Medical Board of Australia v Evans
[2013] QCAT 217
•30 April 2013
| CITATION: | Medical Board of Australia v Evans [2013] QCAT 217 |
| PARTIES: | Medical Board of Australia (Applicant/Appellant) |
| v | |
| Dr Ross Alexander Evans (Respondent) |
| APPLICATION NUMBER: | OCR090-12 |
| MATTER TYPE: | Occupational regulation matters |
| HEARING DATE: | 8 April 2013 |
| HEARD AT: | Brisbane |
| DECISION OF: | Judge Alexander Horneman-Wren SC, Deputy President Dr Sandra Congdon |
| DELIVERED ON: | 30 April 2013 |
| DELIVERED AT: | Brisbane |
| ORDERS MADE: | 1. In relation to each of Grounds 1 to 3 of the Referral, the Tribunal finds, pursuant to s 240(1) of the Health Practitioners (Professional Standards) Act 1999 (“Professional Standards Act”), that a ground for disciplinary action has been established against Mr Ross Evans in that he has behaved in a way that constitutes unsatisfactory professional conduct as defined in the Schedule to that act. 2. In relation to Ground 4 of the Referral, the Tribunal finds, pursuant to s 196(1)(b)(ii) of the Health Practitioner Regulation National Law (Queensland), that Mr Evans has behaved in a way that constitutes unprofessional conduct as defined in s 5 of that act. 3. The Tribunal approves, pursuant to s 241(2)(c) of the Professional Standards Act, the undertaking given by Mr Evans to the Board that he will not reapply for registration as a health practitioner in any jurisdiction in Australia and that he will never apply to be relieved of that undertaking. 4. The undertaking approved in Order 3, above, must be recorded on the Medical Board’s register for the period it is in force. 5. Mr Evans must pay the Medical Board’s costs of and incidental to the proceedings fixed at the sum of $61,000. 6. Publication is prohibited of any information identifying the patients listed in the Medical Board’s Application for Non-Publication Order (the relevant documents are listed in the Schedule to these orders). |
| CATCHWORDS: | PROFESSIONS AND TRADES – HEALTH CARE PRFOESSIONALS – MEDICAL PRACTITIONERS – DISCIPLINARY PROCEEDINGS – where the registrant prescribed controlled an/or restricted drugs to persons he knew or ought to know were drug dependant – where the registrant prescribed controlled and/or restricted drugs in breach of the Health (Drugs and Poisons) Regulation 1996 – whether the registrants conduct amounted to unsatisfactory professional conduct PROFESSIONS AND TRADES – HEALTH CARE PRFOESSIONALS – MEDICAL PRACTITIONERS – DISCIPLINARY PROCEEDINGS – where the registrant administered an unconventional treatment to a patient – where the treatment was not registered in Australia – where the treatment was not approved by the Therapeutic Goods Association – whether the registrant’s conduct amounted to unsatisfactory professional conduct PROFESSIONS AND TRADES – HEALTH CARE PRFOESSIONALS – MEDICAL PRACTITIONERS – DISCIPLINARY PROCEEDINGS – where the registrant’s endorsement under the Health (Drugs and Poisons) Regulation 1996 was cancelled – where the registrant was aware complaints had been made against them – whether the registrant should have disclosed relevant matters in their application for renewal of registration – whether a failure to disclose relevant matters amounts to unprofessional conduct – whether a failure to disclose relevant matters amounts to professional misconduct PROFESSIONS AND TRADES – HEALTH CARE PRFOESSIONALS – MEDICAL PRACTITIONERS – DISCIPLINARY PROCEEDINGS – where the registrant admitted conduct – where the registrant provided an undertaking – where the parties proposed a joint sanction – whether sanction is appropriate Health (Drugs and Poisons) Regulation 1996, s 78, s 122, s 213, s 120, s 79, s 79(4)(c), s 79(4)(e), s 79(4)(i), s 79(4)(k) Medical Board of Australia v Broadbent (No 3) [2010] QCAT 488 |
APPEARANCES and REPRESENTATION (if any):
| APPLICANT: | Mr Forbes of DLA Piper for the Medical Board of Australia |
| RESPONDENT: | Dr Evans |
REASONS FOR DECISION
Ross Alexander Evans was a registered medical practitioner. He was the sole practitioner at the Monterey Keys Medical Centre on the Gold Coast. He ceased medical practice on 28 March 2013.
