) 68-178 w CAL EXAMINERS + i INARY MEI DAS! 20 BEFORE THE NEVADA STATE BOARD OF VETERINARY MEDICAL EXAMINERS In the Matter oft | ) Case No. 08-2016DVM-36 MAUREEN ADAMS, DVM ) ) SETTLEMENT AGREEMENT AND ORDER License #1060 ) ) ‘The Nevada State Board of Veterinary Medical Examiners, by and through its inve: ting board member Scott Bradley, D.V.M., and Maureen Adams, D.V.M. stipulate and agree to resolve and settle the above-captioned matter. This stipulation is made and based upon the following information, BACKGROUND FOR SETTLEMENT AG) MENT AND ORDER 1. Atall times pertinent to this matter, Dr. Adams was licensed as a licensed veterinarian in the State of Nevada and is, therefore, subject to the jurisdiction of the Board, At all times pertinent to this matter, Dr. Adams owned or co-owned All Creatures Veterinary Hospital (ACVH) located at 7111 S. Virginia Street, Suite A6 in Reno, Nevada, 2. On January 26, 2017, the Board reviewed and approved a Consent Decree negotiated between the Investigating Board Member, Dr. Scott Bradley, and Dr. Adams. The underlying factual basis for the Consent Decree involved Dr. Adams’ treatment of a 2-year-old, male, neutered cat which Dr. Adams diagnosed as having Feline Urological Syndrome (FUS) and upon which Dr, Adams performed a perineal urethrostomy surgery. According to Dr. Adams’ records, the surgery took almost three hours to complete (when it normally should take less than an hour), and was not done to the standard of care expected of a general practice veterinarian, ‘The eat was eventually taken to a board- certified surgeon who repaired Dr. Adams’ negligent surgery, and the cat was thereafter able to function normally. Additional findings in the investigation included that Dr. Adams’ records were substandard and that Dr. Adams and her practice did not communicate effectively or ethically with the cat’s owner 3. Asa result of the investigation and negotiations with Dr. Adams, the Consent Decree provided that Dr. Adams’ license would be on probation fora period of two years and that the conditions of the probation included:(775) 688-1788 2 Z Building 0, 5 a 2 2 z 5 Zz DARD OF VE NEVADA SI (2) Dr. Adams’ hospital shall be subject to random inspections throughout the period of probation. If the inspections note any violations of Nevada law, Dr, Adams shall immediately Temediate all such violations. The inspections may include the pulling of medical records, in the discretion of the inspector. (b) Dr. Adams shall not perform any surgery and shall refer any patient in need of Surgical treatment to another veterinarian in her practice or to an appropriate veterinarian outside the practice, and Dr. Adams shall perform no surgery after the period of probation unless she has obtained such additional training, knowledge. and skills sufficient to satisfy the Investigating Board Member (IBM) that she could perform surgery safely and competently The IBM may limit the scope of such surgeries that Dr. Adams will be allowed to perform after the period of probation as the IBM deems necessary and appropriate and may modily the seope of such surgeries at Dr. Adams’ request and upon determination that Dr. Adams may perform such additional surgeries safely and competently. (©) Dr. Adams agrees that ACVH needs to employ a practice administrator to oversee the operations of ACVH, and Dr. Adams commits to seeking to employ an experienced practice administrator as soon as practicable, Dr. Adams shall report to the Board's staff in writing by the first day of each month regarding the efforts she has made to employ an experienced Practice administrator until such time as she is able to employ such a person. It will bea violation of the probation if the IBM determines that Dr. Adams is not making continuous good faith effort to find and employ an experienced practice administrator. (@) Dr. Adams shall assure that all routine communications seeking response from ‘owners or their agents or representatives are addressed by an appropriate member of the ACVHL staff no later than 24 hours after the communication is initiated and that if the communication indicates medical decline, emergency, or necessity, the communication receives a response commensurate with the information provided by the owner, agent, or representative. (e) The practices of Dr. Adams and ACVH shall be monitored