(4).
128.     Paragraphs W and W(l), W(l)a, W(l)b, W(2), W(3) and W(3)a
         and/or W(4).
129.     Paragraphs X and X(l), X(l)a, X(l)b, X(2), X(3) and X(3)a and/or

                                        35
                                                                            L

                 X(4).
          130. Paragraphs Y and Y(l), Y(l)a, Y(l)b, Y(2), Y(3) and Y(3)a and/or
                 Y(4) *
          131.   Paragraphs Z and Z(l), Z(l)a, Z(l)b, Z(2), Z(3) and Z(3)a and/or

                 Z(4).


                    ONE HUNDRED THIRTY SECOND SPECIFICATION
                          FAILURE TO PROVIDE MEDICAL RECORDS
          Respondent is charged with committing professional misconduct as defined in
    N.Y. Educ. Law §6530(28)(McKinney Supp. 1999) by failing to make available
    relevant medical records with respect to an inquiry or complaint about the licensee’s
    professional misconduct, as alleged in the facts of:


          132. Paragraphs A and A(5), B and B(5), C and C(5), D and D(5), E and
                 E(5), F and F(5), G and G(5), H and H(5), I and l(5), J and J(5), K and
                 K(5), L and L(5), M and M(5), N and N(5), 0 and O(5), P and P(5), Q
                 and Q(5), R and R(5), S and S(5), T and T(5), U and U(5), V and V(5)
                 W and W(5), X and X(5), Y and Y(5), Z and Z(5).




                                         .
                         ONE HUNDRED THIRTY THIRD SPECIFICATION
        WILLFUL OR GROSS FAILURE TO COMPLY WITH FEDERAL, STATE OR
                           LOCAL LAWS, RULES OR REGULATIONS
          Respondent is charged with committing professional misconduct as defined in
    N.Y. Educ. Law §6530(16)(McKinney Supp. 1999) by failing to comply with
    substantial provisions of federal, state or local laws, rules, or regulations governing

I                                               36
                                                                    i
the practice of medicine, as alleged in the facts of:
      133. Paragraphs A and A(5), B and B(5), C and C(5), D and D(5), E and
             E(5), F and F(5), G and G(5), H and H(5), I and l(5), J and J(5), K and
             K(5), L and L(5), M and M(5), N and N(5), 0 and O(5), P and p(5), Q
             and Q(5), R and R(5), S and S(5), T and T(5), U and U(5), V and v(5)
             W and W(5), X and X(5), Y and Y(5), Z and Z(5).




DATED:       March
             New York,’ iz?York


                                                    ROY NEMERSON
                                                    Deputy Counsel
                                                    Bureau of Professional
                                                     Medical Conduct




                                           37

				
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