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BEFORE THE NEVADA STATE BOARD OF DENTAL EXAMINERS

IN REGARDS TO THE MATTER OF:

Request to Amend the Stipulation


Agreement(s) approved by the Board
on January 24, 2013 and June 27,
2014 regarding Paragraphs 130) and 14-0627
Paragraph 5(c) as it relates to the
reimbursement of the investigation
costs and request for monthly
installment payments

On June 27, 2014, pursuant to agenda item 4(c)(2) at a properly noticed meeting
held at the Nevada State Board of Dental Examiners (“Board”) office located at 6010 S
Rainbow Boulevard, Suite A-i, Las Vegas, Nevada 89118 the “Board” addressed the
following request:

Dr. Jade A Miller Present


Dr Gregory Pisani Present
Dr Jason Champagne Present
Dr. Timothy Pinther Present
Dr. James G Kinard Present
Dr. J. Stephen Sill Present
Dr Byron Blasco Present
Ms. Caryn Solie Present
Mrs. Leslea Villigan Present
Mrs. Theresa Guillen Present
Mrs. Lisa Wark Present

BACKGR~U}1D
1. On January 24, 2013 and June 27, 2014, Adam Lousignont, DMD entered into a
stipulation agreement with the Board.

2. Pursuant to Paragraphs 13(i) and Paragraph 5(c) of said agreements, Adam


Lousignont, DMD is required to reimburse the Board for the costs of the
investigation and monitoring in the current amount for both stipulation agreements
($9616.67+9616.66+1800.00) of $21,033.33.

3. Nevada licensee, Adam Lousignont, requested to amend the stipulation


agreements set forth above with regards to the current amounts due to the
Board for the cost of the investigation and monitoring in the amount of
$21,033.33 and requests the reimbursement payments to the Board be made in
the installment payments Listed beLow:

December 31, 2014 $5298.33


June 30, 2015 $5,245.00
December 31, 2015 $5,245.00
June 30, 2016 $5,245.00

4. Public notice of the above-referenced request to amend the stipulation


agreement(s) was provided in accordance with NRS and NAC Chapter 631.

II.
DJSCUSSK~N

Discussion was held regarding Dr Lousignont’s request to amend the stipulation


agreements approved by the Board on January 24, 2013 and on June 27, 2014,
limited to, Paragraphs 13(i) and 5(c) regarding the reimbursement payments in the
current totaL amount of $21,033.33 for the investigation costs and monitoring to be
paid in installment payments as set forth in Paragraph 3 of this agreement.

111.
After considering and discussion, a motion to approve the request to amend
the stipulation agreements approved by the Board on January 24, 2013 and June 27,
2014, limited to, Paragraph 13(i) and 5(c) regarding the reimbursement payments in the
current total amount of $21,033.33 for the investigation costs and monitoring to be
paid in installment payments as set forth in Paragraph 3 of this agreement.

The motion passed unanimously approving the request to amend the


stipulation agreement(s) approved by the Board on January 24, 2013 and June 27,
2014, Limited to, Paragraph 130) and 5(c) regarding the reimbursement payments in the
current total amount of $21,033.33 for the investigation costs and monitoring to be
paid in installment payments as set forth in Paragraph 3 of this agreement. All other
provisions of the stipulation agreements dated January 24, 2013 and June 27, 2014
shall remain in full force and effect until all reimbursements costs are paid to the
Board.

Dated the 27th of June, 2014

JAMES C KINARD, DDS, PRESIDENT


Nevada State Board of Dental Examiners
ORIGINAL
STATE OF NEVADA
4
BEFORE THE BOARD OF DENTAL EXAMINERS
5
.6 ___________________

NEVADA STATE BOARD OF DENTAL


7 EXAMINERS, Case No. 12-2456
8 Complainant,
9
vs.
10 STIPULATION AGREEMENT
11 ADAM LOUSIG-NONT, DMD,
12 Respondent.
13
14
15 IT IS HEREBY STIPULATED AND AGREED by and between ADAM LOUSIG
16
NONT, DMD (hereafter “Respondent”), represented by ANDIE THORSTEINSSON, ESQ., of
17
18 the law offices of ALVERSON, TAYLOR, MORTENSEN & SANDERS, and the NEVADA
19 STATE BOARD OF DENTAL EXAMINERS (hereafter “Board”), by and though BRADLEY
20 STRONG, DDS, Disciplinary Screening Officer, and the Board’s legal counsel, JOFIN A.
21 HUNT, ESQ., of the law finn of RALEIGH & HUNT, PC as follows:
22
23 1. On August 1, 2012, the Board notified Respondent of a verified complaint received from
24 Shelly Duncan. On August 31, 2012, Respondent submitted his answer to the verified
25 complaint of Shelly Duncan.
26 2. On April 9, 2012, the Board notified Respondent of a verified complaint received from

Pagelof23

Rolcigh & Hunt, P.C.


500 S. R~ncho Dr., SuOto II
I_as Vc9ao. Nevada 09106
0 1 Carl Tiveron. On May 23, 2012, Respondent submitted his answer to the verified complaint of
2 Carl Tiveron.
3
3. On May 25, 2012, the Board notified Respondent of a verified complaint received from
4
Luo Lucio R. Deleon. On June 20, 2012, Respondent submitted his answer to the verified

6 complaint of Luo Lucio R. Deleon.


7 4. On August 20, 2012, the Board notified Respondent of a verified complaint received
8 ..
from Patricia Carr. On September 20, 2012, Respondent submitted his answer to the venfied
9
complaint of Patricia Can
10
5. Based upon the limited investigation conducted to date, Disciplinary Screening Officer,

