COURT FILE NUMBER 1803 01472 COURT QUEEN'S BENCH OF ALBERTA JUDICIAL CENTRE EDMONTON ‘APPLICANT(S) DR.VILIAM MAKIS RESPONDENT(S) COLLEGE OF PHYSICIANS AND SURGEONS OF ALBERTA (COMPLAINT REVIEW COMMITTEE) DOCUMENT AFFIDAVIT ADDRESS FOR SERVICE 5970 MULLEN WAY, #36560 AND. EDMONTON, AB, TER OT4 CONTACT INFORMATION Attention: Dr. Viliam Makis OF Phone: (780) 937-8745 PARTY FILING THIS DOCUMENT AFFIDAVIT OF DR.VILIAM MAKIS ‘Sworn on January 25, 2018 1, Dr-Viliam Mi of Edmonton, Alberta, SWEAR AND SAY THAT: 1. am the Applicant in this matter and I have personal knowledge of the matters | refer to in this affidavit. 2. lam a Nuclear Medicine physician licensed to practice medicine in the province of Alberta. 3. | practiced Nuclear Medicine at the Cross Cancer Institute (“CC!") in Edmonton, Alberta, in the Department of Diagnostic Imaging (“DI”), from August 5, 2013 until October 31, 2016 4. On dune 1, 2016, | filed a formal written complaint with the College of Physicians and ‘Surgeons of Alberta (‘CPSA’) in respect of physical and or verbal abuse inflicted on me and other healthcare workers of DI at CCI, by a regulated member of the CPSA and Alberta Health Services Administrator and Site Chief of DI at CCI, Dr.Robert MacEwan. A copy of the complaint is attached to this affidavit as Exhibit A. 5. The CPSA Complaints Director reviewed the complaint, File 160350, determined that there is “insufficient evidence of unprofessional conduct to move forward with further investigation into Dr.MacEwan's conduct’ and dismissed the complaint. A copy of the dismissal letter is attached to this affidavit as Exhibit B. vMooo;10. 1. 12. 13. 14, 15. 16. | filed an appeal of CPSA File 160350, however the CPSA claimed that it was received 1 day outside the 30-day appeal period and dismissed the appeal. A copy of the appeal dismissal is attached to this affidavit as Exhibit C. On October 14, 2016, | filed a new complaint with the CPSA in respect of Dr. MacEwan's unprofessional conduct, with new allegations of abusive conduct toward healthcare staff of DI at CCI, and new supporting documents. A copy of the new complaint is attached to this affidavit a¢ Exhibit D. CPSA Complaints Director reviewed the complaint, File 160618, claimed that allegations 1-4 and 6-10 were previously submitted and considered, dismissed 160618 and refused to initiate an investigation. A copy of the 160618 dismissal letter is attached to this affidavit as Exhibit E. ‘On November 24, 2016, | wrote a letter to CPSA Registrar Dr.Trevor Theman, expressed my intention to appeal the 160618 dismissal, and expressed my concerns about the safety of the CC! healthcare staff who continued to be abused. A copy of this letter is attached to this affidavit as Exhibit F. CPSA Registrar did not respond to my November 24, 2016 letter. On December 14, 2016, | filed an appeal of the CPSA 160618 complaint dismissal with the Complaint Review Committee ("CRC"). A copy of the 160618 appeal is attached to this affidavit as Exhibit G. ‘On April 3, 2017, the CRC reviewed the appeal of the CPSA 160618 complaint dismissal, and issued their findings on July 20, 2017 ("The Decision’). A copy of the July 20, 2017 CRC Decision is attached to this affidavit as Exhibit H. In the Decision, the CRC made a number of biased and erroneous statements in the “Background” section. Specifically, | did not send emé ‘complaining about the Investigated Member's alleged incompetent leadership’, the eroding relationship between myself and the Investigated Member did not result in an “Alberta Health Services Triggered Initial Assessment Investigation” and | have never filed “civil litigation against the Investigated Member’, as claimed by CRC. In the Decision, the CRC repeated the erroneous claim made by the CPSA Complaints Director that 160618 Allegations 1-4 and 6-10 were submitted and fully considered Previously and therefore should be dismissed. In the Decision, the CRC made the erroneous claim that “the complainant does not deny that the same allegations were made in the past’, notwithstanding that in my December 14, 2016 appeal (Exhibit G) I denied that the same allegations were made in the past. In the Decision, the CRC stated: “The CRC has considered whether there is sufficient evidence that the Investigated Member has engaged in “unprofessional conduct” to warrant a hearing by a Hearing Tribunal". The CRC did not state if it considered whether there was sufficient evidence to warrant an Investigation. vmoo00217. 18. 19. 21. ‘SWORN BEFORE ME at Edmonton, Alberta, this 25th day of January, 2018. (Conafhissioner for Oaths in and for the Province of Alberta) In the Decision, the CRC made a biased conclusion in favour of Dr.MacEwan, stating that while Dr.MacEwan slapping a nurse ‘suggests rude behavior by the Investigated Member, there is insufficient evidence of conduct which would amount to “unprofessional ‘conduct’. The CRC made this conclusion in the absense of any Investigation into Dr.MacEwan's professional conduct. In the Decision, the CRC made a biased conclusion in favour of Dr. MacEwan, stating that in Dr.MacEwan’s role as site director “any critique of a physician in this role is not necessarily demonstrative of harassment or abuse, let alone of unprofessional conduct ‘The CRC made this conclusion in the absense of any Investigation into Dr. MacEwan’s professional conduct. In the Decision, the CRC made no comments in respect of the safety, health or well- being of the healthcare staff of the DI at CCI. In the Decision, the CRC concluded: “The CRC believes that the decision made by the ‘Complaints Director was reasonable; there is insufficient evidence of a violation of the relevant provisions of the Code of Ethics, Standards of Practice, any other legislation which might apply to the Investigated Member, or any conduct which would harm the integrity of the profession, to refer the matter for investigation or for a hearing.” The CRC made this biased conclusion in the absense of any Investigation into Dr. MacEwan’s professional conduct. ‘The CRC dismissed the complaint 160618 on July 20, 2017. (Signature) ROBERTA ALLISON BITNER ‘ACOMIASSIONER FOR OATHS AND TOME PROMNDE OF Appa Downes corosen wate ) ) ) ) VM0003A sre Ths fo Ean 9/7) tefered to Dr.Villam Makis, MD, FRCPC at ilien ote kis is. Department of Diagnostic Imaging Pirie; Cross Cancer Institute ot danny “201 11560 University Ave NW, Edmonton, AB, T6G 122 June 1, 2016 "Brno fo Cae ‘nad for Alber Dr.Trevor Theman ‘ACOMMSSONER FOR OATHS WANE Registrar EXPIRES OCTOWEN fe College of Physicians and Surgeons of Alberta 2700 - 10020 100 Street NW Edmonton, AB, TSJON3 CANADA Professional conduct of Dr.Robert MacEwan MD, FRCPC (Site Lead, Diagnostic Imaging, Cross Cancer institute). Dear Dr.Theman, | am filing a formal CPSA complaint regarding the professional conduct of Dr.Robert MacEwan, Site Lead Diagnostic Imaging, Cross Cancer institute (CC). Please find attached 222 pages of supporting documentation, in 90 document clusters. Background am a nuclear medicine physician currently working in the Diagnostic Imaging department of the CCI. | started working at CCI on August 5, 2013 and | perform both imaging work and radioisotope therapy work for cancer patients (hereafter referred to as “therapy work"). 1. Physical Assaults: (Dr. David Williams, Deb Haldorson! (On Nov.26, 2025, Dr. David Williams (a CCI radiologist) came to my CC! office in the afternoon and. appeared to be in shock. He told me that he had just been physically assaulted by Dr.Robert MacEwan during a heated verbal argument in Dr.Williams’ office, when Dr. MacEwan approached Dr.Williams and pushed him forcefully and repeatedly on the shoulder as Dr. Williams was sitting down. Dr. Williams demonstrated on me the manner and force with which Dr.MacEwan touched him and | was pushed backward in my seat. Dr.MacEwan also allegedly told Dr.Williams during that verbal argument that Dr.Williams should resign and look for another job. Dr-Williams told me that Dr. MacEwan had also recently physically assaulted a CCI radiology nurse, Ms.Deb Halldorson during a procedure that the two were performing together on a patient at work. Dr.Williams was not sure of the date of the incident and estimated that it occurred in October 2015. Dr. MacEwan allegedly slapped Ms.Halldorson’s hand forcefully during the procedure. Ms.Halldorson reported this incident to her AHS ‘manager, Quinn West, however Quinn West allegedly took no further action and covered up the incident which was very upsetting for Ms.Halldorson. ‘On Nov.26, 2015, shortly after the physical assault, Dr.Williams, Dr.€mmanuel Hudson and | discussed Dr.MacEwan’s recent worsening of his abusive and aggressive behavior. Or.Williams stated that he felt that aj ExuieiT A VMOCO4Dr.Macéwan had targeted him with retaliation for Dr.Wiliams’ support of a May 1, 2015 request made to CCI Medical Director Dr.Matthew Parliament to remove Dr.MacEwan for ongoing incidents of unprofessional conduct. | told Dr.Williams that | too had been targeted for retaliation (see paragraphs 5-8) by Dr. MacEwan for support of the same May 1, 2015 request. We discussed what steps Dr.Williams should take next and | suggested that Dr-Williams report the incident, and he subsequently reported it to Dr-Matthew Parliament. Dr-Williams met with Dr.Parliament in early December 2015. In anticipation of that meeting, Dr.MacEwan submitted a written document to Dr.Parliament which, according to Dr.Williams, falsely accused Dr. Wiliams of bullying in order to severely damage Dr. Williams’ professional reputation with Dr.Parliament. Dr.Williams showed me this document and given my professional 3-year knowledge of Dr.Williams, | found it to be extremely defamatory. Itis my understanding that Dr. MacEwan faced no disciplinary action and faced no consequences for the physical assault. | spoke with Dr. Wiliams several times in late December 2015 and he allegedly reported the physical assault to the CMPA and a legal counsel but was advised to only continue documenting incidents and take no action at the time. He was extremely disillusioned by these developments and began looking for a new job outside Edmonton and out of the province. Verbal Abuse of Dr.Francois-Alexandre Buteau (currently working in Quebec City, QC) When | started working at the CCI on August 5, 2013, | was told by Dr-Francois-A Buteau, the physician who | was replacing, that Dr.MacEwan was verbally abusive toward him when Dr.Buteau was a fellow in 2011- 2012 and the verbal abuse continued when Dr.Buteau became a staff in 2012-2013, One specific inci Dr.Buteau told me about was Dr. MacEwan telling him “Francois, you don’t have to be anyone's bitch, but if you're going to be someone's bitch, | prefer you be my bitch”, Dr.Buteau seems to have taken this verbal abuse reasonably well, however several staff, including nurse Karey McCann and clerk Salima Haji(Beattie) confirmed that the quote was not a joke, but was a real representation of Dr.MacEwan's attitude and behaviour towards Dr.Buteau, Dr.MacEwan allegedly constantly overloaded Dr.Buteau with excessive workloads, harassed Dr.Buteau about time that he was spending with patients to the point where he was forcing Dr.Buteau to log the times when he started seeing a patient and finished seeing a patient, which Dr.Buteau was not able to sustain long term due to the excessive stress that it placed on him. Nuclear Medicine technologist Brittany Sammann told me that many nuclear medicine technologists would joke that Dr.Buteau had “Rob’s Bitch” tattooed on his buttocks, which was subsequently confirmed to me by Karey McCann and Dr.Buteau himself. Karey McCann and Salima Hali(Beattie) warned me repeatedly in Aug-Sep, 2013 of Dr.MacEwan’s abusive behavior toward Dr.Buteau. Dr.Buteau also warned me that | might experience abusive behavior from Dr.MacEwan and he urged me to log all my work so that | could have a sense of how much work | was doing, as | ‘would apparently get almost no credit from Dr. MacEwan for any of my therapy work. It was within these first few ‘Weeks of my employment at the CCI that | became aware that | was entering an extremely abusive and toxic environment at the CCI, but | was determined to work hard and make the situation work for the benefit of my family. | felt that if | worked hard, ! would not be abused by Dr. MacEwan, but | was incorrect in this assumption. During my first year, l witnessed numerous incidents of verbally abusive behavior of Dr. MacEwan directed towards CCI nuclear medicine staff, including Brittany Sammann, Jennifer Forer, Terence Riauka, Karey McCann, Salima Haji(Beattie), Charlotte Krasowski, Joanne Snydmiller, and Vincent Wong. Dr.MacEwan’s verbal ‘abuse consisted of any of; yelling, insults, interrogation style questioning, humiliation, intimidation and even the slamming of doors. | documented some of these abuses in my Aug.20, 2014 harassment complaint to Dr.Matthew Parliament and Dr.David Mador (Edmonton Zone Medical Director) (ref 25), however it is my nt 2 vM O00understanding that this complaint was not properly investigated, no staff members were ever questioned about the abuses that | documented and no steps were taken to protect these staff from further abuse. It Is also my understanding that Dr.MacEwan did not face any disciplinary actions resulting from the Aug.20, 2014 harassment complaint. Please note that Dr. MacEwan would subsequently refer to my Aug.20, 2014 harassment complaint as. my “unprofessional conduct” and retaliated against me severely and extensively, in violation of AHS Medical Staff By-laws by embarking on a long term pre-meditated destruction of my medical career, which is detailed in paragraphs 5-8 (ref 75, 76). Harassment of Dr. Viliam Makis: Formal harassment complaint dated Aug.20, 2014 {As | was on probation for 1 year, | did all of the work that Dr.MacEwan asked of me, however Dr.MacEwan was loading me with more and more work to the point of near physical collapse. My wife recounts that by July 2024, | would regularly come home from work and collapse to fall asleep at 6 or 7pm, sometimes without having dinner and would be unable to play with my children for the rest of the evening from exhaustion. | advised Dr. MacEwan of my heavy workload and exhaustion numerous times including on Feb.24, 2014 and ‘Aug.6, 2014 (ref 03, 11) which Dr. MacEwan ignored. Dr. MacEwan refused to staff the nuclear medicine department properly which began to adversely impact patient care (ref 01-08). | began to complain about these unsustainable workloads starting July 10, 2024 (ref 04). | filed a longer complaint with Quinn West on July 24, 2014 (ref 07) and itis after this complaint that Dr.MacEwan’s behavior toward me drastically changed and became hostile. | noticed that Dr.MacEwan started holding secret meetings with Quinn West and he began attacking my therapy work repeatedly starting July 25, 2014 (ref 09, 11). | began limiting PET/CT work from July 25 to try to restore the workloads to more reasonable and sustainable levels (ref 08, 10), and asked Dr.MacEwan repeatedly to help me by scheduling another nuclear medicine colleague Dr. Hudson to work more on nuclear medicine instead of CT (ref 11, 12). Dr.Hudson was very eager to help me but was repeatedly denied the ability to do so. Dr. MacEwan first cornered me in my office on ‘Aug.6, 2014 and threatened me regarding my emails about physician staffing, and told me | was not allowed to discuss concerns about patient care issues with anyone but him, so | wouldn’t be “wasting people's time”. This ‘was the first time | felt threatened at work at CCI (ref 11, 15-22). Dr. MacEwan would subsequently refer to Aug.6, 2014 as the start of my “consistently unprofessional conduct”, which “began on day 366 of his employ’, when he began retaliating against me by advocating for the destruction of my CCI medical career via an email sent to senior AHS directors, including Quinn West, Dr.Matthew Parliament and Dr.8ill Anderson on Aug.23, 2015 (ref 75). | found it unacceptable and a violation of CPSA codes of conduct that Dr.MacEwan would try to prevent me from communicating with other physicians about patient related issues in a threatening manner, and | continued to document the patient related problems in the department caused by poor management decisions of Dr.MacEwan and Quinn West in an Aug.8, 2014 email (ref 12). 1 would list problems and provide solutions, which I thought would be appreciated. However, at this point | was also afraid of being cornered and harassed by Dr.MacEwan again and | bought a voice recording iphone application (Aug.11, 2014, ref 16) and left the recorder ‘on as soon as | arrived at work in the subsequent days to record any further incidents. ‘On Aug.11, 2014, Dr.MacEwan responded to my attempts to fix the physician scheduling (ref 12, 14) by threatening my job at CCI when he replied directly to my email that documented failures in Quinn West's and Dr.MacEwan’s management (ref 12), Dr. MacEwan stated: “! would ask that everyone remember that itis a privilege to work at the CCI and itis a privilege to work with this unique patient population”, implying that this 3 véMo00g“privilege” could be taken away by Dr.MacEwan (ref 15). | wrote to Salima Haji (Beattie) that | felt threatened and asked her to arrange an appointment with Dr Parliament (ref 17). Dr.MacEwan cornered me agai ‘unexpectedly, on Aug.12, 2014 and since | had my voice recording application already running, | was able to record the conversation. Dr. MacEwan stated “I've asked you not to email before, and you continued to email. “the emails you're sending are...they are offensive, and they have to stop..and you're upsetting everybody”. When | continued to repeatedly state that | did not wish to talk to him, Dr.MacEwan refused to leave, stating “that’s not really an option Will”. | asked Dr. MacEwan 12 times to not have any discussions at that time before he finally left my office (ref 19). | was so distressed by this incident that | began locking my door and | immediately asked Quinn West to tell Dr. MacEwan to not talk to me in the near term. That same evening, at approximately ‘Spm after hours with no one else in the department, Dr.MacEwan called my office 3 times and came to my door knocking twice, all of which | didn’t answer out of fear for my physical safety (ref 21) | felt very threatened and | continued to lock my office door daily until my meeting with Dr.Parliament on Aug.18, 2014. | filed a harassment. complaint with Dr.Parliament in writing on Aug.20, 2014. | received a letter from Dr.David Mador on August 22, 2014 asking me to “come to a resolution’..."without implementing the formal process through the AHS Medical Staff Bylaws” and | took Dr.Mador's advice (ref 11, 15-22, 25-27). \ subsequently had a meeting with Dr.Parliament and Dr.Bill Anderson where the focus was on fixing the workload issues. | was advised that Dr.MacEwan’s abusive behavior would be addressed but | was not given any Information as to how this would be achieved. | expected an apology from Dr. MacEwan and received none. | expected other radiologists and staff that | reported as having been abused to be questioned, and they were not. | expected some steps to have been taken to protect my staff, and | am not aware that anything was done to protect them. \ expected more than two meetings with Dr.Parliament and Dr.Anderson and I also expected a follow-up from Dr.David Mador, but none of these transpired. As months passed by, | was perplexed as to why no one approached me regarding formalizing a mutual resolution and | began to suspect that this harassment complaint was not being taken seriously and | regretted my decision to follow Dr. David Mador’s advice and not go to the CPSA formally, Dr.MacEwan’s behavior toward me did improve, but he never apologized for any of his abusive behavior toward me or toward my staff. There was never a mutual resolution to the harassment complaint between Dr. MacEwan and myself, and the harassment complaint remains outstanding to this day. Given that Dr.-MacEwan viewed this harassment complaint as my “unprofessional conduct” (ref 75) and cited it as a reason why he embarked on a long term plan to destroy my medical career in violation of AHS Medical Staff By-laws, itis lear that the AHS complaint system falled me and my staff, in regards to the mis-handling of the Aug.20, 2014 harassment complaint. Request by 8 CCI radiologists to Dr. Matthew Parliament to remove Dr.Robert MacEwan as Director of Diagnostic Imaging, CCI, on May 1, 2015 for ongoing unprofessional conduct. Shortly prior to May 2, 2015, | was approached by Dr.David Williams who said that the majority of the radiologists had decided to ask Dr.Parliament to formally remove Dr. MacEwan as Director of Diagnostic Imaging for his ongoing unprofessional conduct, and asked me if | would support them in this request. He stated that this course of action was supported by almost al of the radiologists in the department except Dr. Michelle Janoski and Dr.Ron Hennig, | agreed to offer my support and I gave Dr. Williams a letter of support to give to Dr.Parliament on May 1, 2015 as | was away that day (ref 46), and Dr.Aalo Duha made an appointment with Dr. Parliament on May 4 VM00071, 2015 to make this request formally on behalf of the department. I s my understanding that 5 radiologists came to Dr. Parliament's office (Or. Williams, Dr.Susan Bates, Dr.Aalo Duha, Dr.Barb Campbell, Dr.Emmanuel Hudson) along with letters or verbal confirmation of support from radiologists who couldn't come (Dr.Makis, Dr. Marie Smerdiey) (for a total of 7, with undeclared support of Dr.Sandy McEwan for a total of 8), and asked for Dr.MacEwan to be formally removed as Director of Diagnostic Imaging. It is my understanding that Dr.Parliament declined to remove Dr.MacEwan as Director but instead offered to mediate a meeting between the radiologists and Dr.MacEwan, which would be held on May.4, 2015, Shortly prior to May 4, 2015, Dr.Williams gave me a letter that was composed by several radiologists which listed some of the concerns that the radiologists had about Dr. MacEwan’s ongoing unprofessional conduct that would be brought up at the upcoming May 4, 2015 meeting (ref 47). These included: © a) Unilateral decisions, autocratic, rigid and inconsistent leadership (1,2,3,5) © ie, nuclear medicine job offer to Dr.kulsherstha without consulting nuclear medicine physicians Dr.Hudson and Dr.Makis (ref 28, 29). (© denial of MITNEC research trial without consulting the physicians involved (ref 56). © denial of locum provision without consensus of radiology group leading to loss of ~ $300,000, of locum funding on fiscal year end Mar.31, 2015 (ref 50, 52-54, 57-58). © repeated denial of protected research time in violation of radiologist AHS contract provisions (requests made by Dr.Makis on Feb.24, 2014, April 30, 2015) (ref 03), until unanimous approval by radiology group on June 25, 2015 (ref 62-63). ‘© Inconsistency on rules (i.e. Dr-MacEwan enforced rules for limiting radiologist access to agenda creation for physician meetings but did not keep minutes of meetings according to Edmonton Zone rules) (ref 45). ‘+ b) Dismissal of radiologists concerns (2,3) © Dr.MacEwan was dismissive of most PET/CT scheduling concerns expressed by Dr.Makis in July-Aug, 2014 until the filing of a harassment complaint on Aug.20, 2014 forced Dr. MacEwan to drastically increase staffing in nuclear medicine and PET/CT. © €)Denial of medical appointments, family crises, personal crises (4) © Dr.MacEwan denied a 1 day leave for me to take my wife for surgery and support her, resulting in my wite neecing to take a taxi by herself to Grey Nun's hospital on May 9, 2014 to have her surgery without any emotional support, and subsequently having to wait by hersolf in fear after surgery for several hours while on pain medication until | was able to pick her up after work. ‘© Dr.Barb Campbell was allegedly denied an urgent medical appointment ‘© Dr.Edrise Mueller was allegedly denied a short term leave of absence to deal with a family is, with these denials resulting in her crying at work on several occasions as witnessed by Dr.Emmanuel Hudson in his office, shortly before Dr. Mueller resigned her job, allegedly due to Dr.MacEwan’s refusal to provide the needed leave of absence to deal with her family crisis (she is currently providing occasional locum work for CC!) (© Dr-Mary-Ann Johnson was denied time off in the summer as a transition plan to her retirement, allegedly leading to her decision to take an early full retirement on Dec.15, 2014. 