On 4 April 2013, Mr Evans surrendered his registration to the Medical Board of Australia with effect from 5 April 2013.[1]
[1]Exhibit 2.
In March 2012 the Board referred this disciplinary proceeding to the Tribunal. The referral raised four grounds upon which disciplinary action might be taken against Mr Evans.
Grounds 1 to 3 each alleged that Mr Evans behaved in a way that constituted unsatisfactory professional conduct for which he was liable to be disciplined under s 124(1)(a) of the Health Practitioners (Professional Standards) Act 1999 (“HP Act”). The conduct alleged in respect of each of those grounds occurred prior to the commencement of the Health Practitioner Regulation National Law(Queensland) (“National Law”) on 1 July 2010.
Furthermore, the former Medical Board of Queensland had commenced investigations into complaints about those matters prior to 1 July 2010.[2] Therefore, the former Medical Board of Queensland had started dealing with those matters prior to the commencement of the National Law and they are to be dealt with in these proceedings under the HP Act as if that Act had not been repealed.[3]
[2]See letter of 22 September 2010 from the Australia Health Practitioner Regulation Agency to Dr Ross Evans; Document 61 in the Board’s Material tendered by agreement.
[3]Sections 288 - 289, National Law; Medical Board of Australia v Grant [2010] QCAT 285.
Ground 4 relates to conduct which occurred after the commencement of the National Law. The Board alleges that conduct constitutes professional misconduct for which Mr Evans is liable to be disciplined under s 196 of the National Law.
The parties have filed a Statement of Agreed and Disputed Facts. In that document, Mr Evans has made a number of admissions concerning his conduct. In particular, he admits in respect of each of grounds 1, 2 and 3 that he has behaved in a way that constitutes unsatisfactory professional conduct. Further, in respect of ground 4, Mr Evans admits that he behaved in a way that constitutes professional misconduct.[4]
[4]Whether the Tribunal should act upon that admission shall be considered later in the reasons.
Whilst those admissions would be sufficient for the Tribunal to proceed to discipline Mr Evans under both s 240 and s 241 of the HP Act and s 196 of the National Law, something further should be said of those grounds and the admissions made in respect of each of them.
Ground 1
Ground 1 concerns Mr Evans having prescribed controlled and/or restricted drugs of dependency to patients whom he knew, or ought to have known, were drug dependent. Mr Evans admits to having prescribed controlled and/or restricted drugs of dependency to 18 patients on a total in excess of one thousand occasions.[5]
[5]Including numerous occasions on which multiple repeats were prescribed.
Section 78 of the Health (Drugs and Poisons) Regulation 1996 (the “Regulation”) provides that a medical practitioner must not prescribe a specified condition drug without the approval of the Chief Executive of Queensland Health. Section 122 of the Regulation provides that if a medical practitioner reasonably believes a person is a drug dependent person, the practitioner must not prescribe a controlled drug for the person without the approval of the Chief Executive. Section 213 of the Regulation provides that if a medical practitioner reasonably believes a person is a drug dependent person, the practitioner must not prescribe restricted drugs of dependency for the person without the approval of the Chief Executive.
Mr Evans admits that in prescribing to the 18 identified patients he did so without the requisite approval of the Chief Executive of Queensland Health. He also concedes that he knew, or ought to have known that those patients were drug dependent at the time at which he wrote those prescriptions.
Furthermore, s 120 of the Regulation provides that a medical practitioner must report to the Chief Executive regarding treatment of a patient with controlled drugs for a period of more than two months. Mr Evans admits that he prescribed controlled drugs to seven patients over lengthy periods, well in excess of two months, and that he failed to report to the Chief Executive regarding his treatment of those patients as required by s 120 of the Regulation. Queensland Health had sought reports from Mr Evans on a number of occasions concerning some of those patients. In many instances, Mr Evans did not provide the reports requested.