12 BRADLEY STRONG, DDS, applying the administrative burden of proof of substantial evidence
13 as set forth in State, Emp. Security v. Hilton Hotels, 102 Nev. 606, 608, 729 P.2d 497, 498
14 (1986); and see Minion v. Board ofMedlical Examiners, 110 Nev. 1060, 881 P. 2d 1339 (1994),
15
16 see also NRS 233B.135(3)(e) & NRS 631.3500), but not for any other purpose, including any
17 other subsequent civil action, fmds there is substantial evidence Respondent violated NAC
1 8 631 .23O(l)(c), regarding the treatment rendered to patient Shelly Duncan when Respondent:
19
a. Surgically placed four (4) maxillary implants, without first successfully treating the
20 patient’s periodontal disease and several periapical abscesses. Respondent placed the
21 four implants without talcing into consideration to the patient’s overall physical and oral
health. Respondent failed to maintain proper stability and fit of the immediate
22 maxillary denture delivered by Respondent due to Respondent’s failure to recognize the
immediate maxillary denture delivered by Respondent had fractured thereby
23 compromising the four (4) healing implants underneath to the degree that resulted within
24 a reasonable degree of dental certainty that the four ~4) implants placed by Respondent
would fail in the future.
25
26
h. Performed crown & bridge treatments (and the associated temporization of teeth)
27 on patient Shelly Duncan without first successfully treating and properly assessing the
28
Page 2 of 23
Raleigh Sc Bunt, P.C.
5005. RrnzcIi~ Or., S,ite I?
La, Vegas, Nevada 89105 A
0 1
. ..
patient’s periodontal condition and establishing a proper periodontal diagnosis and
2 treatment plan.
3
c. Directed a dental hygienist in his employ to perform two (2) quadrants (LL and
LR) of scaling and root planing without an appropriate periodontal diagnosis and
5 periodontal charting. The two (2) quadrants (LL and LR) of scaling and root planing
6 were also performed prior to eliminating periapical abscesses.
7
d. Placed mandibular temporary restorations that were broken, sharp, had excess
8 cement, and open margins that contributed to the patient’s declining periodontal
9 condition, resulting in the compromising of structural integrity of the teeth.
10
e. Left visible decay on teeth #26, & 27 which resulted in the subsequent
11 fracture of teeth #26 & 27 leaving both teeth non-restorable.
12
13 f. Failed to take into consideration and maintain the patient’s vertical dimension of
14 occlusion.
opposing anThe final impressions
ill-fitting and broken,fortemporary
the mandibular permanent
maxillary restorations
immediate denture. were taken
By not
15 stabilizing this maxillary appliance and properly establishing the vertical dimension, it
exacerbated the patient’s failing occlusion.
16
g. Failed to deliver the restorations in a timely manner which in turn caused the
17 patient to experience unnecessary painisuffering and increased the likelihood of the
18 failure of the natural teeth and the newly placed dental implants by Respondent.
19
20 h. Records for the patient failed to have any entries indicating the patient’s
preoperative and post-operative physical condition and vital signs. It should be noted
21 even without this information, Respondent pre-medicated the patient with Triazolam
22 (Halcion~ 0.5 milligrams. Respondent’s record for the patient does not contain a
peridontal chart even though the patient received two (2) quadrants (LL and LR) of
23 scaling and root planing.
24
25
26
27
28
Page 3 of 23
Raleigh & Hunt, P.C.
500 S. Rancha Dr~ Suite II
Lu, Vegas, Nevada 59106
0 1 6. Applying the administrative burden of proof of substantial evidence as set forth in State,
2 Emp. Security v, Hilton Hotels, 102 Nev. 606, 608, 729 .P.2d 497, 498 (1986); and see Minton v.
3
Board of Medical Examiners, 110 Nev. 1060, 881. P. 2d 1339 (1994), see also NRS
4
5 2338.135(3)(e) & NRS 63 1.350(1.), Respondent admits, but not for any other purpose, including
6 any subsequent civil action, that the Board has substantial evidence to prove Respondent’s
7 treatment of Shelly Duncan violated NAC 631 .230(1)(c), when Respondent:
8
a. Surgically placed four (4) maxillary implants, without first successfully treating the
patient’s periodontal disease and several periapical abscesses. Respondent placed the
10 four implants without taking into consideration to the patient’s overall physical and oral
health. Respondent failed to maintain proper stability and fit of the immediate
11 maxillary denture delivered by Respondent due to Respondent’s failure to recognize the
12 immediate maxillary denture delivered by Respondent had fractured thereby
compromising the four (4) healing implants underneath to the degree that resulted within
13 a reasQnable degree of dental certainty that the four (4) implants placed by Respondent
would fail in the future.
14
15
b. Perfonned crown & bridge treatments (and the associated temporization of teeth)
16 on patient Shelly Duncan without first successfully treating and properly assessing the
17 patient’s periodontal condition and establishing a proper periodontal diagnosis and
treatment plan.
18
19
20 e. Directed a dental hygienist in his employ to perform two (2) quadrants (LL and
LR) of scaling and root planing without an appropriate periodontal diagnosis and
21 periodontal charting. The two (2) quadrants (LL and LR) of scaling and root planing
22 were also perfonued prior to eliminating periapical abscesses.
23
d. Placed mandibular temporary restorations that were broken, sharp, had excess
24 cement, and open margins that contributed to the patient’s declining per.iodontal
25 condition, resuhing in the compromising of structural integrity of the teeth.
26
27
28
Page 4 of 23
Raleigh & Hunt1 P.C.
500 S. Rancha Dr., Salle 7
Las Vegas. Nevada S9506 A
1 e. Left visible decay on teeth #26, & 27 which resulted in the subsequent
2 fracture of teeth #26 & 27 leaving both teeth non-restorable.
3
f. Failed to take into consideration and maintain the patient’s vertical dimension of
4 occlusion. The final impressions for the mandibular permanent restorations were taken
opposing an ill-fitting and broken, temporary maxillary immediate denture. By not
stabilizing this maxillary appliance and properly establishing the vertical dimension, it
6 exacerbated the patient’s failing occlusion.
7 g. Failed to deliver the restorations in a timely manner which in turn caused the
patient to experience unnecessary pain/suffering and increased the lilcelihood of the
8 failure of the natural teeth and the newly placed dental implants by Respondent.
9
10 h. Records for the patient failed to have any entries indicating the patient’s
11 preoperative and post-operative physical condition and vital signs. It should be noted
even without this information, Respondent pre-medicated the patient with Triazolam
12 (Ralcion) 0.5 milligrams. Respondent’s record for the patient does not contain a
13 peridontal chart even though the patient received two (2) quadrants (LL and LR) of
scaling and root planing.

0 7. Based upon the limited investigation conducted to date, Disciplinary Screening Officer,
16
17 BRADLEY STRONG, DDS, applying the administrative burden of proof of substantial evidence
as set forth in State, Enyi. Security v. Hilton Hotels, 102 Nev. 606, 608, 729 P.2d 497, 498

19 (1986); and see Minton v. Board of Medical Examiners, 110 Nev. 1060, 881 P. 2d 1339 (1994),
20 see also NRS 233B.135(3)(e) & NRS 631.350(1), but not for any other purpose, including any
21
other subsequent civil action, fmds there is substantial evidence Respondent violated NAC
22
23 631 ,230(1)(c), regarding the treatment rendered to patient Carl Tiveron when Respondent
24 a. Failed to diagnose, inform, and treat the patient’s maxillary tori/exostosis prior to
25 fabricating the patient’s maxillary denture.
26 b. Directed a dental hygienist in his employ to perform two (2) quadrants (LL
and LR) of scaling and root planing without an appropriate periodontal diagnosis and
27 periodontal charting.
28
Page 5 of 23
Raleigh & Hunt, P.C
500 S. Ranelto Dr. Suite 17
LsVegn,, Nevadl 59106
1~
c. The records for the patient do not contain a periodontal chart, even though the
2 patient received two (2) quadrants (LL and LR) of scaling and root planing.
3
8. Applying the administrative burden of proof of substantial evidence as set forth in State,

5 Emp. Security v, Hilton Hotels, 102 Nev. 606, 608, 729 .P.2d 497, 498 (1986); and see Minton v.
6 Board of Medical Examiners, 110 Nev. 1060, 881. P. 2d 1339 (1994), see also NRS

2338.135(3)(e) & NRS 631.3500.), Respondent admits, but iTot for any other purpose, including
8
any subsequent civil action, that the Board has substantial evidence to prove Respondent’s

10 treatment of Carl Tiveron violated NAC 631 .230(l)(c), when Respondent:


11 a. Failed to diagnose, inform, and treat the patient’s maxillary torifexostosis prior to
12 fabricating the patient’s maxillary dentures.
1~I
13
b. Directed a dental hygienist in his employ to perform two (2) quadrants (LL
14 and LR) of scaling and root planing without an appropriate periodontal diagnosis and
15 periodontal charting.
16 c. The records for the patient do not contain a periodontal chart, even though the
patient received two (2) quadrants (LL and LR) of scaling and root planing.
17
18
19 9. Based upon the limited investigation conducted to date, Disciplinary Screening Officer,
20 BRADLEY STRONG, DDS, applying the administrative burden of proof of substantial evidence
21 as set forth in State, Einp. Security v. Hilton Hotels, 102 Nev. 606, 608, 729 P.2d 497, 498
22
23 (1986); and see Minton v. Board ofMedical Examiners, 110 Nev. 1060, 881 P. 2d 1339 (1994),
24 see also NRS 233B.135(3)(e~ & NRS 631.3500), but not for any other purpose, including any
25 other subsequent civil action, finds there is substantial evidence Respondent violated NAC
26 631.2300)(c), regarding the treatment rendered to patient Luo Lucio R. DeLeon when
27
28
Page 6 of 23
Raleigh & Hunt, P.C.
$00 S. Ranch, Dr~ Suite I?
Las Ve5aa. Nevada 89106 A
n 1 Respondent:
2 a. Placed (4) maxillary implants where there was insufficient bone support. The
3 implants were placed too far anterior and at improper angulation. The #9 implant extends
through to the base of the patient’s nose. These implants were also placed prior to treating
4 the patient’s advanced periodontal disease (lower anteriors) and extensive caries (#17).
There was inadequate anterior/posterior (AlP) spread of the implants, resulting in excess
rocking and instability of the implant-retained overdenture. The overdenture fabricated
6 by Respondent was rough, had inadequate borders, lacked proper extension, and the male
portion of the Locator Attachments were damaged and non-flinctional.
7
8 b. The records for the patient do not contain any entries of a comprehensive
periodontal examination, periodontal diagnosis, or periodontal charting being performed.
9 Additionally, Respondent failed to take and record a blood pressure on a known
hypertensive patient prior to and following an invasive surgery.
10
10. Applying the administrative burden of proof of substantial evidence as set forth in State,