5 v4 0008© consider these to be violations of basic human rights, as the department always has the capacity to accommodate medical or personal emergencies, 4d) unprofessional treatment of CCI radiologists (demoralizing micromanagement, refusal to recognize, promote and capite on radiologists’ subspecialty expertise, expression of perceived shortcomings of one radiologist to other radiologists (2,5) ‘* From 2013-2015 Dr.Hudson was repeatedly denied by Dr.MacEwan requests for more ‘nuclear medicine work in his radiology schedule (ref 39). ‘* Dr.Hudson also described to me numerous instances of demoralizing micromanagement from Dr.MacEwan during 2013-2015. ‘+ Lexperienced demoralizing micromanagement from Dr.MacEwan until the fling of the Aug.20, 2014 harassment complaint. ‘© _Dr.MacEwan told me repeatedly that Dr.Hudson was retiring in 2-3 years while Dr. Hudson. completely denied this. ) Unprofessional treatment of allied health professionals © Dr.MacEwan has been verbally abusive toward IT staff (Vincent Wong, Viktor Konkov, Doug Bridgeman). Example includes a Mar 11, 2015 email to Dr.Wong where Dr. MacEwan stated in front of Dr.Wong’s colleagues that Dr.Wong should abandon his job until our workstations were fixed (“perhaps you should abandon your post downtown until such time as Hermes is working properly”) (ref 41). ‘© _Jalso witnessed Dr.MacEwan being verbally abusive to Mr.Andrew Prideaux, a Hermes application specialist who spent several days in 2014 upgrading our workstations. Mr.Prideaux was apparently so traumatized by the situation, that his boss, Mr.Rene Rebaud (Chief Operating Officer for North America Hermes Medical Solutions) told me during a social dinner at a Canadian Association of Nuclear Medicine Meeting in Halifax, Nova Scotia on ‘April 22, 2016, that Mr.Prideaux is still traumatized by the abusive experience from CCI two years later (ref 89, 90). ‘0 Ms.Madeleine Sousa, a product specialist for Siemens Healthcare, the company that provides the cameras for the Diagnostic Imaging department at CCI, told me of an incident where Dr.Mactwan openly mocked her in front of her industry colleagues for the way in which she pronounced the word “dessert”, as she is from Quebec and English is her second language. She felt humiliated by the incident as she is self-conscious of her English language and accent. ‘The concluding paragraph of the May 4, 2015 CCI radiologist summary of Dr.Macwan’s unprofessional conduct stated: “Our group will not survive under this autocratic, rigid, and inconsistent leadership model. We are having continued problems in recruitment and retention under the current regime.” | will note that recruitment problems were severe during late 2014 and early 2015 with no less than 6 applicants accepting a job Position at CCI during this time only to refuse to start work and find a job elsewhere (including: Dr.Priya Gupta, Dr.Bilal Anmed, Dr. Heather Hausmann, Dr.Hosheng Zakaria, Dr.Anton Shapoval, a female French-Canadian resident applying for a fellowship). | would note that Dr. MacEwan monopolized all communications with radiology job candidates against the wishes of the radiology group (ref 30) and several CCI radiologists VM 00095. (Or.Wiliams, Dr.Susan Bates, Dr. Hudson) expressed concern that Dr. MacEwan's communications with radiology job applicants were contributing to the severe recruitment problems at CCl. Five radiologists were able to meet with Dr. MacEwan on May 4, 2015 to discuss his unprofessional ‘conduct (Or. williams, Dr.Duha, Dr.Bates, Dr.Campbell and Dr.Makis) and were eageriy awaiting mediation from Dr-Parliament, however Dr.Parliament did not come for the May 4, 2015 meeting, Dr. MacEwan listened to the radiologists’ concerns and took notes, but was visibly agitated and cut the meeting short, lasting only 30 minutes, ‘hich did not allow enough time to address all the issues of unprofessional conduct. A summary of the meeting ‘and issues that were discussed was signed by 5 CCI radiologists (ref 48). Dr.Williams, Dr.Bates and myself discussed arranging a follow-up meeting to see if Dr.MacEwan would be willing to make drastic changes in his professional conduct and leadership (ref S1). Dr. MacEwan finally addressed the team’s concerns on May 21, 2015 but he blamed most of the radiologists’ concerns on short staffing stresses and the radiologists themselves, and he took almost no responsibility for his ongoing unprofessional conduct (ref 55). Furthermore, Dr.MacEwan denied the fact that he had denied medical appointments, or leave of absence for family/personal crises, The radiology team was very disillusioned by Dr-Parliament’s refusal to address Dr.MacEwan’s unprofessional conduct and Dr. MacEwan's denial of any ‘wrongdoing. Once again, Dr. MacEwan faced no consequences for his unprofessional conduct. Retaliation for Aug.2014 Harassment Complaint: interference in research activity May-June 2015 Dr.MacEwan started engaging in retaliatory actions against me from June 2015 by interfering with my requests to participate in research work. Dr.MacEwan had denied my requests for protected research time on Feb.24, 2014 (ref 03) and Apr.30, 2015 during a radiologist monthly meeting, in violation of my AHS contract Provisions which specify at least a 10% allocation (5% for research and 5% for academic work). During a monthly radiologist meeting on Apr.30, 2015, Dr.MacEwan stated that in the department's history, no one had ever had protected research time, which Dr.Sandy McEwan confirmed was a lie, as both Dr.FA Buteau and Dr.Ernst Postema had protected research time prior to 2013. Dr. MacEwan also unilaterally denied approval for the MITNEC trial on or about May 22, 2015 without asking the investigators on the trial (Dr.Sandy McEwan, Dr.Emmanuel Hudson and myself) for their final opinion on the matter (ref 56). This prompted me to request a meeting between us that was held on June 9, 2015 where Dr. McEwan, Dr.Hudson and myself expressed support for the trial while Dr.MacEwan and Quinn West resisted the trial. On June 10, 2015, 1 was attacked in writing by both Quinn West and Dr.Macéwan about protected research time, with Quinn West going 2s far as to attempt to. legally interpret my AHS contract in such a manner that | would have no protected research time at all t was at Point that | realized that Dr.MacEwan and Quinn West would be working together to interfere with or sabotage my CC! medical practice going forward (ref 61). Retaliation for Aug.2014 Harassment complaint: accusations of imaging mistakes to damage my career using the CPSA (July-Aug 2015). (On July 23, 2015, | received an email from Dr.MacEwan that stated “l just reviewed this case for the CPSA” (ref 64, 65). Dr. MacEwan did not explain why he was doing this, or what this meant, given that he had no ‘authority or reason to review my imaging studies with the CPSA. He then accused me of making several mistakes in this report. | would like to ask the investigators to obtain CPSA records of Dr.MacEwan’s communications with PSA about this imaging study (or other studies), as Dr. MacEwan did not have my consent to review any of my imaging studies. vM00I0I recelved more emails where Dr.MacEwan attempted to document alleged mistakes in my imaging reports on Aug.18 and Aug.19, 2015 (ref 70, 71). | asked Dr.MacEwan to meet with me and Dr.Bates regarding ‘one such email to discuss the patient related issues and potentially amend our imaging reports, but Dr.MacEwan refused, saying it was not relevant (ref 70). | would note that none of the alleged mistakes that Dr.MacEwan had documented were clinically relevant and none required amendment of the radiology report. | am assuming that Dr.MacEwan was attempting to build a case with the CPSA to question my competence as a radiologist in order to inflict damage on my medical career. | would note that these emails stopped when | sent Dr.MacEwan a notice of a PET/CT imaging mistake that he made that was clinically relevant and impacted patient care, on Aug.31, 2015 (ref 78). | had been approached by Dr.Michael Sawyer for @ 2 opinion, as he felt that Dr.MacEwan’s imaging report was not providing the needed clinical information, Dr.MacEwan had missed the location of a primary malignancy which | subsequently found and documented with Dr-Sawyer and Dr.MacEwan. Dr.MacEwan subsequently made corrections to his radiology report without doing an addendum, to hide this mistake, in violation of AHS rules. Retaliation for Aug.2014 harassment complaint: advocating for my contract non-renewal, defamation and threats by Dr. MacEwan and Quinn West (Aug.2015 - Dec.2015) In August 2015, Or.Macewan, in partnership with AHS Director Quinn West, embarked on a long term pre- meditated effort to destroy my medical career, in retaliation for my Aug.20, 2014 harassment complaint. Dr.MacEwan confessed his intentions to Dr.Matthew Parliament and Dr.Bill Anderson in an Aug.23, 2015 email directed to them and to Quinn West (ref 75). a) Defamation by Dr.MacEwan in Aug.23, 2015 email to senior AHS Directors ‘+ “Ithink that we (AHS) should strongly consider exploring contract non-renewal and | will begin advocating for same this coming week". | would like to ask the CPSA investigators to determine who Dr.MacEwan was advocating my AHS contract non-renewal with, as I suspect Dr.MacEwan was advocating with the AHS Director of CancerControl Alberta, Dr.Paul Grundy. * “your technology staff need to write everything down... they will not, then perhaps you / Scott could meet with each of them individually” ~ this describes pre-meditated harassment and coercion of unwilling staff to file formal complaints against me. Please note that Dr.MacEwan gave these instructions to harass and coerce technologists to AHS Directors Quinn West and Scott Simmons, however Dr.MacEwan subsequently engaged in harassment and coercion himself (see paragraph Ba). '* Defamation: “I'm convinced that this physician out to be dismissed from the organization..it’s likely the only way forward”: Dr.MacEwan confirms his intentions to get me fired, although | do not understand the statement “it's likely the only way forward”. ‘* Defamation: “any of his contributions...are far overshadowed by the divisive nature of his character and his consistently unprofessional conduct, which | will remind you began on day 366 of his employ” (please note that day 366 of my employ was Aug.6, 2014, which was the first incident | documented in my Aug.20, 2014 harassment complaint). Dr. MacEwan clearly states that the reason he wants me fired is my Aug.20, 2014 harassment complaint, consistent with retaliation, which is a serious violation of the AHS Medical Staff By-laws and CPSA Code of conduct. ‘* Defamation: “to be so unprofessional toward the technologists is another level altogether... have ever seen anyone behave like this in the profession... feel badly for the technologists who have to 8 vMocnwork closely with him... wouldn't be surprised if we lose staff because of him’. | have an excellent relationship with my technologists and these statements were extremely defamatory. Please note that Brittany Sammann threatened to quit her job because of Dr.MacEwan’s harassment of her (ref 76, 79). Also please note that this incident was actually re-harassment, as | documented harassment of Brittany Sammann by Dr.MacEwan in my Aug.20, 2014 complaint to Dr.David Mador, and nothing was done by the AHS Complaint System to protect her. b) Verbal threats by Quinn West, Aug.21, 2015 and Dec.18, 2015 ‘© Quinn West first threatened me on Aug.21, 2015 when he was secretly taking pictures of my office door without asking for permission and attempting to leave without explanation. | ran into the hallway and asked what he was doing. He didn’t explain and simply threatened me, saying: “You just crossed a line you cannot come back from”, implying that he was going to either cause me disabling. physical harm or get me fired from my job. He confessed this in his Aug,28, 2015 email (ref 77). ‘* Quinn West threatened me a 2" time on Dec.18, 2015 when | sent an email detailing his fallures of management and the severe adverse impact on patient care including the loss of two precious cancer treatments, to his manager Mr.Peter Froese. Quinn West came to my office very angry. | said: “sorry Quinn, you have no choice, we have to work together”. He responded: “We are not going to be ‘working together. There will be an aftermath. There will be an aftermath for you.” | took this as a threat that | was going to get fired, to which | responded: “well, | have a good lawyer.” (ref 86). ©) Defamation by Quinn West Aug.19, 2015 12:59pm email Quinn West falsely accused me of being “divisive” (same accusation made by Dr.MacEwan in his ‘Aug.23, 2015 email), “unprofessional” and having a “lack of respect for a group of peers within the department” (ref 72). These false staterients were defamatory in nature and the wording was consistent with Dr.MacEwan’s pre-meditated Aug.23, 2015 plan to destroy my medical career via defamation, threats, etc (ref 75, 76). 8 Retaliation for Aug.2014 harassment complaint: Dr.MacEwan conspiring with Quinn West to destroy my ‘medical career via harassment and coercion of staff, and soliciting fraudulent complaints (Aug.2015 — Dec.2015). a) Harassment and coercion of nuc med technologist Brittany Sammann Aug.28, 2015 In his Aug.28, 2015 incident report, Quinn West hid the fact that the initiating factor to Aug.18, 2015 events was that Dr. MacEwan was scheduled to provide patient care but was absent from 12-2pm and this caused chaos among the imaging technologists who needed him to review imaging studies. | was on therapy work duties and the imaging technologists were interrupting my therapy work, but | was happy to help them. Nevertheless, they remained upset as a result of Dr.MacEwan's absence. Dr.MacEwan and Quinn West twisted the facts in this case, and did everything to try to blame me for the techs being upset. In the subsequent days, both Quinn West and Dr.MacEwan harassed and coerced two nuclear medicine techs, Brittany Sammann and Joanne Snydmiller into filing fraudulent formal complaints against me, which they both refused to do. | witnessed as Dr.MacEwan dragged Brittany Sammann into his office on the morning of Aug.28, 2015 and closed the door just prior to harassing her. Brittany was so stressed, so fearful and so traumatized by the incident that she threatened to quit her job as a result of Quinn West’s and Dr.MacEwan’s harassment. She sent me 9 vMoolrb) ° ¢) texts that same morning, after leaving Dr.MacEwan's office, documenting her horrific experience (ref 76). She came to my office one week later and was still very traumatized by the experience (ref 79). Allegedly, Dr.MacEwan wouldn't take no for an answer despite Britney's repeated refusals, and Dr.MacEwan even offered Brittany a chance to file a formal complaint against me anonymously (ref 79), then proceeded to use profanities in front of her. Harassment and coercion of Joanne Snydmiller Aug.2015 Itsubsequently came to my attention that nuclear medicine technologist Joanne Snydmiller was also being harassed and coerced into filing a fraudulent complaint against me. She also refused, stating: “! don’t want to get in the middle of a war between Dr. MacEwan and Dr.Makis”. The technologist, (Clayton Kozak) who related this to me in Dec.2035, stated that it was common knowledge among all nuclear medicine technologists, that Quinn West and Dr.MacEwan were actively soliciting formal ‘complaints against me among the nuclear medicine support staff from August 2015 until December 2015, when they finally succeeded with Brent Schaitel and Ms.Sarah Rayner. Incident report by Quinn West containing false and defamatory statements (Aug.28, 2015) It is my understanding that when Quinn West and Dr.MacEwan failed to coerce Brittany Sammann and Joanne Snydmiller into filing fraudulent complaints against me on the morning of Aug.28, 2015, they decided to create an “incident report” which contained false and defamatory statements which they could use at a future time to damage my medical career. | would note that some of these defamatory statements written by Quinn West, would later resurface almost identically in a highly suspicious Dec.3, 2015 complaint that was filed by Brent Schaitel and Sarah Rayner, that became part of a CPSA complaint by Ms.Rayner. Some examples of Quinn West's defamatory statements in the ‘Aug.28, 2015 document include: a. “Ihave asked him not to widely broadcast his emails.” | do no such thing, b. “he does not recognize his part in the interaction’ this was false. | offered to meet with Quinn West several times and to meet with any technologist who was upset. “it was unprofessional and disrespectful” The sign on my door was completely benign. d. “no acceptance of responsibility” this was false, as | accepted responsibility and even offered to apologize to any technologist who was upset, which Quinn West refused, stating “I don’t think your apology would be genuine, so I'd rather you make no apology at all”. Defamation and soliciting fraudulent complaints between Aug.2015 and Dec.2015. On October 7, 2015 | received texts from Brittany Sammann where she said that Dr. MacEwan was ‘making negative comments about me and called me “trouble maker”. When she came to my office she explained that Dr.MacEwan was always saying negative or defamatory things about me to the ‘nuclear medicine staff whenever he was in the department. She said Dr. MacEwan continued soliciting complaints from her. | witnessed one incident in October 2015 where Brittany Sammann was about to enter my office, saw that | was busy with 2 patient chart and noticed Dr.MacEwan ‘coming down the hallway. | raised my head and she stated, “it’s ok, don’t worry, 'l check this study with Dr.MacEwan”. As she began walking toward Dr.MacEwan's office, | overheard Dr.MacEwan say: “oh, Dr.Makis refused to help you? Don’t worry, come here, Ill help you.” | had made no such refusal of patient care but Dr. MacEwan was purposely engaging in defamation against me with staff, to damage or destroy my professional reputation. 