Section 79 of the Regulation provides that a medical practitioner must not prescribe a controlled drug unless the prescription complies with certain requirements including the following particulars being recorded:
·that the date of birth of the person for who it is prescribed;
·the quantity of the drug;
·for a repeat prescription, a direction stating the time that must elapse between each dispensing of the drug.[6]
[6]Sections 79(4)(c), (e) and (i) of the Regulation.
This information must appear on the front of a paper prescription. Furthermore, if the controlled drug is dexamphetamine, then the words “specified condition” must also appear on the front of the paper prescription.[7]
[7]Section 79(4)(k) of the Regulation.
Mr Evans admits that he wrote prescriptions for the controlled drug dexamphetamine in which those particulars did not appear on the front of the prescription.
In his oral submissions before the Tribunal, Mr Evans indicated that he had never provided such particulars in writing prescriptions throughout his 30 year medical career. With respect, this somewhat misses the point. It has been a requirement that written prescriptions contain those particulars, with the exception of the age of the person for whom the drug was prescribed, from, at least, the making of the Regulation in 1996. The requirement to include the date of birth of the person for whom the drug was prescribed was included in 1999.[8]
[8]Health (Drugs and Poisons) Amendment Regulation (No. 2); SL Number 258 of 1999, s 7.
Mr Evans concedes that his failures in this regard constitute unsatisfactory professional conduct in that he has engaged in professional conduct that is of a lesser standard than that which might reasonably be expected of him by the public or his professional peers, and that it is conduct that demonstrates incompetence, or a lack of adequate knowledge, skill, judgment or care, in the practise of his profession.
Those admissions are appropriately made. His conduct certainly can be characterised that way and thus constitutes unsatisfactory professional conduct.[9]
[9]Section 124(1)(a) of the HP Act.
Failings of the kind to which Mr Evans admits are not to be seen to be mere technical breaches of regulations. The systems of controls established by the Regulation are integral to the protection of members of the community from potentially harmful drugs. The privilege of an endorsed medical practitioner to prescribe such drugs brings with it the burden of responsibility of doing so only in compliance with the regulatory regime.
This is particularly so when the persons for whom the drugs are being prescribed may be drug dependent. The Health Act 1937 defines a drug dependent person to be a person who, as the result of repeated administration of controlled or restricted drugs or poisons, demonstrates impaired control, or exhibits drug seeking behaviour that suggests impaired control, over the person’s continued use of controlled or restricted drugs and who, when the administration of those drugs ceases, suffers, or is likely to suffer, mental of physical distress or disorder.[10] The vulnerability of each person is patent. For these reasons, such failures are serious matters indeed.
[10]Section 5, Health Act 1937.
Ground 2
Ground 2 also concerns the prescribing by Mr Evans of controlled drugs and/or restricted drugs of dependency to patients as outlined above. It alleges that in so doing he conducted himself in a manner which constituted unsatisfactory professional conduct by providing those persons with health services of a kind that was excessive, unnecessary, or not reasonably required for those person’s wellbeing.[11]
[11]Section 124(1)(a) and paragraph (f) of the definition of unsatisfactory professional conduct in the Schedule to the HP Act.
Mr Evans admits that he prescribed the controlled and/or restricted drugs of dependency to those patients in circumstances where there was not sufficient medical reason to do so, or where it was otherwise inappropriate.
Quite clearly, prescribing controlled and/or restricted drugs of dependency on a regular basis to persons known by the medical practitioner to be drug dependent (or where the practitioner ought to have known that), in the absence of a sufficient medical reason, or otherwise inappropriately, is unsatisfactory professional conduct.
Ground 3
Ground 3 concerns the treatment by Mr Evans of a child patient who presented in Mr Evans’ rooms in July 2009. There is some dispute between the parties as to the symptoms with which the patient presented. On Mr Evans version, the patient presented with symptoms of coryza, otherwise known as the common cold. Mr Evans says that he suggested to the child’s mother that the child continue to be treated with paracetamol, fluids and rest; but that the mother implored of him as to whether there was anything further which he could do. On the mother’s version, the child presented with symptoms of influenza.