12 Emp. Security v, Hilton 1-lotels, 102 Nev. 606, 608, 729 .P.2d 497, 498 (1986); and see Minton v.
13 Board of Medical Examiners, 110 Nev. 1060, 881. P. 2d 1339 (1994), see also 1’~RS

(Th 14 2338.135(3)(e) & NRS 631.350G.), Respondent admits, but not for any other pugpose, including
15
16 any subsequent civil action, that the Board has substantial evidence to prove Respondent’s
17 treatment of Luo Luicio R. DeLeon violated NAC 63l.230(l)(c), when Respondent:
18 a. Placed (4) maxillary implants where there was insufficient bone support. The
implants were placed too far anterior and at improper angulation. The #9 implant extends
19 through to the base of the patient’s nose. These implants were also placed prior to treating
20 the patient’s advanced periodontal disease (lower anteriors) and extensive caries (#17).
There was inadequate anterior/posterior (AlP) spread of the implants, resulting in excess
21 rocking and instability of the implant-retained overdenture. The overdenture fabricated
22 by Respondent
portion was rough,
of the Locator had inadequate
Attachments borders, and
were damaged lacked proper extension, and the male
non-functional.
23
b. The records for the patient do not contain any entries of a comprehensive
24 periodontal examination, periodontal diagnosis, or periodontal charting being performed.
25 Additionally, Respondent
hypertensive patient failed
prior to and tofollowing
take andan
record a blood
invasive pressure on a known
surgery.
26
27
28
Page 7 of 23
RnIeigh & Hunt, P.C.
$00 S. Sancho Dr., Stake I?
Las Vegat, Nevada 89106 A
0 1 11.
.. .
Based upon the limited mvestigation conducted to date, Discipimary Screemng Officer,
2 BRADLEY STRONG, DDS, applying the administrative burden of proof of substantial evidence
3
as set forth in State, Emp. Security v. Hilton Hotels, 102 Nev. 606, 608, 729 P.2d 497, 498
4
(1986); and see Minton v. Board ofMedical Examiners, 110 Nev. 1060, 881 P. 2d 1339 (1994),

6 see also NRS 233B.135(3)(e) & NRS 63 1.350(1), but not for any other purpose, including any
7 other subsequent civil action, finds there is substantial evidence Respondent violated NAC
8 631.230(1 )(c), regarding the treatment rendered to patient Patricia Can when Respondent:
9
10 a. Performed crown & bridge treatments (and the associated temporization of teeth)
on patient Patricia Can without first successfully treating and properly assessing the
11 patient’s periodontal condition and establishing a proper periodontal diagnosis and
12 treatment plan. The crown & bridge performed by Respondent resulted in renlaining
caries, open crown margins, excess cement extruding from temporaries, perforated
13 crowns which further exacerbation of periodontal issues that Respondent failed to
resolve prior to commencing the crown & bridge treatments. It is evident Respondent
14 either gave no thought or did not understand the dental concept of maintaining the
15 patient’s vertical dimension of occlusion or overall occusion.
16
17 b.
patient toFailed to deliver
experience the restorations
unnecessary in a timely
pain/suffering andmanner which
increased in turn caused
the likelihood the
of the
is failure of the patient’s dentition placed by Respondent.
19
c. The implants previously placed by an associate to the Respondent on Teeth #7 &
20 8 were non-restorable because they were convergent at the occiusal aspect of the
21 implants and positioned too close together. The Respondent incorrectly informed the
patient the implants placed on Teeth # 7 & 8 were restorable.
22
23 d. The records
periodontal for theperiodontal
examination, patient do diagnosis,
not containorany entr es ofcharting
periodontal a comprehensive
being performed.
24
e. Failed to diagnose and properly inform the patient of caries, open margins, and
25 periapical pathology.
26
27
28
Page 8 of 23
RnI&gh & flunt, P.C.
SVO S. Rrn,cho Dr., Sufte I?
LisVcp~ Nev,da 89106 A
1 12. Applying the administrative burden of proof of substantial evidence as set forth in State,
2 Emp. Security v, Hilton Hotels, 102 Nev. 606, 608, 729 .P.2d 497, 498 (1986); and see Minton v.
3
Board of Medical Examiners, 110 Nev. 1060, 881. P. 2d 1339 (1994), see also NRS
4
5 2338.135(3)(e) & NRS 631.350(1.), Respondent admits, but not for any other purpose, including
6 any subsequent civil action, that the Board has substantial evidence to prove Respondent’s
7 treatment of Patricia Carr violated NAC 631.230(1 )(c), when Respondent:
8
a. Performed crown & bridge treatments (and the associated temporization of teeth)
on patient Patricia Can without first successfully treating and properly assessing the
10 patient’s periodontal condition and establishing a proper periodontal diagnosis and
treatment plan. The crown & bridge performed by Respondent resulted in remaining
11 caries, open crown margins, excess cement extruding from temporaries, perforated
12 crowns, which further exacerbation of periodontal issues that Respondent failed to
resolve prior to commencing the crown & bridge treatments. It is evident Respondent
13 either gave no thought or did not understand the dental concept of maintaining the
patient’s vertical dimension of occlusion or overall occlusion.
14
15
1,. Failed to deliver the restorations in a timely maimer which in turn caused the
16 patient to experience unnecessary painisuffering and increased the likelihood of the
17 failure of the patient’s dentition placed by Respondent.

c. The implants previously placed by an associate to the Respondent on Teeth #7 &


19 8 were non-restorable because they were convergent at the occiusal aspect of the
implants and positioned too close together. The Respondent incorrectly informed the
20 patient the implants placed on Teeth # 7 & 8 were restorable.
21
d. The records for the patient do not contain any entries of a comprehensive
22 periodontal examination, periodontal diagnosis, or periodontal charting being performed.
23 e. Failed to diagnose and properly inform the patient of caries, open margins, and
24 periapical pathology.
25
26 13. Based upon the limited investigation conducted to date, the findings of the Disciplinary
27 Screening Officer, BRADLEY STRONG, DDS, and the admissions cohtained in Paragraphs 6,
28
Page 9 of 23
Raleigh & Hunt, P.C. Qt_t(
500 S. Ranch. Dr., Sulk I?
Las WEas. Navada 39106
0 1 8, 10, & 12 the parties have agreed to resolve the pending disciplinary action regarding the
2 verified complaints of Shelly Duncan, Carl Tiveron, Luo Lucio R, DeLeon & Patricia Can
3
pursuant to the following terms and conditions:
4
a. Pursuant to NRS 631.350(l)(d), Respondent shall be placed on probation for a period of

6 two (2) years. The probationary period shall be effective and shall commence upon the
7 adoption of the Stipulation Agreement by the Board. During the two (2) year
8 probationary period, Respondent shall allow either the Executive Director of the Board
9
and/or an agent appointed by the Executive Director of the Board to inspect the records
10
of patients who have received either crown, bridge or, implants treatments during normal

12 business hours without notice. Respondent shall provide copies of requested patient
13 records including but not limited to patient charts, billing and/or radiographs at
14 . . .
Respondent’s expense at the time of the inspection. Durmg the probationary period, the
15
16 agent assigned by the Executive Director’s duties shall include, but not be limited to
17 having unrestricted access to observe Respondent administering treatments to patients
18 who are receiving either crown, bridge or, implants treatments. During the probationary
19 period, the agent assigned by the Executive Director’s duties shall also include, but will
20
not be limited to contacting patients who have received either crown, bridge or, implants
21
22 treatments from Respondent.
23 b. In the event Respondent no longer practices dentistry in the State of Nevada prior to
24 completion of the probationary period, the probationary period shall be tolled. In the
25 event the probationary period is tolled because Respondent does not practice in the State
26
of Nevada and the terms and conditions of this Stipulation Agreement are not satisfied
27
28
Page 10 of23
Rakigh & Hunt, P.C.
5008. Ranclm Dr.• SuiL~ 7
Las Vega; Nevada 89106 AL
1 within thirty-six (36) months of adoption of this Stipulation Agreement by the Board,
2 Respondent agrees his license to practice dentistry in Nevada shall will be deemed
3
voluntarily surrendered with disciplinary action. Thereafter, the Board’s Executive
4
5 Director, without any further action or hearing by the Board, shall issue an Order of
6 Voluntary Surrender with disciplinary action and report same to the National Practitioner
7 Data Bank.

c. During the two (2) year probationary period, Respondent shall maintain a daily log
9
containing the following information for any patient(s) who receive either crown, bndge
10
or, implants treatments.