10 vMool3)_ Planning for my removal/firing from the CCl Diagnostic Imaging Department Nov.2015 In early Novernber 2025, Dr. MacEwan began assigning my Bone Densitometry Studies (BMD for bone mineral density) to radiologist Dr.Neesha Merchant, who was not qualified to read them (she had no ISCD certification, no BMD training and no experience reporting them), In violation of PSA code of conduct. | had extensive experience reading BMD studies from my Brandon, Manitoba Practice, where | had read thousands of BMD studies. | was the only BMD study reader at CCI outside of Dr.Mact wan. Dr.Merchant came to my office shocked and perplexed and asked me why Dr.MacEwan started assigning her my BMD studies and how she could report them when she had absolutely no experience doing so. | took these BMD studies back and reported them and told her that it made no sense, it was unacceptable by CPSA regulations and that | would speak to Dr.MacEwan about it. | did ask Dr. MacEwan about it in an email, but he refused to provide an answer. itis my belief that Dr.MacEwan was anticipating success in his plot to have me fired and was already preparing replacements to do some of my work. In ate November 2015, Dr.MacEwan blatantly excluded me from the hiring process of a radiologist. | was the only radiologist in the department he excluded from all communications about this new radiology job applicant, and this had never happened before. | had been on several hiring ‘committees before and was instrumental in correcting the recruitment disasters of the department 1 2014 and early 2015, and Dr.MacEwan's exclusion of me in this very important process was highly suspicious. Dr. MacEwan resisted my inclusion very much and even tried to hide a social dinner with the radiology candidate from me. t was only with the intervention of my colleagues who gave me the emails that Dr. MacEwan was hiding from me, and copying Dr. Matthew Parliament on my emails to Dr.MacEwan, that | was able to participate in the hiring process of this radiology candidate. its my belief that Dr. MacEwan was anticipating success in having me fired and thus felt | should not be involved in the hiring process of this radiologist (I have emails pertaining to this which | will submit at alater date). )_Dr.MacEwan conspiring with therapy nurses to file a fraudulent complaint against me on Dec.3, 2015, which became part of a CPSA complaint. ‘On Nov.27, 2025, | sent an email to Ms.Sandra Gordey (Regulatory Affairs, Internal Quality Assurance for Lutetium Clinical Trial) detailing some very concerning incidents that were adversely impacting and jeopardizing patient care under the Lutetium Clinical Trial (ref 83). She thanked me for my email (ref 84) and offered to help. On Dec.3, 2015, a formal complaint was secretly submitted by ‘two therapy nurses and a clerk to Dr. MacEwan and Dr. Matthew Parliament while | was away on conference. When I returned on Dec.7, 2015, Dr.MacEwan was unusually friendly to me and we chatted about the conference, but he made no mention of any complaint. From Dec.7, 2015 to Dec.16, 2015, Dr.MacEwan did not say anything to me about the existence of any complaint, or any ‘concerns whatsoever by therapy nurses or clerks, in violation of AHS Medical Staff By-laws and CPSA Code of Conduct. | believe Dr.MacEwan was plotting to keep the complaint a secret and escalate the ‘complaint to a more serious level, which was done by Ms.Rayner on Dec.23 resulting in a CPSA complaint. | was horrified to finally get a copy of the original Dec.3, 2015 formal complaint from Dr.Parliament on the afternoon of Dec.16, 2015 at 3:45pm in my office. This highly suspicious 1 VM 00 ty) ‘complaint was full of false accusations, and included an identical version of Quinn West’s Aug.28 statements of defamation regarding my “mass sending of emails”. | was falsely accused of abusive ‘communication, public shaming, harassment, creating a toxic environment, ete. none of which had ‘ever taken place. Please note that even more suspicious was the inclusion of a Aug.19, 2015 email of mine which detailed the events of Aug.18, 2015, the same events that Quinn West and Dr.MacEwan tried to use to harass and coerce technologists Brittany Sammann and Joanne Snydmiller into filing fraudulent complaints, which they had refused to do. its my belief that Quinn West and Dr-MacEwan conspired to convince and/or pressure Brent Schaitel and Sarah Rayner into filing the Dec.3, 2015 complaint, which everyone involved kept secret from Dec.7-Dec.16, 2015 in anticipation of a drastic escalation when a 2" CPSA complaint was filed against me by Ms.Rayner on Dec.23, 2015. Please note that Quinn West would submit his false Aug.28, 2015 incident report as a “supporting document” for the CPSA complaint, on Jan.20, 2016. Foreknowledge of my removal/firing and violations of confidentiality of AHS TIA (Triggered Initial Assessment) process. (On Dec.28, 2015, Dr. MacEwan sent emails to Dr.Hudson and Dr.Smerdley stating “Confidential” and that | “will be on administrative leave for an indefinite period of time” (ref 87, 88). r.Hudson approached me about this on Dec.30, 2015 at 8am and was horrified and very stressed and concerned as to what was happening, especially given that he was aware of Dr.Mactwan’s physical assaults, harassment and attempts to destroy my career. | became very frightened and | called Dr.Williams to ask him if he knew what was going on. This terror lasted for about 30 minutes, when Ms.Sandra Plupek and Dr.Wilson Roa approached my office, gave me a copy of a CPSA complaint and told me that a TIA (Triggered initial assessment) had been initiated. | was removed from my office in front of Dr.Hudson who was very traumatized by the incident. itis my belief that Dr.MacEwan's sending of emails to my radiology colleagues prior to my own notification, and their wording, were violations of confidentiality terms of the TIA and violations of AHS Medical Staff Bylaws as well as violations of CPSA Code of Conduct. Itis also my belief that Or. MacEwan gave this information to my colleagues in order to damage my reputation with my colleagues and to intimidate them, as both Dr.Hudson and Dr.Smerdley had supported Dr. MacEwan's removal as director on May 41,2015. |! was subsequently notified by one of my colleagues that during the first week of January 2016, Dr.MacEwan had told several of my radiology colleagues that | was likely not returning to work at the CCI (in violation of the terms of the TIA and AHS Medical Staff By-laws) and Dr.MacEwan specifically asked Dr.Karim Samii if he knew of any nuclear medicine/radiology residents who were looking for jobs and who could take my job at CCI. Dr.MacEwan openly discussing me not returning ‘to work at CCl and seeking my replacement before the TIA panel was even formed and before any TIA witnesses were even questioned, suggests Dr. MacEwan was confident that the two suspicious complaints comprising Ms.Rayner's CPSA complaint would succeed in getting me fired and Dr-MacEwan was likely significantly involved in their creation, wording and submission (please note that Dr-MacEwan has worked for the CPSA before). Please note that the Dec.3, 2015 complaint was very suspiciously addressed to Dr.MacEwan, who has no involvement in any of the therapy work and who has no jurisdiction over such work. According to AHS Medical Staff By-Laws and rules, such a 12 vMooIscomplaint should only have been addressed to either the manager Quinn West, the principal investigator of the study Dr.Sandy McEwan, one of the co-Investigators of the study (Le. Dr.Todd McMullen, Dr.Michael Sawyer or Dr.Don Morrish), or Sandra Gordey (Internal Quality Assurance, Regulator Affairs, Clinical Trials Coordinator). One of the complainants (Brent Schaitel) was intimately familiar with Dr. MacEwan’s abusive history towards me and Dr.MacEwan’s Intent to get me fired, and the decision by the complainants to submit a formal complaint to Dr.MacEwan, who had no involvement in therapy work whatsoever (dated Dec.3, 2015, ref 85) could only have been made in bbad faith and with malicious intent to destroy my medical career, rather than to address any cancer patient related issues. 9, False accusations against other CCI physicians to damage their professional reputation and career b) Dr.Sandy McEwan ~ Dr.Sandy McEwan showed me an email he received from Dr. MacEwan shortly after a June 8, 2015 meeting where Dr.MacEwan’s unilateral rejection of the MITNEC tral was discussed by 5 individuals present (Dr Hudson, Or.S.McEwan, Or.Makis, Or. MacEwan and Quinn West) (ref $6, 61). In this email, Dr. MacEwan accused Dr. Sandy McEwan of personally attacking him during this June 9, 2015 ‘meeting, in order to damage Dr.S.McEwan's professional reputation. As a witness during that meeting, | can state categorically that the discussion was lively but no such personal attack took place. Dr.Hudson also confirmed that no such attack took place. Dr.David Williams — Dr. Williams showed me a letter that Dr.\Macwan submitted to Dr.Parliament that falsely accused Dr.Williams of bullying and other unprofessional conduct. Dr.\MacEwan allegedly did this after physically assaulting Dr. Williams on Nov.26, 2016 (see paragraph 1). 10. Adverse Impacts on work related issues, patient care: ‘a)_Autocratic decisions taken on behalf of group without consulting radiology group Dr.MacEwan often took unilateral decisions on behalf of the radiology group without consulting the radiology group, most commonly in regards to recruitment. As an example, Dr. MacEwan offered a job position to Dr.Kulshrestha for a semi-fellowship nuclear medicine position without consulting the nuclear medicine physicians (ref 28-30). Dr.Bates (CCI radiologist) once noted “recruitment should be done by committee ~ and not as a solitary decision” (ref 33). The autocratic decisions had devastating impact on recruitment into the department (ref 28-33). ‘Another area of autocratic decisions was the refusal to allow people to have protected research time as per their AHS contract provisions (ref 59,60,61,63). The people who requested research time included Dr.Williams, Dr.Hudson and Dr.Bates, all of whom were denied any protected research time in violation of their AHS contract provisions. | was allowed research time two years after starting work at the CCI only after showing extensive research activity that | performed on my ‘own personal time (ref 59,62,63). b) Refusal to provide patient care to therapy patients: ‘The diagnostic Imaging department has approximately 250 neuraendocrine cancer patients of which approximately 160 are undergoing radioisotope therapies on an ongoing basis. Since Aug.2013, | ‘asked Dr.MacEwan several times to help provide some care for these patients as t've documented how overloaded with work | was (ref 01-15, 23-25, 35-40, 42-44). Dr. MacEwan repeatedly refused to provide any patient care for our radioisotope therapy patients, despite the fact that he is fully trained B VMOoléand licensed to do so, and did provide patient care for radioisotope therapy patients prior to 2013 (ref 23). 1 have always considered this refusal a violation of the CPSA code of conduct, however, Dr.MacEwan always insisted that therapy work was my responsibility, regardless of the impact on my imaging work, and regardless of the impact on the department. My overloading of both imaging and therapy work by Dr.MacEwan resulted in conflicts as my office was being used to both see therapy patients and review imaging studies with imaging technologists. This would result ina situation, where an imaging technologist walked into my office without knocking while | was seeing a cancer therapy patient and their family, and the imaging technologist would be upset that | would be unable or unwilling to pull up another patients’ study and review it. | desperately tried to alert Quinn West and Dr.MacEwan to these conflicts between imaging work and therapy work both being done in my office even invoking the term “medico-legal issue” (ref 42-44, 68-69, 72-74) and instead of dealing with these urgent patient related issues, Quinn West and Dr.MacEwan ignored these problems and instead, attempted to use these conflicts to destroy my medical career (specifically using the events of Aug.18, 2015) via defamation and harassment/coercion of staff into filing fraudulent formal complaints (ref 72, 75, 76, 77, 85). Please note that the events of Aug.18, 2015 arose from Dr.MacEwan’s refusal to provide imaging patient care from 12pm-2pm without telling anywhere where he was. Although Dr.MacEwan and Quinn West failed to elicit a formal complaint against me from their harassment/coercion of Brittany Sammann and Joanne Snydmiller, they persisted and kept soliciting complaints from nuclear medicine staff on a regular basis for 4 months until finally succeeding with my therapy nurses Brent Schaitel, Sarah Rayner and Emmanuelle, who were upset at ‘me over a Nov.27, 2015 email | sent (ref 83, 84), where I pointed out some patient care concerns, which were the responsibility of Sandra Gordey and Dr Sandy McEwan, neither of whom had a negative reaction to that Nov.27, 2015 email. €) Failure to provide adequate physician staffing on nuclear medicine: Dr.MacEwan's failure to provide adequate staffing for nuclear medicine is extensively documented ‘and was reported in the August 20, 2014 harassment complaint (ref 11-13). Following the harassment complaint, staffing partially improved, however it remained inadequate, resulting in several incidents where my therapy work came into conflict with my imaging work (ref 43, 44, 68). Please note that Dr.MacEwan used my struggles with his failure of proper nuclear medicine staffing to attack me in his attempts to destroy my medical career with fraudulent complaints. 4) Failure to provide imaging patient services when scheduled: ‘When Dr.MacEwan was scheduled to provide patient care in nuclear medicine he would sometimes disappear from the department for several hours at a time without notifying anyone, which ‘sometimes caused chaos in the department. | documented this with Dr.Matthew Parliament and Dr.Bill Anderson on Sep.2, 2014, however this concern was dismissed by Dr.Parliament who stated “rm sure | don’t need to remind you that Dr.MacEwan Is actually the AHS physician leader of your radiology AHS site, and as such, does require appropriate time in his schedule to execute his ‘administrative responsibilities” (ref 35). tried once again to address the issue (doing administrative work during scheduled patient care time) during a Sep.4, 2014 meeting but was unsuccessful as Dr.MacEwan removed it from the agenda (ref 36-38). “ VMoolFItis notable that Dr. MacEwan was absent on Aug.18, 2015 from 12-2pm and his failure to provide scheduled patient care resulted in chaos where I had to deal with both imaging and therapy work simultaneously with imaging techs interrupting my therapy patient work. Unfortunately, Dr.MacEwan used this Aug.18, 2015 chaos caused by hs absence in his attempt to destroy my career by harassing and coercing Brittany Sammann and Joanne Snydmiler into filing fraudulent complaints against me, These efforts failed and upon feiling, Quinn West documented the Aug.18 events in a ‘Aug.28 incident report which covered-up Dr. MacEwan's absence as the cause of the departmental chaos, and used it instead to attack me, to threaten me and to damage my professional reputation, DrMactwan and Quinn West most likely worked closely wth Brent Schaltel and Sarah Rayner to include the Aug.18, 2015 events in their highly suspicious CPSA Dec.3, 2015 complaint (ref 85) and Quinn West submitted his Aug.28, 2015 incident report tothe TIA investigation panel on Jan.20, 2016 ina pre-meditated attempt to destroy my career and make good on his two threats he made against me on Aug 21, 2015 and Dec.18, 2025, to get me fired, ) interfering with patient care on clinical trials: Dr-MacEwan harassed Dr.Buteau from 2013-2013 and me from 2013-2014 to spend as lite time as possible wth Clinical Trial patients, in violation of Health Canada regulations (ref 24). On July 28, 2014 Ms Sandra Gordey sent a cautionary email that Health Canada regulations should not be Violated by rushing the time spent with patients (ef 24). Dr. MacEwan’s harassment only stopped when I led my Aug.20, 2014 harassment complaint agains him (ref 09,11, 15, 24,25). 4). lying to Cct staff about work elated issues. Dr.MacEwan has lied to his colleagues numerous times about work related issues. Specific examples include: 4. Lying about providing more PET/CT imaging support through DrHudson during uly 2014- ‘Aug.2014, When | attempted to implement Dr.MacEwan’s promise to provide more physician support to nuclear medicine, via an email to Sharon Gregg on Aug.11, 2014 at 8:26pm (ref 14), Dr-Mactwan promptly threatened my job on Aug.11, 2014 at 9:05am (ref 15) and rescinded his promise to provide better PET/CT imaging support (re 04,08, 10-15) 2. Lying about his personal work limit of reading ne more than 9 PETs per day, explaining that only a total of9 studies were booked on those days (Sep.29, 2014, 11:08am, ref 40), when in reality there were often more than 9 PETs booked but Or. MacEwan would leave that work to be done by Dr-Hudson or Dr.Makis In excess of our scheduled work, resulting in both of us being overworked. 3._ Lying in a May 12, 2015 12:05pm email regarding missing $300,000 of locum funds that “you were part of the discussion back in January where it was decided by the group not to pursue external locums" (ref 50). No such decision was ever made by the radiology group. The discussion was open ended with only 2 out of 10 radiologists openly opposing locums and others being neutral or in support oflocums. 4. Lying during an April 30, 2015 4pm radiologist monthly meeting where Dr. MacEwan stated: “historically, no one has ever had protected research time inthis department” which was ale as both Dr. FA Buteau and Dr.Ernst Postema had protected research times prior to 2013, This was cone ofr: MacEwan’s efforts to deny me research time in violation of my AHS contract provisions. 15 vMO0I85. Lying during a June 9, 2015 meeting involving Or. Makis, Or.McEwan, Or.Hudson, Dr. MacEwan and Quinn West regarding the denial of a MITNEC research trial. During the meeting, Dr.MacEwan stated that he had a meeting with Dr.Hudson and myself and that the three of us agreed to reject the MITNEC trial. No such meeting ever took place and both Dr. Hudson and | confirmed that such a meeting never took place and no such decision was ever discussed or reached, 8) Missing/forfeited physician salary/locum funds (~ $300,000) and refusal to provide locum services during radiologist shortage, putting severe strain on patient care. Several CCI Radiologists were in agreement that locums were an important option to utilize during times of radiologist shortage. This included Dr.David Williams, Or.Xi Wang (ref 30), Dr. Susan Bates (ref 31), Dr. Barb Campbell (ref 32) and Dr.£mmanuel Hudson. During a severe (two) radiologist shortage in late 2014 and early 2015, a January 2015 meeting was held where locums were discussed. Although only 2 of the 8 radiologists present opposed locum work, there was no vote or decision taken. Instead, Dr. MacEwan made the unilateral decision, without the radiology group's knowledge, to not provide locum support. This placed tremendous strain on the radiologists to absorb the work of two missing radiologists with unnecessary strain placed on patient care, increasing the potential for medical errors in imaging reports. By May 2015, discussion of locum funds came up again in a monthly meeting with several radiologists asking about using the pool of available locum funds, which by that point would have totaled between $300,000 and $470,000 (due to the shortage of 2 physicians and their salaries not being utilized or paid out from Oct.2014 to May 2015). Dr.Ron Hennig, a former Director of the CC! Diagnostic Im department stated that these funds should be available (as they allegedly are in all other CCI departments), and that these funds should roll over into the next fiscal year. Dr.MacEwan however, insisted that these funds were “gone” at the end of AHS fiscal year ending March 31, 2015. A committee of 3 radiologists {Dr.Makis, Dr. Williams, Dr.Hudson) was formed to investigate the missing physician salary/locum funds (ref 53, 54), however Dr.MacEwan refused to provide any answers and Dr.Parliament declined to provide any financial documents that would address the issue (ref 57). These funds remain unaccounted for and their disappearance remains unexplained. 11. legal reporting by Dr.MacEwan of therapy work studies performed by Dr.Makis: ‘Since the April 29, 2014 initiation of the Lutetium Clinical Trial (LUT-001) approved by Health Canada, Dr.MacEwan has illegally reported hundreds of Lutetium Therapy studies that were performed mostly by me, or occasionally by Dr.Sandy McEwan. These therapy reports state the radioisotope dose that a patient was administered and any adverse events that the patient may have experienced during administration. It is my understanding that Dr. MacEwan reported these studies in violation of Health Canada regulations, which only allow a physician to perform work on the Lutetium Clinical Trial, as a physician, if you are either a co- investigator or principal investigator, as per documents SP-GEN-006.5 and RF-GEN-006 (ref 80, 81), overseen by Ms.Sandra Gordey, Regulatory Affairs, Internal Quality Assurance and Clinical Trials Coordinator. Please note that | am 2 co-investigator on the Lutetium Clinical Trial and | am authorized by Health Canada to report these studies, Dr.MacEwan is not an investigator on the Clinical Trial and he is not authorized by Health Canada to perform any work on the Lutetium Clinical Trial. Furthermore, Dr.MacEwan has not participated in the 16 VM 0019patient care of any of the cancer patients who received radioisotope (lutetium) therapy and whose therapy studies he has reported, and Dr.MacEwan would not be able to properly document any patient adverse effects or adverse reactions on his reports. Please note that Dr.MacEwan has reported studies of patients ‘whose treatment | had overseen and whose treatments | was on-call for. lam deeply concerned that r.MacEwan’s reporting of my therapy work studies isa violation of CPSA Codes of conduct. had several discussions about this issue with Dr.Hudson who has not reported these cases to my knowledge, as he is also not an investigator on the trial and is not authorized to report them. Dr.David Wiliams performed an unofficial audit in December 2015 and found that therapy work reports comprised up to 10% of Dr. MacEwan’s total reported radiology work. | wll note that these reports are falrly quick to perform and Dr.MacEwan has likely reported these therapy studies for the purposes of artificially inflating his productivity numbers at a minimal time cost. | would request expert opinion on this highly sensitive issue. CONCLUSION: Since starting to work at the Cross Cancer Institute in August 2013, | have read 2500 PET/CTs, more than any other radiologist in the province of Alberta during this time, and I had 1500 patient visits and provided more radioisotope cancer treatments than any other physician in Canada. | have also published 36 peer-reviewed medical papers in collaboration with staff from numerous departments within the Cross Cancer institute and University of ‘Alberta Hospital. | was loved by my patients, who numbered up to 250 by December 2015, and | was well liked and respected by my colleagues. For all my efforts, | was abused, harassed, threatened and targeted for retaliation by Dr. MacEwan (and his [AHS Director partner Quinn West), both of whom finally succeeded to destroy my medical career and medical practice at the CCI in December 2015, after embarking on an extensive pre-meditated 6-month effort to get me fired by any means possible, starting in July 2015, as Dr. MacEwan confessed in his Aug.23, 2015 email to senior AHS Directors Dr. Matthew Parliament and Dr.Bill Anderson. As a result of Dr.MacEwan’s retaliatory actions, which constitute serious violations of AHS Medical Staff By-laws, | have been removed from my practice for 5 months now. | ‘miss my patients and | have grave concerns regarding their care. have witnessed many of my staff get harassed and abused. | have seen my colleagues resign their jobs as a result. | have experienced a complete failure of the AHS Complaint system to investigate this abuse, despite a detailed harassment compiaint filed with Dr.David Mador on Aug.20, 2014. 1 have seen the AHS Complaint system fall to protect me and protect my CC! staff from re-harassment and retaliation, both of which are severe violations of ‘AHS Medical Staff By-laws. | fear for my CCI staff's safety, as they are forced to work every day at the Cross Cancer Institute under unacceptable conditions, with absolutely no protection. Dr. MacEwan has faced absolutely no ‘consequences for any of his abusive actions, and following the Aug.2014 harassment complaint and lack of any ‘consequences for Dr.MacEwan, his abusive behavior has only worsened with the two alleged physical assaults ‘occurring only very recentiy. wv vm 0c20‘The stress that my wife and | have suffered as a result of these horrific work-related experiences in Albert indescribable. Severe damage has been inflicted on our health and our emotional and mental states, from which we may never recover. 1am asking for a fair, honest, and thorough investigation into these matters by an impartial investigative body, preferably a trustworthy independent third party who will have no conflicts of interest in this matter. Thank you, liam Makis MD, FRCPC VM0o2)APPENDIX: Supporting Documents #__ [MM/DD/YY | Time | Description ‘pp 1,__| 12/03/2013 | 11:56 | Email from Makis to MacEwan, Hudson, re: workloads 1 2.__| 12/12/2013 | 5:50pm _| Email from Makis to Simmons, re: workloads 1 3,__| 02/24/2014 | 9:12am_| Email btw Makis and MacEwan re: workloads, research 2 ‘4 [07/10/2014 | 10:05am | Email btw Makis and MacEwan, re: staffing 1 5.