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State of Illinois Department of Professional Regulation

DEPARTMENT OF PROFESSIONAL REGULATION
of the State of Illinois,
Complainant
No. 1988-10343-01
v.
Bennett G. Braun MD,
License No. 036042542,
Respondent

C. S. License No. 336010503

COMPLAINT

Now comes the DEPARTMENT OF PROFESSIONAL REGULATION of the State of Illinois, by its Chief of Medical Prosecutions, Thomas Glasgow, and as its COMPLAINT against Bennett G. Braun MD, Respondent, complains as follows:

THE PARTIES, JURISDICTION, AND BACKGROUND

1. Bennett G. Braun MD is presently the holder of a Certificate of Registration as a physician & surgeon in the State of Illinois, License No. 036042542, issued by the State of Illinois, Department of Professional Regulation. Bennett G. Braun’s physician & surgeon license is presently in active status.

2. Bennett G. Braun MD is presently the holder of an Illinois controlled substance license in the State of Illinois, License No.336010503, issued by the State of Illinois, Department of Professional Regulation. Bennett G. Braun’s controlled substance license is presently in active status.

3. At all times material to the complaint the Respondent specialized in the practice of psychiatry and represented that he had expertise in the areas of psychopharmacology, psychoanalysis, hypnosis, and hypnotherapy with an emphasis on the treatment of dissociative disorders and in particular "multiple personality disorder" ("MPD").

4. At all times material to this complaint, the Respondent was Director of the Center for Dissociative Studies at Rush Presbyterian St. Luke’s Hospital in Chicago, Illinois (the "Center"). Under the auspices of its Dissociative Disorder program, the Center studied MPD diagnosed patients.

From August 1985 through approximately November 1992, Respondent, as Director of the Dissociative Disorders Program, determined the eligibility for admission and ongoing participation of all program patients.

6. At all times material to this complaint, Respondent was involved in a psychiatrist-patient relationship with both P.B and her minor children, J.B. and M.B.

7. On and before February 5, 1986, and at all times material to this complaint, Respondent represented publicly and to P.B., to her husband, and to her minor children J.B. and M.B. that he possessed expertise in the retrieval of "repressed memories" and the identification and treatment of survivors of alleged or supposed "satanic ritual abuse" at the hands of transgenerational, organized, world-wide satanic cults.

8. From February 1986 through approximately November 1992, P.B. was continuously under the care and treatment of Respondent because of his diagnosis that P.B. suffered from MPD.

9. On February 5, 1986, Respondent a) performed an out-patient evaluation of P.B. to determine her eligibility for participation in the Dissociative Disorders Program at Rush and b) determined that P.B. should be admitted to Rush as a patient of the Dissociative Disorders Program as soon as a vacancy became available.

10. On March 5, 1986, as a part of the care and treatment rendered to P.B. by Respondent, P.B. was admitted as a resident patient to the Dissociative Disorders Program in the psychiatric care unit at Rush.

11. On and after March 5, 1986, Respondent diagnosed P.B. as suffering from mental illness, including MPD.

12. From March 5, 1986 through approximately June 11, 1988, P.B. was continuously a resident patient of the Dissociative Disorders Program at Rush under Respondent’s care.

13. From approximately June 11, 1988 through approximately October 1992, P.B. continued as an out-patient participant in the Dissociative Disorders Program under Respondent’s care.

14. From March 5, 1986 through approximately October 1992, P.B. participated in an unbroken and continuous course of treatment under Respondent’s care.

15. When P.B. consented to her admission and continued hospitalization and participation as an in-patient of the Dissociative Disorders Program at Rush, she relied on Respondent’s advice, expertise, and good faith.

16. On and before February 5, 1986, and at all times material to the complaint, P.B. and her husband were the parents and natural guardians of their minor sons, J.B. and M.B.

17. In conjunction with P.B.’s treatment, Respondent advised P.B. and her husband that their sons, J.B. and M.B., should be admitted to the Rush psychiatric unit for a short period of resident examination and evaluation.

18. On March 22, 1986 along with the admission and/or treatment of P.B., minor J.B. was admitted as a resident patient to the child psychiatric care unit at Rush.

19. On October 11, 1986, along with the admission and/or treatment of P.D., minor M.B. was admitted as a resident patient to the child Psychiatric care unit at Rush.