and assessed by an experienced veterinary practice administrator approved by the IBM (hereinafter “practice monitor”), Dr. Adams shall cooperate fully with all reasonable requests for access to ACVHL facilities and records from the practice monitor. The practice monitor shall review medical records, policies and procedures, forms, and other practice-related documents in such quantity and under such conditions as he or she deems appropriate to assure that Dr. Adams and ACVH are making records that conform with NAC 638.0475, that Dr, Adams performs no surgery, and that Dr. Adams and the staff at ACVH are complying with the communications requirement in the immediately preceding subparagraph. In furtherance of his or her duties, the practice monitor may also observe Dr. Adams's practice to assure compliance with this Consent Decree and may contact owners to discuss their interactions with Dr. Adams and ACVH. ‘The practice monitor shall inform each owner contacted, that he or she is conducting a routine follow-up contact regarding the treatment of the animal, ‘The practice monitor shall dedicate sufficient time in the performance of his or her duties. ‘The practice monitor shall present a report of his or her findings, conclusions, and observations regarding Dr. Adams's compliance with this Consent Decree to the Board at least every three months throughout the probationary period, Each such report shall also be contemporancously submitted to Dr, Adams. If any report raises an issue or concern regarding the compliance with the terms of this Consent Decree, the IBM and Dr, Adams shall discuss the concerns and shall reach an understanding from Dr. Adams about how she will address and alleviate the concern. (Dr. Adams shall comply with all laws, whether federal or state and whether statutory or regulatory, related to the practice of veterinary medicine. Any substantive violations of such Jaws during the period of probation shall be considered violations of her probationTE. BOARD OF VETERINARY MEI 2 20 3. On July 11, 2017, the Board's Staff leamed from Dr. Adams’ staff that Dr. Adams had performed or participated in surgeries on animals at ACVH on January 31, February 2, February 7, and March 1, 2017, all in violation of the terms of probation contained in the Consent Decree. 4, Also on July 11, 2017, the Board’s Staff learned from Dr. Adams’ staff that Dr. Adams secretively had removed from ACVH’s stock quantities of tramadol tablets for her personal use. ‘Subsequent investigation, including Dr. Adams" personal admissions, determined that Dr. Adams had removed the tramadol tablets for her personal ingestion and that she had taken actions to keep the removal and use of the tramadol from being discovered by ACVH staff, which would constitute a Violation of Nevada law and, therefore, the terms of probation contained in the Consent Decree. 5. Subsequent investigation revealed that Dr, Adams’ removal and personal ingestion of tramadol occurred at least through the period of January 2017 through March 2017. During this period, Dr. Adams saw and treated animals at ACVH, which would constitute a violation of Nevada law and, therefore, the terms of probation contained in the Consent Decree. 6. After Dr. Adams’ removal and personal ingestion of tramadol from ACWH was discovered by ACVH staff and the Board, Dr, Adams admitted herself into in-patient treatment for substance abuse where she treated for 30 days in March and April, 2017. After her release from the in-patient treatment program, Dr. Adams did not join the PRN program or any other program of aftercare. 7. On July 27, 2017, Dr, Adams met with the Board’s Staff at the Board’s office, At the meeting were Dr. Adams, Dr. Adams’ son David, Executive Director Jennifer Pedigo, and Board Counsel Louis Ling. The discussion entailed Dr. Adams’ removal and use of tramadol from ACV and options to address the situation. Ultimately, the parties agreed that Dr. Adams would voluntarily put her license into abeyance effective immediately, that Dr. Adams would not practice veterinary medicine thereafter, that Dr. Adams would not enter the premises of ACVH thereafter except as an owner of animals seeking treatment, that Dr. Adams would voluntarily join the PRN program, and that Dr. Adams would actively abide by the conditions imposed by the PRN program. Dr. Adams acknowledged