__| 07/17/2014 | 10:34am | Email btw Makis, Gordey, McEwan, re: workloads 1 6.__[ 07/18/2014 | 12:13pm | Email btw Makis, MacEwan, Hudson re:workloads 1 7.__[ 07/24/2014 | 8:44am_| Jul.23, 2014 Complaint to Quinn West re: workloads, staffing | 6 8.__ [07/25/2014 | 11:53am | Email btw Makis, West, etc. re: workloads, staffing 2 9. | 07/29/2014 | 8:41am _| Emall btw Makis, Gordey, MacEwan, etc. re: patient care time | 4 10. | 07/31/2014 | 10:04am | Email btw Makis, West re: staffing 1 11. | 08/06/2014 ‘Documentation of 08/06/2014 incident with MacEwan 1 32. | 08/08/2014 Email from Makis re: poor management impacting patient care | 2 13._ | 08/11/2014 Email btw Makis and Beattie, Documentation of Aug.6 2 24. | 08/11/2014 Email btw Makis, Gregg, re: scheduling 1 15._ | 08/11/2014 Email btw MacEwan and Makis, re: job threat 2 16._| 08/11/2014 Receipt from itunes, voice recording application, re: harassment _| 2 27. | 08/11/2014 Email btw Makis, Salima, re: job threat 3 18. | 08/12/2014 Email btw Makis and Parliament, re: harassment 1 19._ | 08/12/2014 ‘Transcript of audio recording of meeting Makis and MacEwan | 1 20. | 08/12/2014 Email from Makis to Parliament 1 21. | 08/13/2014 “Texts btw Makis and Salima Beattie re: Aug.12 harassment 1 22. | 08/13/2014 Email btw Makis and MacEwan re: Aug.12 harassment 1 23. | 08/18/2014 Email btw Makis and MacEwan re: workload 2 24._| 08/19/2014 Email from Makis to MacEwan re: workload, patient care time | 4 25._ | 08/20/2014 Formal complaint to Dr.Parliament, Dr.Mador 8 26.__| 08/20/2014 Nuclear Medicine Audit (included in Aug.20 formal complaint) __| 6 27._ | 08/22/2014 Letter from Dr.David Mador to Makis 1 28.__| 08/29/2014 Email from Makis to Radiologists re: candidate Kulshrestha 3 29._ | 08/29/2014 Email from Makis to Radiologists re: CCI recruitment 3 30. | 08/29/2014 | Email btw Xi Wang to Makis re: candidate Kulshrestha, locums | 2 31._| 08/29/2014 Email from Bates to Makis re: recruitment, locums. 1 32.__| 08/29/2014 Email from Campbell to Makis re: recruitment 1 33._ | 08/29/2014 Email from Bates to Radiologists re: recruitment a 34. | 09/02/2014 Email between Makis and MacEwan re: recruitment 6 35.__| 09/02/2014 Emails btw Makis and Parliament re: MacEwan admin time 2 36.__| 09/03/2014 Email from Makis to radiology group re: physician meeting 1 37._ | 09/04/2014 Email from Makis to radiology group: re: staffing 9 38.__| 09/04/2014 Minutes of Physician meeting 3 39.__| 09/09/2014 Emails btw Makis, MacEwan and Hudson re: MD staffing 2 40._ | 09/29/2014 Emails btw Makis, MacEwan, Parliament, Anderson 5 41.__| 03/11/2015 Email from MacEwan to Wong 1 42. | 03/16/2015 Email from Makis to therapy team 2 43.__| 03/17/2015 Email btw Makls, MacEwan, Helps re: reviewing studies 2 ‘44. | 04/09/2015 Emall from Makis to DI 1 45.__| 04/30/2015 Email btw Makis, MacEwan, Williams 3 ‘46. [04/30/2015 Email from Makis to Williams, letter to Matt Parliament 2 vq 0022‘47._[ 05/04/2015 Letter from Williams/Radiologists to Makis 2 48._ [05/04/2015 ‘Summary/minutes of Meeting of 5 radiologists with MacEwan | 1 ‘49._ | 05/08/2015 Email btw Makis and MacEwan 7 1 50._| 05/12/2015 Email btw Makis and MacEwan re: locum funds 3 S1.__[ 05/12/2015 Email btw Makis, Bates, Williams re: replacing director 2 '52.__| 05/12/2015 Email btw Makis, MacEwan re: locus 5 53,_| 05/19/2015 Email btw Makis, Henschel re: financials review 2 54. | 05/19/2015 Email string between Makis, MacEwan re: MD renumeration 4 55. | 05/21/2015 ‘01 Physician Monthly Meeting transcript 4 '56._ | 05/22/2015 Email btw Makis, MacEwan, McEwan, Haji 2 '57._| 05/26/2015 Email btw Makis, Parliament re: missing locurn funds 5 58._ | 05/26/2015 Email btw Makis, MacEwan re: missing locum funds 2 59._ [05/29/2015 Email from Makis to radiologists: research proposal 3 60. | 06/02/2015 Email btw Makis, Bates re: research at CCI 2 61._ | 06/12/2015 Email btw Makis, MacEwan: research proposal 6 62. [06/25/2015 (01 Physician Monthly Meeting Minutes 1 63._ | 06/25/2015 Research Proposal submitted at Monthly Meeting 5 64. [07/23/2015 | 3:55pm _| Email from MacEwan to Makis re: CPSA. 1 65. | 07/27/2015 | 10:11am | Emall btw MacEwan and Makis re: CPSA 1 66. | 08/12/2015 | 3:20pm _| Emall from MacEwan to Makis re: gift fund 1 ‘67._| 08/13/2015 | 9:22am _| Email btw MacEwan and Makis re: invoices 2 68._ | 08/18/2015 Documentation: incident with Joanne Snydmilier 1 69. | 08/19/2015 | &:18am_| Email from Makis to West, Helps 2 70._| 08/19/2015 | 10:11am | Email btw Makis, MacEwan, Bates re: Imaging mistakes 3 71.__[ 08/19/2015 | 10:56am | Email btw Makis, MacEwan, re: imaging mistakes 2 72._ | 08/19/2015 Email btw Makis, West: re: West insults 3 73._[ 08/19/2015 | 3:26pm _| Email from Makis to MacEwan re: work issues 1 74. | 08/20/2015 | 12:51pm | Email btw Makis, West, MacEwan 3 75._| 08/23/2015 | 4:28pm _| Emall from MacEwan to Parliament, West, Anderson 2 76. | 08/28/2015 | 10:46am | Texts from Brittany Sammann 3 77._[ 08/28/2015 | 2:14pm_| Email from West to MacEwan 3 78._ | 08/31/2015 | 2:45pm _| Emall from Makis to MacEwan 1 79. | 09/03/2015 | 2:02pm | Documentation of Conversation with Brittany Sammann 1 80. | 09/16/2015 ‘SP-GEN-006.5 LUT-001 Clinical Trial 4 ‘81._| 09/16/2015 RF-GEN-006-3.0 LUT-001 Clinical Trial 3 82. | 10/07/2015 | 3:15pm_| Texts from Brittany Sammann a 83.__| 11/27/2015 [1:26pm _| Emall from Makis to therapy team 2 84._ [31/27/2015 | 3:22pm_| Email from Gordey to Makis 1 ‘85. | 12/03/2015 Formal Complaint from Therapy nurses to Macewan, Parliament _| 8 86. | 12/18/2015 | 13:34am | Email from Makis to Froese, West re: failure of nursing support _| 2 87._ [12/29/2015 _[ 1:53pm _| Email from MacEwan to Hudson 1 38.__| 12/29/2015 Email from MacEwan to Smerdley 1 89. | 05/30/2016 | 3:43pm_| Email btw Makis and Rene Rebeaud COO for NA, Hermes Med Sol_| 2 90. [06/01/2016 Email btw Makis and Prideaux 1 vm0023College of Physicians & Surgeons of Alberta Ser the public by aiding the medial profession. —etered ee PERSONAL AND CONFIDENTIAL —Vilien Th rs be July 8.2016 ‘Syom before ms Dr. Viliam Makis, a4 AE delivered via Courier 4009 MacTageart Dr _ Edmonton AB TER 033 7 Sas ‘mand for Alberta ROBERTA ALL ISON BITNER Dear Dr. Makis: RE: File No. 160350.1.1 ‘Complaint: Dr. Robert MacEwan I reviewed your June 2, 2016 letter of complaint, noting your concerns about Dr. MacEwan. Your ‘concerns centre on the “professional conduct” of Dr. MacEwan. Please note that throughout your Complaint, Mr. Quinn West is also presented as a respondent. As this individual is not a regulated ‘member of our College, I make no commentary regarding his alleged actions or communications. Summary of Complaint ‘Your complaint consists of several parts, which I identify in the sequence in which they have been presented. 1) You have alleged that another radiologist (Dr. Williams) at the Cross Cancer Institute had complained ofa physical assault at the hands of Dr. MacEwan; furthermore, a radiology nurse (Ms. Halldorson) was also assaulted by Dr. MacEwan. Neither of these instances were witnessed by you. Subsequent to this, you suggested to your radiology colleague that a report should be made to Dr. Matthew Parliament. 2) You have alleged that Dr. MacEwan was verbally abusive towards another radiologist (Dr. Buteau) while the latter was in training in Edmonton and subsequently attending at the Cross Cancer Institute a staff radiologist. You furthermore witnessed what you believe to be verbal and other harassment of other individuals working in the department; some of this information was subsequently sent to Dr. Parliament and Dr. David Mador. You are not certain that any formal discipline was applied to Dr. ‘MacEwan as a consequence of your letter to the Edmonton Zone Medical Director. 3). Yow allege that you have been the subject of harassment by Dr. MacEwan, which has taken the form of excess workload expectations, a refusal to change the scheduling of other radiologists to support ‘your work and an implied refusal to allow you to speak to other radiologists about patient related issues. This includes commentary by Dr. MacEwan that working at the Cross Cancer Institute is a “privilege.” You subsequently had a meeting with Dr. Parliament and Dr. Anderson in an attempt to follow Dr. Mador’s advice regat informal resolution of this matter. You expressed dissatisfaction with this outcome. 4) You allege that a variety of reasons have been presented to Dr. Parliament which support the removal of Dr, MacEwan from his role as Director of Diagnostic Imaging at the Cross Cancer Institute. It is ExmerT & vMoo24 2700 10020 '20Street NW Edmonton Alberts Canada 15J0N3 P 7804234762 F 7004249617Dr. Viliam Makis 2 July 8, 2016 clear that there is an expectation that Dr. MacEwan would not, himself, be responsible for removing himself from this position, but rather it should be the responsibility of Dr. Parliament. 5) You allege that, in violation of your contractual agreement with Alberta Health Services, you have not been given protected research time as per your expectation. You purport that Dr. MacEwan’s understanding of the history of same within the department is incorrect and that it is evident that both Dr. MacEwan and Mr. Quinn West have a different interpretation of your contract. 6) Youallege that Dr. MacEwan has acted without CPSA authority in reviewing imaging studies reported by you (your reference 64-65). You further noted additional commentary by Dr. MacEwan regarding other studies performed by you with the interpretation tha damage on your medical career. You fee! that this has since stopped since you were asked to provide an opinion on a PET scan originally read by Dr. MacEwan. 7) Youallege that Dr. MacEwan was actively defaming you in an attempt to find cause for your removal from the Department at the Cross Cancer Institute. 8) You allege further harassment of members of Department technical staff by Dr. MacEwan; this. includes the filing of “fraudulent” complaints against you. There is further suggestion of Dr. MacEwan making negative comments about you with other department staff, Dr. MacEwan ing bone mineral densitometry studies to another radiologist and Dr. MacEwan violating confidentiality in the context of a pending Triggered Initial Assessment process under AHS Medical Staff Bylaws. It is noted that, as part of this latter concern, Dr. MacEwan reportedly informed several radiology colleagues of your pending absence from the Department. 9) You allege further false accusations against Drs. Sandy McEwan and David Williams by Dr. MacEwan. 10) You allege a) decision-making by Dr. MacEwan was often done on behalf of the radiology group without consultation with other radiologists, b) Dr. MacEwan declining to provide assistance in clinical care during periods of alleged overwork, c) Dr. MacEwan failing to provide for adequate physician staffing in nuclear medicine, d) Dr. MacEwan failing to provide assistance with diagnostic imaging review, e) Dr. MacEwan interfering in clinical trials, f) Dr. MacEwan deliberately lying to staff regarding workplace issues, and g) Dr. MacEwan’s refusal to aid in providing locum services and funding for same. 1) You allege inappropriate reporting by Dr. MacEwan on studies performed under the auspices of the LUT clinical trial approved by Health Canada. In summary, you are asking for a “fair, honest and thorough investigation into these matters by an impartial investigative body, preferably a trustworthy independent third-party who will have no conflicts of interest in this matter.” Complaint Process At this point in the complaint process, my role is to determine if there is sufficient evidence that Dr. ‘MacEwan engaged in unprofessional conduct to warrant an investigation into his conduct. The term “unprofessional conduct” is defined by the Health Professions Act: In this particular scenario, I have considered whether Dr. MacEwan: 1) displayed a lack of knowledge of or lack of skill or judgment in the ve o0zsDr. Viliam Makis 3 July 8, 2016 provision of professional health services; 2) contravened the College's Code of Conduct or Standards of Practice; or 3) harmed the integrity of the profession. Analysis With regards to the concem over physical assault allegations, please note that the College is not the appropriate venue for the investigation of such a matter; rather, law enforcement agencies have the requisite skill and resources to provide a review of potentially criminal matters. The individuals who are reported to be victims of same should be advised to approach Edmonton Police Service with their If Dr. Buteau has, in fact, been the subject of verbal harassment by Dr. MacEwan, or for that matter any other staff at the Cross Cancer Institute, the expectation would be that those individuals would directly approach AHS with their concems. Realizing that you have detailed your own concerns to AHS, itis not clear that any of these other individuals have done so; there is a process available to them under AHS Medical Staff bylaws that would allow for investigation. If AHS, as a result of investigation arising from ‘complaints from the named individuals, found concerns with Dr. MacEwan, the College would review said findings on the request of AHS. Issues relating to the method of commur among staff/with physicians should be a discussion point ‘amongst individuals working in a particular institution. Your allegations speak to a concern that is appropriately directed first towards AHS—noting that you previously did not implement the formal ‘process provided by the Medical Staff bylaws, I would suggest that your most appropriate direction is to implement that formal process. ‘The decision on who occupies a department director position is made by the institution; AHS has sole responsibility for this. The College is not in a position to adjudicate this regardless of the concerns which ‘may have led some staff to ask for Dr. MacEwan’s removal from same, nor is the College in a position to review a leadership model/ method of department leader: ‘A contractual dispute regarding designated research time in the allotment of same is an internal AHS issue. Direction is suggested to discuss directly with AHS Legal as to the interpretation of your contract and the reported protected time for research and academic work. Dr. MacEwan may provide work for the Accreditation Department at the College, under which he would be allowed to review studies by other physicians (whether at the Cross Cancer Institute or other itutions/private clinics). This is allowed for under the rules that govern the accreditation of diagnostic imaging centres inclusive of those located within AHS facilities. With regards to the alleged error made by Dr. MacEwan on the PET scan on August 31, 2015, you have provided no evidence that patient harm ‘occurred due to this (as per your commentary earlier regarding notations on your studies made by Dr. MacEwan). If you feel an AHS rule has been violated in his actions, then review through the AHS process ‘would be the most appropriate action at this time. You have provided no evidence that Dr. MacEwan's concems with your employment are a direct result of, or specifically direct, an active campaign of harassment against you. What you have provided are allegations which are best tested in the context of the AHS structure, or in a civil court proceeding where a sitting judge may make a judgment as to the credibility of one party/story over another. As mentioned, Mr. Quinn West is not a regulated member of this College. VM0026Dr. Viliam Makis 4 July 8, 2016 ‘Your commentary regarding harassment/coercion of technologists Ms. Sammann and Ms. Snydmiller are ‘a mix of hearsay and unsupported evidence, which the College cannot investigate meaningfully. Decisions about the allocation of reporting work within the facility is the purview of AHS. If there are concems about the reporting of particular diagnostic studies that may have impacted patient health, preferable that they be presented individually to the College for review inclusive of patient identifiers, for the purpose of complaint investigation. Decisions regarding the hiring of new radiologists, inclusive of input from other staff radiologists, is wholly within the purview of AHS. ‘You have presented no evidence that Dr. MacEwan “conspired” with anyone as part of a complaint against you at the College. Concems with the confidentiality of a TIA process should be directed to AHS; however, itis not unreasonable for a department head to anticipate an impending absence of a practitioner in an attempt to try and manage workload amongst the remaining individuals. Tam not in possession of any email from Dr. Sandy McEwan regarding commentary from Dr. MacEwan and the latter being “personally [attacked ]” by the former during the meeting. Regardless, the adjudication of email commentary as follow-up to an eyewitness meeting would be difficult if not impossible for any outside party. ‘Administrative decisions made within the department (whether those involving recruitment or research) should be reviewed within the AHS structure that exists; the College has no role in adjudicating these. This would include decisions made by Dr. MacEwan as to how much time he would potentially have to dedicate to clinical care versus administration or any other tasks that he has. Therefore, an inability to participate in patient care in the therapy area does not constitute a de facto violation of the Code of Conduct. The radiology staffing of the nuclear medicine department is an issue for AHS. as is reported absences by Dr. MacEwan when he would be expected to be available for clinical care. The allegation of harassment over clinical trials and the time spent involved in same is not supported by evidence. If Dr. MacEwan reportedly lied about matters such as PET/CT scanning support and denial of a MITNEC research trial, then corollary evidence/support from others with knowledge of same would be expected. Otherwise, in such matters it is impossible to determine with the requisite amount of certainty whose story is correct. With regards to concern regarding missing monies ostensibly for locum coverage, such matters would rest within AHS and their internal financial reporting structure. Certainly, if there is a concern with regards to funds that are “missing,” the expectation would be that this would be brought to the attention of AHS for investigation (forensic or otherwise) if required. A difference of opinion with regards to the decision on locum coverage is not in and of itself evidence of wrongdoing with regards to funding or decision- ‘making. With regards to the LUT-100 tral, it should be noted that Health Canada would be responsible for decision making as far as investigators and those physicians that would report said studies. While you have provided the clinical study responsibility delegation/signature log, there is no documentation provided regarding the alleged reporting of the studies by Dr. MacEwan. If these alleged reports are in fact in violation of trial protocol, then the reporting of same should be to Health Canada who oversees this investigation. If, on their review, there are further concerns with the management ofthis trial and the involvement of Dr. MacEwan, they may choose to contact the College for further review. VM 0027Dr. Viliam Makis 5 July 8, 2016 Decision Based on the information provided in your letter of complaint and my analysis above, I have determined that there is insufficient evidence of unprofessional conduct to move forward with further investigation into Dr. MacEwan’s conduct.” If you find my decision is unreasonable, you may request a review by a Complaint Review Committee. ‘Your request must be in writing, include valid reasons and be sent to the College’s Hearings Director ‘within 30 days of receipt of this letter. Please contact Ms Marilyn Brown, Patient Advocate, at 1-866-969-4955, She can help you understand how the decision to dismiss the complaint was made, and your rights and responsibilities when requesting a review of this decision to the Hearings Director. Please ensure you review the enclosed Dismissed Complaints handout for more information on the review process, including timelines and appropriate reasons. Sincerely, Za ‘achoel Caffaro, MO, COFP, FCP -Asictant Regitrar and Complaints Director Signed by: Raylene Campbell MChre Encl: Complaint Dismissal Handout ce: Dr. Robert MacEwan References * Health Profesions det, RSA 2000, ¢ H-7.s. MPP’) " Regarding all the circumstances and pursuant to section $5(2)() of the HPA vM0028College of Physicians & Surgeons of Alberta ‘Serving the public by guiding the medical profession. This is Exhibit -C. * referred to in the Affidavit ‘August 17, 2016 Vile Matis Personal and Confidential at___. = Dr. Viliam Makis a or Cathe ~ 4009 MacTaggart Drive ode Edmonton, AB T6R 0J3 ROBERTA ALLISON BITNER nO FOR OATS MAN Dear Dr. Makis: emcee cP Dr. Robert MacEwan File 160350.1.1 acknowledge receipt of your request for review and accompanying documentation, dated August 8, 2016. ‘Signature for the delivery of the Complaints Director’s closing letter; delivered via registered mail, was July 8, 2016. Your request for review was received August 9, 2016, which is outside the 30 day timeframe mandated in the Health Professions Act. Therefore, I am denying your request. Yours sincerely, Ber K. E. Reed, MD, CCFP Hearings Director KER/abg ce: Ms. Marilyn Brown, Patient Advocate Phone: 1-866-969-4955 Exaieir ce VvMo0o024 2700 10020 100 Street NW Edmonton Alberta Canada 15JON3 P 780.473.4764 F 780.420.0651 cpsaabcaDr.Villam Makis, MD, FRCPC Department of Diagnostic Imaging Cross Cancer Institute eee Dangers! bd 111560 University Ave NW, ws ee Edmonton, AB, T66 122 Ste aay Tel. (780) 937-8745 ‘Swom before me this_ FF makisw79@yahoo.com Oct.14, 2016 ——Famisabner ‘rane forAbere Dr.Trevor Theman ROBERTA ALLISON BrTNER Registrar Fone provnce ors ne BES OoTONEA fe 2 College of Physicians and Surgeons of Alberta 2700 10020 100 Street NW Edmonton, AB, TSION3 CANADA Re: Professional conduct of Dr.Robert MacEwan MD, FRCPC (Diagnostic Imaging, Cross Cancer Institute). Dear Dr.Theman, | am filing a formal CPSA complaint regarding the professional conduct of Dr.Robert Mac wan, Diagnostic Imaging, Cross Cancer institute (CCI). Please find attached 19 clusters of supporting documentation. | am abiding by the following responsibilities as a physician: © CPSA Standards of Practice: Duty to Report a Colleague 1 ~ A physician must report another physician to the College when the first physician believes, on reasonable grounds, that the conduct of the other physician places patients at risk or is considered unprofessional conduct under the Health Professions Act. ‘© CPSA Standards of Practice: Duty to Report a Colleague 1 ~ Knowledge of physician conduct that should be reported in subsection (1) includes but is not limited to situations in which a physician: suffers from a Physical, cognitive, mental or emotional condition that is negatively impacting the work or is reasonably likely ‘to negatively impact the work of the physician ‘+ CPSA Standards of Practice: Duty to Report a Colleague 2(c) - Knowledge of physician conduct that should be reported in subsection (1) includes but is not limited to situations in which a physician: repeatedly or consistently falls to address his or her behavior in a manner that interferes with the delivery of care to Patients, the ability of other physicians, learners or healthcare workers to provide care to patients, or is not competent in the care of patients. éxHl6(T D vM0030ALLEGATIONS: 1. Workplace Violence - Physical assault of Dr.David Williams (Nov.26, 2015) 2. Sabotage of medical practice of Dr.David Williams following physical assault (Dec.21, 2015) 3, Threats to the medical practice of Dr.David Williams (Dec.2015) 4. Workplace violence - Physical assault of Deb Halldorson (CT Nurse) (Jul.7, 2015) 5. Workplace violence - Verbal assault of Marion Bonilla-Salazar (CT Tech) (Oct.9, 2015) 6. Workplace violence - Harassment of Dr.Viliam Makis and verbal abuse of CCI staff (Aug.2014) 7. Conspiracy to destroy the medical practice of Dr.V.Makis via abuse of the AHS and CPSA complaint systems and harassment of CC! staff (Brittany Sammann, Joanne Snydmiller) (Aug.2015 - May.2016) Conspiracy to provide coordinated, false and defamatory testimony to an AHS Investigation to sabotage and destroy Dr.V.Makis’ medical practice (lan-Mar, 2016) 9. Human Rights Abuses of CCI Staff (2011-2016) 10, Patient care - Illegal radiology reporting of unsupervised cancer patient therapy work DETAILS OF ALLEGATIONS: 1. Workplace Violence - Physical assault of Dr.David Williams (Nov.26, 2015) On Nov.26, 2025, CCI radiologist Dr.David Williams came to my CCI office in the afternoon and appeared to be in shock. He told me that he had just been physically assaulted by Dr.Robert MacEwan during a heated verbal argument in Dr. Williams’ office, when Dr. MacEwan approached Dr.Williams and pushed him forcefully and repeatedly on the shoulder as Dr. Williams was sitting down. Dr. Williams demonstrated on me the manner and force with which Dr.MacEwan touched him and | was pushed backward in my seat. Dr.Williams reported the physical assault to Dr.Matthew Parliament (Senior Medical Director CancerControl Alberta) by email on Nov.26, 2015, and arranged a meeting with him (Ref004). 