20. From the time of their respective admissions to June, 1989, minors J.B. and M.B. continuously were resident patients of the Dissociative Disorders Program at Rush under the care provided by Respondent, among others.

21. From June, 1989 through approximately December, 1990, minors J.B. and M.B. continued as out-patients under Respondent’s care.

22. From March 5, 1986 through approximately December 1990, minors J.B. and M.B. participated in an unbroken and continuous course of treatment under the care provided by Respondent, among others.

23. P.B. and her husband consented to the admission and continued hospitalization of J.B. and M.B. in reliance on the advice, expertise and good faith of Respondent.

24. The Respondent at all times was aware that P.B. and her husband had no expertise in matters related to mental illness.

25. At all times material to this complaint, Respondent encouraged P.B. and her husband to rely on his professed skill and qualifications, with respect to the diagnosis and treatment of P.B., as well as their minor children J.B. and M.B.

26. At all times material to this complaint, P.B. and her husband relied on Respondent’s professed skill and qualifications.

27 . At the time of their admission to the Rush psychiatric unit as stated, J.B. and M.B. suffered from no mental illness.

28. Within the first twelve months of the minors’ hospitalization, Respondent, acting with the consent and assistance of other members of the Rush staff, advised P.B. and her husband that J.B. and M.B. were suffering from mental illness which required their protracted hospitalization and treatment as in-patients and out-patients of the Rush psychiatric unit for treatment of such claimed illness.

29. In reliance upon the professed expertise of Respondent, P.B. and her husband consented to the hospitalization and out-patient treatment of their sons.

30. At the time of her admission to the Rush psychiatric unit, P.B. did not suffer from mental illness which required in-patient hospitalization.

31. The Respondent advised P.B. and her husband that P.B. was suffering from mental illness which required her protracted hospitalization and treatment as an in-patient and out-patient of the Rush psychiatric unit for treatment of such claimed illness.

32 In reliance upon Respondent’s professed expertise, P.B. and her husband consented to P.B.’s hospitalization and treatment as an in-patient and out-patient.

33. The Respondent, without any appropriate or reasonable medical justification, confined J.B. and M.B. in Rush’s mental institution for a continuous period of approximately three years.

34. The Respondent, without any appropriate or reasonable medical justification, confined P.B. in Rush’s mental institution for a continuous period of approximately twenty-seven months.

35. For the entire period of time that P.B.’s minor children were confined at Rush, P.B. and her husband witnessed the nature of the treatment rendered their minor children, the extent to which such treatment affected their minor children and the impact said treatment had on the physical and mental well-being of the minor children.

36. For the entire period of time that their minor children were confined at Rush, P.B. and her husband, in reliance upon Respondent’s professed expertise and qualifications, consented to the treatment rendered to their minor children.

37. For the entire period of time that their minor children were confined at Rush, P.B. and her husband were included in and participated in the therapy sessions as part of the treatment rendered to their minor children at Respondent’s insistence and direction.

38. During various therapy sessions with Respondent, the minor children and P.B. were instructed to and did discuss imaginary episodes of abuse that P.B. had come to believe that the minor children and she had participated in, individually and jointly, and in conjunction with other family members, and a supposed transgenerational, organized, satanic cult. These imaginary episodes allegedly consisted of sexual, physical and emotional abuse, human sacrifice and human torture.

39. For the entire period of time that their minor children were confined at Rush, P.B. and her husband were instructed to and did encourage their minor children to cooperate and participate in the above described therapy sessions.

40. For the entire period of time that their minor children were confined at Rush, P.B. and her husband, as guardians of their minor children, were informed of the diagnoses and progression of the minor children’s conditions, and the bases therefor.

41. For the entire period of time that their minor children were confined at Rush, P.B. and her husband, as guardians of their minor children, were informed of the issues and subject matters addressed in the minor children’s therapy.

42. As a result of the therapy prescribed and administered to P.B. and the minor children, the minor children came to believe that they had participated in episodes of abuse at the hands of P.B., other family members, and a supposed transgenerational, organized, satanic cult, including repeated episodes of sexual, physical and emotional abuse, human sacrifice and human torture.

