Assistance Program and to engage in ongoing clinical counseling after successful
completion of the primary treatment program. Respondent was to enter treatment due to
his diagnoses of Obsessive Compulsive Disorder; Frotteurism and Professional Sexual
Misconduct; and Depressive Disorder. Respondent also agreed to not practice clinical
medicine until successfully completing the above treatment program.

3. On or about September 2, 2009, ISMA terminated Respondent?s
Continuing Care Contract due to the fact that Respondent had failed to enter into a
treatment program and stated to ISMA that he had no plans to do so.

COUNT 

Respondent?s conduct as described above constitutes a violation of Indiana Code 
in that Respondent has continued to practice although he has become
un?t to practice due to physical or mental disability as evidenced by the Respondent?s
diagnoses of Obsessive Compulsive Disorder, Frotteurism and Professional Sexual
Misconduct; and Depressive Disorder; and his failure to enter into treatment for these
disorders.

WHEREFORE, Petitioner demands an order against the Respondent, that:

1. Imposes the appropriate disciplinary sanction;
2. Directs Respondent to immediately pay all the cost incurred in the
prosecution of this case; i

3. Provides any other relief the Board deems just and proper.