2. Sabotage of medical practice of Dr.David Williams following physical assault (Dec.21, 2015) Dr.Williams met with Dr.Parliament on Dec.21, 2015 to report Dr.MacEwan’s Nov.26, 2015 physical assault in ‘more detail. At this meeting, Dr.Parliament gave to Dr.Williams a letter dated Dec.9, 2015 that Dr. MacEwan wrote to Dr.Parliament, where Dr.MacEwan was falsely accusing Dr. Williams of bullying, intimidation and. ‘threats: “surprised how irritated and aggressive he was...he commanded in a very threatening tone...his attempt to bully and intimidate me..is unacceptable behavior..diagnostic imaging staff have noticed the increased tension..bullying and intimidation are not acceptable behaviors in the workplace” (Ref002). Or.Williams noted ‘these were all false allegations and had told me that Dr.Karim Samii was a witness to at least some of these events and could corroborate the allegations as false and defamatory. | have known Dr.Williams professionally for three years and Dr.Williams has never been intimidating, bullying or threatening in any way. Dr.MacEwan gave this extremely defamatory letter about Dr. Williams to Dr.Parliament ahead of the Dec.21, 2015 meeting between Dr.Williams and Dr.Parliament, most likely to sabotage and damage Dr.Williams’ professional reputation. When Dr.Williams reported the Nov.26, 2015 physical assault to Or.Parliament on Dec.21, 2015, Dr.Parliament allegedly dismissed the physical assault report, refused to acknowledge it and cited Dr.MacEwan’s Dec.9, 2015 letter as an excuse. Dr-Parliament allegedly refused to take any action on Dr. MacEwan and suggested that if Dr.Williams could not get along with Dr.MacEwan, that maybe Dr. Williams should look for ‘another job. Dr. Williams was extremely demoralized by the physical assault, the threat to ‘damage to his professional reputation caused by Dr.MacEwan’s defamatory Dec.9, 2015 letter. Dr.Williams has 2 vt] 0031routinely talked about abandoning his CCI job, and leaving the province of Alberta as a result and has taken concrete steps toward leaving Alberta. 3. Threats to the medical practice of Dr.David Williams (Dec.2015) Dr-Williams told me that Dr. MacEwan had threatened Dr. Williams’ job several times in late 2015, telling Dr-Williams that he should look for alternative employment. One of these threats were allegedly issued by Dr.MacEwan during the Nov.26, 2015 verbal argument between Dr. MacEwan and Dr.Williams, which resulted in Dr.MacEwan physically assaulting Dr.Williams (Ref002). ‘4. Workplace violence - Physical assault of Deb Halldorson (CT Nurse) (Jul.7, 2015) On July 7, 2035, a radiology nurse was performing a radiology procedure with Dr.MacEwan, when Dr.MacEwan slapped her. Ms.Halldorson reported this incident to AHS Manager Mr.Quinn West in an email titled “slapping”: “I was working in specials this morning with Dr.MacEwan...he slapped my hand. | don’t appreciate this behavior. Its unprofessional and | would appreciate an apology from him. In addition, if this should ever happen. again, | will report his behavior to HR, my union and to the College of Physicians.” (Ref003). This incident was allegedly covered up by Mr.West, who took no action to address it. | was notified of this incident of workplace violence on Nov.26, 2015 by Dr.David Williams, right after Dr.williams himself had been physically assaulted. Dr.Williams, Dr.£.Hudson, and myself had a long conversation that afternoon about the deterioration of Dr.MacEwan’s abusive conduct toward healthcare staffin our department. Dr. MacEwan had issues with a very short temper, outbursts of anger, would routinely engage in intimidation and humiliation of staff, and had no insight into his abusive conduct toward healthcare staff. Futhermore, any reports of workplace violence made by victims to AHS staff manager Mr.Quinn West, were being covered up by Mr.West (Mr. West has received reports of workplace violence committed by Dr. MacEwan toward Deb Halldorson, Marion Bonilla-Salazar and Mary Fitzpatrick — who allegedly filed two reports with Mr.West). Workplace violence - Verbal assault of Marlon Bonilla-Salazar (CT tech) (Oct.9, 2015) On Oct.9, 2015, a radiology technologist (Marlon Bonilla-Salazar) was allegedly the victim of a verbal assault by Dr.MacEwan. A colleague (Deb Halldorson) reported this incident to AHS Director Mr.Quinn West, who covered it up: “Dr.MacEwan was extremely rude and denigrating with Marlon...the tension in the room was pelpable...Dr.Macwan was short, rude and condescending with Marlon. It made It very difficult for Marion to do his job” (Ref003). Dr.Williams told me on Nov.26, 2015, that Marlon cried at work following this incident of verbal abuse. 6. Workplace violence - Harassment of Dr.Villam Makis and verbal abuse of CC! staff (Aug.2014) ‘On Aug.6, 2014, | was cornered in my office by Dr. MacEwan and threatened and harassed regarding my July discussions with Mr.West about patient care issues. | documented this incident with Ms.Salima Haji: “I felt | was being interrogated...he told me | must go to him and him alone with any concerns | have... felt threatened at this, point, as this was delivered as an ultimatum and in an aggressive manner” (Ref004). Dr. Mactwan threatened my Job on Aug.11, 2014 in a 9:05am email, after | continued to document patient care problems in the department. Dr.MacEwan replied directly to my email by saying: “I would ask that everyone remember that it is a privilege to work at the Cross Cancer Institute and it is a privilege to work this this patient population.” (Ref004, p.7). | felt vM 0032this statement was a direct threat against my job at the CCI, as it was a direct reply to my Aug.8, 2014 email where | had documented patient care concerns, despite being threatened by Dr.MacEwan on Aug.6, 2014 to not ‘communicate with other physicians about patient care concerns. Dr.MacEwan was reminding me that it was a privilege for me to work at the CCI, a privilege that could be taken away. | documented this with a colleague, Salima Haji (Beattie) in Aug.11, 2014 emails and asked her to arrange an appointment with Dr.Parliament for me: “salima..| think Rob has just indirectly threatened my job, for speaking up about the department's problems..should there be any further threats to me or acts of aggression, | will ask your help in setting up an ‘appointment with Dr.Parliament for me.«l am very uncomfortable with this situation, Could you please arrange a private meeting for me with Dr.Parliament this week if possible?” (Ref004, p.11). | felt extremely uncomfortable being cornered in my office by Dr.MacEwan who is a tall and imposing figure, and who would routinely enter my office unannounced, would close the door so no one could witness what was going on, and would then engage in intimidation and threats while remaining standing, with me usually sitting. | was afraid of being cornered and harassed by Dr. MacEwan again to the point where | bought a voice recording iphone application on Aug.11, 2014, and turned the recorder on as soon as | arrived at work in the subsequent days to record any further incidents (Ref004, p.9-10). | was cornered by Dr.MacEwan in my office again on Aug.12, 2014, and since | had my voice recording application already running, the conversation was recorded. Dr. MacEwan stated: “I've asked you not to email before, and you continued to emall..", “the emails you're sending are...they are offensive, and they have to stop...and you're upsetting everybody”. | told Dr.MacEwan 12 times that | did not wish to talk to him, but Dr.MacEwan continued to harass me and refused to leave, stating “that's not really an option Will” (Ref004, p15). | was so distressed by this incident that | began locking my door and | asked Quinn West to tell Dr.MacEwan to not talk to me in the near term. That same evening, at approximately Spm after hours with no one else in the department, Dr.MacEwan called my office 3 times and came to my door knocking twice, all of which | didn’t answer out of fear for my physical safety. | documented this incident with a colleague Salima Haji (Ref004, p.17).| felt very threatened and I continued to lock my office door daily (witnessed by Salima Haji) until ‘my meeting with Dr-Parilament on Aug.18, 2014. | wrote to Dr. Parliament on Aug.12, 2014: “I would lke to report an incident where my job at the Cross Cancer Institute was threatened publicly by Dr.Robert MacEwan in ‘an August 11, 2014 email. This is the second incident in the past week that | have felt threatened by Dr.MacEwan and | have asked Salima to arrange a meeting with you to discuss the matter as soon as possible” (Ref004, p-14)."Dr.Rob MacEwan came to my office and requested a discussion on recent events. | told him several times that I did not wish to have any discussions today. He replied “that’s not an option”. He also said “I told you not to write emails” (Ref004, p.16). | filed a harassment complaint with Dr.Parliament and Dr.Mador in writing on Aug.20, 2014 (Ref005). In the Aug.20, 2014 harassment complaint, | reported Dr.MacEwan’s verbally abusive and aggressive conduct toward my staff, specifically: Terence Riauka, Karey McCann, Salima Haji (Beattie), Brittany Sammann, Jennifer Forer, and Joanne Snydmiller, | documented: “these incidents would often involve outbursts of anger and yelling”. | also documented the toxic effect of Dr. MacEwan’s behavior on the department and delivery of Patient care: “three of my technologists: Brittany Sammann, Jennifer Forer and Joanne Snydmiller, refuse to review imaging studies with Dr.Robert MacEwan, apparently due to previous incidents of inappropriate behavior...these technologists insist on reviewing imaging studies with me and have asked me specifically not to. send them to Dr.Robert MacEwan’s office, to review studies.”(Ref005). vm 0033| subsequently had a meeting with Dr.Parliament and Dr.Bill Anderson. When | suggested that Dr.Parliament speak to staff and radiologists of the Diagnostic Imaging Department of CC! about Dr.MacEwan’s, abusive conduct, Dr.Parliament replied tersely: “we will decide who we interview”. Itis my understanding that none of the staff and none of the radiologists were ever interviewed and that no investigation ever took place. | ‘was also told by Dr.Bill Anderson that Dr.MacEwan’s abusive conduct toward healthcare staff would be addressed. itis my understanding that Dr. MacEwan did not face any disciplinary action for this abusive conduct. Neither my staff, nor | received an apology, and no attempts were made by Dr.MacEwan, Dr.Parllament or Dr.Mador to engage in any form of mutual resolution with me or my staff. | would also note that none of my staff were offered any protection from further abuse. Several months after the fling of the Aug.2014 harassment ‘complaint, l came to understand that the complaint was completely covered up. The harassment complaint remains outstanding to this day. Conspiracy to destroy the medical practice of Dr.V.Makis via abuse of the AHS and CPSA complaint systems and harassment of CC! staff (Brittany Sammann, Joanne Snydmiller) (Aug.2015 - May.2016) (On Aug.23, 2015, Dr.MacEwan wrote an email to AHS Directors Quinn West, Dr.Parliament and Dr.Bil ‘Anderson confessing a detailed and premeditated plan to destroy my medical practice and take steps to ensure the non-renewal of my AHS contract. "| think that we (AHS) should strongly consider exploring contract non- renewal and | will begin advocating for same this coming week... 'm convinced that this physician ought to be dismissed from the organization...it’s likely the only way forward” (Ref006). Dr.MacEwan asked Mr.West, Dr.Parliament, and Dr.Anderson to participate in the conspiracy to destroy my medical practice: “Chat this week Quinn. Quinn and | will fill you in on Monday Bill. Matt, | am hopeful that you have time to meet this week (sorry to have sent a work email during your vacation last week)’. In the subsequent months, Mr.West and Dr.Parliament would be active participants in Dr. MacEwan’s conspiracy to destroy my medical practice. In the Aug.23, 2015 email confession, Dr.MacEwan instructed Mr.West to harass and coerce staff into filing written complaints against me, even if they were unwilling, in order to get me fired: “Your technology staff need to write everything down. if they will not, then perhaps you/Scott could meet with each of them individually and record each of her/his experiences with Dr.Makis. 'm convinced that this physician ought to be dismissed from the organization” Dr.MacEwan explained that he wanted me fired in retaliation for my filing of the Aug.2014 harassment complaint against him: ~..divisive nature of his character and his consistently unprofessional conduct, which | will remind you, began on day 366 of his employ” — day 366 is Aug.6, 2014, the first incident of harassment detailed in my harassment complaint of Aug.20, 2014 (Ref005).. Dr-MacEwan then proceeded to engage in extensive defamation of me to Mr.West, Dr.Parliament and Dr.Anderson “any of his contributions...are far overshadowed by the divisive nature of his character...his consistently unprofessional conduct..he’s been unprofessional enough...to be so unprofessional toward the technologists... have never seen anyone behave like this in the profession... feel badly for the technologists who have to work closely with him...1 wouldn’t be surprised if we lose staff because of him..he’s a disgrace to the profession" (Ref006). From Aug.2015 — Dec.2015, | was notified by technologist staff Brittany Sammann and Clayton Kozak that Dr.MacEwan was routinely harassing and coercing staff into filing malicious formal complaints against me, which they refused to do, In August 2015, Dr. MacEwan and Quinn West harassed and coerced at least two nuclear vm 0034medicine technologists, Brittany Sammann and Joanne Snydmiller into fling formal complaints against me, which they both refused to do. | witnessed as Dr. MacEwan dragged Brittany Sammann into his office on the morning of ‘Aug.28, 2015, closed the door, and proceeded to harass her. When she left his office, Brittany was so stressed, so fearful and so traumatized by the incident that she threatened to quit her job as a result of Dr.MacEwan’s harassment. She sent me texts that same morning, after leaving Dr. MacEwan’s office, documenting her horrific experience: “| did not say anything bad or put in a formal complaint or any of that shit but both rob and Quinn talked to me. | do not want to be part of this..please don’t say | told u anything...’d rather not txt and I don’t wanna go in your office while robs here...makes me uncomfortable and feel ike I'm part of the conflict when | want nothing to do with it..! hate being put on the spotl...do not repeatl...if my name comes up again 'm fucking quitting lke seriously..‘m gonna get glared at if! go near you or your office”(Ref007). Brittany came to my office one week later and was still very traumatized and shaken by the experience. Allegedly, Dr.MacEwan wouldn't take no for an answer despite Britney's repeated refusals, and Dr.MacEwan even offered Brittany a chance to file a formal complaint against me anonymously, then proceeded to use profanities in front of her (Ref007). Brittany Sammann confirmed to AHS investigator Mr.Peter Ratcliff on Mar.8, 2016, that Dr.MacEwan was harassing several staff and was trying to coerce them to file formal complaints against me to get me fired. He was also engaging in defamation of me to my staff: “everyone knows that Dr.MacEwan and Dr.Makis don’t get along” “Dr.MacEwan made it clear that there was a problem with Dr.Makis” “he was digging for something...he asked some of the other techs too” “she had no interest in laying a formal complaint against Dr.Makis and told Dr. MacEwan that” (TIA Report, p.30) It subsequently came to my attention that nuclear medicine technologist Joanne Snydmiller was also being harassed and coerced by Dr.MacEwan and Mr.West into filing a malicious complaint against me. She also refused, stating: “I don’t want to get in the middle of a war between Dr.MacEwan and Dr.Makis”. The technologist (Clayton Kozak) who related this to me on Dec.23, 2015, stated that it was common knowledge ‘among all nuclear medicine technologists, that Quinn West and Dr. MacEwan were routinely harassing and coercing staff and soliciting formal complaints against me from August 2015 until December 2015, when they finally succeeded after meeting with two therapy nurses, Brent Schaitel and Ms.Sarah Rayner, on Dec.2, 2015. | documented Clayton Kozak’s revelation to my wife on Dec.23, 2016 (Ref007, p.6). Joanne Snydmiller testified to AHS Investigator Mr.Peter Ratcliff on Mar.8, 2016: “about two weeks after the incident Quinn emailed her and asked her to come to his office. She was asked if she wanted to make a complaint and she declined” (TIA Report p.31) Mr.West was carrying out the Aug.23, 2015 instructions of Dr.MacEwan’s confessed plot to sabotage my ‘medical practice. Mr.West asked Joanne Snydmiller to file a formal complaint, despite the fact that he himself documented : “I considered this to be a minor incident...in his opinion it was not really an incident...he didn’t think that Villam did anything wrong” (Ref008). ‘On October 7, 2015 | received texts from Brittany Sammann stating that Dr. MacEwan was making negative ‘comments about me and called me “trouble maker”. When she came to my office she explained that r.Macwan was always saying negative or defamatory things about me to the nuclear medicine staff whenever hhe was in the department. She said Dr.MacEwan continued soliciting complaints from her. | witnessed one incident in October 2015 where Brittany Sammann was about to enter my office, saw that | was busy with a 6 VMN 903s"patient chart and noticed Dr.Macéwan coming down the hallway. | raised my head and she stated, “it’s ok, don’t worry, Ill check this study with Dr. MacEwan”. As she began walking toward Dr.Macéwan’s office, | overheard Dr.MacEwan say: “oh, Dr.Makis refused to help you? Don’t worry, come here, Illhelp you.” | had made no such refusal of patient care but Dr. MacEwan was purposely engaging in defamation against me with staff, to damage ‘my professional reputation (Ref007,p.5). In late 2015, Dr.MacEwan took several actions as if| was no longer working in the department. On Oct.30 2015, Dr.MacEwan assigned my Bone Mineral Density radiology work to Dr.Neesha Merchant, who had very limited training and no experience in the reading of these studies, which violated CPSA standards. Dr. MacEwan did not ask my permission or even discuss the matter with me. This violated CPSA Code of Ethics 1 (consider first the well-being of the patient). Dr.Merchant panicked and came to my office to ask for help how to report these studies. | told her that it was Inappropriate for Dr.MacEwan to assign her my BMD work and | wrote to Dr.MacEwan that | was not agreeable to this. | reclaimed the BMD studies from Dr.Merchant and reported them (Ref009). (On Nov.6, 2015, | was the only radiologist that Dr. MacEwan excluded from interviews for a new departmental hire. | had never been excluded from this important radiology team process before. On Nov.26, 2015, Dr.MacEwan excluded me from the social dinner with the interviewee. Dr.MacEwan was treating me as if ‘was no longer working in the department (Ref010). On Dec.2, 2015, Dr. MacEwan held a secret meeting with 2 AHS Directors (Mr.West and Dr. Sandy McEwan) and 2 nurses (Brent Schaitel, Sarah Rayner), while | was away on conference leave. Dr. MacEwan testified to AHS Investigator Mr-Peter Ratcliff that these 5 individuals as a group decided to write a complaint that falsely accused me of inflammatory language, public shaming over emails, abusive communication, creating a toxic environment, unrealistic demands, and inability to work within a team setting: © MacEwan: “He was included in the 3 December 2015 letter..and after he, Dr.Sandy McEwan, Sarah and Brent met to discuss the issues they had with Dr.Makis’ Nov.27 emai...it was suggested that ‘they outline thelr concerns around Dr.Makis behavior in a more formal manner and this led to the 3 december letter” (Ref011, TIA Report, p.13, Interview: Jan.14, 2016) © MacEwan: “..Sarah Rayner had come to Quinn West with her and Brent Schaitel’s concerns on 2 december 2015 and it was agreed that the four of them: Quinn, Brent, Sarah and he, meet to discuss the best course of action to deal with the concerns..it was decided at that meeting that Sarah and Brent