Statutes & Events

The Arizona Naturopathic Physicians Medical Board is referred to herein as “the Board." Names are withheld for patients and victims of the Board, in order to protect their privacy.

EXHIBITS that contain MP3 or MP4 audio files are found at https://www.datedevidence.com/blank-1

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Page 1 of 10

Statutes violated by members and other personnel of the

Arizona Naturopathic Physicians Medical Board (herein “the Board”)

State of Arizona statutes violated by the Board

Arizona Revised Statutes Title 44

STATUTE:

ARS 44-1402 Contract, combination or conspiracy to restrain or monopolize trade

A contract, combination or conspiracy between two or more persons in restraint of, or to monopolize, trade or commerce, any part of which is within this state, is unlawful. ↓

EVENTS:

10/12/22: CH takes screenshots of business websites of 4 of 7 Board members, who are all direct competitors with CH, all offering IV nutrient treatments. [EXHIBIT G] Each of their sites shows less information about the nutrients used in IV treatments than that of CH, yet . . .

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STATUTE:

ARS 44-1403 Establishment, maintenance or use of monopoly

The establishment, maintenance or use of a monopoly or an attempt to establish a monopoly of trade or commerce, any part of which is within this state, by any person for the purpose of excluding competition or controlling, fixing or maintaining prices is unlawful. ↓

EVENTS:

10/12/22: CH takes screenshots of business websites of 4 of 7 Board members, who are all direct competitors with CH, all offering IV nutrient treatments. [EXHIBIT G] Each of their sites shows less information about the specific nutrients used in IV treatments than that of CH, who discusses all of the nutrients in videos with date stamps that predate the events of this case, yet . . .

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Page 2 of 10

Statutes violated by members and other personnel of the

Arizona Naturopathic Physicians Medical Board (herein “the Board”)

State of Arizona statutes violated by the Board

Arizona Revised Statutes Title 41

STATUTE:

ARS 41-1030 Invalidity of rules not made according to this chapter; prohibited agency action; prohibited acts by state employees; enforcement; notice.

(B) An agency shall not base a licensing decision in whole or in part on a licensing requirement or condition that is not specifically authorized by statute, rule or state tribal gaming compact. A general grant of authority in statute does not constitute a basis for imposing a licensing requirement or condition unless a rule is made pursuant to that general grant of authority that specifically authorizes the requirement or condition.

(E) This section may be enforced in a private civil action and relief may be awarded against the state.The court may award reasonable attorneys fees, damages and all fees associated with the license application to a party that prevails in an action against the state for a violation of this section.
(F) A state employee may not intentionally or knowingly violate this section.A violation of this section is cause for disciplinary action or dismissal pursuant to the agency’s adopted personnel policy. ↓

EVENTS:

10/12/22: CH takes screenshots of business websites of 4 of 7 Board members, who are all direct competitors with CH, all offering IV nutrient treatments. [EXHIBIT G] Each of their sites shows less information about the specific nutrients used in IV treatments than that of CH, who discusses all of the nutrients in videos with date stamps that predate the events of this case, yet . . .

10/13/22: Board votes to revoke CH license on the basis of ARS 32-1501-31 (L) for use of a “secret means, method, medicine, treatment.” [EXHIBIT A]

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Page 3 of 10

Statutes violated by members and other personnel of the

Arizona Naturopathic Physicians Medical Board (herein “the Board”)

State of Arizona statutes violated by the Board

Arizona Revised Statutes Title 13

STATUTE:

ARS 13-2407 Tampering with a public record; classification

A. A person commits tampering with a public record if, with the intent to defraud or deceive, such person knowingly:

Makes or completes a written instrument, knowing that it has been falsely made, which purports to be a public record or true copy thereof or alters or makes a false entry in a written instrument which is a public record or a true copy of a public record; or

Presents or uses a written instrument which is or purports to be a public record or a copy of such public record, knowing that it has been falsely made, completed or altered or that a false entry has been made, with intent that it be taken as genuine; or

Records, registers or files or offers for recordation, registration or filing in a governmental office or agency a written statement which has been falsely made, completed or altered or in which a false entry has been made or which contains a false statement or false information; or

Destroys, mutilates, conceals, removes or otherwise impairs the availability of any public record; or ↓

EVENTS:

5/25/21: Complaint and Notice of Hearing to OAH.

Gail Anthony signed her name to this document [EXHIBIT D] that contained 17 knowingly and maliciously false statements.