Mr Evans admits that he treated the child by providing a solution containing sodium chlorite. He informed the child and the child’s mother that the treatment treated cancer and influenza and that the child’s symptoms would be gone in a couple of hours.
Immediately following the digestion of the solution, the child was ill and vomited.
The treatment provided by Mr Evans had not been approved by the Therapeutic Goods Association. Sodium chlorite forms the chemical chlorine dioxide after ingestion through interaction with stomach acid. Chlorine dioxide is toxic and if ingested causes oesophageal burns, nausea, vomiting, abdominal cramps and mental confusion. Mr Evans does not, however, admit that he provided a dose to the child which would cause those symptoms.
Mr Evans further admits that the treatment was not registered in Australia as a substance for internal therapeutic use and it was inappropriate for him to administer it to the patient. He also admits that he failed to comply with the Board’s policy on unconventional medical practice.
Mr Evans admits that his conduct concerning this child patient constituted unsatisfactory professional conduct in that it was conduct of a lesser standard than that which might reasonably be expected of him by the public or his peers; that demonstrated incompetence, or lack of adequate knowledge, skill, judgement or care, in the practice of his profession; was discreditable to his profession; was the provision of health services of a kind that were excessive, unnecessary or not reasonably required for the patient’s wellbeing and was otherwise improper or unethical conduct.
Again, Mr Evans’ admissions in respect of his conduct are appropriate. Accepting Mr Evans’ version of events, he provided his unconventional and unregistered treatment to a child who merely exhibited symptoms of a common cold. The mother’s exhortations are beside the point. Medical practitioners cannot embark upon such unconventional and potentially dangerous methods simply because a loved one of the patient implores them to do something. To submit to such exhortations is to abdicate responsibility and to abandon professional propriety. It was conduct which certainly constituted unsatisfactory professional conduct within the meaning of the HP Act.
Ground 4
Ground 4 concerns the renewal by Mr Evans of his registration in July 2011. The Board alleges that in applying for the renewal of his registration at that time, Mr Evans failed to disclose certain matters.
The Board further claims that in failing to disclose those matters, Mr Evans signed a false declaration on his renewal of registration application.
The first matter which the Board alleges Mr Evans failed to disclose was the fact that on 30 May 2011 his endorsement pursuant to the Regulation to prescribe restricted and controlled drugs had been cancelled.
Mr Evans admits that his endorsement was cancelled on that date. He also admits that he failed to disclose that fact in his application for renewal of his registration.
However, he says that he in fact completed the renewal application on 26 May 2011; that is, four days prior to the cancellation taking place.
The declaration in the copy of the renewal application tendered in the proceedings bears the date 26 May 2011. That document also bears a stamp which shows it was received by the Australian Health Practitioner Regulation Agency (AHPRA) on 12 July 2011. It was received under cover of a letter dated 10 July 2011.[12] In that letter, Mr Evans refers to having sent his application on 26 May 2011. He refers to having checked his banking details and having discovered that the deduction of his renewal fee, authorised in the application, had not been processed.
[12]Document 56 in the Board’s Material tendered by agreement.
The renewal date for his registration had been 30 June 2011. In his submissions to the Tribunal Mr Evans said that a colleague or acquaintance had drawn his attention to the fact that his registration was showing on the AHPRA website as not having been renewed.
It is clear that Mr Evans did not update the application which he had signed on 26 May 2011 when he resubmitted it in July 2011 to include reference to his endorsement to prescribe controlled drugs having been cancelled.
Section E of the application for renewal of registration sets out the obligations of a registered medical practitioner to inform the Board of any change in his or her status in relation to various matters. Those matters include that the practitioner’s authority under a law of a State to prescribe a scheduled medicine, or class of schedule medicine, has been cancelled or restricted.
Section E does not, however, require, of itself, any disclosure. It merely reminds a practitioner of the obligation to inform the Board of such matters. That obligation is imposed by s 130(1) of the National Law. Section 130 obliges registrants to inform the Board of a “relevant event” within seven days of its occurrence. A relevant event includes that the practitioner’s authority under a State law to prescribe scheduled medicines, or a class of scheduled medicine, has been cancelled or restricted.[13]
[13]Section 130(3)(a)(vi) of the National Law.