43. As a result of the therapy prescribed and administered to P.B. and the minor children, P.B. and her husband likewise came to believe that the minor children had participated in episodes of abuse at the hands of P.B., other family members, and a supposed transgenerational, organized, satanic cult, including repeated episodes of sexual, physical and emotional abuse, human sacrifice and human torture.

44. During the time that P.B. was under the supervision and care of the Respondent, Respondent prescribed Inderal, Halcion, Xanax, sedatives and hypnotic psychotropic drugs to P.B.0. The Respondent prescribed dosages of these drugs at experimental, untested, and medically inappropriate levels.

45. On January 15, 1998, the Department received information for the first time that P.B. and her children had settled a civil lawsuit against the Respondent on October 31, 1997.

COUNT I
GROSS NEGLIGENCE - P.B.

1-45.The Department realleges and adopts the above paragraphs 1-45 as paragraphs 1-45 of Count I.

46. From February 5, 1986, through approximately October, 1992, and at all times material to this complaint, Respondent was reckless, careless, and demonstrated a disregard for the safety or well being of P.B. which resulted in injury to P.B.; in one or more of the following respects:

(a) Failed to adequately evaluate P.B’s condition;

(b) Failed to accurately diagnose P.B.’s condition;

(c) Failed to properly treat P.B.’s condition;

(d) Established an unorthodox treatment regimen in assigning to P.B. various "personalities";

(e) Improperly implemented the aforesaid treatment regimen, encouraging and assisting P.B. in developing "personalities" which the Respondent represented were "alter" personalities within P.B., when no such personalities existed;

(f) Improperly implemented the aforesaid treatment regimen using suggestive and coercive techniques to encourage and assist P.B. to "remember" episodes of abuse.

(g) Failed to discuss and/or offer alternative, less expensive, less intrusive, and more efficacious methods of treatment;

(h) Uncritically accepted the previous diagnosis that P.B. had of multiple personality disorder;

(i) Failed to perform available and competent psychiatric and psychological testing;

(j) Uncritically applied hypnotic techniques in the course of therapy;

(k) Improperly prescribed for P.B. various sedative, hypnotic, psychotropic drugs, and other medications including Inderal, Halcion, and Xanax;

(l) Improperly prescribed medications which would increase the patient’s vulnerability to suggestion;

(m) Subjected P.B. to massive, off-label experimental doses of Inderal both alone and in combination with other psychotropic drugs;

(n) Used the results of the off-label or experimental drug regimen to further bolster his diagnosis of "multiple personality disorder" without an adequate basis for doing so;

(o) Subjected P.B. to extremely stressful situations including separation from her children and family;

(p) Subjected P.B. to long-term isolated inpatient hospitalization when such hospitalization was not reasonably necessary;

(q) Subjected P.B. to long-term out-patient treatment when such treatment was not reasonably necessary;

(r) Subjected P.B. to extensive hypnosis;

(s) Subjected P.B. to abreaction or reliving of supposed traumas in full leather restraints;

(t) Improperly used post-hypnotic suggestions with P.B.;

(u) Advised P.B. and her husband that years of confinement were necessary in the interest of treating P.B.’s condition;

(v) Advised P.B. and her husband that P.B.’s condition could be hereditary;

(w) Advised P.B. and her husband that years of confinement were necessary for the evaluation and treatment of their minor children, J.B. and M.B.;

(x) Advised P.B. and her husband that "multiple personality disorder" is caused by extreme childhood abuse which is not remembered or "repressed";

(y) Advised P.B. and her husband that individuals could repress or dissociate all knowledge of traumatic events so that a person can have suffered from extreme abuse for many years from early childhood through adulthood with no conscious knowledge that such events ever occurred;

(z) Advised P.B. and her husband that "repressed memories" were common in persons with "multiple personality disorder;"

(aa) Advised P.B. and her husband that "repressed memories" being uncovered during the course of her treatment and her children’s treatment represented real memories of actual historical events;

(bb) Advised P.B. and her husband that organized, world-wide transgenerational satanic cults which engaged in mass murder, torture, satanic ritual abuse, human sacrifices and similar activities did in fact exist and that their existence and activities were well-known;

(cc) Repeatedly advised and convinced P.B. and her husband, when either or both expressed doubt as to the existence of satanic ritual abuse and the validity of the memories of such abuse, that they were the only people questioning such concepts and beliefs;