CH identifies each of the 17 false statements in [EXHIBIT E]. Those statements are proven to be false mostly in the subpoenaed document of October 23, 2020 delivered to the Board by email, which e-mail and attachment still exist. [EXHIBIT F]

4/8/21 and 10/13/22 Board meeting

audiotape spoliation, as indicated under 18 USC 1512, above.

10/13/22: Board meeting audiotape, as uploaded to Board website on 10/18/22 shows from 1:04:28 to 1:04:35 the following: A muffling of the audio that was not the case during the Board meeting. During the meeting, Tam Spat was clearly heard twice saying “abstain.” This was his vote in response to Bruce Sadilek’s motion to accept the recommendation for revocation of license. Now only those 8 seconds are muffled to inaudibility.

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Page 4 of 10

Statutes violated by members and other personnel of the

Arizona Naturopathic Physicians Medical Board (herein “the Board”)

State of Arizona statutes violated by the Board

STATUTE:

ARS 13-2407 Tampering with a public record; classification (continued)

In this section "public record" means all official books, papers, written instruments or records created, issued, received or kept by any governmental office or agency or required by law to be kept by others for the information of the government.

Tampering with a public record is a class 6 felony. ↓

EVENTS:

4/8/2021: Board meeting audiotape, as uploaded to Board website shortly thereafter shows on p 6 of transcript that Diva Galan had denied that CH was willing to comply with a Board request, and Clinton Campbell said: “Did you even listen? [CH] said she was willing to do as we asked.” (p 6 of written transcript). This was then erased. [EXHIBIT C]

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STATUTE:

ARS 13-2702 Perjury; classification

A person commits perjury by making either:
1. A false sworn statement in regard to a material issue, believe it to be false.
2. A false unsworn declaration, certificate, verification or statement in regard to a material issue that the person subscribes as true under penalty of perjury, believing it to be false.
Perjury is a class 4 felony. ↓

EVENTS:

5/25/21: Complaint and Notice of Hearing to OAH.

Gail Anthony signed her name to this document [EXHIBIT D] that contained 17 knowingly and maliciously false statements.

4/8/21 and 10/13/22 Board meeting

audiotape spoliation, as indicated under 18 USC 1512, above.

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Page 5 of 10

Statutes violated by members and other personnel of the

Arizona Naturopathic Physicians Medical Board (herein “the Board”)

State of Arizona statutes violated by the Board

STATUTES:

ARS 13-2703 False swearing; classification

A. A person commits false swearing by making a false sworn statement, believing it to be false.

B. False swearing is a class 6 felony.

ARS 13-2707 Proof of guilt

Proof of guilt beyond a reasonable doubt is sufficient for perjury or false swearing and it shall not be necessary that proof be made by a particular number of witnesses or by documentary or other evidence. ↓

EVENTS:

5/25/21: Complaint and Notice of Hearing to OAH.

Gail Anthony signed her name to this document [EXHIBIT D] that contained 17 knowingly and maliciously false statements.

4/8/21 and 10/13/22 Board meeting

audiotape spoliation, as indicated under 18 USC 1512, above.

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STATUTE:

ARS 13-2809 Tampering with physical evidence; classification

A. A person commits tampering with physical evidence if, with intent that it be used, introduced, rejected or unavailable in an official proceeding which is then pending or which such person knows is about to be instituted, such person:

Destroys, mutilates, alters, conceals or removes physical evidence with the intent to impair its verity or availability; or
Knowingly makes, produces or offers any false physical evidence; or . . . ↓

EVENTS:

4/8/21: Board meeting audiotape, as uploaded to Board website shortly thereafter shows on p 6 of transcript that Diva Galan had denied that CH was willing to comply with a Board request, and Dr. Clinton Campbell said: “Did you even listen? [CH] said she was willing to do as we asked.” (p 6 of written transcript). This was then erased.

[EXHIBIT C]

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Page 6 of 10

Statutes violated by members and other personnel of the

Arizona Naturopathic Physicians Medical Board (herein “the Board”)

State of Arizona statutes violated by the Board

STATUTE:

ARS 13-2923 Stalking; classification; exceptions; definitions

A. A person commits stalking if the person intentionally or knowingly engages in a course of conduct that is directed toward another person and if that conduct causes the person to:

1. Suffer emotional distress or reasonably fear that either: (a) The victim’s property will be damaged or destroyed. ↓

EVENTS:

A serial pattern of abusive and harassing and stalking behavior emerges in the series of frivolous claims against CH, including several multi-hour defamatory rant sessions / Board meetings against CH, made by the Board since 2018. These are summarized below:

2018: Case No. 18-102: Board member and CH competitor Dan Rubin filed a complaint with the Board that he did not like CH website.