The Board’s case as to Mr Evans having failed to disclose the cancellation of his endorsement proceeds on the basis that the failure occurred in the completion of the application for renewal, and that Mr Evans signed a false declaration in that regard. It does not proceed on the basis of Mr Evans otherwise having failed to discharge the obligation to inform the Board of a relevant event imposed by s 130 of the National Law.[14]
[14]See paragraphs 41-5 of the Board’s Submissions on Sanction filed 4 April 2013.
For those reasons, the Tribunal would not find that the failure of Mr Evans to include in an application signed on 26 May 2011 information concerning a cancellation which had then not occurred involved the making of a false declaration.
The second matter which the Board alleges Mr Evans failed to disclose in his application for renewal of registration is the complaints which had been made against him. Those complaints were of the prescription of controlled and restricted drugs in return for sexual favours referred by the Health Quality and Complaints Commission; the prescription of controlled drugs in return for sexual favours notified by Queensland Health; and the complaint of the practice of unconventional medicine to which ground three relates.
Those matters of complaint had been notified to Mr Evans, at the latest, in a notice to show cause issued to him in respect of the allegations on 20 September 2010.[15]
[15]Document 61 in the Board’s material tendered by agreement.
Each of those complaints was a relevant event as defined by s 130(3)(a)(vii) as it was a complaint about him to an entity having functions relating to the regulation of health practitioners.[16]
[16]See s 219(1)(e) of the National Law.
As with the obligation to inform the Board of the cancellation of his endorsement to prescribe scheduled medicines, section E of the application for renewal referred to that obligation; but again without creating a separate obligation of disclosure within the application itself.
However, unlike the cancellation of the endorsement, paragraph 14 of section D of the renewal application did require the separate disclosure, within the application itself, of complaints. Answering ‘no’ to the question posed in that section as to whether there had been any such complaints made against him was false. It was also known to be false at the time at which the declaration was made on 26 May 2011. Mr Evans admits to not having disclosed those complaints. Unlike the endorsement cancellation, this was not a matter which only arose after the declaration was signed.
The declaration signed by Mr Evans on 26 May 2011 was, therefore, false. But, does that constitute professional misconduct?
The Board submits that Mr Evans has admitted sufficient facts to establish professional misconduct. In the Statement of Agreed and Disputed Facts, Mr Evans makes the admission that his conduct in this regard constituted professional misconduct. That admission is made on the basis that it was unprofessional conduct that amounts to conduct that is substantially below the standard reasonably expected of a registered health practitioner of an equivalent level of training and experience.[17]
[17]See paragraph (a) of the definition of ‘professional misconduct’ in s 5 of the National Law.
Notwithstanding that admission of misconduct, it is for the Tribunal to be satisfied Mr Evans has, in fact, engaged in professional misconduct.
The declaration itself states that it is made in the knowledge that a false declaration amounts to a contravention of the National Law and may lead to disciplinary action for unprofessional conduct. No mention is made of professional misconduct. Conduct may constitute unprofessional conduct but not professional misconduct.
Because the Tribunal has not heard full argument on this point, and because the sanctions proposed jointly by the parties are not dependent upon a finding of professional misconduct under the National Law, the Tribunal finds that the false declaration made by Mr Evans in this case is unprofessional conduct without deciding whether it was also professional misconduct.
Findings about conduct
The Tribunal is satisfied, and finds, pursuant to s 240(1) of the HP Act that, in respect of each of grounds one to three, a ground for disciplinary action has been established in that Mr Evans has behaved in a way which constitutes unsatisfactory professional conduct.
The Tribunal is also satisfied, and finds, pursuant to s 196(1)(b)(ii) of the National Law that, in respect of ground four, Mr Evans has behaved in a way that constitutes unprofessional conduct.
Sanction
The Board has proposed orders which it says would be an appropriate sanction of Mr Evans’ conduct in this case. Central to that sanction is the provision by Mr Evans of an undertaking to the Medical Board of Australia that he will not reapply for registration as a health practitioner in any jurisdiction in Australia.