(dd) Repeatedly advised and convinced P.B. and her husband, when either or both expressed doubt as to the existence of satanic ritual abuse and the validity of the memories of such abuse, that in order to progress therapeutically, it was necessary to accept as true the memories of such abuse;

(ee) Advised P.B. that she had caused psychological harm to her minor children;

(ff) Advised P.B. that she had sexually abused her minor children;

(gg) Advised P.B. and her husband that P.B. had physically abused their minor children;

(hh) Advised P.B. and her husband that P.B. had caused their minor children to participate in various satanic ritual activities including human and animal sacrifice, cannibalism, and various acts of human torture;

(ii) Failed to adequately inform P.B. and her husband of the risk that the techniques used in treatment were capable of causing false memories of events which never occurred but which nevertheless seem real to the patient;

(jj) Failed to adequately inform P.B. and her husband of the risk that the diagnosis of multiple personality d±sorder was controversial and that the diagnosis was not widely accepted in the mental health community;

(kk) Failed to inform P.B. and her husband that there was further controversy in the mental health community as to whether or not multiple personality disorder was being overdiagnosed and often found in people who did not in fact have that disorder;

(ll) Failed to inform P.B. and her husband of the risk that "multiple personality disorder" can be caused by improper therapy;

(mm) Failed to inform P.B. and her husband that the theory of repression lacked scientific validity and was not generally accepted in the scientific community;

(nn) Failed to adequately supervise other health care providers participating in hypnosis sessions and "therapy" with P.B.;

(oo) Failed to adequately advise P.B. and her husband of the unauthorized, unstructured, uncontrolled, experimental nature of the drug regimen employed in her treatment;

(pp) Failed to adequately advise P.B. and her husband of the risks associated with the unstructured, uncontrolled, experimental or off-label drug regimen employed in her treatment;

(qq) Failed to inform P.B. and her husband of the risk that the use of post-hypnotic suggestion had effects which are known to be harmful and long-lasting;

(rr) Placed P.B. in a "therapeutic milieu" without taking adequate precautions against contamination among the patients in the milieu; or

(ss) Was otherwise grossly negligent.

47. As a result of the forgoing acts and/or omissions Respondent caused P.B. to be held in a psychiatric facility for approximately two years for no medically justifiable reason; caused P.B. to believe that she and her children suffered from "multiple personality disorder" which Respondent insisted was triggered by the participation of P.B. and her children in satanic and cannibalistic cults; placed P.B. in a situation of extreme risk to her physical health through dangerous and inappropriate drug therapies; charged P.B. large sums of money for in-patient and out-patient treatments which were not medically indicated; deprived P.B. of the society and companionship of her husband and young children for extended periods of time; and caused P.B. various other emotional, mental, and physical injuries.

48. The foregoing acts and/or omissions constitute gross negligence by the Respondent.

49. The forgoing acts and/or omissions are grounds for revocation or suspension of a Certificate of Registration pursuant to 225 Illinois Compiled Statutes 60/22(A)4 (1998) and the Rules for the Administration of the Medical Practice Act, Illinois Administrative Code Title 68, Section 1285.240 (c).

WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF PROFESSIONAL REGULATION of the State of Illinois, by Thomas Glasgow, its Chief of Medical Prosecutions, prays that the physician and surgeon license and controlled substance license of Bennett G. Braun MD be suspended, revoked, or otherwise disciplined.

COUNT II
GROSS NEGLIGENCE - J.B.

1-45.The Department realleges and adopts paragraphs 1-45 of Count I as paragraphs 1-45 of Count II.

46. From March 22, 1986, through approximately December 1990, and at all times material to this complaint, Respondent was reckless, careless, and demonstrated a disregard for the safety or well being of J.B. which resulted in injury to J.B.; in one or more of the following respects:

(a) Failed to adequately evaluate J.B’s condition;

(b) Failed to accurately diagnose J.B.’s condition;

(c) Failed to properly treat J.B.’s condition;

(d) Established an unorthodox treatment regimen in assigning to J.B. various "personalities";

(e) Improperly implemented the aforesaid treatment regimen encouraging and assisting J.B. in developing "personalities" which the Respondent represented were "alter" personalities within J.B., when no such personalities existed;

(f) Improperly implemented the aforesaid treatment regimen using suggestive and coercive techniques to encourage and assist J.B. to "remember" episodes of abuse.