that the result of the agreement of the parties was that she would immediately cease the practice of veterinary medicine and that the cessation of practice might be for a prolonged period ofsn, Nevaela BOSD © Kiclrke Lit Zz 3 3 3 Zz 8 s z ‘months or years, or even indefinitely, depending upon her progress in the PRN program. Subsequently and in accord with the agreement between the parties, Dr. Adams did enter into a substance abuse treatment contract with PRN. 8. On September 5, 2017, Board Staff was informed by ACVH staff that on September 3 and 4, 2017, Dr. Adams had allowed herself into ACVH to treat a coatimundi. Subsequent investigation, including admissions from Dr. Adams, confirmed that Dr. Adams did see and treat the coatimundi on September 3 and 4 by providing the materials for subcutaneous hydration to the owner of the coatimundi. Dr. Adams made no records regarding her treatment of the coatimundi. The treatment of the coatimundi and the failure to make records related thereto constitute violations of Nevada law, the agreement Dr. Adams had reached with Board Staif, and the terms of probation contained in the Consent Decree. 9. On December 20, 2017, the Board, through its investigating board member, filed an Accusation in this matter, stating therein seven Causes of Action related to the matters set out in the preceding cight paragraphs. This Settlement Agreement and Order is intended to fully and fairly resolve the issues raised in the Accusation. ACKNOWLEDGMENTS AND APPLICABLE LAW, 1. Dr. Adams is aware of, understands, and has been advised of the effect of this settlement agreement, which she has carefully read and fully acknowledged. Dr. Adams consulted with and was represented by competent counsel of his choice, namely Stephanie Funk of Fahtendorf, Viloria, lig & Oster. 2. Dr. Adams has entered into the settlement agreement, and she is aware of her rights to contest the charges pending against her. These rights include representation by an attorney at her own expense, the right to a public hearing on any charges or allegations formally filed, the tight to confront and cross: examine witnesses called to testify against her, the right to present evidence on her own behalf, the right to testify on her own behalf, the right ro obtain any other type of formal judicial review of this matter, and any other rights which may be accorded to her pursuant the provisions of Chapters 2338, 622,2 3 ©, Suite 2 z 2 g z BOARD OF a 2 20 622A, and 638 of the NRS and the NAC. Dr. Adams Board's a waiving all these rights in exchange for the wecoptance of this settlement agreement. 3. Should the secclement agreement be rejected by the Board, itis agrecd that presentation to and consideration by the Board of stich proposed settlement agreement or other documents or matters pertaining to the consideration of this settlement agreement shall not unfairly oF illegally prejudice the Board or any of its members from further participation, consideration, adjudication, or resolution of these proceedings and that no Board member shall be disqualified or challenged for bias. 4, Dr. Adams and the Board acknowledge that NRS 638.152 provides immunity for the Board, its employees, and its retained specialists from any potential action that might be brought by Dr. Adams and that for the purposes of NRS 638.152, Dr. Adams acknowledges that the Board, its employees, and its retained specialists have acted in good faith throughout the conduct of this matter. 5, Dr. Adams acknowledges that the settlement agreement shall only become effective after both the Board and she have duly executed it 6, Dr, Adams enters into this settlement agreement after being fully advised of her rights and as to the consequences of this settlement agreement. This settlement agreement embodies the entire agrcement reached between the Board and Ds. Adams. It may not be altered, amended, ot modified ‘without the express consent of the parties 7. In an effort to avoid the cost and uncertainty of a hearing, the parties have agreed to settle this matter. For the purposes of resolving this matter, Dr, Adams acknowledges that the facts contained in the above “Background for Settlement Agreement and Order” portion of this agreement are true and correct. Dr. Adams further acknowledges that certnin facts contained in the preceding four paragraphs could be found to constitute violations of the various provisions of Nevada law contained in the Accusation if this matter went to a Board hearing. 