Criminal Complaint against Michael Andrew


From May 2001 until May 2003, Michael Andrew misrepresented himself as a surgeon and graduate of Johns Hopkins University School of Medicine. He served as chief executive officer of Meadows Diagnostic Imaging Center in Henderson, Colorado and supervised at least ten contrast x-ray procedures while pretending to be a physician. (During such procedures, a dye is injected into the patient to highlight the areas that are being studied. A physician's presence is necessary in case the dye causes anaphylactic shock, a potentially fatal allergic reaction.) Michael had received a bachelor’s degree from the now-defunct Hamilton University, a nonaccredited online school based in Wyoming, and was enrolled in St. Luke’s School of Medicine, a correspondence school that has since been shut down by Liberian government authorities. In June 2005, Michael pleaded guilty to one felony count of attempt to practice medicine without a license. In August he was sentenced to serve 120 days in the Clark County Detention Center to be followed by 4 years of intensive supervision probation.


IN THE JUSTICE COURT OF LAS VEGAS TOWNSHIP
IN AND FOR THE COUNTY OF CLARK, STATE OF NEVADA

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THE STATE OF NEVADA

Plaintiff,

vs.

ANDREW ELIAS MICHAEL,
#1270175,

Defendant.


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AFFIDAVIT IN SUPPORT OF
CRIMINAL COMPLAINT

STATE OF NEVADA

CLARK COUNTY

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BERNARD T. VELETA, being duly sworn, deposes and states, under penalty of perjury, that I am the Affiant herein and I am an Investigator with the State of Nevada, Office of the Attorney General. I have been an Investigator for three years 10 months. I am a graduate of the Community College of Southern Nevada’s Law Enforcement Training Academy Class 99-2. There I completed 736 hours of instruction in courses that comprise a Nevada POST Category I Basic Academy. In addition to my POST training, I have earned a Master of Public Health from the University of Illinois at Chicago.

1. Your Affiant learned the following facts, which lead your Affiant to believe that Andrew Elias Michael committed the offense of PRACTICING MEDICINE WITHOUT A LICENSE, a felony (NRS 630.400) between May 1, 2001 and May 1, 2003.

2. This Affidavit was made of my own personal knowledge, except where stated on information and belief, and as to those matters, I believe them to be true and if called as a witness, I could competently testify thereto.

3. In support of the assertion to constitute the existence of probable causes for the requested warrant, the following facts have been offered.

4. On or about January 13, 2003, Attorney General Investigator Linda Rosel received an anonymous telephone call that alleged North American Medical Company was operating a business without an active industrial insurance policy.

In addition, the caller alleged that ANDREW MICHAEL, the President of North American Medical Company, was falsely representing himself as a physician and practicing medicine without a license.

5. On or about January 14, 2003, Investigator Rosel, Division of Industrial Relations Investigator Peter Wahlquist, and your Affiant went to North American Medical Company. After investigation, it was determined that North American Medical Company was operating without an active industrial insurance policy. Investigator Rosel issued Andrew Michael a misdemeanor citation for the violation. During the issuance of the citation, MICHAEL stated that he was a physician, but was not licensed to practice in Nevada. Michael stated that he was licensed to practice medicine in New Mexico.

6. On or about February 6, 2003, Investigator Rosel and your Affiant interviewed Deborah Dort, M.D. Dort was an employee for North American Medical Company. Dort advised that Michael had represented to her that he was cardiothoracic surgeon that trained at Johns Hopkins in Baltimore, Maryland. Dort provided a copy of a business card that listed ANDREW MICHAEL as an “M.D., PhD, FACS.” FACS is an abbreviation for Fellow American College of

Surgeons. Furthermore, Dort provided the name of a patient J.L. that ANDREW MICHAEL monitored during a cat scan procedure. Dort explained that during an imaging procedure that required the use of contrast dye, a physician needed to be on site because of the potential for an anaphylactic reaction in the patient.

7. On or about February 7, 2003, Investigator Rosel and your Affiant interviewed Brandi Johnson. Johnson was the facilities manager for Meadows Diagnostic Medical Imaging Center, a subsidiary of North American Medical Company. Johnson advised that ANDREW MICHAEL told her that he attended Johns Hopkins for his medical training. Johnson advised that she was told to use the suffix “M.D.” on all correspondence to ANDREW MICHAEL. If Johnson did not use the suffix “M.D.” ANDREW MICHAEL did not read the correspondence. Johnson advised that she had witnessed ANDREW MICHAEL supervising numerous contrast injections of patients during imaging procedures. Such procedure requires supervision by a physician. Johnson provided your Affiant with the following list of patients whom she witnessed ANDREW MICHAEL monitor contrast injections during various imaging procedures:

NAME

DATE OF SERVICE
P.R 6/19/01
S.V 6/22/01
D.R 6/25/01
B.K 6/25/01
J.A 6/28/01 & 6/29/01
N.R 6/29/01
J.B. 7/10/01
J.V 8/9/01
S.C 8/20/01
E.A 8/22/01

Johnson further provided your affiant with a copy of a document entitled:

Meadows Diagnostic Medical Imaging Center, LLC;
Business Plan for Northern and Southern Nevada
April 2001

Written By
Andrew Michael

Affiant reviewed this document and discovered that on page 6 of the document in a section titled “Key Personnel Background,” ANDREW MICHAEL is described as having a Medical Doctorate degree from the University of New Mexico School Medicine. MICHAELis also described as the President of North American Medical Company and CEO of Meadows Diagnostic Medical Imaging Center.