Mr Evans has provided such an undertaking. He has also undertaken never to apply to be relieved of that undertaking.[18]
[18]Exhibits 2 and 3. The draft order provided by the Board to the Tribunal does not reflect the further undertaking not to apply to be relieved from the primary undertaking not to seek re-registration. The orders of the Tribunal should reflect both the primary and secondary undertakings.
In deciding what action to take against a person in respect of whom the Tribunal has decided a ground for disciplinary action has been established, the Tribunal must have regard to the purposes of disciplinary action mentioned in s 123 of the HP Act,[19] which are to protect the public; uphold the standards of the practice within the relevant health profession, and to maintain public confidence in the profession. These purposes mirror the objects of the HP Act.[20] The purpose of disciplinary proceedings is protective is not punitive.
[19]Section 244(1)(a) of the HP Act.
[20]Section 6(a), (b), (c), of the HP Act.
Had the undertaking given by Mr Evans not been provided, this is a matter in which suspension for a considerable period of time would have been appropriate to satisfy the purposes of these disciplinary proceedings. In the circumstances of this case, approving the undertaking entered into by Mr Evans with the Medical Board of Australia would satisfy those purposes.
Through his surrendering his registration and undertaking never to seek re-registration the protection of the public is ensured. His withdrawal from all medical practice as a consequence of these proceedings having been brought will also maintain public confidence in the profession and assist in upholding the standards of practice within it.
The approval of such an undertaking is a form of sanction as provided for by the HP Act.[21] In other cases, the Tribunal has considered such an undertaking as an appropriate sanction.[22]
[21]Section 241(2)(c).
[22]Medical Board of Queensland v Broadbent (No 3) [2010] QCAT 488; Pharmacy Board of Australia v Brenton [2011] QCAT 302; Pharmacy Board of Australia v The Registrant [2012] QCAT 515.
In my view, to impose a sanction beyond that which has been proposed by the Board would be to act in a punitive rather than a protective manner.
Section 242(1) of the HP Act requires that where the sanction imposed is the approval of an undertaking entered into with the Board, the Tribunal must also decide whether details of the undertaking must be recorded in the Board’s register for the period for which the undertaking is in force. I consider that the recording of the undertaking in the Board’s register is appropriate.
Non-Publication Order
The Board seeks an order pursuant to s 66(1) of the Queensland Civil and Administrative Tribunal Act 2009 prohibiting the publication of certain documents filed in the proceedings so as to avoid the publication of confidential information relating to the persons to whom the application relates.
Those documents do contain a large volume of information personal to those persons, including their medical records, the publication of which would be contrary to the public interest.[23] It may also be the case that publication of that information may endanger the mental health of those persons.[24] It is also in the interests of justice to prohibit the publication of that material in order to balance on the one hand, the need for such material to be referred to in medical disciplinary proceedings such as these, with the protection of the rights to privacy and confidentiality which would otherwise attach to sensitive medical records.[25]
[23]Section 66(2)(d), QCAT Act.
[24]Section 66(2)(b), QCAT Act.
[25]Section 66(2)(e), QCAT Act.
For those reasons, the Tribunal will make an order prohibiting the publication of the documents contained in the schedule attached to these reasons.
Costs
The parties have agreed to an order that Mr Evans pay the Board’s costs of and incidental to the proceedings fixed in the sum of $61,000.00.
Whilst that is a considerable amount, at the hearing the Board was given leave to read and file an affidavit of Brooke Elisabeth Carruthers which deposed to the costs of the Board being significantly more than that amount.
Until a few weeks prior to the hearing the matter was to have proceeded as a fully contested hearing which had been listed for five days. There had been a number of earlier steps taken including five directions hearings and three compulsory conferences. On a number of occasions Mr Evans had failed to comply with directions and the Board’s solicitors were required to take steps in an attempt to seek his compliance.
In the circumstances, the Tribunal will make the costs order agreed between the parties.