(g) Failed to discuss and/or offer alternative, less expensive, less intrusive, and more efficacious methods of treatment;

(h) Failed to perform available and competent psychiatric and psychological testing;

(i) Uncritically applied hypnotic techniques in the course of therapy;

(j) Improperly prescribed for J.B. various sedative, hypnotic, psychotropic drugs, and other medications including Inderal, Halcion, and Xanax;

(k) Improperly prescribed medications which would increase the patient’s vulnerability to suggestion;

(1) Subjected J.B. to extremely stressful situations including separation from his family;

(m) Subjected J.B. to long-term isolated inpatient hospitalization when such hospitalization was not reasonably necessary;

(n) Subjected J.B. to long-term out-patient treatment when such treatment was not reasonably necessary;

(o) Advised J.B.’s parents that years of confinement were necessary in the interest of treating J.B.’s condition;

(p) Advised J.B.’s parents that J.B.’s condition could be hereditary;

(q) Advised J.B.’s parents that "multiple personality disorder" is caused by extreme childhood abuse which is not remembered or "repressed";

(r) Advised J.B. ’s parents that individuals could repress or dissociate all knowledge of traumatic events so that a person could have suffered from extreme abuse for many years from early childhood with no conscious knowledge that such events ever occurred;

(s) Advised J.B.’s parents that "repressed memories" were common in persons with "multiple personality disorder;"

(t) Advised J.B.’s parents that "repressed memories" being uncovered during the course of his treatment represented real memories of actual historical events;

(u) Advised J.B.’s parents that organized, world-wide transgenerational satanic cults which engaged in mass murder, torture, satanic ritual abuse, human sacrifices and similar activities did in fact exist and that their existence and activities were well-known;

(v) Failed to adequately inform J.B.’s parents of the risk that the techniques used in treatment were capable of causing false memories of events which never occurred but which nevertheless seem real to the patient;

(w) Failed to adequately inform J.B.’s parents of the risk that the diagnosis of multiple personality disorder was controversial and that the diagnosis was not widely accepted in the mental health community;

(x) Failed to inform J.B.’s parents that there was further controversy in the mental health community as to whether or not multiple personality disorder was being overdiagnosed and often found in people who did not in fact have that disorder;

(y) Failed to inform J.B.’s parents of the risk that "multiple personality disorder" can be caused by improper therapy;

(z) Failed to inform J.B.’s parents that the theory of repression lacked scientific validity and was not generally accepted in the scientific community; or

(aa) Was otherwise grossly negligent.

47. As a result of the foregoing acts and/or omissions, Respondent caused J.B. to be held in a psychiatric facility for over three years for no medically justifiable reason; subjected him to other out-patient treatments which were not medically indicated; deprived J.B. of the society and companionship of parent; during the time that he was between the ages of five and eight; deprived J.B. of the opportunity for a normal childhood; and caused P.B. various other emotional, mental and physical injuries.

48. The foregoing acts and/or omissions constitute gross negligence by the Respondent.

49. The forgoing acts and/or omissions are grounds for revocation or suspension of a Certificate of Registration pursuant to 225 Illinois Compiled Statutes 60/22(A)4 (1998) and Rules for the Administration of the Medical Practice Act, Illinois Administrative Code Title 68, Section 1285.240(c).

WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF PROFESSIONAL REGULATION of the State of Illinois, by Thomas Glasgow, its Chief of Medical Prosecutions, prays that the physician and surgeon license and controlled substance license of Bennett G. Braun MD be suspended, revoked, or otherwise disciplined.

COUNT III
GROSS NEGLIGENCE - M.B.

1-45.The Department realleges and adopts.paragraphs 1-45 of Count I as paragraphs 1-45 of Count III.

46. From March 22, 1986, through approximately December 1990, and at all times material to this complaint, Respondent was reckless, careless, and demonstrated a disregard for the safety or well being of M.B. which resulted in injury to M.B.; in one or more of the following respects:

(a) Failed to adequately evaluate M.B’s condition;

(b) Failed to accurately diagnose M.B.’s condition;

(c) Failed to properly treat M.B.’s condition;

(d) Established an unorthodox treatment regimen in assigning to M.B. various "personalities";

(e) Improperly implemented the aforesaid treatment regimen, encouraging and assisting M.B. in developing "personalities" which the Respondent represented were "alter" personalities within M.B., when no such personalities existed;

(f) Improperly implemented the aforesaid treatment regimen using suggestive and coercive techniques to encourage and assist M.B. to "remember" episodes of abuse.