8. On or about February 7, 2003, Investigator Rosel and your Affiant interviewed Nancy Morenault. Morenault was a staff technician at Meadows Diagnostic Medical Imaging Center, a subsidiary of North American Medical Company. Morenault advised that she witnessed ANDREW MICHAEL monitor a contrast injection of patient J.L. on December 26, 2002.

9. On or about February 7, 2003, Investigator Rosel and your Affiant interviewed Douglas Howard, M.D. Howard was the Chief of Radiology at Meadows Diagnostic Imaging Center, a subsidiary of North American Medical Company. Howard advised that ANDREW MICHAEL told him that he attended the University of New Mexico School of Medicine and completed a residency in cardiothoracic surgery at Johns Hopkins in Baltimore, Maryland.

10. On or about February 11, 2003, Investigator Rosel and your Affiant interviewed LaTasha Newsome. Newsome was the receptionist for Meadows Diagnostic Medical Imaging Center, a subsidiary of North American Medical Company. Newsome advised that ANDREW MICHAEL told her that he was a medical doctor and introduced himself as “Dr. MICHAEL.”

11. On or about February 11, 2003, Investigator Rosel and your Affiant interviewed Mary Jane Ensor. Ensor was the facilities manager for Meadows Medical Diagnostic Imaging Center, a subsidiary of North American Medical Company. Ensor advised that ANDREW MICHAEL told her that he trained at the University Medical Center in Las Vegas, Nevada and trained in cardiothoracic surgery at the University of New Mexico.

12. Affiant reviewed the Radioactive Material license application for Meadows Diagnostic Medical Imaging Center. Affiant’s review demonstrated that ANDREW MICHAEL used the suffix “M.D.” in correspondence between North American Medical Company and the Nevada Health Division on January 7, 2002 and in an undated document titled “Program for Maintaining Occupational Radiation Exposure ALARA Meadows Diagnostic Medical Imaging Center-South” ANDREW MICHAEL used the suffix “M.D.”

13. On or about February 19, 2003, your Affiant contacted the medical licensing boards for Nevada, New Mexico, California, and Maryland. Affiant was informed by each board that ANDREW MICHAEL was never licensed to practice medicine in these states.

14. On or about February 19, 2003, your Affiant searched the American College of Surgeons online directory of Fellows. Affiant did not locate a fellow named ANDREW MICHAEL in Nevada.

15. On or about March 21, 2003, your affiant interviewed Li Ren. Ren was the former junior vice president for operations for North American Medical Company. Ren advised that ANDREW MICHAEL told her on several occasions that he was a medical doctor and a graduate of the University of New Mexico School of Medicine.

16. On or about March 26, 2003, your Affiant contacted the Registrar’s Office for Johns Hopkins University School of Medicine. Affiant was informed that ANDREW MICHAEL (SSAN: ______________; DOB: 3/15/1968)was never enrolled as a medical student or resident.

17. On or about March 26, 2003, your Affiant contacted the Registrar’s Office at the University of New Mexico School of Medicine. Affiant was informed the ANDREW MICHAEL (SSAN: ______________; DOB: 3/15/1968) was never enrolled as a medical student or resident.

18. On or about March 26, 2003, your Affiant contacted the Physicians’ Services at University Medical Center in Las Vegas, Nevada. Affiant was informed that ANDREW MICHAEL was never a member of the physician staff at University Medical Center.

19. On or about April 1, 2003, your Affiant interviewed Natasha Del Gado. Del Gado is the former marketing manager for North American Medical Company. Del Gado advised that ANDREW MICHAEL told her he trained at Johns Hopkins University and attended the University of New Mexico School of Medicine.

20. On or about April 4, 2003, your Affiant interviewed Chris Roussel. Roussel was the insurance biller for North American Medical Company. Roussel advised that ANDREWMICHAEL told him he was a cardiothoracic surgeon and attended the University of New Mexico School of Medicine.

21. On or about April 9, 2003, your Affiant interviewed Gayle Raveling. Raveling was an administrative assistant for North American Medical Company. Raveling advised that she had received medical advice from ANDREW MICHAELabout an upcoming heart surgery during November 2002. Raveling stated that ANDREW MICHAEL gave her the medical advice after a review of her medical records. Furthermore, Raveling advised that ANDREW MICHAEL used a model of the human heart to facilitate his explanation regarding her surgery to her. Raveling recalled that she was very relieved after talking to ANDREW MICHAEL because she believed he was a medical doctor.

22. It is respectfully submitted that the foregoing establishes probable cause that ANDREW MICHAEL, committed the offense of PRACTICING MEDICINE WITHOUT A LICENSE, a felony, (NRS 630.400) between June 1, 2001 and May 1, 2003, at and within the County of Clark, State of Nevada.

23. Accordingly, I respectfully request that a warrant for the arrest of ANDREW ELIAS MICHAEL, SSAN:______________, DOB _____1968 be issued.

DATED this __________ day of May, 2003.

__________________________________
 BERNARD T. VELETA
ATTORNEY GENERAL INVESTIGATOR

SUBSCRIBED AND SWORN to before me

This ______ day of May, 2003

___________________________________
NOTARY PUBLIC

BRIAN SANDOVAL
Attorney General
GERALD J. GARDNER
Chief Deputy Attorney General
500 E. Washington Ave.
Las Vegas, Nevada 89102
(702) 486-3396

This page was posted on August 22, 2005..

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