Result: Dismissed.

2019: Board Case No 19-122: Patient JF has never met CH, and never had any doctor / patient or other relationship. JF confessed that her complaint was facilitated by a contract doctor with Board member and CH competitor Dan Rubin.

Result: Dismissed.

2020 - 2022: Board case No 20-160: Patient AM admitted in front of two witnesses on her initial consult with CH that she was well known to the same Dan Rubin. Later that same Patient AM confessed to having 2 aliases, and later another alias, none of which she had given to us, that she had a history of government intelligence work, bullied CH staff into letting her commandeer private office space in CH’s clinic, and was also a patient of the most abused doctor by the Board, Dr. --, and then demanded protected proprietary information.

Result: The ongoing current case.

2021: Board case No 21-203: A person, JR, unknown to CH, interrupted a conversation between CH and another person on a public forum, complaining to CH and then to the Board about CH’s “probabl[e]” use of vitamin D. Result: Dismissed.

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Page 7 of 10

Statutes violated by members and other personnel of the

Arizona Naturopathic Physicians Medical Board (herein “the Board”)

Federal statutes violated by the Board

What the law says, and what the Board did and when

Title 18

STATUTES:

18 USC 1513 Retaliating against a witness, victim or an informant

(e) Whoever knowingly, with the intent to retaliate, takes any action harmful to any person, including interference with the lawful employment or livelihood of any person, for providing to a law enforcement office any truthful information relating to the commission or possible commission of any Federal offense, shall be fined under this title or imprisoned not more than 10 years, or both. ↓

EVENTS:

10/13/22: Board meeting audiotape, as uploaded to

Board website on 10/18/22 shows from 1:02:46 to 1:03:50 the following, [See Exhibits]

Brian Popiel said:

“In an e-mail directly received by [CH] five days ago, number one she threatened criminal complaints against all of us or most of us. . . . And this is the second or third time she’s threatening the Board with criminal action. . . . but I think she’s made it clear that again that she’s completely under the impression that she’s . . . she’s being targeted and singled out, and the whole concept of what our concerns are has been missed completely. So I actually vote to second [Bruce Sadilek]’s motion.” [Bruce Sadilek had motioned for revocation for license.] [EXHIBIT A] This was said after the Board was informed in writing that the criminal complaints against them had already been filed with the AZ Attorney General’s Office and updated a number of times. [EXHIBIT B]

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STATUTE:

18 USC 1512 Tampering with a witness, victim or informant

(1) alters, destroys, mutilates, or conceals a record, document, or other object, or attempts to do so, with the intent to impair the object’s integrity or availability for use in an official proceeding; Shall be fined under this title or imprisoned not more than 20 years or both. ↓

EVENTS:

10/13/22: Board meeting audiotape, as uploaded to Board website on 10/18/22 shows from 1:04:28 to 1:04:35 the following:

A muffling of the audio that was not the case during the Board meeting. During the meeting, Tam Spat was clearly heard twice saying “abstain.” This was his vote in response to Bruce Sadilek’s motion to accept the recommendation for revocation of license. Now only those 8 seconds are muffled to inaudibility.

4/8/21: Board meeting audiotape, as uploaded to Board website shortly thereafter shows on p 6 of transcript that Diva Galan had denied that CH was willing to comply with a Board request, and Dr. Clinton Campbell said: “Did you even listen? Dr. Huber said she was willing to do as we asked.” (p 6 of written transcript). This was then erased.

[EXHIBIT C]

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Page 8 of 10

Statutes violated by members and other personnel of the

Arizona Naturopathic Physicians Medical Board (herein “the Board”)

Federal statutes violated by the Board

Title 18 (continued)

STATUTE:

18 USC 1001 Statements or entries generally

(a) Except as otherwise provided in this section, whoever in any matter within the jurisdiction of the executive, legislative or judicial branch of the Government of the United States, knowingly and willfully

(1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact; (2) makes any materially false fictitious,

or fraudulent statement or representation; or

(3) makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or

fraudulent statement

Shall be fined under this title, imprisoned not more than 5 years . . .” ↓

EVENTS:

5/25/22: Complaint and Notice of Hearing to OAH.

Gail Anthony signed her name to this document [EXHIBIT D] that contained 17 knowingly and maliciously false statements.

5/31/22: CH identifies in [EXHIBIT E] each of the 17 false statements made by Gail Anthony in [EXHIBIT D]. Those statements are proven to be false mostly in the subpoenaed document of October 23, 2020 delivered to the Board by email, which e-mail and attachment still exist.

