The following document is the Refutation I wrote to the Determination and Order.  Again, as stated in the Vacatur Petition, it is really something for the Obstetrican/Gynecologist to read since it goes into serious clinical detail and may be a bit too technical for the average reader.  It was written as a line by line, paragraph by paragraph rebuttal to the State's conviction document (the D&O).  Therefore, the best way to utilize it is to open both of them up side by side and read the D&O and see the real truth in the Rebuttal.  I submit this for completeness, since again, I will not shy away from anything as it pertains to this entire matter, including the actual care rendered to the patients which was fraudulently represented in the Determination and Order.

Refutation to the Determination and Order

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