(g) Failed to discuss and/or offer alternative, less expensive, less intrusive, and more efficacious methods of treatment;

(h) Failed to perform available and competent psychiatric and psychological testing;

(i) Uncritically applied hypnotic techniques in the course of therapy;

(j) Improperly prescribed for M.B. various sedative, hypnotic, psychotropic drugs, and other medications including Inderal, Halcion, and Xanax;

(k) Improperly prescribed medications which would increase the pat±ent’s vulnerability to suggestion;

(l) Subjected M.B. to extremely stressful situations including separation from his family;

(m) Subjected M.B. to long-term isolated inpatient hospitalization when such hospitalization was not reasonably necessary;

(n) Subjected M.B. to long-term out-patient treatment when such treatment was not reasonably necessary;

(o) Advised M.B.’s parents that years of confinement were necessary in the interest of treating J.B.’s condition;

(p) Advised M.B.’s parents that M.B.’s condition could be hereditary;

(q) Advised M.B.’s parents that "multiple personality disorder" is caused by extreme childhood abuse which is not remembered or "repressed";

(r) Advised M.B.’s parents that individuals could repress or dissociate all knowledge of traumatic events so that a person could have suffered from extreme abuse for many years from early childhood with no conscious knowledge that such events ever occurred;

(s) Advised M.B.’s parents that "repressed memories" were common in persons with "multiple personality disorder;"

(t) Advised M.B.’s parents that "repressed memories" being uncovered during the course of his treatment represented real memories of actual historical events;

(u) Advised M.B.’s parents that organized, world-wide transgenerational satanic cults which engaged in mass murder, torture, satanic ritual abuse, human sacrifices and similar activities did in fact exist and that their existence and activities were well-known;

(v) Failed to adequately inform J.B.’s parents of the risk that the techniques used in treatment were capable of causing false memories of events which never occurred but which nevertheless seem real to the patient;

(w) Failed to adequately inform M.B.’s parents of the risk that the diagnosis of multiple personality disorder was controversial and that the diagnosis was not widely accepted in the mental health community;

(x) Failed to inform M.B.’s parents that there was further controversy in the mental health community as to whether or not multiple personality disorder was being overdiagnosed and often found in people who did not in fact have that disorder;

(y) Failed to inform M.B.’s parents of the risk that "multiple personality disorder" can be caused by improper therapy;

(z) Failed to inform M.B.’s parents that the theory of regression lacked scientific validity and was not generally accepted in the scientific community; or

(aa) Was otherwise grossly negligent.

47. As a result of the foregoing acts and/or omissions, Respondent caused M.B. to be held in a psychiatric facility for approximately three years for no medically justifiable reason; subjected him to other out-patient treatments which were not medically indicated; deprived M.B. of the society and companionship of parents during the time that he was between the ages of four and seven; deprived J.B. of the opportunity for a normal childhood; and caused P.B. various other emotional, mental and physical injuries.

48. The foregoing acts and/or omissions constitute gross negligence by the Respondent.

49. The forgoing acts and/or omissions are grounds for revocation or suspension of a Certificate of Registration pursuant to 225 Illinois Compiled Statutes 60/22(A)4 (1998) and the Rules for the Administration of the Medical Practice Act, Illinois Administrative Code Title 68, Section 1285.240 (c).

WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF PROFESSIONAL REGULATION of the State of Illinois, by Thomas Glasgow, its Chief of Medical Prosecutions, prays that the physician and surgeon license and controlled substance license of Bennett G. Braun MD be suspended, revoked, or otherwise disciplined.

COUNT IV
DISHONORABLE, UNETHICAL, AND UNPROFESSIONAL CONDUCT - P.B.

1-45.The Department realleges and adopts paragraphs 1-45 of Count I as paragraphs 1-45 of Count IV.

46. From February 5, 1986, through approximately October, 1992, and at all times material to this complaint, Respondent engaged in dishonorable, unethical, or unprofessional conduct with regard to P.B. in one or more of the following respects:

a-rr The Department realleges and adopts paragraphs 46 (a)-(rr) of Count I as paragraphs 46 (a)-(rr) of Count VI.

ss. Was otherwise dishonorable, unethical, or unprofessional in his conduct with P.B.

