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Jameson v Cote Complaint

Jameson v Cote Complaint

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Published by Statesman Journal
Jameson v Cote Complaint
Jameson v Cote Complaint

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Published by: Statesman Journal on Jul 18, 2013
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08/02/2013

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Page
of 

COMPLAINT
 
CONRAD
 
E.
 
YUNKER,
 
P.C.
 
PO
 
Box
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Conrad
 
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Yunker
 
OSB
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CONRAD
 
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YUNKER,
 
P.C.
 
PO
 
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Salem
 
OR
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conrad@ceypc.com
 
Of 
 
A
orneys
 
for
 
plain
ff 
Kim
 
Jameson,
 
DC
 
In the Circuit Court for the State of OregonFor the County of Marion
Kim Jameson, DC,
 Plaintiff,
 
v.
Daniel Cote
, DC, president of theOregon Board of Chiropractic Examiners;
Oregon Board of ChiropracticExaminers,
a state agency, and
EllenF. Rosenblum
, Attorney General,
 Defendants.
Case no. ____________
C
OMPLAINT
 
Declaratory Relief; JudicialReview (Order Other Than inA Contested Case)
Filing fee: $240 (ORS 21.135(2))
Not Subject to mandatoryArbitrationGeneral Allegations
1
 
For her claims against defendants, plaintiff Kim Jameson, DC, alleges:
2
 
1
3
 
Dr. Jameson is a resident of Clackamas County. She has been licensed to
4
 
practice chiropractic in Oregon since 2008, and has practiced successfully at her clinic
5
 
 
 
Page
of 

COMPLAINT
 
CONRAD
 
E.
 
YUNKER,
 
P.C.
 
PO
 
Box

 
Salem
 
OR
‐
(

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(voice)
 
•(
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‐
(fax)
 
in Clackamas. From 1996 to 2008, before coming to Oregon, Dr. Jameson practiced
1
 
chiropractic in California with distinction, and was appointed by the governor of 
2
 
California to be a Qualified Medical Examiner in that state.
3
 
2
4
 
Defendant Daniel Cote, DC, is the president of the Oregon Board of 
5
 
Chiropractic Examiners. Defendant Oregon Board of Chiropractic Examiners is the
6
 
health professional regulatory board that regulates the practice of chiropractic in
7
 
Oregon pursuant to ORS 684.010—684.990. Defendant Ellen F. Rosenblum is a
8
 
member of the Oregon State Bar; is the elected attorney general of Oregon and the
9
 
state’s chief law enforcement officer, and is counsel for defendant Oregon Board of 
10
 
Chiropractic Examiners.
11
 
3
12
 
For more than two years Dr. Jameson has battled against false and unjustified
13
 
charges of professional misconduct made by defendant Oregon Board of Chiropractic
14
 
Examiners. In April 2013—three months ago—Dr. Jameson was cleared of all
15
 
disputed charges by an administrative law judge. In a proposed order that followed a
16
 
12-day contested case hearing, the ALJ found that the board’s case against Dr.
17
 
 Jameson was based on perjury by its principal witness—who was a former employee
18
 
Dr. Jameson had fired for theft and other misconduct—and the ALJ altogether
19
 
rejected the lying witness’s testimony. The ALJ also found that the board’s
20
 
 
 
Page
of 

COMPLAINT
 
CONRAD
 
E.
 
YUNKER,
 
P.C.
 
PO
 
Box

 
Salem
 
OR
‐
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investigator, Thomas Rozinski, alternately threatened the witness and falsely promised
1
 
the witness absolute immunity from criminal charges and civil penalties in order to
2
 
obtain the testimony he wanted, even though Rozinski had no authority to offer or to
3
 
grant such immunity.
4
 
4
5
 
At least until the board leveled its charges against her, Dr. Jameson enjoyed an
6
 
excellent professional reputation and respect among her patients and the community
7
 
generally. She is a gifted practitioner, and many of her patients have achieved results
8
 
not obtained with other care providers. Insurance companies recognized Dr.
9
 
 Jameson’s services and paid for treatment she provided their insureds; her practice
10
 
was thriving, and she enjoyed the privilege of being a chiropractor in Oregon.
11
 
5
12
 
After the board publicized its charges against Dr. Jameson, however, her
13
 
practice began to suffer. Some patients stayed away, even some who did not know of 
14
 
the charges until Rozinski sought them out and informed them. Insurance carriers, as
15
 
is policy toward accused practitioners, refused payment for her services. Her revenues
16
 
diminished. Dr. Jameson was emotionally distraught by the charges; sleeplessness and
17
 
stress increased to an unhealthy level, and Dr. Jameson developed Type-II diabetes as
18
 
a result. She has incurred substantial loss of income and legal expense to defend
19
 
against the false charges.
20
 

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