12 a). Name of patient


13 b). Date treatment commenced
14 c). Explanation of treatment
1~ d). Respondent
radiographs shall
for all take and maintain
crown/bridge patients. pre-operative and post operative
16 e). Respondent shall take and maintain pre-operative and post operative
radiographs for all implant patients.
17
18
19 The daily log shall be made available during normal business hours without notice.
20 Failure to maintain and/or provide the daily log upon request by an agent of the Board
21 shall be an admission of unprofessional conduct. Upon receipt of substantial evidence
22 that Respondent has either failed to maintain or has refused to provide the daily log upon
23
request by an agent assigned by the Executive Director; and/or Respondent has refused to
24
25 allow the agent assigned by the Executive Director to observe Respondent rendering
26 treatment to any patient who receives either crown, bridge or, implants treatments; and/or
27 Respondent has refused to provide copies of patient records requested by the agent

N, 28
Page 11 of23
Roleigh & Hunt, P.C.
SDO S. Rancho Dr. Suke 17
ba Vegn~, Ncvada S9~O6
1 assigned by the Executive Director, Respondent agrees his license to practice dentistry iii

2 the State of Nevada shall be automatically suspended without any further action of the
3
Board other than the issuance of an Order of Suspension by the Executive Director.
4
5 Thereafter, Respondent may request in writing a hearing before the Board to reinstate
6 Respondents license. However, prior to the full Board hearing, Respondent waives any
7 right to seek judicial review, including injunctive relief from either the Nevada Federal
8 District Court or the Nevada State District Court to reinstate his privilege to practice
9
dentistry in the State of Nevada pending a final Board hearing. Respondent shall also be
10
11 responsible for any costs or attorney’s fees incurred in the event the Board has to seek
12 injunctive relief to prevent Respondent from practicing dentistry during the period
13 Respondent’s license is automatically suspended.
14
15
16 d. Pursuant to NRS 631.350(k), in addition to completing the required continuing
education, Respondent shall obtain a total of One Hundred and Six (106) hours of an
additional supplemental education in the areas of crown and/or bridge and/or surgical
18 placement of implant(s) and/or implant restoration treatments and other areas of concerns
19 raised during the course of this investigation. The areas and hours required for the
20 supplemental education shall be a follows:
21 i. Twenty-Eight (28) hours of supplemental education in the areas of the
22 surgical placement of implants and the optimal restoration of implants
and;
23
ii. Twenty (20) hours of supplemental education related crown and
24 bridge treatments/preparation design; and
25
iii. Seventeen (17) hours of supplemental education related to
26 treatment planning and case presentation; and
27
28
Page 12 of 23
Ralcigh & Hunt, P.C.
500 S. Rnr,cho Dr., Suite 17
(.rc’
L,s Vests, Nevad, s~so~
C 1 iv. Seventeen (17) hours of supplemental education related to
2 occlusion; and

v. Twelve (12) hour of supplemental education related to periodontal


4 diagnosis, treatment planning, and penodontal treatment; and
5
vi. Six (6) hours of supplemental education related to complete
6 dentures; and
7
B vii. Six (6) hours of supplemental education related to ethics

The supplemental education must be submitted in writing to the Executive


10 Director of the Board for approval prior to attendance. Upon the receipt of the
11 written request to attend the supplemental education the Executive Director of the
12 Board shall notify Respondent in writing whether the requested supplemental
13 education is approved for attendance. Respondent agrees seventy (70%) percent
14 of the supplemental education shall be completed through attendance at live
15 lecture and/or hand on clinical demonstration. The remaining thirty (30%)
16 percent of the supplemental education may be completed through online/home
17 study courses. The cost associated with this supplemental education shall be
paid by Respondent. In the event Respondent fails to complete the supplemental
education, set forth in 13(dXi) and 13(dXii) within six (6~ months of adoption of this
19 Stipulation by the Board, Respondent agrees his license to practice dentistry in the State
20 of Nevada may be automatically suspended without any further action of the Board other
21 than the issuance of an Order of Suspension by the Executive Director. Upon
22 Respondent submitting written proof of the completion of the supplemental
23 education, Respondent agrees to waive any right to seek injunctive relief from
24 any Federal or State of Nevada District Court to prevent the automatic suspension
25 of Respondent’s license to practice dentistry in the State of Nevada due to
26 Respondent’s failure to comply. Respondent shall also be responsible for any
costs or attorney’s fees incurred in the event the Board has to seek injunctive
27
28
Page 13 of 23
Raleigh & Huot, CC.
5005. Rancho Dr., Swat 17
ct—i—
Las Ve~aa, Nevada 50506 .A -
relief to prevent Respondent from practicing dentistry during the period
2 Respondent’s license is automatically suspended. In the event Respondent fails to
3 complete the supplemental education, set forth in 13(d)(ii) and 13(d)(iv~ and 13d(v)
and 13d(vi) and 13d(vfi) within eighteen (18’~ months of adoption of this

5 Stipulation by the Board, Respondent agrees his license to practice dentistry in the State
6 of Nevada may be automatically suspended without any ffirther action of the Board other
than the issuance of an Order of Suspension by the Executive Director. Upon
Respondent submitting written proof of the completion of the supplemental education,
8 Respondent agrees to waive any right to seek injunctive relief from any Federal or State

of Nevada District Court to prevent the automatic suspension of Respondent’s license to


10 practice dentistry in the State of Nevada due to Respondent’s failure to comply.
11 Respondent shall also be responsible for any costs or attorney’s fees incurred in the event
12 the Board has to seek injunctive relief to prevent Respondent from practicing dentistry
13 during the period Respondent’s license is automatically suspended.
14
15 e. Pursuant to NRS 631.350(1), Respondent agrees to reimburse Shelly Duncan in the
16 amount often thousand ($10,000.00) dollars made payable to Shelly Duncan as set forth
below. The first payment in the amount of $5,000.00 shall be delivered to the Board
within one hundred and eighty (180) days of adoption of this Stipulation by the Board.
18 The second payment in the amount of $5,000.00 shall be delivered to the Board within
19 (180) days of delivery of the first payment. All payments shall be physically delivered to
20 the Board on the dates set forth above and all payments shall be made payable to Shelly
21 Duncan.
22
23 f. Pursuant to NRS 63 1.350(1), Respondent agrees to reimburse Luo Lucio DeLeon in the
24 amount of ($5,875.00) made payable to Luo Lucio DeLeon as set forth below. The first
25 payment in the amount of $2,937.50 shall be delivered to the Board within one hundred
26 and eighty (180) days of adoption of this Stipulation by the Board. The second payment
27 in the amount of $2,937.50 shall be delivered to the Board within (180) days of delivery
28
Page 14 of23
Raleigh & Hunt, P.C.
50a S. Ranch, Dr.. Suite II
Lea Vega,, Nevada t9l06
1 of the first payment. All payments shall be physically delivered to the Board on the dates
2 set forth above and all payments shall be made payable to Luo Lucio DeLeon.
3
~ g. Pursuant to NRS 631.350(1), Respondent agrees to reimburse Carl Tiveron in the amount
of ($1,650.00) made payable to Carl Tiveron as set forth below. The first payment in the