would co-author a letter and send it to Dr.Parliament which they did.” (Ref011, TIA Report, .32, Interview: Mar.29, 2016) This complaint was malicious in intent and was filed in bad faith for the purpose of sabotaging my medical practice. It was addressed to Dr. MacEwan and Dr.Parllament, the co-conspirators of a plot outlined in Dr-MacEwan’s Aug.23, 2015 email confession, of how to get me fired via soliciting complaints from staff (Ref006). This complaint was investigated by AHS from Dec.29, 2015 until Jun.14, 2016 under a Triggered Initial Assessment, and al Allegations stemming from the Dec.3, 2015 complaint (Allegations 1,2,3) were ruled “unfounded” and were dismissed by Dr.David Mador on July 11, 2016. Conspiracy to provide coordinated, false and defamatory testimony to an AHS Investigation to sabotage and destroy Dr.V.Makis’ medical practice (Jan-Mar, 2016) Dr.MacEwan was interviewed by AHS Investigators on Jan.14, 2016 and Mar.29, 2016. Dr.MacEwan provided false and defamatory testimony against me that was coordinated with his AHS Director co-conspirators: a VM 0036r.Parliament, Dr. McEwan and Mr.West (as well as 2 nurses), for the purpose of sabotaging the AHS Investigation and destroying my medical practice. (On Aug.23, 2015, Dr. MacEwan had confessed in writing to senior AHS Directors that he was planning to execute a long term plan to get me fired and ensure that my AHS contract was not renewed. Dr. MacEwan also had an outstanding harassment complaint that | had filed against him in Aug.2014. As a medical professional, Dr.MacEwan should have known that he was a hostile witness and therefore should have recused himself from providing any testimony about me to an AHS Investigation. a) Dr.MacE wan and Dr.Parliament coordinated false testimonies regarding my Aug.20, 2014 harassment ‘complaint, which they painted as a “leadership” and “workload” issue rather than a complaint regarding Dr.MacEwan’s abuse of healthcare staff, and harassment of and threats against Dr.Makis (Ref005): ‘© MacEwan: “complaining about Dr.MacEwan’s incompetent leadership and his failure to resolve his workflow issues”, (Ref011, TIA Report, p.12) ‘© Parliament: “Dr.Makis approached him with serious concerns about Dr.Rob MacEwan's leadership...perception of unfair workload...” (Ref011, TIA Report, p.17) b) The 5 individuals who met during a secret Dec.2, 2015 meeting and planned the filing of malicious AHS complaints against me (including AHS co-conspirators Dr.MacEwan, Mr.West, Dr.McEwan), coordinated false testimonies regarding my professional communication and interpersonal skils, falsely accusing me of sending “mass emails”, “spam emails” or “inappropriate emails’: © MacEwan: “they have had “countless” discussions around method of communication...that face-to-face discussions were more constructive than the spam emails” (TIA, p.13) © Macéwan: “he could retrieve a history of his email interactions with Dr.Makis that would show 2 pattern of inappropriate and unnecessary communication” (TIA, p.13) ‘© West: “these mass emails were unnecessary...he had spoken to Or.Makis numerous times in the past to not engage in the use of mass emails but he continued to send them..there was no need for him to send emails to people external to the issue..they don’t respond to his spam emails” (TIA, p.14) © McEwan: “that he should send less emails and send those emails to less people...began increasing the number of emails..is pompous as a physician and his manner of communications often reflects that” (TIA, p.19) © Ms.Rayner: “she found his emails to be highly inappropriate, unfair and unnecessary.” (TIA, p37) ‘© MrSchaitel: “email dated 19 Aug..sarah, emma and he are external to the issue and he felt should not have been involved” (TIA, p.8) Overall, the coordinated false testimonies of the co-conspirators accused me of sending mass emails, spam emails, inappropriate emails, or unnecessary emails to people “external to the issue”. ‘As evidence, the co-conspirators (including Or. MacEwan) produced a total of 2 emails that | sent over my 2.5 years at CCI (emails dated Aug.19, 2015 and Nov.27, 2015), which were assessed by AHS investigators as: “An objective read of the content of these emails does not indicate any language that is inflammatory or otherwise inappropriate” (TIA, p.36). No evidence of “mass emails”, “spam emails” or “inappropriate emalls” 8 VM 0037was ever produced. Dr.MacEwan's assertion that he “could” retrieve a history of email interactions that were inappropriate, but didn’t actually produce any, is consistent with defamation and intent to sabotage my ‘medical practice and professional reputation via abuse of an AHS investigation process. In terms of my communication and interpersonal skills, my CCI colleagues, several of whom worked with the 5 co-conspirators: Dr.MacEwan, Mr.West, Dr. McEwan, Ms.Rayner, Mr.Schaitel, have described me as (Ref012): Dr.Nawald Usmant: “I found his communication and interpersonal skills to be good...ls overall pleasant demeanor..| have always found him smiling..and have had very enjoyable interactions with him... have always found him approachable” Dr.Michael Sawyer: “Viliam has excellent interpersonal skills in my opinion..I very much enjoyed working with Viliam” Dr.Todd McMullen: “overall | was never aware of any significant interpersonal issues between team members in our neuroendocrine clinic (i.e. Dr. McEwan, Mr.Schaitel, Ms.Rayner) Dr.Matthew Kuruvilla: “he worked well with his team in a non-confrontational and respectful manner. He had no problems communicating with the rest of the staff and juniors in an effective way.” Dr.Susan Bates: “he was quite approachable...during his tenure at Cross Cancer Institute, Dr.Makis ‘was professional, ethical and accessible...my interactions with Dr.Makis were professional and ‘congenial without exception and | found him to be a welcome colleague”. Dr.Karim Samji: “He has excellent interpersonal and team working skills. Dr.David williams: “he is very approachable... have witnessed his interactions with all members of the department from booking clerks to peers and he has always treated everyone with the greatest courtesy, respect and professionalism. Dr.Winston Ying; “Dr.Makis was professional and considerate...his interactions with the other personnel at the Cross Cancer Institute were relaxed and he seemed to get along well with his peers.” Ms.Sandra Gordey: “I found him to be approachable, available, and enjoyed his sense of humour. ‘Overall, would say that | enjoyed working with him as a colleague” )_ The 5 individuals who met during a secret Dec.2, 2015 meeting and planned the filing of malicious AHS ‘complaints against me (Including AHS co-conspirators Dr..Macewan, Mr.West, Dr.McEWan) conspired to falsely accuse me of using lawyers or lawsuits to “intimidate”, “threaten” or “bully” my colleagues: 4 MacEwan: “he is aware of the current law suit that Dr. Makis launched against former colleagues and the impact that that knowledge has on people addressing the issues they have with him” (TIA, p.13) ‘* West: “when confronted about his behavior he often says, “I've got @ good lawyer” which Intimidates people into leaving him alone” (TIA, p.15) ‘* McEwan: “Dr.Makis has told him he has “damned good lawyers” (TIA, p.21) © Rayner: “he is currently involved in a civil law suit with some previous colleagues..she felt he takes pleasure in describing that law suit..and the impact it is having on his ex-colleagues...he Is very vindictive as is obvious from the previous lawsuit, his visible enjoyment in making people's lives difficult” (TIA, p.7) vM 003g3) ‘* Rayner: “she believes that the bloody Viking face photo and his comment on facebook are a threat to her and Brent that they are the next people to be subjected to this treatment — civil suit or worse.” (TIA, p.7) ‘© Schaitel: “he felt the post to be even more threatening because he has made no secret of the fact that he is currently in the midst of a lawsuit against some previous colleagues” (TIA, p.9) All of these testimonies are false. | have never threatened anyone with lawyers or a lawsuit. In terms of my lawsuit in Manitoba, itis a simple contract dispute regarding work sharing with a partner. | have never told Dr.MacEwan, Mr.West, Dr.McEwan or Ms.Rayner about this legal case. These false accusations that Dr.MacEwan submitted to AHS investigators and coordinated with other co- conspirators, were damaging to my professional reputation, and undermined my medical practice. ‘The 3 AHS co-conspirators who met during a secret Dec.2, 2015 meeting and planned the filing of the malicious AHS complaints, conspired to falsely accuse me of lying about being a highly productive physician, consistent with defamation, in order to undermine my professional reputation within the AHS investigation: © MacEwan: “Other doctors have much bigger patient loads than he does...the average number of patients seen by other doctors on a daily basis varies between 10 to 15. Dr. MacEwan believes Dr-Makis is not overworked as he often claims.” (TIA Report, p.12) West: “He had been complaining about how hard he was working and how busy he was but in reality he wasn’t and other doctors are working harder” (TIA Report, p.15) © McEwan: “Dr.Makis began gaming the system, increasing the number of patients and limiting the number of scans he was reporting” (TIA Report, p.19) Dr.MacEwan's statement to AHS Investigators: “Other doctors have much bigger patient loads than he does...the average number of patients seen by other doctors on a daily basis varies between 10 to 15” was false and defamatory. Clinical Trial therapy patients were seen only by myself or Dr.S.McEwan, who never saw more than 6 Clinical Trial patients in a clinic, which can be confirmed by an audit of Dr.S.McEwan’s Aria physician notes or Aria patient schedule. An emall from therapy nurse Sarah Rayner confirms that a clinic with 6 Clinical Trial patients is “big” (Ref013) and Sandra Gordey (\nternal Quality Assurance, Regulatory Affairs, Clinical Trials Coordinator) can confirm that seeing more than 6 Clinical Trial patients in a clinic would not only be impossible, but would violate Health Canada regulations if attempted. Dr. MacEwan had not seen a single cancer therapy patient since 2013 and had never educated nor informed himself about the department's Clinical Trial and Dr. MacEwan’s statement “patients seen by other doctors on a daily basis varies between 10 to 15” is entirely made up, in order to sabotage my reputation with AHS investigators. ‘On Aug.21, 2016, | reported these defamatory statements to AHS Vice President Dr.David Mador. | also provided to Dr.Mador a list of 1581 patient visits | performed during 2013-2015, far more than any other physician in the department, and 2475 PET/CT imaging studies | reported, far more than any other physician in the department. This evidence can be obtained from Dr.David Mador, to support my allegation that Dr. MacEwan engaged in defamation of me to AHS Investigators in order to undermine my medical practice. 10 VM 003qe) The 5 individuals who met during a secret Dec.2, 2015 meeting and planned the filing of malicious AHS complaints against me (including AHS co-conspirators Dr.MacEwan, Mr.West, Dr.McEwan) conspired to frame me with a TV show photo stolen from my facebook which they claimed I posted after a Dec.10, 2015 staff meeting, to falsely accuse me of being “threatening”, “bullying”, “violent”, “aggressive”, “rude”. © MacEwan: “he was not present for the Dec 10 meeting...but heard that it did not go well, that Dr.Makis was aggressive and condescending” (TIA, p.13) © West: “Quinn was not at the (Dec.10) meeting but heard that Dr.Makis was very rude and condescending..that day or shortly after..Dr.Makis put a photo of a bloody face on his Facebook that was very threatening to the staff..he did not see it but was told of it.” (TIA, p.16) © McEwan: “he was becoming increasingly difficult to work with. this included his behavior during the 10 december meeting..he was advised that the photo of the bloody face went up on Dr.Makis’ facebook page the day after their meeting” (TIA, p.21) ‘+ Ms.Rayner: “on Dec.10 there was a meeting...Dr.Makis was rude and condescending to Sarah, Brent and Emmanuelle...later that day ~ 10 december ~ Dr.Makis posted a photo of a bloody Viking face on his Facebook page..she felt that the photo and comment were directly related to the December 10 meeting and his reaction in the meeting...she believes that the bloody Viking face photo and his comment on facebook are a threat to her and Brent” (TIA, p.7) © MrSchaitel: “there was a meeting...on Dec.10..Dr.Makis was extremely agitated, disrespectful to Brent..that same day, Dr.Makis posted a photo of a bloody Viking face on his Facebook...he took this as a direct threat to him and Sarah” (TIA, p.9) All of these testimonies are false. | was not aggressive, agitated, rude or condescending during the Dec.10, 2015 staff meeting, although | was concerned about patient care issues, specifically the improper scheduling of patients in conflict with the radiology schedule of the imaging work done in the department, and documented this immediately following the meeting (Dec.10, 2015, 1:40pm email) while offering to help Brent and Sarah improve their scheduling of patients (Ref014). Dr. MacEwan was not present at this meeting, however he provided testimony to AHS investigators that | was “aggressive and condescending”, which is consistent with his prior known and confessed malicious intent to destroy my medical practice. The other co-conspirators attempted to link these false accusations (that | was “aggressive, agitated, rude, condescending”) to a photo stolen from my Facebook, claiming that | posted this TV show photo of a “bloody Viking face” after the Dec.10 meeting as a “threat” to them. Unfortunately none of the five ‘co-conspirators noticed the small date stamp below the photo which referred to Tuesday, December 8, 2015 at 12:34am, which exposed the malicious attempt by these 5 individuals (including Dr. MacEwan) to frame me, as all 4 individuals made the same identical mistake of claiming the photo was posted after the Dec.10, 2015 meeting. r.MacEwan’s involvement in this conspiracy, to give false information to AHS investigators claiming that | was “aggressive” severely damaged my medical career, as this particular testimony related to TIA Report “Allegation 5” which was subsequently used by Dr.David Mador as an excuse to prevent me from 1 vm oo4oreturning to work for 9 months, between Jan-Oct.2016. Dr.MacEwan caused extensive damage to my medical practice, and to the care of thousands of patients at the Cross Cancer institute. f) The S individuals who met during a secret Dec.2, 2015 meeting and planned the fling of malicious AHS ‘complaints (including AHS co-conspirators Dr.MacEwan, Mr.West, Dr.McEwan) conspired to request, in ‘an AHS investigation, that | essentially be fired from my job: ‘MacEwan: “He can’t see how Dr.Makis can return to the area given the concerns that have been raised.” (TIA, p.13) ‘© West: “if Dr.Makis returns to the area, Quinn believes he will be looking for at least three staff ‘members: Brent, Sarah and Emmanuelle will not return” (TIA, p.16) ‘McEwan: “if Dr.Makis is returned to the area, Dr.McEwan believes they will all quit ~Sarah, Brent and Emma” (TIA, p.21) © Schaitel: “it would be extremely difficult to work with him if he returned to the workplace” (MIA, p.10) © Ms.Rayner: (TIA, p.7) “if Dr.Makis returns to the unit she said she will not come back and work with him Dr.MacEwan’s request to AHS that | be fired from my job or not be allowed to return to work, is consistent with his confessed plot to sabotage and destroy my medical practice. My colleagues informed me that Dr.MacEwan and Dr.Parliament conspired to hire a nuclear ‘medicine physician to replace me (Dr.Kelly Chiu) in approximately April 2016, while my investigation was ongoing, and installed her in my office on July 15, 2016 — with all my personal items such as medical diplomas and professional books still in my office. My colleagues also informed me that from approximately May 2016, Dr. MacEwan was openly admitting that my AHS contract would not be renewed and that the funds of my AHS contract would be ‘made available to him to hire someone else. My AHS contract was not renewed by Dr. MacEwan's co- conspirator Dr.Parliament only on July 28, 2016 (without any explanation provided), and Dr.MacEwan's foreknowledge of this, is consistent with his active and long term participation in a conspiracy to destroy ‘my medical career at the CCI (Ref015). Human Rights Abuses of CCI Staff (2011-2016) Dr.MacEwan has a long standing history of abusing the human rights of Diagnostic Imaging staff at the cel. Dr-Francois Buteau was a fellow in the Diagnostic Imaging Department at the CCI during 2011-12, and staff during 2012-2013. | worked with Dr.Buteau during August 2013, and | was replacing him as he was leaving Alberta to work in Quebec. In Aug.2013, Dr.Buteau told me that Dr.MacEwan denigrated him by stating several times: “Francois, you don’t have to be anyone's bitch, but if you're going to be someone’s bitch, | prefer you be my bitch”. This was accompanied by verbal abuse that was inflicted on Dr.Buteau throughout his 2 years at CCI. The diagnostic imaging staff would then join the verbal abuse by repeatedly calling Dr.Buteau “Rob's bitch”, This was witnessed by Dr.Terence Riauka, Karey McCann, Salima Haji, Brittany Sammann and myself. | was told by several staff that Dr.MacEwan’s denigrating treatment of Dr.Buteau, contributed to Dr. Buteau leaving his CC! radiology job. 2 vm O04‘My colleagues Karey McCann and Salima Haji (Beattie) warned me repeatedly in Aug-Sep, 2013 of Dr.MacEwan’s abusive behavior toward Dr.Buteau. Dr.Buteau also warned me that | might experience abusive behavior from Dr.MacEwan. It was within these first few weeks of my employment at the CCI that | became aware that | was entering an extremely toxic environment at the CCl as a result of Dr.MacEwan's abusive conduct toward his healthcare colleagues. During my first year, 2013-2024, | witnessed numerous incidents of verbally abusive behavior by Dr.Macéwan directed towards CCI nuclear medicine staff, including Brittany Sammann, Jennifer Forer, Terence Riauka, Karey McCann, Salima Haji(Beattie), Charlotte Krasowski, Joanne Snydmiller, and Vincent Wong. Dr.MacEwan's verbal abuse consisted of any of: yelling, insults, interrogation style questioning, humiliation, intimidation and even the slamming of doors. | documented some of these abuses in my Aug,20, 2014 harassment complaint to Dr.Matthew Parliament and Dr.David Mador, however the harassment complaint was covered up without any investigation performed and without any protection offered to the Victims of Dr. MacEwan’s abusive conduct. No attempt was made by either Dr. MacEwan, Dr.Parliament or Dr.Mador to engage in a mutual resolution with any of the victims of abuse, and the harassment complaint remains outstanding to this day. It is also my understanding that Dr. MacEwan did not face any disciplinary actions (Ref005), In May 2014, | asked Dr.MacEwan for a 1-day leave to be able to take my wife for surgery and support her. Dr.MacEwan denied my request, despite the department being fully staffed (Ref016). As a result, | was unable to provide any emotional support to my wife who had day surgery at Grey Nun’s hospital ‘on May 9, 2014, and after her surgery had to wait by herself for several hours in a pain medication daze and fear, until was able to pick her up from the hospital after work. Medical leaves were denied to other physicians, including Dr.Barbara Campbell and Dr.Emmanuel Hudson, whose wife was diagnosed with cancer in2016. Leaves for family emergencies were also denied unilaterally by Dr. MacEwan. Dr.Edrise Mueller was allegedly denied a short term leave of absence in 2013 to deal with a family crisis. These denials by Dr.MacEwan would cause Dr.Mueller to cry at work on several occasions, as she related these incidents to Dr.Hudson and would cry in his office. Shortly thereafter, Dr.Mueller resigned her job, allegedly at least in part due to Dr.MacEwan’s refusal to provide the needed leave of absence for her to deal with her family crisis (she Is currently providing occasional locum work for CC). This information was related to me by Dr.Hudson and Dr.Williams on Nov.26, 2015, on the same day that Dr.Williams was physically assaulted by Dr.MacEwan. In 2014, Dr.Mary-Ann Johnson had requested some time off in the summer as a transition plan to her retirement and was denied by Dr.MacE wan. This allegedly contributed to Dr.Johnson’s decision to retire early ‘on Dec.15, 2014. Dr.Johnson was one of the most productive radiologists at CCI and her early retirement had a very adverse impact on the department's provision of patient care services. |n 2014, | was told by Dr. Williams and Dr.Hudson that Dr. MacEwan had engaged in verbally abusive ‘and denigrating conduct toward Dr.Marie Smerdley, repeatedly harassing her and insulting her about the radiology services that she was providing, claiming that she was very slow and unproductive. This abusive conduct allegedly spanned several years and had a devastating impact on Dr.Smerdley. | witnessed as Dr.Smerdley refused to participate in any social events of the department staff and rarely participated in departmental meetings. | was advised by Dr.Hudson and Dr. Williams that due to the long term abuse that 2B vm 0042,she suffered, Dr-Smerdley was terrified of Dr. MacEwan and avoided as many social functions and departmental meetings as she could. ‘A female medical resident from Quebec was supposed start a fellowship with us on July 1, 2014. in June 2014, Dr.MacEwan boasted to me that he would force the new female medical resident to work very hard and very iong hours (until 7 or 8pm, Le. 11-12 hours a day), regardless of the fact that she just had a baby. He told me that he had related this to her and laughed about it. The fellow came to Alberta to start her fellowship and promptly resigned her fellowship before working a single day in our department. Dr.MacEwan was verbally abusive and denigrating toward non-diagnostic imaging and non-CC! healthcare workers as well. | witnessed Dr. MacEwan being verbally abusive toward IT staff (Vincent Wong, Viktor Konkov, and Doug Bridgeman. One example includes a Mar 11, 2015 email to Mr.Wong where Dr.MacEwan stated in front of Mr.Wong's colleagues that Mr. Wong should abandon his job until our workstations were fixed ("I thought that Hermes was fixed. Perhaps you should abandon your post downtown until such time as Hermes is working properly”) (Ref017). | also witnessed Dr. MacEwan being, verbally abusive to Mr.Andrew Prideaux, a Hermes application specialist who spent several days in 2014 upgrading our workstations. Mr.Prideaux was apparently so traumatized by the situation, that his boss, Mr.Rene Rebaud (Chief Operating Officer for North America Hermes Medical Solutions) told me during a social dinner at a Canadian Association of Nuclear Medicine Meeting in Halifax, Nova Scotia on April 21, 2016, that Mr.Prideaux still traumatized by the abuse he received from Dr.MacEwan, two years later (Ref018). |lam aware that Deb Halldorson and Mary Fitzpatrick reported Dr.MacEwan's abusive conduct to AHS Director Quinn West, who covered up these reports of abuse toward healthcare staff. 