8. Both parties acknowledge that it is in the best interests of each to resolve this matter without a full hearing on the merits hecause of the cost and risk involved for each party. 9, Both parties acknowledge that the Board has jurisdiction to consider and ratify this settlement agreement and order because Dr. Adams is a veterinarian licensed by the Board. Dr. Adams expressly,5) 688-1788 0, Suite 2 g NEVADA STATE BOARD OF VETERINARY MEDICAL EXAMIN 16 knowingly, and intentionally waives the 21-day notice requirement contained in the Nevada Open Meeting Law and acknowledges that this settlement agreement and order may be presented to the Board for its consideration and potential ratification at the Board's meeting on January 24 or 25, 2018, AGREED DISCIPLINE Based upon the above, the parties desire to resolve the Accusation in this matter by affirming, that the terms and cont ions of the Consent Decree entered by the Board on January 26, 2017 remain in effect and to add thereto the following terms and conditions: 1. Effective upon the Board’s approval of this Settlement Agreement and Order, Dr. Adams’ veterinarian’s license (License #1060) shall be indefinitely suspended, Thereafter, Dr. Adams shall surrender any keys she has to ACVH to the staff of ACVH, and Dr. Adams agrees and understands that staff of ACVH can take any and all actions necessary to assure that Dr. Adams cannot gain entry to ACVH, including but not limited to changing the locks and entry codes. Thereafier, Dr, Adams will not enter any veterinary facility except as the owner of an animal seeking treatment of her personal animals, and Dr. Adams will not perform any veterinary services upon any animals except her own personal animals at any veterinary facility or any other place and whether for compensation or not unless and until the suspension of her license is lifted. 2. Dr. Adams will comply with and participate in the PRN program pursuant to all terms and conditions required of her by PRN as PRN determines are necessary and beneficial to further Dr ‘Adams’ recovery and prognosis. PRN is authorized to provide updates, reports, and other documentation to the Board's office related to the course of her treatment with PRN. Dr. Adams shall bbe responsible for all costs related to her participation in the PRN program and shall timely pay those costs as she is billed or notified by PRN of them. 3. Within 10 days of the effective date of this Settlement Agreement and Order, Dr. Adams will arrange to be examined by a psychiatrist or psychologist selected by the Board's Staff and the IBM Dr. Adams shall participate in the examination in good faith with the intent being to determine whether, and iso, to what extent she may have psychiatric or psychological conditions related to her anger management, antiauthoriarianism, untruthfulness, untrustworthiness, and substance abuse. Dr. Adams 62 = (775) 68 1 New ing O, Suite 265 * Ren INARY MEDICAL EX AMIN! DA STATE BOARD OF V shall execute whatever documents are necessary 1o authorize the psychiatrist or psychologist to provide reports, files, and other documents related to the examination and determinations related to Dr. Adams. Ifthe psychiatrist or psychologist determines that Dr. Adams suffers from one or more conditions amendable to treatment, the psychiatrist or psychologist shall so notify Dr. Adams and Board Staff in writing, Thereafter, Dr. Adams and the IBM shall consult to determine whether, and if so, how Dr ‘Adams will treat or address the issues identified by the psychiatrist or psychologist. Dr. Adams and the Board shall each pay for one-half of the costs of the psychiatric or psychological examination under this paragraph, 4, Dr. Adams may apply for the lifting of her indefinite suspension oaly upon the following terms and conditions: (@) Submittal by PRN of a written notice that Dr. Adams has been fully compliant with her PRN program and that PRN believes to a reasonable degree of certainty that Dr. Adams could safely resume the practice of veterinary medicine. PRN may, as part of the written notice, suggest terms and conditions that it believes would be necessary or beneficial to Dr. Adams? continued wellness once she was allowed to resume the practice of veterinary medicine. (b) Maintaining of an active license with the Board throughout the period of the indefinite suspension, including proving the successful completion of all requited continuing education, (©) Completion of all of the other terms and conditions of this Settlement Agreement and Order. 