6 amount of $825.00 shall be delivered to the Board within one hundred and eighty (180)
days of adoption of this Stipulation by the Board. The second payment in the amount of
$825.00 shall be delivered to the Board within (180) days of delivery of the first
8
payment. All payments shall be physically delivered to the Board on the dates set forth
above and all payments shall be made payable to Carl Tiveron.
10
11 h. Pursuant to NRS 63 1.350(1), Respondent agrees to reimburse Patricia Carr in the amount
12 of $12,463.00 made payable to Patricia Carr as set forth below. The first payment in the
13 amount of $6,231.50 shall be delivered to the Board within one hundred and eighty (180)
14 days of adoption of this Stipulation by the Board. The second payment in the amount of
15 $6,231.50 shall be delivered to the Board within (180) days of delivery of the first
16 payment. All payments shall be physically delivered to the Board on the dates set forth
17 above and all payments shall be made payable to Patricia Can.
18
i. Pursuant to NRS 622.400, Respondent agrees to reimburse the ‘Board’ for the cost of the
19
investigation and the monitoring of this Stipulation Agreement in the amount of Twenty-
20 Eight Thousand Eight Hundred and Fifty ($28,850.00) dollars made payable to the Board
21 as set forth below. The first payment in the amount of $9,616.66 shall be delivered to the
22 Board within One (1) year of the adoption of this Stipulation Agreement by the Board.
23 The second payment in the amount of $9,616.66 shall be delivered to the Board within
24 (180) days of delivery of the first payment. The third payment in the amount of
25 $9,616.67 shall be delivered to the Board within (180) days of delivery of the second
26 payment. All payments shall be physically delivered to the Board on the dates set forth
27 above and all payments shall be made payable to the Nevada State Board of Dental
28
Page 15 of23
Raleigh & Hunt~ P.C.
500 S. Ranelsa Dr.. Suile I I
Las Vegas, Nevada 89106 AL
0 1 Examiners.
2
~ j. In the event Respondent defaults on the payments set forth in Paragraphs 13(e) and/or
13(f), and/or 13(g) and/or 13(h) and/or 13(i) Respondent agrees his license to practice

5 dentistry in the State of Nevada may automatically be suspended without any fbrther
6 action of the Board other than issuance of an Order of Suspension by the Executive
Director. Subsequent to the issuance of the Order of Suspension, Respondent agrees to
pay a liquidated damage amount of Twenty Five Dollars ($25.00) for each day
8 Respondent is in default on the payment(s) of any of the amounts set forth in Paragraph

13(e) and/or 13(f)), and/or 13(g) and/or 13(h) and/or 13(i). Upon curing the default of the
10 applicable defaulted paragraph, Respondent’s license to practice dentistry in the State of
Ii Nevada will automatically be reinstated by the Executive Director of the Board, assuming
12 there are no other violations of any of the provisions contained in this Stipulation
13 Agreement. Respondent shall also be responsible for any costs or attorney’s fees incurred.
14 In the event the Board has to seek injunctive relief to prevent Respondent from practicing
0 15 dentistry during the period in which his license is suspended. Respondent agrees to waive

16 any right to seek injunctive relief from either the Nevada Federal District Court or the
Nevada State District Court to reinstate his license prior to curing any default on the
17
amounts due and owing.
18
19 k. During the two (2) year probation/supervisory period, Respondent shall allow either the
20 Executive Director of the Board and/or an agent appointed by the Board’s Executive
21 Director to inspect Respondent’s records to ensure compliance with this Stipulation
22 regarding Respondent’s issuance of controlled substances. Such inspections shall be
23 performed, without notice, during normal business hours. All prescriptions issued by
24 Respondent during the probationary period must be in Respondent’s handwriting and
25 must have an original signature of Respondent. The prescriptions issued must be done on
26 a form that is in triplicate, serially numbered, which have been pre-approved by the
Executive Director. A copy of the prescription must be maintained in the patient’s file
27
28
Page 16 of 23
Rukigi, & Hunt, P.C.
uDO S. Rsscho Dr., Suite 17
I~us Vegas, Nevada 89166
1 who has been issued a prescription by Respondent. During the probationary penod
2 Respondent is prohibited from placing telephone prescriptions for controlled substances.
In the event of an patient’s dental emergency Respondent may phone in prescriptions for

4 controlled substances. Respondent must fax the emergency prescription. Emergency


5 prescriptions for controlled substances must contain Respondent’s signature on the fax
6 which must be sent to the pharmacy issuing such prescnptions on the next business day.
Upon adoption of this Stipulation by the Board, Respondent shall perform a prescription
inquiry to the Nevada State Board of Pharmacy and obtain a print out of all controlled
8 substances issued by Respondent to all of Respondent’s patients. Thereafter during the

probationary period, Respondent shall every six (6) months perform a prescription
10 inquiry to the Nevada State Board of Pharmacy and obtain a print out of all controlled
11 substances issued by Respondent dur ng the six (6) month periods. Respondent will
12 provide a copy of the inquiry to the Executive Director of the Board with thee (3) days
13 of receiving the print out from the Nevada State Board of Pharmacy.
14 1. in the event the Board’s Executive Director has substantial evidence to believe
15 Respondent has failed to comply with any of the provisions contained in Paragraph 13(k)
16 the Executive Director, without any further hearing or action by the Board, shall issue an
17 order suspending Respondent’s license to practice dentistry in the State of Nevada.
18 Thereafter, Respondent may request a hearing before the Board but during the pendency
19 of the hearing before the Board, Respondent waives any right to seek judicial review to
20 reinstate his privilege to practice dentistry in the State of Nevada pending a final Board
21 hearing.
22
m. In the event the Board’s Executive Director has substantial evidence to believe
23
Respondent has failed to comply with any of the provisions contained in Paragraph 13(k)
during the probationary period, Respondent agrees to surrender his License No.
25 FLXXXX with the United States Department of Justice, D.E.A. for Class II, Class I[N,
26 Class III, Class II1N, Class IV, and Class V for a period of three (3) years commencing
27 upon the date of the Order of Suspension issued by the Executive Director. At the
28
Page 17 of23
Ralaigis & Hunt, P.C
SODS. Ranclsn Dr.. Suilo I?
Las Va~o,. Nevada 89106
I conclusion of the three (3) year period, Respondent may apply to the United States
2 Department of Justice, D.E.A. to have his License No. FLXXX reinstated. If Respondent
3 should request a hearing and should the Board find there was not substantial evidence
that Respondent violated any of the provisions of paragraph 13(k) then the Executive

5 Director shall issue an order to United States Department of Justice, D.E.A. that
6 Respondent’s License No. FLXXX should be reinstated.
7 n. In the event the Board’s Executive Director has substantial evidence to believe
8 Respondent has failed to comply with any of the provisions contained in Paragraph 13(k)
9 during the probationary period, Respondent agrees to surrender his License No. CSXXX
10 with the Nevada State Board of Pharmacy for Class II, Class TIN, Class III, Class IIIN,
11 Class IV, and Class V for a period of three (3) years commencing upon the date of the
12 Order of Suspension issued by the Executive Director. Al the conclusion of the three (3)
13 year period, Respondent may apply to the Nevada State Board of Pharmacy to have his
License No. CSXXX reinstated. If Respondent should request a hearing and should the
Board fmd there was not substantial evidence that Respondent violated any of the
15 provisions of paragraph 13(k) then the Executive Director shall issue an order to Nevada
16 State Board of Pharmacy that Respondent’s License No. CSXXX should be reinstated.
17
18 o. In the event the Board’s Executive Director has substantial evidence to believe
19 Respondent has either issued or has caused to be issued prescriptions for controlled
20 substances identified as Class II, Class TIN, Class Ill, Class TITN, Class IV or Class V
21 subsequent to surrendering his United States Department of Justice, D.E.A., License No.
22 FLXXX and Nevada State Board of Pharmacy, License No. CSXXX the Executive
23 Director, without any further hearing or action by the Board, shall issue an Order
revoking Respondent’s license to practice dentistry in the State of Nevada. Thereafter,
Respondent may request a hearing before the Board but during the pendency of the
25 hearing before the Board, Respondent waives any right to seek judicial review to reinstate
26 his privilege to practice dentistry in the State of Nevada pending a final Board hearing.
27
28
Page 18 of23
Raleigh & Hunt1 P.C. -
5000. Rnacl,o Dr.. Suite 17
I.,. Vegas.Nenda ~9l00
4~N~