11am also aware of three reports of Dr.MacEwan’s abusive conduct to Dr.Parliament, who also covered-up all three reports without taking any action to address Dr. MacEwan’s abusive conduct, or protect any of the victims of Dr.MacEwan’s abuse. This includes my Aug.2014 harassment complaint, an Apr.29, 2015 report of Dr.MacEwan’s human rights abuses to Dr.Parliament by 7 radiologists, and Dr.Williams’ Nov.26, 2015 report of physical assault. In Apr.29, 2025, 7 radiologists submitted a formal report to Dr.Parliament asking Or. MacEwan to be removed as Director of Diagnostic imaging for workplace violence and human rights abuses. The Apr.29, 2015 letter describes: ‘+ "Frayed and damaged work relationships with physicians, and referring physicians and radiology colleagues in the community. ‘© “increasingly difficult working environment for allied and non-allied health professionals within the department” “autocratic and rigid decisions in areas that directly affecting team members such as time off, leaves, daily work hours, etc.” “members are routinely denied ability to attend medical appointments/family matters or personal crisis/events” in numerous instances you have made comments that have no place in a professional work environment” The report also described the effect of Dr. MacEwan’'s abusive conduct on the department's morale: “These issues have seriously degraded morale in all areas of the department and are incompatible with the Department's future”. | lent my support to the radiology team’s request to address Dr.MacEwan’s abusive ‘conduct and ask for a new Director (Ref018). 4 VM 0043| received another letter from a radiology colleague that had been composed by several CCI radiologists which had further comments regarding Dr. MacEwan’ abusive conduct: ‘© “demoralizing micromanagement of physician workload” © “allied health professionals have voiced complaints regarding your interactions/treatment of them” ‘© “aggressive wording of outside case reviews fractures relations with other AHS radiologists” “instances in which you have expressed perceived shortcomings of one individual in the department to another member of the department” Further toxic effects on the healthcare staff were documented: ‘© “concerns about your management style and its devastating effect on our group..we believe the group will dissolve in the near future...ack of confidence in your continuing leadership..our group will nt survive under this autocratic, rigid and inconsistent leadership...we are having continued problems in recruitment and retention under the current regime” (Ref019) Dr.Aalo Duha made an appointment with Dr. Parliament on May 1, 2015 to make a formal request for Dr.MacEwan’s removal as Director of Diagnostic Imaging. It is my understanding that 5 radiologists came to Dr. Parliament's office (Dr.Williams, Dr.Susan Bates, Dr.Aalo Duha, Dr.Barb Campbell, Dr.Emmanuel Hudson) along with letters of support from radiologists who couldn’t come (Dr.Makis, Dr. Marie Smerdley) (for a total of 7), and asked for Dr. MacEwan to be formally removed as Director of Diagnostic Imaging. Dr-Parliament denied this request and arranged a mediation meeting on May 4, 2025, which he then failed to attend. Five radiologists were able to meet with Dr.MacEwan on May 4, 2015 to discuss his unprofessional conduct (Dr. Williams, Dr.Duha, Dr.Bates, Dr.Campbell and Dr.Makis). Dr.MacEwan took notes but was very agitated during the meeting. A summary of the meeting was recorded (Ref019). On May 21, 2015, Dr.MacEwan addressed the radiologists’ concerns about his abusive conduct by denying virtually all the allegations and concerns (Ref019).. | have been informed by my colleagues that Dr. MacEwan continues to engage in verbal abuse and bullying of several Diagnostic Imaging staff, including technologists and physicians. | remain deeply concerned about the physical safety of my colleagues at the Cross Cancer Institute, who have not been offered any protection, despite numerous documented reports of Dr.MacEwan's abuses. 10. Patient care - illegal radiology reporting of unsupervised cancer patient therapy work ‘On Nov.8, 2015, Dr-MacEwan illegally reported 3 radiology reports on the administration ofthe radioisotope cancer treatment “Lutetium (also known as Lu-177 or 177Lu-DOTATATE) to patients whose drug administration | supervised and who were under my care as inpatients for 24 hours including: 41110-6861, West, Allan 22941-1861, Papadopoulos, Socrates 84187-3871, Palidwor, Terry Dr.MacEwan had no authority from Health Canada to report these studies, he did not know these patients, and he had no involvement in the medical care of these patients. Dr.MacEwan was scheduled on radiology and did not observe these patients who were being treated in the nuclear medicine department. Dr.MacEwan was not able ‘to observe any patient adverse events and was thus unable to document any adverse events in his radiology reports, 15 VM 0044‘Since the April 29, 2014 initiation of the Lutetium Clinical Trial (LUT-001) approved by Health Canada, Dr.MacEwan has illegally reported hundreds of Lutetium Therapy studies that were performed mostly by me, or ‘occasionally by Dr.Sandy McEwan and has nelther informed us, nor asked our permission. These therapy reports state the radioisotope dose that a patient was administered and any adverse events that the patient may have experienced during administration. It is my understanding that Dr.MacEwan reported these studies in violation of Health Canada regulations, which only allow a physician to perform work on the Lutetium Clinical Trial, as a physician, if ou are either a co-investigator or principal Investigator. Dr. MacEwan was neither and this can be confirmed by Ms.Sandra Gordey, Regulatory Affairs, Internal Quality Assurance and ical Trials Coordinator. Please note that | was a co-investigator on the Lutetium Clinical Trial and was authorized by Health Canada to report these studies. ‘There are approximately 140 Lutetium Clinical Trial patients who have been affected by Dr.MacEwan's illegal reporting of their treatments. | remain deeply concerned about the safety of these patients and the risk that they are being placed in by Dr. MacEwan’ illegal medical reporting of cancer treatments that he did not supervise, administered to patients whose care he has not participated in. SUMMARY OF ALLEGED CPSA Code of Ethics (CoE) and CPSA Standards of Practice (SoP) Violations by Dr.MacEwan: 1. Workplace Violence - Physical assault of Dr.David Williams (Nov.26, 2015) ‘© CoE 9: Refuse to participate in or support practices that violate basic human rights © CoE 52: treat your colleagues with dignity and as persons worthy of respect ‘© SoP Collaboration in patient care 2: A physician must treat other healthcare providers with dignity and respect 2. Sabotage of medical practice of Dr.David Williams following physical assault (Dec.21, 2015) © CoE 7: Resist any influence or interference that could undermine your professional integrity ‘© CoE 9: Refuse to participate in or support practices that violate basic human rights '* CoE 48: Avoid impugning the reputation of colleagues for personal motives * CoE 52: treat your colleagues with dignity and as persons worthy of respect ‘© SoP Collaboration in patient care 2: A physician must treat other healthcare providers with dignity and respect 3, Threats to the medical practice of Dr.David Williams (Dec.2015) ‘© CoE 9: Refuse to participate in or support practices that violate basic human rights ‘© CoE'52: treat your colleagues with dignity and as persons worthy of respect ‘© SoP Collaboration in patient care 2: A physician must treat other healthcare providers with dignity and respect 4. Workplace violence - Physical assault of Deb Halldorson (CT Nurse) (Jul.7, 2015) ‘© CoE 9: Refuse to participate in or support practices that violate basic human rights ‘© CoE 52: treat your colleagues with dignity and as persons worthy of respect * SOP Collaboration in patient care 2: A physician must treat other healthcare providers with dignity and respect 16 VM 0045"2 ‘Workplace violence - Verbal assault of Marlon Bonilla-Salazar (CT Tech) (Oct.9, 2015) * CoE 9: Refuse to participate in or support practices that violate basic human rights © CoE 52: treat your colleagues with dignity and as persons worthy of respect © SoP Collaboration in patient care 2: A physician must treat other healthcare providers with dignity and respect Workplace violence - Harassment of Dr.Villam Makis and verbal abuse of CC! staff (Aug.2014) © CoE 9: Refuse to participate in or support practices that violate basic human rights * CoE 52: treat your colleagues with dignity and as persons worthy of respect ‘© SoP Collaboration in patient care 2: A physician must treat other healthcare providers with dignity and respect ‘Conspiracy to destroy the medical career of Dr.V.Makis via abuse of the AHS and CPSA complaint systems and ‘harassment of CCI staff (Brittany Sammann, Joanne Snydmiller) (Aug.2015 — May.2016) ‘© CoE 7: Resist any influence or interference that could undermine your professional integrity CoE 9: Refuse to participate in or support practices that violate basic human rights ‘© CoE 48: Avoid impugning the reputation of colleagues for personal motives ‘© CoE'52: treat your colleagues with dignity and as persons worthy of respect ‘* SoP Collaboration in patient care 2: A physician must treat other healthcare providers with dignity and respect Conspiracy to provide coordinated, false and defamatory testimony to an AHS Investigation to sabotage and destroy Dr.V.Makis’ medical practice (Jan-Mar, 2016) ‘© CoE 7: Resist any influence or interference that could undermine your professional integrity ‘* CoE 9: Refuse to participate in or support practices that violate basic human rights '* CoE 48: Avoid impugning the reputation of colleagues for personal motives * CoE 52: treat your colleagues with dignity and as persons worthy of respect ‘SOP Collaboration in patient care 2: A physician must treat other healthcare providers with dignity and respect Human Rights Abuses of CCI Staff (2011-2016) © CoE 7: Resist any influence or interference that could undermine your professional integrity CoE 9: Refuse to participate in or support practices that violate basic human rights ‘= CoE 48: Avoid impugning the reputation of colleagues for personal motives * CoE 52: treat your colleagues with dignity and as persons worthy of respect ‘© SoP Collaboration in patient care 2: A physician must treat other healthcare providers with dignity and respect 10. Patient care - Illegal radiology reporting of unsupervised cancer patient therapy work * CoE 1: Consider first the well-being of the patient ‘+ CoE 3: Provide for appropriate care for your patient * CoE 14: Take all reasonable steps to prevent harm to patients * CoE 15: Recognize your limitations © CoE 51: Do not keep secret from colleagues the diagnostic or therapeutic agents and procedures you employ 7 VM 0046REFOO) wecs TELUS OE < Messages Dave Williams 12:97PM Cora kon te uous eee Yep... and | emailed Matt... didn't meet until dec 21 Cie as cau es Yes just to discuss... and it was on dec.21 that Presa otto Set cy Semen Yes... I haven't really read the letter as it was so my spin bs.... Ididn't supply my statement to Matt... and it was swept under the carpet 7 AGM) eorooTELUS UF 12:38PM axe Details < Messages Dave Williams Details Ididn't supply my statement to Matt.. and it was swept under ‘the carpet Nope... was basically told we have to work together... Peake Ree ean Basically.. rob also suggested a few times | look elsewhere Poe arm taie Cees eas Oe ao ee Hopefully it does... oa VMO0KFREFOOZ-) 9, 2015 Dear Dr Parliament, Lacknowledge that we have a meeting set-up on December 22” to discuss and hopefully esolve the conflict that has recently arisen betwen Dr. Williams and me, as the site However, | am writing to inform you of a conceming incident that occurred on December 2 atnoon. ‘To summarize, had reported ona technical issue that had experienced 2 few times in the past month with the power port peel-away sheath and valve mechanism. Tepreseniative, Kareem Johnson, had agreed to meet with me to discuss the issue Kareem was set up in the general tech area and when I arrived, Drs. Samji and Williams were discussing some of the other produets with him. ‘Shortly thereafter, Kareem addressed the issue that I was having with the device. 1 started to explain what was happening during the procedure and Dr. Williams interrupted, stating. “Why don’t you just take the whole thing out, refering to both the wire andthe stiffener in one motion. Surprised by how imitated and aggressive he was, I Tooked over ‘athim, He then walked over to me, and in font ofthe rep, 2 general technologists, Christine and Sarah, and our new radiologist colleague, Karim Samji, he commanded, in a very threatening tone, “Don't look at me like that”, and walked out” He retumed about 30 sec later and continued to interact with the rep. Kareem asked him whether he had had the same issue that 1 was having, to which he responded, “No, I've done thousands of these”, and walked out again. I had no idea what generated this level of personal contempt; however, his intention was ‘obviously to intimidate me in front of staff, an industry representative, and a new colleague and I take this very seriously. Dr. Williams and I have not had any interaction since the aftemoon that you met with him, apart from minimal, benign, small talk during, a recruitment luncheon the Friday before. The only issues of concern that he raised in advance of the meetings that we each had with you on the 26%, were the Christmas call schedule rearrangement (which he knows I had nothing to do with) and the fact that he was asked to take the academic time that he was given to prepare grand rounds at the CCI, rather than at home, in accordance with AHS expectations (its noted that 1 of the 2 half days that he was given for grand rounds preparation was taken at home and be was not penalized). tis always my preference to discuss contentious matters face-to-face. Dr. Williams and } used to be able to have @ cordial conversation; however, he has become unreseptive the tast 2 oF 3 times that I have attempted to communicate with him. I wonder whether he is ‘experiencing stress outside of the workplace, which has prompted a change in behavior. vM congIhe perceives a change in me, then would like that he share thi e this and make the necessary adjustments if required, oe ‘The end goal ist establish a peaceful, respectful workplace, where the focus is on our patients, referring physicians, and tumor teams. Unfortunately Tam not sure how best to achieve this goal, given the recent events, His attempt .o bully and intimidate me n front of our recently recruited mutual colleague, two general radiography technologists, and the Bard representative, is unacceptable behavior that will ned to be addressed. itis my expectation that Dr, Williams agrees to the end goal in writing and that he issues an apology for his actions, This type of behavior influences the whole team and diagnostic imaging staf have noticed the increased tension. As suc, its also important that Dr. Williams be encouraged to apologize to those who observed this incident, so as to ensure that they be made to feel comfortable that bullying and intimidation are not acepable ‘behaviors in the workplace. ‘This event and others like it in the recent past are unfortunate and they impact all of us. ‘We each bring unique skills to the practice and these events distract us from realizing our full potential, If we were unified, we would assuredly be greater than the sum of us as individuals, {remain committed to resolving these issues, puting them behind us, and redirecting the focus toward our clinical priorities. David is a valuable member ofthe team and I would be pleased if he would work with me toward reconciliation. ‘Thank you for your assistance with this matter, REF 002-2 via 0044REFOO3 From: Deborah Halldorson Sent: July 7, 2015 11:09 AM To: Quinn West ‘Subject: Slapping Hi Quinn, I was working in specials this morning with Dr. MacEwan and when I was not fast enough to do as he asked, because I was attaching an needless access end to the central line, he slapped my hand. I don't appreciate this behavior. It is unprofessional and I would appreciate an aopolgy from him. In addition, if this should ever happen again I will report his behavior to HR, my union and to the College of Physicians. Deb Halidorson RN From: Deborah Halldorson Sent: October 9, 2015 3:44 PM To: Quinn West; Scott Simmons ‘Subject: Dr. MacEwan I worked in Specials today with Dr. MacEwan and Marlon for two lines. Both times Dr. MacEwan was extremely rude and denigrating with Marlon. Dr. MacEwan wanted Marlon to “adjust” the xray picture but did not give him specific directions as to what he wanted. He just kept telling Marion to “adjust” the xray picture. The tension in the room was palpable. This happened again for the second line the I worked with Marion and Dr. MacEwan. Dr. MacEwan was short, rude and condescending with Marlon. It made it very difficult for Marlon to do his job. T thought you should be aware of this. Deb Halldorson RN VM 000REFOO4-) On Wednesday, August 6, 2014, at approximately 10am, Dr.Rob MacEwan came to my office and closed the door. He began questioning me about my therapy patient work and if| found ways to decrease the time | spend with patients. He fist brought up the issue on July 24, 2014 during a meeting in the nuclear medicine department at 9:30am with Dr.Hudson and myself, where he offered more PET imaging ‘support in the form of 5 half-days per week by Dr.Hudson (I had written to Quinn West on July 23, 2014 about being chronically overworked, and PET coverage being chronically inadequate), but Dr. MacEwan also expressed frustration at the Lutetium therapy clinical trial and the associated research paperwork. He felt most of the work associated with seeing Lutetium therapy patients should be done by a nurse, ‘and he expressed this sentiment in his July 29, 2024 email, where he accused the therapy team of Inefficiency and Inappropriate use of resources. | described to Dr.MacEwan my experience of enrolling 40 of the 50 Lutetium therapy Clinical Trial patients since April 28, 2014, and | explained to him that | was very efficient with my time and was not able to decrease the time | spend with patients. | went into great detail as to how my time is spent. | explained that screening a patient for the trial can take 45-60 minutes, consent can take 45-60 minutes and post therapy image review can take 20-30 minutes. Dr.MacEwan repeatedly challenged me on these times and | felt | was being interrogated rather than being part of a discussion. | had to repeatedly explain why the time | spent was appropriate and necessary. | mentioned to Dr.MacEwan that | did an audit of the nuclear medicine department work done since January 1, 2014, which revealed that | am chronically overworked and providing more than 1.0 service approximately 40% of the time. He said that he was not aware of this, and that he only recently learned of the amount of work involved with Lutetium therapy Clinical Trial patients. He asked me if | could move my therapy patient appointments around so that there was at least one day when | was not seeing any therapy patients, and offered 4 imaging half-days of support instead of 5. | asked Dr.MacEwan for a meeting of all 4 nuclear medicine physicians to discuss the problems facing the nuclear medicine department and to reach a consensus on solutions, but Dr.MacEwan stated “there sno need for any meeting” and refused. He then told me that | must go to him and him alone, with any concerns | have, and that he would decide what to do next. | felt threatened at this point, as this was delivered as an ultimatum and in an aggressive manner. He repeated that | must go to him only, and run everything by him first, and that he would determine how to act on my suggestions, so that | would not bbe “wasting people's time” by bringing up my concerns at meetings with other physicians. 