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office. The purpose of the meeting was to tour the medical
practice. At that meeting Ms. Davis asked for canceled checks,
which had been listed in the three IDR's. Petitioner told her
that he had given the checks to Mr. Bruno, he had returned them,
and then the checks were stolen out of his automobile. Also
during that meeting petitioner stated that each patient's medical
file contained copies of each check he had received from the
patient's attorney for the payment of medical services rendered.
Ms. Davis requested access to petitioner's patient files and
a list of the attorneys who had made payments to him. The
purpose of the request was to locate the attorneys who had paid
petitioner and independently verify the amounts paid to him
during 1987. Petitioner would not release the patient files
because of the patient-physician privilege. He told Ms. Davis
that he did not possess a list of the attorneys with whom he
dealt, and he did not offer to write down the names of the
attorneys for her. He again stated that he kept a running total
of his income in his head.
Up to and immediately after the December 8, 1989, meeting,
Ms. Davis had received no information regarding any of
petitioner's investment accounts, despite three IDR's requesting
that information. Mr. Bruno relied on petitioner to furnish him
with the documents requested in each of the three IDR's. To the
extent Mr. Bruno had the requested documentation in his
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