13

on November 29, 1995 in Lisa’s name. Dr. Minkoff had never seen
or talked to Lisa as a patient. Dr. Minkoff has testified that he was never told the details or severity of Lisa’s mental
condition and denies prescribing or authorizing magnesium injections or the use of an irrigating syringe to force medicate
Lisa with aspirin and Benadryl. Minkoff testified that doing these things without physician authorization would in his opinion be practicing medicine.

Your Affiant further learned from sworn, immunized testimony
of. the various caretakers and other employees/staff members of CSFSO that several of Lisa’s caretakers had some medical training. Janice Johnson had been a practicing, licensed
anesthesiologist in Arizona specializing in chronic pain management. Your Affiant has reviewed her licensing file from that state and determined that when she ran into disciplinary trouble in the early 1990’s, she surrendered her authority to
prescribe controlled substances and in 1994 let her medical
license lapse. The Florida Board of Medicine has confirmed to
your Affiant that she has never been licensed in this state nor has she applied for a Florida license. Laura Arrunada, another
of Lisa’s caretakers from the Medical Liaison Office, testified she had graduated medical school in Mexico but had never
practiced. Rita Boykin testified she had experience as a nursing assistant. Testimony indicated that Janice Johnson had assumed a
supervisory role in caring for Lisa, visited her on numerous


10

13