47. The foregoing acts and/or omissions constitute dishonorable, unethical, or unprofessional conduct by the Respondent.

48. The forgoing acts and/or omissions are grounds for revocation or suspension of a Certificate of Registration pursuant to 225 Illinois Compiled Statutes 60/22(A)5 (1998), and the Rules for Administration of the Medical Practice Act, Illinois Administrative Code Title 68, Section 1285.240(a)l-A, B, C, D, E, and F and 1265.240 (a) 2-B, C, D, and E.

WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF PROFESSIONAL REGULATION of the State of Illinois, by Thomas Glasgow, its Chief of Medical Prosecutions, prays that the physician and surgeon license and controlled substance license of Bennett G. Braun MD be suspended, revoked, or otherwise disciplined.

COUNT V
DISHONORABLE, UNETHICAL, OR UNPROFESSIONAL CONDUCT -J.B.

1-45.The Department realleges and adopts paragraphs 1-45 of Count I as paragraphs 1-45 of Count V.

46. From March 22, 1986, through approximately December 1990, and at all times material to this complaint, Respondent engaged in dishonorable, unethical, or unprofessional conduct with regard to J.B. in one or more of the following respects:

a-z The Department realleges and adopts paragraphs 46 (a)-(z) of Count II as paragraphs 46 (a)-(z) of Count V.

aa. Was otherwise dishonorable, unethical, or unprofessional in his conduct with J.B.

47. The foregoing acts and/or omissions constitute unprofessional conduct by the Respondent.

48. The forgoing acts and/or omissions are grounds for revocation or suspension of a Certificate of Registration pursuant to 225 Illinois Compiled Statutes 60/22(A)5 (1998), and the Rules for Administration of the Medical Practice Act, Illinois Administrative Code Title 68, Section 1285.240(a)l-A, B, C, D, E, and F and 1285.240 (a) 2-B, C, D, and E.

WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF PROFESSIONAL REGULATION of the State of Illinois, by Thomas Glasgow, its Chief of Medical Prosecutions, prays that the physician and surgeon license and controlled substance license of Bennett G. Braun MD be suspended, revoked, or otherwise disciplined.

COUNT VI
DISHONORABLE, UNETHICAL, OR UNPROFESSIONAL CONDUCT - M.B.

1-45.The Department realleges and adopts paragraphs 1-45 of Count I as paragraphs 1-45 of Count VI.

46. From October 11, 1986, through approximately December 1990, and at all times material to this complaint, Respondent engaged in dishonorable, unethical, or unprofessional conduct with regard to M.B. in one or more of the following respects:

a-z The Department realleges and adopts paragraphs 46 (a)-(z) of Count III as paragraphs 46 (a)-(z) of Count VI.

aa. Was otherwise dishonorable, unethical, or unprofessional in his conduct with M.B.

47. The foregoing acts and/or omissions constitute dishonorable, unethical, or unprofessional conduct by the Respondent.

48. The forgoing acts and/or omissions are grounds for revocation or suspension of a Certificate of Registration pursuant to 225 Illinois Compiled Statutes 60/22(A)5 (1998), and the Rules for Administration of the Medical Practice Act, Illinois Administrative Code Title 68, Section 1285.240(a)l-A, B, C, D, E, and F and 1285.240 (a) 2-B, C, D, and E.

WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF PROFESSIONAL REGULATION of the State of Illinois, by Thomas Glasgow, its Chief of Medical Prosecutions, prays that the physician and surgeon license and controlled substance license of Bennett G. Braun MD be suspended, revoked, or otherwise disciplined.

COUNT VII
MAKING A FALSE OR MISLEADING STATEMENT REGARDING THE SKILL OR EFFICACY OR VALUE OF THE MEDICINE, TREATMENT, OR REMEDY PRESCRIBED BY HIM AT HIS DIRECTION IN THE TREATMENT OF ANY DISEASE OR OTHER CONDITION OF THE BODY OR MIND.

1-45.The Department realleges and adopts paragraphs 1-45 of Count I as paragraphs 1-45 of Count VII.

