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July 27, 2004

Kentucky Board of Chiropractic Examiners
PO Box 183
Glasgow, KY 42142-0183

Dear Board Members,

I wish to file formal complaints against Paul R. Hollern and James P. Stapleton for multiple violations of Kentucky laws governing the practice of chiropractic. I do this at personal risk of retribution from Hollern and the possibility that I will not receive payment for my practice purchased by Hollern in October of 2003. However, I feel morally, ethically and legally obligated to provide information regarding what I perceive as multiple violations of the ethics and standards of care set forth by your agency.

201 KAR 21:015, Code of conduct. KRS 312.019
(5) A licensee shall practice his profession in accordance with the provisions of KRS Chapter 312 and the board’s administrative regulations. He shall avoid professional association with individuals or groups who do not practice according to such statutes and administrative regulations.

(10) In any dispute between or among chiropractors involving matters of ethics, the matter in controversy shall be referred to the board for comment.

(13) Illegal, unethical and incompetent conduct by licensees shall be reported to the board.

I began working for Paul Hollern part time in July of 2003. This worked into an agreement for full time employment and the sale of my practice in October 2003. My official title with the company was Chief Operating Officer. As a full time employee I was to work in my former practice for a few months during a transition period while James Stapleton gradually took over the practice. The remainder of my time was to be spent at the Uncle Paul (Hollern’s chiropractic training business) Corporation. I was also required to attend the Hollern business seminars that the training doctors had to sit through in order to understand the Hollern system.

Although I had practiced chiropractic for over 15 years, I had never bought or sold a practice. I had never had an associate or partner. Hollern on the other hand had over 80 practices and 21 students working in three offices preparing to go into practice under the Hollern system. When I questioned how billing would occur at my former office during the transition period Hollern assured me that he had done this multiple time and that he and his assistant Marilyn Sexton would take care of everything and that it was all perfectly legal.

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Editor's Note: Those doctors who would like more information about this complaint may contact Dr. Miller through ChiroWeb at DrMiller@DCMedia.com.

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