Stipulated Offense Two (Patient B). On or about August 2, 2012, at Peru, in the Northern District of Illinois, Eastern Division, defendant XXXXXXX did knowingly and intentionally dispense to Patient B a controlled substance, namely, a quantity of mixtures and substances containing Oxycodone, a Schedule II Controlled Substance, outside the course of professional practice and without a legitimate medical purpose, in violation of Title 21, United States Code, Section 841(a)(1). More specifically, between approximately June 2012 and August 2012, Patient B was an employee at XXXXXXX’ medical clinic in Peru, Illinois. While Patient B was an employee, XXXXXXX prescribed Oxycodone to Patient B on 11 occasions without requiring Patient B to register as a patient, make appointments, submit to any physical examination or provide a prior medical history. Beginning in approximately September 2013, Patient B stopped working at XXXXXXX’ clinic and registered as a new patient. Patient B began making appointments and paying a visit fee to see XXXXXXX. Between approximately September 2012 and April 2013, XXXXXXX continued to prescribe Oxycodone to Patient B without conforming to the standards of the medical profession and knowing that Patient B was opioid dependent and that doing so was potentially harmful to Patient X. XXXXXXX prescribed all of the above controlled substances to Patient B outside the course of professional practice and without a legitimate medical purpose. Throughout July and August 2012, XXXXXXX prescribed Oxycodone to Patient B even though Patient B was not XXXXXXX’ patient and was never examined by XXXXXXX. Even after Patient B registered as a patient at XXXXXXX’ clinic, XXXXXXX avoided performing the type of routine examinations, diagnostic tests and review of the patient’s medical history that a professional acting in the usual course of medical practice would have performed, and failed to document any legitimate medical reason for dispensing Oxycodone to Patient B. Despite knowing there was no legitimate medical reason for Patient B to receive Oxycodone, XXXXXXX prescribed this controlled substance to Patient X. XXXXXXX acknowledges that the controlled substances he illegally prescribed to Patient B are accurately summarized in the chart below. For the purpose of computing his sentence under Guideline § 2D1.1, XXXXXXX acknowledges that the total weight of these prescriptions corresponds to approximately 404 kilograms of marijuana. Date Substance Prescribed Drug Strength Metric Qty. Tot...