1 P. Pursuant to NRS 631.350(1)(j), Respondent shall retake the jurisprudence test as


2 required by NRS 631.240(2) on the contents and interpretation of NRS 631 and the
3 regulations of the Board. Respondent shall have ninety (90) days, commencing upon
4 adoption of this Stipulation, to complete the re-examination. The jurisprudence
5 examination is administered on the first Monday of each month at 10:00 am, and 2:00
6 p.m. at the Board’s office. Respondent shall contact the Board to schedule a time to
submit to the re-examination. In the event Respondent fails to successfully complete the
re-examination within ninety (90) days of adoption of this Stipulation, Respondent
agrees his license to practice dentistry in the State of Nevada shall be automatically
suspended without any further action of the Board other than issuance of an order by the
10 Executive Director. Upon successful completion of the re-examination and paying the
11 reinstatement fee, Respondent’s license to practice dentistry in the State of Nevada will
12 be automatically reinstated, assuming all other provisions of this Stipulation are in
13 compliance. Respondent agrees to waive any right to seek injunctive relief from any
14 Federal or State of Nevada District Court to prevent the automatic suspension of
15 Respondent’s license to practice dentistry in the State of Nevada due to Respondent’s
16 failure to comply with Paragraph 13(q). Respondent shall also be responsible for any
costs or attorney’s fees incurred in the event the Board seeks injunctive relief to prevent
Respondent from practicing dentistry during the period Respondent’s license is
18 automatically suspended.
19
20 q. In the event Respondent fails to cure any defaults in payment within forty-five (45) days
21 of the default, Respondent agrees the amount may be reduced to judgment.
22
23 r. Respondent waives any right to have the amount owed pursuant to Paragraphs 13(e)
24 and/or 13(f)), and/or 13(g) and/or 13(h) and/or 13(i) discharged in bankruptcy.
25 CONSENT
26 14. Respondent has read all of the provisions contained in this Stipulation Agreement and
27 agrees with them in their entirety.

Page 19 of23
Raleigh & hunt P.C.
500 5. Rsnclrn Dr., Suite I?
Las Vegas, Nevada B9I%
1 15. Respondent is aware by entering into this Stipulation Agreement, he is waiving certain
2 valuable due process rights contained in, but not limited to, NRS 631, NAC 631, NRS 233B and
3
NAC 233B.
4
16. Respondent expressly waives any right to challenge the Board for bias in deciding

6 whether or not to adopt this Stipulation Agreement in the event this matter was to proceed to a
7 full Board hearing.
8 17. Respondent and the Board agree any statements andlor documentation made or
9
considered by the Board during any properly noticed open meeting to determine whether to
10
~ adopt or reject this Stipulation Agreement are privileged settlement negotiations and therefore
12 such statements or documentation may not be used in any subsequent Board hearing or judicial
13 review, whether or not judicial review is sought in either the State or Federal District Court.
14 18. Respondent has reviewed the Stipulation Agreement with his attorney, Andie
15
16 Thorsteinsson, ESQ. who has explained each and every provision contained in this Stipulation
17 Agreement to the Respondent.
18 19. Respondent acknowledges he is consenting to this Stipulation Agreement voluntarily,
19 without coercion or duress and in the exercise of his own freewill.
20
20. Respondent acknowledges no other promises in reference to the provisions contained in
21
22 this Stipulation Agreement have been made by any agent, employee, counsel or any person
23 affiliated with the Nevada State Board of Dental Examiners.
24 21. Respondent acknowledges the provisions in this Stipulation Agreement contain the entire
25 agreement between Respondent and the Board and the provisions of this Stipulation Agreement
26
can only be modified, in writing, with Board approval.
27
28
Page 20 of 23
Raleigh & Hunt, P.C.
SODS. Runcho Dr. Suite 17
La,Vcga,,N.vadaS9lOó Al
1 22. Respondent agrees in the event the Board adopts this Stipulation Agreement, he hereby
2 waives any and all rights to seek judicial review or otherwise to challenge or contest the validity
3
of the provisions contained in the Stipulation Agreement.
4
23. Respondent and the Board agree none of the parties shall be deemed the drafter of this

6 Stipulation Agreement. In the event this Stipulation Agreement is construed by a court of law or
7 equity, such court shall not construe this Stipulation Agreement or any provision hereof against
8 any party as the drafter of the Stipulation Agreement. The parties hereby acknowledge all parties
9
have contributed substantially and materially to the preparation of this Stipulation Agreement.
10
11 24. Respondent specifically acknowledges by his signature herein and by his initials at the
12 bottom of each page of this Stipulation Agreement, he has read and understands its terms and
13 acknowledges he has signed and initialed of his own free will and without undue influence,
14 coercion, duress, or intimidation.
15
16 25. Respondent acknowledges in consideration of execution of this adopted Stipulation
17 Agreement, Respondent hereby releases, remises, and forever discharges the State of Nevada, the
18 Board, and each of their members, agents, legal counsel and employees in their individual and
19 representative capacities, from any and all maa~ner of actions, causes of action, suits, debts,
20
judgments, executions, claims, and demands whatsoever, known and unknown, in law or equity,
21
22 that Respondent ever had, now has, may have, or claim to have against any or all of the persons
23 or entities named in this section related to the pending investigation concerning the verified
24 complaints of Shelly Duncan, Carl Tiveron, Luo Lucio R. DeLeon & Patricia Carr
25 26. Respondent acknowledges in the event the Board adopts this Stipulation Agreement, this
26
Stipulation Agreement may be considered in any future Board proceeding(s) or judicial review,
27
28
Page 21 of23
Raleigh & Hunt, P.C.
500 S. Rancho Dr., SalLe I?
Lu ‘/e3u, Nevada ~9I05
I whether such judicial review is performed by either the State or Federal District Court(s).
2 27. This Stipulation Agreement will be considered by the Board in an open meeting. It is
3
understood and stipulated that the Board is free to accept or reject the Stipulation Agreement
4
and, if the Stipulation Agreement is rejected by the Board, thither disciplinary action may be

6 implemented. This Stipulation Agreement will only become effective when the Board has
7 approved the same in an open meeting. Should the Board adopt this Stipulation Agreement, such

adoption shall be considered a final disposition of a contested case and will become a public
9
record and shall be reported to the National Practitioner Data Bank.
10

DATEDtHs~Mayof ~

3 15 ADAM tojsjc,~woMi~i~
Respondent
16
17
18
19 APPROVED AS TO FORM NTENT
20
21
22 JO A. HUNT, ESQ.
leigh & Hunt, P.C.
23 Board Counsel
24
25
26
27
28
Page 22 of 23
Raleigh & Hunt1 P.C.
509 S. Rar,cho Dr., Sufte I?
LasV~ao,Nevzde89l06 AL
JAN-24—2013 THU 0927 A~ CHRISTOPHER J RALEIGH FAX No. 10265UJ69~ P.024

0
I APPROVED AS TO FORM AND CONTENT

: By:Q~
4 ANDIE THORSTEINSSON
ALVERSON, TAYLOR, MORTENSEN & EAW7O~
Attorneys for Respondent SM.~ .