4/8/21 and 10/13/22 Board meeting audiotape spoliation, as indicated under 18 USC 1512, above.

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STATUTE:

18 USC 1038 False information and hoaxes

(a) (1) In General – Whoever engages in any conduct with intent to convey false or misleading information under circumstances where such information may reasonably be believed and where such information indicates that an activity has taken, is taking, or will take place . . . shall

(A) be fined under this title or imprisoned not more than 5 years, or both. ↓

EVENTS:

5/25/21: Complaint and Notice of Hearing to OAH.

Gail Anthony signed her name to this document [EXHIBIT C] that contained 17 knowingly and maliciously false statements.

CH identifies each of the 17 false statements in [EXHIBIT E]. Those statements were proven to be false two years earlier, mostly in the subpoenaed document of October 23, 2020 delivered to the Board by e-mail, which e-mail and attachment still exist. [EXHIBIT F]

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Page 9 of 10

Statutes violated by members and other personnel of the

Arizona Naturopathic Physicians Medical Board (herein “the Board”)

Federal statutes violated by the Board

Title 5

STATUTE:

5 USC 2302 – Prohibited personnel practices

(b) Any employee who has authority to take, direct others to take, recommend, or approve any personnel action, shall not, with respect to such authority –

(8) take or fail to take, or threaten to take or fail to take, a personnel action with respect to any employee or applicant for employment because of –

(ii) gross mismanagement, a gross waste of funds, an abuse of authority, or a substantial and specific danger to public health or safety. ↓

EVENTS:

2018: Case No. 18-102: Board member and CH competitor Dan Rubin filed a complaint with the Board that he did not like CH website.

Result: Dismissed.

Result: The ongoing current case.

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Page 10 of 10

Statutes violated by members and other personnel of the

Arizona Naturopathic Physicians Medical Board (herein “the Board”)

Federal statutes violated by the Board

Title 15

STATUTE:

15 USC 1 Trusts, etc., in restraint of trade illegal; penalty

Every contract, combination in the form of trust or otherwise, or conspiracy, in restraint of trade or commerce among the several States, or with foreign nations, is declared to be illegal. Every person who shall make any contract or engage in any combination or conspiracy hereby declared to be illegal shall be deemed guilty of a felony, and, on conviction thereof, shall be punished by fine not exceeding $100,000,000 if a corporation, or, if any other person, $1,000,000, or by imprisonment not exceeding 10 years, or by both said punishments, in the discretion of the court. ↓

EVENTS:

10/12/22: CH takes screenshots of business websites of 4 of the 7 Board members, who are all direct competitors with CH, all offering IV nutrient treatments. [EXHIBIT G] Each of their sites shows less information about the nutrients used in IV treatments than that of CH, yet . . .

10/13/22: Board votes to revoke CH license on the basis of ARS 32-1501-31 (L) for use of a “secret means, method, medicine, treatment.” [EXHIBIT A] This is expected to have the effect of eliminating CH as competition. Other past competitors who are known or suspected to be, or seem in danger of being, victims of the same Board violation include, but are not limited to: --, --, and --.

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STATUTE:

15 USC 2 Monopolizing trade a felony; penalty

Every person who shall monopolize, or attempt to monopolize, or combine or conspire with any other person or person, to monopolize any part of the trade or commerce among the several States, or with foreign nations, shall be deemed guilty of a felony, and on conviction thereof, shall be punished by fine not exceeding . . if any other person $1,000,000, or imprisonment not exceeding 10 years, or by both said punishments, in the discretion of the court. ↓

EVENTS:

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STATUTE:

15 USC 4 Jurisdiction of courts; duty of United States attorneys; procedure

The several district courts of the United States are invested with jurisdiction to prevent and restrain violations of sections 1 to 7 of this title; and it shall be the duty of the several United States attorneys, in their respective districts, under the direction of the Attorney General, to institute proceedings in equity to prevent and restrain such violations. ↓

EVENTS:

10/13/22: Board meeting audiotape, as uploaded to Board website on 10/18/22 shows from 1:02:46 to 1:03:50 that BP violated or attempted to violate 18 USC 1513 (e), as described above. [EXHIBIT A] This was done in front of an Arizona Assistant Attorney General, whose Office is now required to act to restrain this activity.

Statutes & Events

State of Arizona statutes violated by the Board

State of Arizona statutes violated by the Board

State of Arizona statutes violated by the Board

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State of Arizona statutes violated by the Board

State of Arizona statutes violated by the Board

Federal statutes violated by the Board

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Federal statutes violated by the Board

Federal statutes violated by the Board

Federal statutes violated by the Board

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