5. When the Board’s Staff receives the written notice from PRN pursuant to the preceding paragraph and determines that Dr. Adams is otherwise fully compliant with the terms and conditions of this Settlement Agreement and Order, then Dr. Adams” matter shall be placed upon the next Agenda for aregular Board meeting. The Board shall thereafter: (@) Review documents and materials pertinent to Dr. Adams’ compliance with her PRN program and the terms and conditions of this Settlement Agreement and Order;Wwike 265 * Reto, Neva ©. AMINERS © (600 Rietwke Lane, B BOARD OF VETERINARY MEDICAL NEVADA ST: 21 8 (b) Question and discuss the matter at the Board’s mecting with Dr. Adams, a PRN representative, and, if requested, any other treatment provider who had worked with Dr. Adams during her period of indefinite suspension to determine whether Dr. Adams; (©) Consider any information or documents presented by Dr. Adams in support of her request to have the indefinite suspension, which may include the testimony of persons Dr. Adams would present; (d) Determine whether lifting Dr. Adams’ indefinite suspension is in the best interests of animals and clients that she might serve and the State of Nevada; and (e) Establish whatever terms and conditions for her return (o the practice of veterinary medicine as the Board deems necessary or beneficial under the circumstances then before the Board. 6. Dr, Adams shall pay the Board's fees and costs incurred in the investigation and processing of this matter subsequent to the entry of the Consent Decree in the amount of $3,449.00 by certified check or money order made payable to “Nevada State Board of Veterinary Medical Examiners.” Dr. Adams may negotiate terms and conditions with the Board’s Executive Director to pay the sum due hereunder upon terms agreeable to the Executive Director and the IBM. Dr. Adams may not seek the lifting of her indefinite suspension unless and until she has paid the entire amount due under this paragraph, 7. All other terms and conditions imposed by the Consent Decree in this matter not inconsistent with this Settlement Agreement and Order remain in force and effect, and any violation of those terms or any of the terms and conditions contained in this Settlement Agreement and Order will be deemed a violation of the Consent Decree and this Settlement Agreement and Order. 8. Dr. Adams acknowledges and agrees that this Settlement Agreement and Order may be enforced on a “zero tolerance” basis, meaning that if the Board’s Staff and the IBM determine to a reasonable degree of certainty that Dr. Adams has substantively breached any of the terms and conditions of this Settlement Agreement and Order, then the Board’s Staff and the IBM may revoke Dr Adams’ license or may impose other terms and conditions upon her license unilaterally and without &a g 2 3 2 3 20 NARY MEDICAL EXAMINERS further notice to or involvement of the Board by issuing a written notice to Dr. Adams of the revocation of her license. Board Staff may take any and ail actions it deems necessary to collect any sums ordered that remain unpaid, If Roard Staff is required to pursue judicial action to affect such collections, it shall be entitled to recover its attorney's fees and costs incurred in pursuing such judicial action, Signed and effective this 2S _ day of January, 2018, NEVADA STATE BOARD OF DR. MAUREEN ADAMS, VETERINARY MEDICAL EXAMINERS ‘Scott Bradley, D.V'Nt Investigating Board Member Respondent ORDER By a majority vote on January_2.5_, 2018, the Nevada State Board of Veterinary Medical Examiners approved and adopted the terms and conditions set forth in the attached Seitlement Agreement and Order Modifying Consent Decree with Maureen Adams, D.V.M. ‘THIS ORDER IS HEREBY MADE EFFECTIVE this 2 day of \anwe ‘THE NEVADA STATE BOARD OI VETERINARY MEDICAL EXAMINERS. INAL ‘ ‘AL, DVM Board President5) 688.17 77 Neva BEFORE THE NEVADA STATE BOARD OF VETERINARY MEDICAL EXAMINERS. In the Matter of: ) ) Case No. 08-2016DVM-36 MAUREEN ADAMS, DVM ) ) ACCUSATION License #1060 ) ) ‘The Nevada State Board of Veterinary Medical Examiner, by and through its Executive Director Jennifer Pedigo, makes the following accusation against Respondent Maureen Adams, D.V.M. (License No, 1060) which shall serve as an accusation pursuant to NAC 638.240 and as a notice of intended action pursuant to NRS 233B.127(3), The pertinent facts and law regarding this accusation are as follows: ‘The Board has jurisdiction over this matter because Respondent Maureen Adams, D.V.M. is a veterinarian licensed by the Board (License No. 1060). Dr. Adams is an owner of All Creatures Veterinary Hospital (ACVH), a licensed veterinary facility (11126), in Reno, Nevada. i (On January 26, 2017, the Board reviewed and approved a Consent Decree negotiated between the Investigating Board Member, Dr, Scott Bradley, and Dr. Adams, ‘The underlying factual basis for ‘the Consent Decree involved Dr. Adams’ treatment of a 2-year-old, male, neutered eat which Dr. ‘Adams diagnosed as having Feline Urological Syndrome (FUS) and upon which Dr. Adams performed perineal urethrostomy surgery. According to Dr. Adams’ records, the surgery took almost three hours to complete, and was not done to the standard of care expected of a general practice veterinarian. A normal surgical time for a perineal urethrostomy without complications is generally less than one hour. TThe cat was eventually taken to a board-certified surgeon who repaired Dr. Adams’ negligent surgery, and the cat was thereafter able to function normally. Additional findings in the investigation included that Dr. Adams’ records were substandard and that Dr. Adams and her practice did not communicate effectively or ethically with the cat's owner.3 g 7 i z ui, Asa result of the investigation and negotiations with Dr. Adams, the Consent Decree provided that Dr, Adams’ license would be on probation for a period of two years and that the conditions of the probation included: (a) Dr. Adams” hospital shall be subject to random inspections throughout the period of probation. Ifthe inspections note any violations of Nevada law, Dr. Adams shall immediately remediate all such violations. The inspections may include the review of medical records, in the discretion of the inspector. (b) Dr. Adams shall not perform any surgery and shall refer any patient in need of surgical treatment to another veterinarian in her practice or to an appropriate veterinarian ‘outside the practice, and Dr. Adams shall perform no surgery after the period of probation unless she has obtained such additional training, knowledge, and skills sufficient to satisfy the Investigating Board Member (IBM) that she could perform surgery safely and competently. The IBM may limit the scope of such surgeries that Dr. Adams will be allowed to perform after the period of probation as the IBM deems necessary and appropriate and may modify the scope of such surgeries at Dr. Adams’ request and upon determination that Dr. Adams may perform such additional surgeries safely and competently (0) Dr. Adams shall comply with all laws, whether federal or state and whether statutory or regulatory, related to the practice of veterinary medicine. Any substantive violations of such laws during the period of probation shall be considered violations of her probation. Iv. On July 11, 2017, the Board’s staff learned from Dr. Adams’ staff that Dr. Adams had performed or participated in surgeries on animals at ACVH on January 31, February 2, February 7, and March 1, 2017 in violation of the terms of probation contained in the Consent Decree. ye (On July 11, 2017, the Board's staff learned from Dr. Adams’ staff that Dr. Adams secretively had removed from ACVH’s stock quantities of tramadol tablets for her personal use. Tramadol is a controlled substance in schedule IV. Subsequent investigation, including Dr. Adams" personal admissions, determined that Dr. Adams had removed the tramadol tablets for her personal ingestion and that she had taken fraudulent, deceitful, or misrepresentative actions to keep the removal and use of the tramadol ftom being discovered by ACVH staff, which would constitute a violation of Nevada law and, therefore, the terms of probation contained in the Consent Decree. vi80502 » (775) GRB-A7RE Z ETERINARY MEDICAL EXAMINERS + 4600 Kictshe ‘ATE BOARD OF EVADAS NE 20 Subsequent investigation