6
7 APP ED AS TO FORM AND CONTENT

(
I
ByV D
R*DThY STRONG,
Disciplinary Screening Officer
______

11
12
13 This foregoing Stipulation Agreement was:
14 Approved’X Disapproved___________
IS by a vote of the Nevada State Board of Dental Examiners at a properly noticed meeting.
16 DATED tbis~V da.y ~ 2013.
17
18
19
20 JAD~ A. MILLER, DDS, pn.sIDENT
NEVADA STATE BOARD OF DENTAL EXAMINERS
21
22
23
24
25
26
21
28
Pago 23 of 23
KiiIt~Ii & Kuot1 re,
3006. both, Dr.. Suit. II
Al
BEFORE THE NEVADA STATE BOARD OF DENTAL EXAMINERS

IN REGARDS TO THE MATTER OF:

Request to Amend the Stipulation


Agreement(s) approved by the Board
on January 24, 2013 and June 27,
2014 regarding Paragraphs 130) and 14-0627
Paragraph 5(c) as it relates to the
reimbursement of the investigation
costs and request for monthly
installment payments

On June 27, 2014, pursuant to agenda item 4(c)(2) at a properly noticed meeting
held at the Nevada State Board of Dental Examiners (“Board”) office located at 6010 S
Rainbow Boulevard, Suite A-i, Las Vegas, Nevada 89118 the “Board” addressed the
following request:

Dr. Jade A Miller Present


Dr Gregory Pisani Present
Dr Jason Champagne Present
Dr. Timothy Pinther Present
Dr. James G Kinard Present
Dr. J. Stephen Sill Present
Dr Byron Blasco Present
Ms. Caryn Solie Present
Mrs. Leslea Villigan Present
Mrs. Theresa Guillen Present
Mrs. Lisa Wark Present

BACKGR~U}1D
1. On January 24, 2013 and June 27, 2014, Adam Lousignont, DMD entered into a
stipulation agreement with the Board.

2. Pursuant to Paragraphs 13(i) and Paragraph 5(c) of said agreements, Adam


Lousignont, DMD is required to reimburse the Board for the costs of the
investigation and monitoring in the current amount for both stipulation agreements
($9616.67+9616.66+1800.00) of $21,033.33.

3. Nevada licensee, Adam Lousignont, requested to amend the stipulation


agreements set forth above with regards to the current amounts due to the
Board for the cost of the investigation and monitoring in the amount of
$21,033.33 and requests the reimbursement payments to the Board be made in
the installment payments Listed beLow:

December 31, 2014 $5298.33


June 30, 2015 $5,245.00
December 31, 2015 $5,245.00
June 30, 2016 $5,245.00

4. Public notice of the above-referenced request to amend the stipulation


agreement(s) was provided in accordance with NRS and NAC Chapter 631.

II.
DJSCUSSK~N

Discussion was held regarding Dr Lousignont’s request to amend the stipulation


agreements approved by the Board on January 24, 2013 and on June 27, 2014,
limited to, Paragraphs 13(i) and 5(c) regarding the reimbursement payments in the
current totaL amount of $21,033.33 for the investigation costs and monitoring to be
paid in installment payments as set forth in Paragraph 3 of this agreement.

111.
After considering and discussion, a motion to approve the request to amend
the stipulation agreements approved by the Board on January 24, 2013 and June 27,
2014, limited to, Paragraph 13(i) and 5(c) regarding the reimbursement payments in the
current total amount of $21,033.33 for the investigation costs and monitoring to be
paid in installment payments as set forth in Paragraph 3 of this agreement.

The motion passed unanimously approving the request to amend the


stipulation agreement(s) approved by the Board on January 24, 2013 and June 27,
2014, Limited to, Paragraph 130) and 5(c) regarding the reimbursement payments in the
current total amount of $21,033.33 for the investigation costs and monitoring to be
paid in installment payments as set forth in Paragraph 3 of this agreement. All other
provisions of the stipulation agreements dated January 24, 2013 and June 27, 2014
shall remain in full force and effect until all reimbursements costs are paid to the
Board.

Dated the 27th of June, 2014

JAMES C KINARD, DDS, PRESIDENT


Nevada State Board of Dental Examiners
LV1 56129

OR~GkNAL

1
2 STATE OF NEVADA
3 BEFORE THE BOARD OF DENTAL EXAMINERS
4
5
NEVADA STATE BOARD OF DENTAL
6 EXAMINERS, Case No. 74127-02643

Complainant,
AMENDMENT
8 TO
VS. THE STIP LILA TIONAGREEMENT
9 FROM CASE NO. 12-2456 WHICH
10 ADAM LOUSIG-NONT, DMD, WAS KPPROVIED BY THE
BOARD ON JANUARY 24, 2013
ii Respondent.
12
13 IT IS HEREBY STIPULATED AND AGREED by and between ADAM LOUISIG
14 NONT, DDS (“Respondent” or “Dr. Lousig-Nont”), by and through his attorney, WALTER R.
15 CANNON, ESQ. of the law firm OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI,
16 and the NEVADA STATE BOARD OF DENTAL EXAMINERS (the “Board”), by and through
17 BRADLEY STRONG, DDS, Disciplinary Screening Officer (“DSO”), and the Board’s legal
18 counsel, JOHN A. HUNT, ESQ., of the law firm MORRIS, POLICH & PURDY, LLP as follows
19 via this Amendment to the Stipulation Agreement from Case No. 12-2456 Which was Approved
20 by the Board on January 24, 2013 (“Amendment”):
21
22 1. Respondent entered into Stipulation Agreement with the Board in the mailer captioned
23 Nevada State Board of Dental Examiners v. Adam Louisig-Nont. DMD, case no. 12-2456
24 (“Stipulation Agreement” or “Agreement”) which was signed by Respondent on January 18,
25 2013, and approved by the Board on January 24, 2013. See Exhibit 1, true and accurate copy of
26 the Stipulation Agreement. It is noted that the relevant time period involved with the below

Moms Paigh & Pordy, LLP


:
5110 S. Ra,cho Drive, Suite 17
Las Vegas, Nevada 89106
~ts initials Page 1 of 7 Respondent’s attorne~itia

Ph. (702) 862-8300


1 referenced patient, John Lilly, occurred and/or overlapped with the time period involved with the
2 matters addressed in the Stipulation Agreement.
3

PATIENT, JOHN LILLY


2. Via a Notice of Complaint & Request for Records dated August 20, 2013, the Board
6 notified Respondent of a verified complaint received from John Lilly. On September 12, 2013,

the Board advised Respondent his request for an extension to file an answer to Mr. Lilly’s
8 verified complaint was granted to and including September 23, 2013. On September 24, 2013,

the Board received Respondent’s written response dated August 18, 2013, and attachments to
10 Mr. Lilly’s verified complaint, a copy of which was provided to Mr. Lilly on October 24, 2013.

On February 25, 2014, the Board received additional supplemental information from Mr. Lilly, a
12 copy of which was provided to Respondent on February 26, 2014. On March 10, 2014, the Board
13 received additional supplemental information from Mr. Lilly, a copy of which was provided to
14 Respondent the same day.
15
16 3. Based upon the limited investigation conducted to date, DSO, Bradley Strong, DDS,
17 finds for this matter and not for any other purpose, including any subsequent civil action,
18 Respondent violated NAC 631 .230(1)(c), regarding the treatment rendered to patient, John Lilly,
19 as follows:
20
A. The maxillary interim denture was improperly designed resulting in inadequate
21 retention, lack of proper ffinction, and several unnecessary repairs. The interim appliance
22 was completely non-ifinctional.
23 B. The final maxillary prosthesis was fabricated was improperly designed resulting
24 in a lack of structural strength and support to withstand ocelusal forces. The appliance
was left rough, lacked adequate retention, and was unusable.
25
26 4. Respondent acknowledges and admits to the findings of the Disciplinary Screening

Page2of7

Morris Pouch & Purdy, UP


espondent s initials Respondent s attorney’s initials
500 S. Rancho Drive, Suite i7
Las Vr5as. Nevada 89i06
Ph. (702) 862.8300
Officer contained in Paragraph 3 and admits and acknowledges if this matter were to proceed to
2 a flail board hearing, a sufficient quantity and/or quality of evidence could be proffered sufficient

to meet a preponderance of the evidence standard of proof demonstrating Respondent violated


NRS 631.230(l)(c) (re: Paragraph 3).
5
6 5. Based upon the limited investigation conducted to date, the findings of the Disciplinary