46. From February 5, 1986, through approximately October 1992, and at all times material to this complaint, Respondent made false or misleading statements to P.B. and her husband regarding the skill or efficacy or value of the medicine, treatment, or remedy prescribed by him at his direction in the treatment of any disease or other condition of the body or mind in one or more of the following respects:

a-n The Department realleges and adopts paragraphs 46 (u)-(hh) of Count I as paragraphs 46 (a)-(n) of Count VII.

47. The foregoing acts and/or omissions constitute making [a] false or misleading statement[s] by the Respondent regarding the skill or efficacy or value of the medicine, treatment, or remedy prescribed by him at his direction in the treatment of any disease or other condition of the body or mind.

48. The forgoing acts and/or omissions are grounds for revocation or suspension of a Certificate of Registration pursuant to 225 Illinois Compiled Statutes 60/22(A)10 (1998).

WHEREFORE, based on the foregoing allegations, the DEPARTMENT 0F PROFESSIONAL REGULATION of the State of Illinois, by Thomas Glasgow, its Chief of Medical Prosecutions, prays that the physician and surgeon license and controlled substance license of Bennett G. Braun MD be suspended, revoked, or otherwise disciplined.

COUNT VIII
PRESCRIBING, SELLING, ADMINISTERING, DISTRIBUTING, OR GIVING ANY DRUG CLASSIFIED AS A CONTROLLED SUBSTANCE OR NARCOTIC FOR OTHER THAN MEDICALLY ACCEPTED PURPOSES.

1-45.The Department realleges and adopts paragraphs 1-45 of Count I as paragraphs 1-45 of Count VIII.

46. From February 5, 1986, through approximately October 1992, and at all times material to this complaint, Respondent prescribed or gave to P.B. drugs classified as a controlled substance or narcotic for other than medically accepted purposes in one or more of the following respects:

a-c The Department realleges and adopts paragraphs 46 (k)-(m) of Count I as paragraphs 46 (a)-(c) of Count VIII.

47. The foregoing acts and/or omissions constitute prescribing, selling, administering, distributing, or giving any drug classified as a controlled substance or narcotic for other than medically accepted purposes by the Respondent.

48. The forgoing acts and/or omissions are grounds for revocation or suspension of a Certificate of Registration pursuant to 225 Illinois Compiled Statutes 60/22(A)17 (1998).

WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF PROFESSIONAL REGULATION of the State of Illinois, by Thomas Glasgow, its Chief of Medical Prosecutions, prays that the physician and surgeon license and controlled substance license of Bennett G. Braun MD be suspended, revoked, or otherwise disciplined.

COUNT IX
A PATTERN OF PRACTICE OR OTHER BEHAVIOR, WHICH DEMONSTRATES INCAPACITY OR INCOMPETENCE TO PRACTICE UNDER THIS ACT.

1-45.The Department realleges and adopts paragraphs 1-45 of Count I as paragraphs 1-45 of Count IX.

46. From February 5,.1986, through approximately October 1992, and at all times material to this complaint, Respondent demonstrated incapacity and incompetence during the care and treatment of P.B. to practice under this act in one or more of the following respects:

a-rr The Department realleges and adopts paragraphs 46 (a)-(rr) of Count I as paragraphs 46 (a)-(rr) of Count IX.

ss. Otherwise demonstrated incapacity and incompetence in his conduct with P.B., her husband and their minor children J.B. and M.B.

47. The foregoing acts and/or omissions constitute a pattern of practice or other behavior which demonstrates incapacity or incompetence to practice under this act by the Respondent.

48. The forgoing acts and/or omissions are grounds for revocation or suspension of a Certificate of Registration pursuant to 225 Illinois Compiled Statutes 60/22(A)26 (1998).

WHEREFORE, based on the foregoing allegations, the DEPARTMENT 0F PROFESSIONAL REGULATION of the State of Illinois, by Thomas Glasgow, its Chief of Medical Prosecutions, prays that the physician and surgeon license and controlled substance license of Bennett G. Braun MD be suspended, revoked, or otherwise disciplined.

DEPARTMENT OF PPOFESSIONAL REGULATION
of the State of Illinois

BY:
Thomas Glasgow
Chief of Medical Prosecutions

Thomas Glasgow
Attorney for the Department
Department of Professional Regulation
100 West Randolph St. - Suite 9-300
Chicago, IL 60601
312/814-4635

TG:qfs

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