revealed that Dr. Adams" removal and personal ingestion of tramadol occurred at least through the period of January 2017 through March 2017. During this period, Dr. ‘Adams saw and treated animals at ACVH, which would constitute a violation of Nevada law and, therefore, the terms of probation contained in the Consent Decree. vil. After Dr. Adams’ removal and personal ingestion of tramadol from ACVH was discovered by ACVH staff'and the Board, Dr. Adams admitted herself into in-patient treatment for substance abuse where she treated for 30 days in June and July, 2017. After her release from the in-patient treatment program, Dr. Adams did not independently pursue any program of aftercare. On July 27, 2017, Dr. Adams met with the Board’s staff at the Board’s office. Present at the meeting were Dr. Adams, Dr. Adams” son David Adams, Executive Director Jennifer Pedigo, and Board Counsel Louis Ling. The discussion entailed Dr. Adams" removal and use of tramadol from ACVH and options to address the situation, Ultimately, the parties agreed that Dr. Adams would voluntarily put her license into abeyance effeetive immediately, that Dr. Adams would not practice veterinary medicine thereafter, that Dr. Adams would not enter the premises of ACVH thereafter except as an owner of animals seeking treatment, that Dr. Adams would voluntarily join the PRN program, and that Dr. Adams would actively abide by the conditions imposed by the PRN program. Dr. Adams acknowledged that the result of the agreement of the parties was that she would immediately cease the practice of veterinary medicine and that the cessation of practice might be for a prolonged period of ‘months or years, or even indefinitely, depending upon her progress in the PRN program. Subsequently and in aceord with the agreement between the parties, Dr. Adams did enter into a substance abuse treatment contract with PRN. x On September 5, 2017, Board staff was informed by ACVH staff that on September 3, 2017, 2017, Dr. Adams had allowed hersel (0 ACVH to treat a coatimundi, Subsequent investigation, including admissions from Dr. Adams, confirmed that Dr. Adams did sce and treat the coatimundi on9502 g 5 2 NEVADA STATE BOARD OF VETERINARY MEDICAL EXAMINE or 25 26 28 September 3 by providing the materials for intravenous hydration to the owner of the coatimundi. Dr. ‘Adams made no records regarding the treatment of the coatimundi-, which constitute violations of Nevada law, the agreement Dr. Adams had reached with Board staff, and the terms of probation contained in the Consent Decree. FIRST CAUSE OF ACTION 4 In being addicted to a controlled substance, namely tramadol (a schedule IV controlled substance), Dr. Adams violated Nevada Revised Statutes (NRS) 638.140(3). SECOND CAUSE OF ACTION XL. In removing a controlled substance, namely tramadol, from her veterinary practice for her personal use, Dr, Adams violated NRS 638.140(1) and Nevada Administrative Code (NAC) 638.048(6). In practicing veterinary medicine or otherwise providing professional services at times when she was under the influence of or impaired by the use of a controlled substance, namely tramadol, Dr. Adams violated NRS 638.140(1) and NAC 638.048(5). FOURTH CAUSE OF ACTION XU In performing surgeries on at least five animals in January through March 2017, Dr. Adams violated the terms of her Consent Decree and, thereby, NRS 638.140(9). FIFTH CAUSE OF ACTION XIV. In practicing veterinary medicine after July 27, 2017 after she had agreed with Board staff that she would not do so and in violation of her subsequent substance abuse treatment agreement with PRN, by which she also agreed not to practice veterinary medicine, namely by0, Suite 265, ee 4 treating a coatimundi in September 2017 as ACVH, Dr. Adams violated NRS 638.140(9). SIXTH CAUSE OF ACTION XV. In seeing and treating a coatimundi and her personal dog in September 2017 and without making medical records regarding the encounters, Dr. Adams violated NRS 638.140(1) or NRS 638.140(9) and NAC 638.0475. SEVENTH CAUSE OF ACTION XVL All of the violations in the First, Second, Third, Fourth, Fifth, and Sixth Causes of Action, or any one of them, constitute violations of Nevada law and, therefore, constitute violations of Dr. Adam’s Consent Decree and NRS 638.140(9). Signed and this 249 “day of December, 2017 investigating | Board Mémber >