Screening Officer, and the admissions by Respondent contained in Paragraph 4 above, the
8 parties have agreed to resolve this matter pursuant to the following terms and conditions:
9
A. All terms and conditions of the Stipulation Agreement (~ Exhibit 1) shall
10 remain in fill force in effect. In addition to the terms and conditions of the Stipulation
11 Agreement, the following terms and conditions of this Amendment shall also apply.
12 B. From the approval of this Amendment by the Board, Respondent’s probation shall
13 be extended until June 30, 2015.
14 C. Pursuant to NRS 622.400, Respondent agrees to reimburse the Board for the cost
of the investigation and cost associated with this Amendment in the amount of $1,800.00
15 within ninety (90) days of the Board’s adoption of this Amendment.
16 D. Pursuant to NRS 631.350(1), Respondent agrees to reimburse John Lilly in the
17 amount of $3,554.00. Respondent shall deliver to Board, a check made payable to John
Lilly within ninety (90) days of adoption of this Amendment by the Board.
18
19 E. In the event Respondent defaults on any of the payments set forth in Paragraphs
5.C. and/or SD., Respondent agrees his license to practice dentistry in the State of
20 Nevada may be automatically be suspended without any further action of the Board other
than issuance of an Order of Suspension by the Board’s Executive Director. Subsequent
21 to the issuance of the Order of Suspension, Respondent agrees to pay a liquidated damage
22 amount of Twenty Five and xx/l00 Dollars ($25.00) for each day Respondent is in
default on the payment(s) of any of the amounts set forth in Paragraphs S.C. and/or SD.,
23 Upon curing the default of the applicable defaulted Paragraphs S.C. and/or SD., and
paying the reinstatement fee, Respondent’s license to practice dentistry in the State of
24 Nevada will automatically be reinstated by the Board’s Executor Director, assuming there
25 are no other violations by Respondent of any of the provisions contained in this
Amendment. Respondent shall also be responsible for any costs or attorney’s fees
26 incurred in the event the Board has to seek injunctive relief to prevent Respondent from
27 Page 3 of 7

Morris P.11th & Purdy,LLP ‘ant’s initials Respondent’s attornSS~nitia1s


50(3 S. Raricho Drive, Suile ‘7
Las Vegas, Nevada 89106
Ph. (702) 862-8300
1 practicing dentistry during the period in which her license is suspended. Respondent
agrees to waive any right to seek injunctive relief from any court of competent
2 jurisdiction, including a Nevada Federal District Court or a Nevada State District Court to
3 reinstate his license prior to curing any default on the amounts due and owing as
addressed above.
4
F. In the event Respondent fails to cure any defaults in payment referenced in
5 Paragraphs 5C and 511 within forty-five (45) days of the default, Respondent agrees
6 the amount may be reduced to judgment.

7~ 0. Respondent waives any right to have the amount owed pursuant to stipulation
discharged in bankruptcy.
8
9, CONSENT

10 6. Respondent has read all of the provisions contained in this Amendment and agrees with

11 them in their entirety.


12
13 7. Respondent is aware by entering into this Amendment he is waiving certain valuable due
process rights contained in, but not limited to, NRS 631, NAC 631, NRS 233B and NAC 233B.
14
15
8. Respondent expressly waives any right to challenge the Board for bias in deciding
16
whether or not to adopt this Amendment in the event this matter was to proceed to a full Board
17 hearing.
18
19 9. Respondent and the Board agree any statements and!or documentation made or
20 considered by the Board during any properly noticed open meeting to determine whether to
21 adopt or reject this Amendment are privileged settlement negotiations and therefore such
22 statements or documentation may not be used in any subsequent Board hearing or judicial
23 review, whether or not judicial review is sought in either the State or Federal District Court.
24
25 10. Respondent acknowledges he has read this Amendment with his attorney WALTER R.
26 CANNON, ESQ. of the law firm OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI,
27 Page 4 of 7
28
%~(‘sinitiais Respondent’s atto
Morris Polkh & Purdy, LI_P
500 S. Ra,’che Drive, Suite Il
I.asVtgas,Nevada 89106
P1,. (702) 862-8300
who has explained each and every provision of the Amendment..
2
3 11. Respondent acknowledges he is consenting to this Amendment voluntarily, without
4 coercion or duress and in the exercise of his own free will.
5
6 12. Respondent acknowledges no other promises in reference to the provisions contained in
this Amendment have been made by any agent, employee, counsel or any person affiliated with
the Nevada State Board of Dental Examiners.
8

13. Respondent acknowledges the provisions in this Amendment contain the entire
10 agreement between Respondent and the Board and the provisions of this Amendment can only be
11 modified, in writing, with Board approval.
12
13 14. Respondent agrees in the event the Board adopts this Amendment, he hereby waives any
14 and all rights to seek judicial review or otherwise to challenge or contest the validity of the
15 provisions contained herein.
16
17 15. Respondent and the Board agree none of the parties shall be deemed the drafter of this
18 Amendment. In the event this Amendment is construed by a court of law or equity, such court
shall not construe it or any provision hereof against any party as the drafter. The parties hereby
acknowledge all parties have contributed substantially and materially to the preparation of this
20 Amendment.
21
22 16. Respondent specifically acknowledges by his signature herein and by his initials at the
23 bottom of each page of this Amendment, he has read and understands its terms and
24 acknowledges he has signed and initialed of his own free will and without undue influence,
25 coercion, duress, or intimidation.
26
27 17. Respondent acknowledges in consideration of execution of this Amendment, Respondent
28 hereby releases, remises, and forever discharges the State of Nevada, the Board, and each of their
Page 5 of 7
Morn, Polieb & Purdy, LEP
500 S. Rzncho Drive, Sake 17 ____________
;a~n~gSOIOi Resp ndent’s initials Respondent’s attorney’s initials
1 members, agents, employees and legal counsel in their individual and representative capacities,
2 from any and all manner of actions, causes of action, suits, debts, judgments, executions, claims,
3 and demands whatsoever, known and unknown, in law or equity, that Respondent ever had, now
has, may have, or claim to have against any or all of the persons or entities named in this section,
4
arising out the complaint(s) of the above-referenced Patient(s).
5
6
18. Respondent acknowledges in the event the Board adopts this Amendment, it may be
7
considered in any fliture Board proceeding(s) or judicial review, whether such judicial review is
8
performed by either the State or Federal District Court(s).
9
10 19. This Amendment will be considered by the Board in an open meeting. It is understood
11 and stipulated the Board is free to accept or reject this Amendment and if it is rejected by the
12 Board, the Board may take other and/or further action as allowed by statute, regulation, and/or
13 appropriate authority. This Amendment will only become effective when the Board has approved
the same in an open meeting. Should the Board adopt this Amendment, such adoption shall be
14
considered a final disposition of a contested case and will become a public record and shall be
15
reported to the National Practitioner Data Bank.
16
17
18
DATED this ,f4day of , 2014.
19
20
By____
21
ADAMe1UISJ~-t~m4D
22 Respondent

23
24
25
26 ‘by this M~y of , 2014.
27~ John A.$unt, Esq.
MorrØolich St Purdy, LLP
28 “Bo~fd Counsel
Page6of7
‘Souls Policis & Purdy. LLP
500 S. Rasicho Drive, Suite 7
Las Vegas. Nevada 89106
Ph. (702) 862-8300 ‘~ent’s initials Respondent’s attorney’s initials
1
2 APPROVED AS T
3
4 this 9 day of~
p

5 Olson, Cannon, Gormley, Angulo & Stoberski


6 Respondent’s Counsel
7 ~R9~ASTOFORMAND CONTENT _

~d1ey~trong, DDS /
Disciplinary Screening Office

BOARD ACTION
1
This this Amendment to the Stipulation Agreement from Case No. 12-2456 Which was
I
Approved by the Board on Januaty 24, 2013 in the matter captioned as Nevada State Board of
1
1 Dental Examiners v. Adam Lousig-Nont. DMD, case no. 74127-02643 was (check appropriate

1 action):
1 Approved Disapproved

by a vote of the Nevada State Board of Dental Examiners at a properly noticed meeting.
21
DATED this 27 day of ICMC , 2014.

23

J. Gordon Kinafli, DDS President


-

NEVADA STATE BOARD OF DENTAL EXAMINERS


2.
H:~WDDOCS~3336\37Z57~LVI35I 50.DOCX
2
2
2
Page 7 of 7
Mania Polkh & Purdy, LLP
SODS. Rasclso Drive, Sujie 17
Las Vesas, Nevada 89106
Ph. (702) 862-8300 initials Respondent’s attor~i~

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