Schedule
1.Annexures A to D of the Referral - Disciplinary Proceedings filed 21 March 2012;
2.Affidavit of Service of Christopher Bruce Bensmann, Process Server dated 16 May 2012 (attachment to the Affidavit contains Annexures A to D of the Referral);
3.Category A Document No. 4 (Email Dr Evans to Helen Luery dated 8.08.2011);
4.Category A Document No. 5 (Agenda Paper of Medical Board of Australia meeting including attachments dated 28.07.2011);
5.Category A Document No. 6 (Agenda Paper of Medical Board of Australia Meeting dated 22.07.2011);
6.Category B Document No. 20 (Agenda Paper of Meeting with Performance and Professional Standards Committee and Medical Board of Australia dated 14.09.2010 including briefing note with attachments);
7.Category B Document No. 22 (Email from AHPRA dated 21.10.2010);
8.Category B Document No. 23 (Email from AHPRA 21.10.2010);
9.Category B Document No. 25 (Preliminary Investigation Report dated 2.11.2010, including Attachment A);
10.Statement of LTW filed 29 November 2012;
11.Statement of BWW filed 29 November 2012;
12.Statement of MAW filed 7 March 2013;
13.Report of Dr Brian Kable filed 13 February 2013;
14.Report of Dr Brian Kable dated 30 March 2013 (to be filed contemporaneously with the Medical Board of Australia's submissions on sanction);
15.Document 1 of the Medical Board of Australia's Material;
16.Document 2 of the Medical Board of Australia's Material;
17.Document 3 of the Medical Board of Australia's Material;
18.Document 4 of the Medical Board of Australia's Material;
19.Document 5 of the Medical Board of Australia's Material;
20.Document 6 of the Medical Board of Australia's Material;
21.Document 7 of the Medical Board of Australia's Material;
22.Document 8 of the Medical Board of Australia's Material;
23.Document 9 of the Medical Board of Australia's Material;
24.Document 10 of the Medical Board of Australia's Material;
25.Document 11 of the Medical Board of Australia's Material;
26.Document 12 of the Medical Board of Australia's Material;
27.Document 13 of the Medical Board of Australia's Material;
28.Document 14 of the Medical Board of Australia's Material;
29.Document 15 of the Medical Board of Australia's Material;
30.Document 16 of the Medical Board of Australia's Material;
31.Document 17 of the Medical Board of Australia's Material;
32.Document 18 of the Medical Board of Australia's Material;
33.Document 19 of the Medical Board of Australia's Material;
34.Document 20 of the Medical Board of Australia's Material;
35.Document 21 of the Medical Board of Australia's Material;
36.Document 22 of the Medical Board of Australia's Material;
37.Document 23 of the Medical Board of Australia's Material;
38.Document 24 of the Medical Board of Australia's Material;
39.Document 25 of the Medical Board of Australia's Material;
40.Document 26 of the Medical Board of Australia's Material;
41.Document 27 of the Medical Board of Australia's Material;
42.Document 28 of the Medical Board of Australia's Material;
43.Document 29 of the Medical Board of Australia's Material;
44.Document 30 of the Medical Board of Australia's Material;
45.Document 31 of the Medical Board of Australia's Material;
46.Document 32 of the Medical Board of Australia's Material;
47.Document 33 of the Medical Board of Australia's Material;
48.Document 34 of the Medical Board of Australia's Material;
49.Document 35 of the Medical Board of Australia's Material;
50.Document 36 of the Medical Board of Australia's Material;
51.Document 37 of the Medical Board of Australia's Material;
52.Document 38 of the Medical Board of Australia's Material;
53.Document 39 of the Medical Board of Australia's Material;
54.Document 40 of the Medical Board of Australia's Material;
55.Document 41 of the Medical Board of Australia's Material;
56.Document 42 of the Medical Board of Australia's Material;
57.Document 43 of the Medical Board of Australia's Material;
58.Document 44 of the Medical Board of Australia's Material;
59.Document 45 of the Medical Board of Australia's Material;
60.Document 46 of the Medical Board of Australia's Material;
61.Document 47 of the Medical Board of Australia's Material;
62.Document 48 of the Medical Board of Australia's Material;
63.Document 49 of the Medical Board of Australia's Material;
64.Document 53 of the Medical Board of Australia's Material;
65.Document 54 of the Medical Board of Australia's Material;
66.Document 55 of the Medical Board of Australia's Material;
67.Document 61 of the Medical Board of Australia's Material.
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