1m Makis MD, FRCPC. vy 0057CCI - ACC#: 5515518 - EXAM DA’ Viliam Makis REerooy-2 From: Viliam Makis Sent: Friday, August 08, 2014 4:54 PM To: Quinn West Ce: Scott Simmons; ‘Rob MacEwan’; Emmanuel Hudson; Sandy Mcewan; Salima Beattie; Kevin Milner; Sharon Gregg; Leanne Dom; Cathy Helps ‘Subject: PETICT booking problems and inadequate PETICT coverage Attachments; PETs Read by Institution.doc Hi Quinn, ‘As a follow-up to our discussion on Wednesday, August 6, about the recent failures of the PET booking process ‘as well as what constitutes proper physician PET coverage, | am providing additional information from a recent ‘survey that | conducted of 5 other large PET centers. ‘The typical daily workload for one radiologist at other PET centers is 10-12 PETs only (no other imaging or therapy service is provided by the PET reader). Since we provide imaging support for 10-20 non-PET studies daily 2s well, a full imaging day at our institution for one radiologist would consist of 9 PETs plus non-PET studies. ‘According to my recent audit of the PET and therapy work done in the nuclear medicine department from January 4, 2014 to July 31, 2014, PET coverage has been chronically inadequate (due to improper PET booking, physician scheduling, lack of co-ordination with our therapy schedule and a general lack of understanding of the work done in the department). The most critical shortages of physician coverage occurred following both previous cyclotron down times, January 7-13, 2014, and July 14-22, 2014, which reflect a failure of proper planning for these events, as well as lack of teamwork and consideration, ‘After discussing these problems with Dr.MacEwan on Wednesday, August 6, and Dr. Hudson last week, we have come to an agreement to adjust the physician schedules to better reflect the current needs of our department, taking into account the growing needs of the Lutetium therapy Ciinical Trial ‘Starting on September 1, 2014, | will be providing 5-6 half-days of imaging service per week, and Dr. Hudson and Dr.MacEwan will be providing at least 4-5 half-days of imaging service per week (with permanent coverage ‘Tuesday to Friday afternoons), which | hope will alleviate the problem of chronically inadequate PET coverage. A half-day provides coverage for up to 5 PETs and a full day provides coverage for up to 10 PETS (to be scheduled ‘a8 9 regular PET slots and 1 emergency PET slot as needed). | will also be providing 4-5 half-days of dedicated therapy patient service and research trial support per week. | agree that our PET/CT scanner ie currently under-utilized and that we should be moving towards performing 12- 15 PETs per day. | believe that once we repair our PET booking process and physician PET scheduling, we can then begin planning towards the goal of performing 12-15 PETs daily. Since we already have the available physician resources, Dr. Hudson and Dr. MacEwan will provide the additional imaging support needed to move beyond 9-10 PETs per day. . | will work closely with Kevin Milner and Leanne Dom on PET booking starting September 1, 2014 (9 PETs plus 1 ‘emergency slot per day), and | will work with Sharon Gregg on the physician PET schedule, to ensure the best possible care for our patients. ‘Thank you all for your support and help, Dr-Viliam Makis MD, FRCPC vi o0s2 8/13/2014REFOO4-3 Maximum workload per one radiologist per day Daily General | Therapy Source of information PETs Nue Patients ‘UAH, Edmonton 10 none: ‘none Dr.Jon Abele UAH, Edmonton 23 yes none Dr.Jon Abele McGill — RVH, Montreal | 12 ‘none none Dr. Mare Hickeson ‘McGill —JGH, Montreal | 10 ‘none none. ‘Dr. Stephan Probst CHUM, Hotel Dieu, in none none Dr.Gad Abikhzer Montreal Dr.Mathieu Charest CHUM, Hotel Diew, 6 yes none Dr.Gad Abikhzer Montreal Dr.Mathieu Charest ‘Saskatoon 7 yes (BMD) _| none Dr.Rajan Rakheja VMoos3CCI - ACC#: 5515518 - EXAM DATE: Jan 10 2014 From: Sent: Monday, August 11, 2014 1:23 AM To: Salima Beattie Ce: Viliam Makis; makisw79@gmail.com Subject: Documentation - meeting with Dr.Rob MacEwan on August 6, 2014 Attachments: 2014-08-06 Meeting with MacEwan.doc Documentation - meeting with Dr.Rob MacEwan on August 6, 2014 vmMoosy 8/13/2014REF OOY-S ‘On Wednesday, August 6, 2014, at approximately 10am, Dr.Rob MacEwan came to my office and closed the door. He began questioning me about my therapy patient work and if| found ways to decrease the time | ‘spend with patients. He first brought up the issue on July 24, 2014 during 2 meeting in the nuclear medicine department at 9:30am with Dr.Hudson and myself, where he offered more PET imaging ‘support in the form of 5 half-days per week by Dr.Hudson (I had written to Quinn West on July 23, 2014 about being chronically overworked, and PET coverage being chronically inadequate), but Dr. MacEwan also expressed frustration at the Lutetium therapy clinical trial and the associated research paperwork. He fett most of the work associated with seeing Lutetium therapy patients should be done by a nurse, ‘and he expressed this sentiment in his July 29, 2014 email, where he accused the therapy team of inefficiency and inappropriate use of resources. | described to Dr. MacEwan my experience of enrolling 40 of the 50 Lutetium therapy Clinical Trial patients since April 28, 2014, and | explained to him that | was very efficient with my time and was not able to decrease the time | spend with patients. | went into great detail as to how my time is spent. explained that screening a patient for the trial can take 45-60 minutes, consent can take 45-60 minutes and post therapy image review can take 20-30 minutes. Dr. MacEwan repeatedly challenged me on these times and | felt | was being interrogated rather than being part of a discussion. | had to repeatedly ‘explain why the time I spent was appropriate and necessary. | mentioned to Dr.MacEwan that | did an audit of the nuclear medicine department work done since January 1, 2014, which revealed that | am chronically overworked and providing more than 1.0 service ‘approximately 40% of the time. He said that he was not aware of this, and that he only recently learned of the amount of work involved with Lutetium therapy Clinical Trial patients. He asked me if | could ‘move my therapy patient appointments around so that there was at least one day when | was not seeing any therapy patients, and offered 4 imaging half-days of support instead of 5. | asked Dr.Macéwan for a meeting of all 4 nuclear medicine physicians to discuss the problems facing the nuclear medicine department and to reach a consensus on solutions, but Dr.MacEwan stated “there Is no need for any meeting” and refused. He then told me that | must go to him and him alone, with any ‘concerns | have, and that he would decide what to do next. | felt threatened at this point, as this was delivered as an ultimatum and in an aggressive manner. He repeated that | must go to him only, and run everything by him first, and that he would determine how to act on my suggestions, so that | would not ‘be “wasting people's time” by bringing up my concerns at meetings with other physicians. Dr.Viliam Makis MD, FRCPC vMoOSS”CCI - ACC#: 5515518 - EXAM DATE: Jan 10 2014 Viliam Makis REF COY-6 From: Viliam Makis Sent: Monday, August 11, 2014 8:26 AM To: Sharon Gregg Co: Quinn West; Scott Simmons; ‘Rob MacEwan’, Emmanuel Hudson; Sandy Mcewan; Salima Beattie; karey mecann ‘Subject: Radiologist Schedule Hi Sharon, ‘As of September 1, 2014, Nuclear Medicine Imaging PM slots from Tuesday to Friday willbe filed with Dr. Hudson (or Dr: MacEwan). These slots will take priority on the schedule, To keep things simple, my schedule will remain unchanged, and | will continue to occupy the "Nuc Med Therapy” slots on the schedule, with the understanding that | will provide 5-6 imaging half-days and 4-5 therapy haif days per week, as the needs of our department require. When | am away, the Nuc Med Imaging AM and PM slots will be fully filed by Dr. Hudson and/or Dr. MacEwan. | anticipate severe physician shortages in ight of upcoming departures of one or more radiologists, therefore ‘when the time comes, we will have to decide as a team, if Dr Hudson will cover radiology during those shortages and if our PET service will be significantly restricted at that time as a result, or whether we will give our PET service priority, and Dr. Hudson (and Dr. MacEwan) will continue to cover the "Nuclear Medicine Imaging” PM slots. ‘Thank you! Dr.Viliam Makis, MD, FRCPC VM Oosé 8/13/2014CCI - ACC#: 5515518 - EXAM DATE: Jan 10 2014 Viliam Makis AEFOOY-? From: Rob MacEwan (macewanr@gmail.com] ‘Sent: Monday, August 11, 2014 9:05 AM To: Viliam Makis. Ce: Quinn West; Scott Simmons; Emmanuel Hudson; Sandy Mcewen; Salima Beattie; Kevin Milner, Sharon Gregg; Leanne Dom: Cathy Helps ‘Subject: Re: PET/CT booking problems and inadequate PETICT coverage Dear Staff and Colleagues, Our diagnostic imaging department is unique for several reasons and unique challenges result, The radionuclide therapy program is one such element. Thave asked that Dr. Makis and other members directly involved in this program examine process and make recommendations that will improve our efficiency and our resource utilization, all the while ensuring that high quality patient care is maintained. Once this is completed, I will look at PET bookings. This will occur in the context of the physician recruitment process. I would ask that everyone remember that itis a privilege to work at the Cross Cancer Institute and it is a privilege to work with this unique patient population, Therefore, please work constructively towards achieving the mandates of this department. ‘Thanks in advance for your contributions. RM On Fri, Aug 8, 2014 at 4:54 PM, Viliam Makis akis@albertahealthservices.ca> wrote: Hi Quinn, ‘As a follow-up to our discussion on Wednesday, August 6, about the recent failures of the PET booking process as well as what constitutes proper physician PET coverage, | am providing additional information from. @ recent survey that | conducted of 5 other large PET centers. ‘The typical dally workload for one radiologist at other PET centers is 10-12 PETS only (no other imaging or therapy service is provided by the PET reader). Since we provide imaging support for 10-20 non-PET studies daly 28 well, 2 fulmaging day at our nttution for one radiologist would consist of 9 PETS plus non PET fies. ‘According to my recent audit of the PET and therapy work done in the nuclear medicine department from January 1, 2014 to July 31, 2014, PET coverage has been chronically inadequate (due to improper PET. booking, physician scheduling, lack of co-ordination with our therapy schedule and a general lack of understanding of the work done in the department). The most critical shortages of physician coverage occurred vM 00S? 8/13/2014CCI - ACC#: 5515518 - EXAM DATE: Jan 10 2014 following both previous cyclotron down times, January 7-13, 2014, and July 14-22, 2014, which reflect a failure of proper planning for these events, as well as lack of teamwork and consideration. RERCO4-B After discussing these problems with Dr MacEwan on Wednesday, August 6, and Dr.Hudson last week, we have come to an agreement to adjust the physician schedules to better reftect the current needs of our department, taking into account the growing needs of the Lutetium therapy Clinical Trial Starting on September 1, 2014, | will be providing 6-6 half-days of imaging service per week, and Dr.Hudson and Dr-MacEwan will be providing at least 4-5 half-days of imaging service per week (with permanent coverage “Tuesday to Friday afternoons), which | hope will alleviate the problem of chronically inadequate PET coverage. ‘A half-day provides coverage for up to § PETs and a full day provides coverage for up to 10 PETs (to be ‘scheduled as 9 regular PET slots and 1 emergency PET slot as needed). | will aso be providing 4-5 half-days of dedicated therapy patient service and research trial support per week. | agree that our PET/CT scanner is currently under-utilized and that we should be moving towards performing 12-15 PETS per day. | believe that once we repair our PET booking process and physician PET scheduling, we can then begin planning towards the goal of performing 12-18 PETs dally. Since we already have the available physician ‘eeuroes, Or Hudson and Dr. MacEwan vil provide te edattonal imaging support needed to mave beyond &- 10 PETs per day. | will work closely with Kevin Milner and Leanne Dom on PET booking starting September 1, 2014 (9 PETs plus 4 emergency slot per day), and | will work with Sharon Gregg on the physician PET schedule, to ensure the best possible care for our patients. ‘Thank you all for your support and help, r.Viliam Makis MD, FRCPC. “This message and any attached documents are ony fo the ue of he ntended repent), ae confidential and may contain prviegod formation ‘Ay unui rove feanumceo, shar hsonare say pohintea Wf Jouhave ecwed ths eseage i ohenpoese neh De ‘ender immediately, and then delete he original message. Thank you. vMoos®8 9/13/2014‘Subject: Your receipt No.142081489945 From: iTunes Store (do_not_reply@itunes.com) To: makisw79@yahoo.com; Date: Monday, August 11, 2014 9:32 AM eErooYy-F @ iTunes Receipt sities To: Fae @yahoocom order 0; wzsrx0vex0 Tae Reese beter coy ieten or Sroetront ss Bron 8 7B 221 Bined Tor ise 9039 or Ren sonar - Super Note: Recrier, Nets, Memos, Pots, v4.2 (44) Heavy Duty Apps 10s App 299 Write a Review Report a Problem Please retain for your records ‘lace See Beow For Terme And Condens Pertaining To This Order, ‘Apple Canads, Inc. Yt can find the Tunes Store Terms of Sele end Seles Pues by leunching your Tunes application and clicking on Terms of Sale or Sales Pocies| Tax Registration #R100236199 ‘answers to frequently asked questions regarding the Tunes Stere can be found at http:/Pwvapple.comjea/supporeunes! ‘Apple 10 Summary © Purchase History ‘pple respects your privacy $2.99 $0.15 $0.24 Order Tota: $3.38 Information regerding your personal ivermation can be Ved at hitos://wmnapple.cam/ca/prNacy/ ‘Copyright © 2014 Ape Canada, Inc. Al rights reserved @ iTunes VM 0059 12Iratsn?96hoo.com REF aoy-10 Vim Mek Date de réception : 11/00/13 31 Wellington Dr Total de la commende : $9.38 Brandon, MB R7B 224 Facturé 8: Vio». 9099 can Article Editeur Type Prix unitaire Super Note: Recorder, Notes, Memos, Photos, v4.1 (4+) Heavy Duty Apps ‘gp pour $2.99 ‘Donner votre vie Signaler 6s Total de la commande : ‘A conserver pour vos dossiers ‘Cansubterc-dessous les Modalnés de cette commande. ‘Apple Canada, Ine. Pour consuiter fs Modaltés et Putiques de vente de ITunes Store, veuller lancer fTunes et clauer sur Hodeltés de vente Numéro de tee 8100236199 Les répanses aux questions fréquemment posées concerant !Tunes Store sont lsponbles au en suhent http://mwwapple.com/ea/t/supparteunes) Données du compte Histerque 'achate ‘Apple respecte vtre canfdentiité La Pattique de confdentatté peut étre consulée la page Nts: //wwanplecom/ea/t/oeiaey/ (© 2014 Apple Canada, Inc. Tous droite réservde sbovtblank vMO0O6O $2.99 $0.15 $0.24 $3.38CCI - ACC#: 5515518 - EXAM DATE: Jan 10 2014 Viliam Makis REFOCO4-1 From: Viliam Makis Sent: Monday, August 11, 2014 1:41 PM To: —‘Salima Beattie ‘Subject: RE: PET/CT booking problems and inadequate PETICT coverage Hi Salima, 1am very uncomfortable with this situation. Could you please arrange a private meeting for me with Dr.Parliament this week if possible? ‘Thank you Dr-Viiam Makis From: Salima Beattie ‘Sent: Monday, August 11, 2014 10:36 AM To: Viliam Makis ‘Subject: RE: PET/CT booking problems and inadequate PET/CT coverage Good Morning Dr. Makis, Of course | can set this up for you. Please let me know soon if you can as | leave this Saturday for three weeks. ‘Thank you, Salima Ph: 780-432-8526 Fax: 780-432-8483, S universiry ALBERTA MMe soe From: Viliam Makis Sent: Monday, August 11, 2014 10:28 AM To: Salima Beattie ‘Subject: RE: PET/CT booking problems and inadequate PET/CT coverage Salima, | think Rob has just indirectly threatened my job, for speaking up about the department's problems. {'m not sure it warrants going to Dr.Parliament yet, but should there be any further threats to me or acts of ‘aggression, | wll ask your help in setting up an appointment with Dr.Partiament for me. Thanks Witiam From: Rob MacEwan (maito:macewenr@gmallcom] _ ‘Sent: Monday, August 11, 2014 9:05 AM ‘Tor Vitiam Makis ‘Cc: Quinn West; Scott Simmons; Emmanuel Hudson; Sandy Mcewan; Salima Beattie; Kevin Mliner; Sharon Gregg; Leanne Dorn; Cathy Helps vM 0061 8/13/2014CCI - ACC#: 5515518 - EXAM DATE: Jan 10 2014 ‘Subject: Re: PET/CT booking problems and inadequate PET/CT coverage Dear Staff and Colleagues, eee ‘Our diagnostic imaging department is unique for several reasons and unique challenges result. ‘The radionuclide therapy program is one such element. have asked that Dr. Makis and other members directly involved in this program examine process and make recommendations that will improve our efficiency and our resource utilization, all the while ensuring that high quality patient care is maintained. Once this is completed, I will look at PET bookings, This will occur inthe context of the physician recruitment process. T would ask that everyone remember that itis a privilege to work at the Cross Cancer Institute and it is a privilege to work with this unique patient population. Therefore, please work constructively towards achieving the mandates of this department. ‘Thanks in advance for your contributions. RM On Fri, Aug 8, 2014 at 4:54 PM, Viliam Makis wrote: Hi Quinn, ‘As a follow-up to our discussion on Wednesday, August 6, about the recent failures of the PET booking process 2s well as what constitutes proper physician PET coverage, | am providing additional information from a recent survey that | conducted of § other large PET centers. ‘The typical daily workload for one radiologist at other PET centers is 10-12 PETs only (no other imaging or therapy service is provided by the PET reader). Since we provide imaging support for 10-20 non-PET studies wrote: Hi Rob, | was on the phone yesterday (Aug.12) with Dr.Francois Benard, BC Cancer Agency, discussing the nuclear medicine physician job position they have posted recently, so | was unable to respond to your calls around 5pm. Thank you, Wiliam TEs meoge and an atch documents mr ony hut of node ela), re content an may onan only pent) 2 review, use, revanamisson, or ote disclosure ie scly profited. you heve reeled ts message n ETO, pleas ny te sander mnnedataly an en Cll he ong assage. Thar Yu VM 0068 8/18/2014 REF OCY-16ode Alberta Health a @ Services Confidential ‘August 22, 2014 Dr. Viliam Makis Diagnostic Imaging Department Cross Cancer Institute 11560 University Ave Edmonton, AB T6G 122 Dear Dr. Makis: ‘Be: Complaint | have received your letter of complaint regarding Dr. Rob MacEwan and workload issues in the Diagnostic imaging Department at the Cross Cancer Institute. have asked Drs. Matt Parliament and Bill Anderson to follow-up with you and Dr. MacEwan to discuss the matter in depth and work on a resolution. It is my preference to come to a resolution by gaining a mutual understanding and without implementing the formal process through the AHS Medical Staff Bylaws. Yours si Dr. David Mador, MD, FRCSC, CPE Vice President and Medical Director, Northern Alberta Edmonton Zone Medical Director Cc: Dr. Matthew Parliament, Medical Director, Cross Cancer Institute David Mador, MD, FRCSC, CPE Vice President and Madical Director - Northern Alberta ‘Alberta Health Services 112.28 WME, 8440-112 Street ‘Edmonton Alberta T6G 287 v1 0069 780.407.6560REFOOS-| ‘August 20, 2014 Dr.Matthew Parliament Dr.David Mador Medical Director Edmonton Zone Medical Director Cross Cancer Institute Alberta Health Services Hello Dr.Parliament, Dr.Mador | would like the following incidents, involving the conduct of Dr.Robert MacEwan, Medical Director of Diagnostic Imaging, Cross Cancer Institute, to be considered as part of a formal complaint. BACKGROUND INFORMATION: | started working at the Cross Cancer Institute as a Nuclear Medicine Physician in the Diagnostic Imaging Department on August 1, 2013. My responsibilities include the reading of PET/CT imaging studies and general nuclear medicine imaging studies. | also see patients with neuroendocrine tumors, whom I treat with radioisotope therapies. My current work schedule comprises of 8 imaging half-days per week and 2 therapy patient half-days per week (1 half day within the department, 1 half day in the neuroendocrine clinic). There are 4 nuclear medicine physicians working in the nuclear medicine department, including myself. Therapy patients are seen by Dr.Sandy McEwan and myself, and imaging is done by Dr.Emmanuel Hudson, Dr.Robert ‘MacEwan and myself. On July 24, 2014 (8:44am), | emailed Quinn West, Director of Diagnostic Imaging (Cross Cancer institute), to document problems involving PET/CT booking and physician scheduling, which jeopardized patient care on July 14, 21 and 22, 2014. There had been no PET/CT service from June 30 to July 10, 2014 due to cyclotron maintenance. This created a backlog of approximately 134 PET/CT studies, many of which were urgent cases. Dr.Robert MacEwan co- ordinated with Scott Simmons, Manager of Diagnostic Imaging, to increase the booking of PET/CTs from 8-9 per day to 15 per day, to clear this backlog. Dr. MacEwan notified me that the increased booking would occur during the week of July 14-18 only, and that I would receive the needed support from Dr.Emmanuel Hudson, to handle this additional workload. Dr. Hudson provides 2 half-days of imaging service per week, and also provides coverage when | am away _ VM ooFOREFoos-2 on vacation. | did not receive the needed support on July 14, as Dr.Hudson and Dr.MacEwan were away on vacation, but I did get some support July 15-18. However, on July 18 I spoke to Kevin Milner, PET/CT supervisor, and was told that increased PET/CT booking would continue during July 21-25 as well. l requested additional PET/CT help from Dr.MacEwan in a July 18, 2014 (12:13pm) email, as well as on July 22 in the morning in person, however | did not receive the necessary PET/CT physician support. As a result, | was forced to handle the work of two radiologists on July 14, 21 and 22, which | felt jeopardized patient care, as | was rushed to report these urgent cases for oncologists who needed the results as soon as possible, while also having to see therapy patients as well. Dr.Hudson was, in fact, available in the Diagnostic Imaging department on July 21 and 22, however Dr.MacEwan refused to make him available for PET/CT, stating that he was needed in the radiology department instead. | discussed this with Dr.MacEwan on July 23, 2014 in person, and we discussed the problem of chronically inadequate PET/CT physician coverage. Dr.MacEwan agreed with me that we needed 5 additional half-days of PET/CT physician support on the radiologist schedule (instead of the current 2 half-days), which would be provided mostly by Dr.Hudson, and that this could be implemented starting September 1, 2014. | documented this discussion in my email to Quinn West on July 24, 2014 (8:44am). Quinn West was away on vacation until August 5, 2014. ‘On July 24, 2014 at approximately 9:30am, Dr.MacEwan convened a brief meeting with Dr.Hudson and myself in the nuclear medicine department, where Dr.MacEwan re-iterated his support for 5 half-days of additional PET/CT physician support to be added to the radiologist schedule starting September 1, 2014, and Dr.Hudson was in agreement. For the first time, however, Dr.MacEwan expressed frustration at the amount of time that | was spending with therapy patients. He referred specifically to the Lutetium Therapy Clinical Trial, which was initiated in our department on April 29, 2014. | am the co-investigator of this trial, and Dr.Sandy McEwan is the principal investigator. The trial involves the enrollment of 400 neuroendocrine tumor patients, to be treated with radioisotope therapy called *”’Lu-DOTATATE, with 12 treatments given over 8 years. Dr.Robert MacEwan expressed that he believed much of the work related to the Clinical Trial could be done by a nurse. | explained to him that | work very efficiently with therapy patients (those who are part of the trial, as well as those who aren’t), however | was willing to look into the issue with other members of the therapy team, to see if any further improvements in efficiency could be achieved. | found this to be very unusual, however, as Dr. MacEwan knew that | was seeing on average 3-4 therapy patients a day since January 15, 2014, and the time that | spend with patients had never been an issue before. On July 25, 2014 (9:04am), | wrote an email to all 4 nuclear medicine physicians, Quinn West, Karey McCann (our therapy nurse co-ordinator), and Sandra Gordey (Clinical Trials 2 v1 0071QEFCOS-3 Coordinator). | described in detail the amount of time it takes to enroll one patient into the Lutetium Therapy Clinical Trial and the workload involved with screening and consenting of a patient. | asked whether the time | spent with patients was reasonable and what could be done to make the process more efficient. On July 28, 2014 (4:45pm), Sandra Gordey responded in an ‘email that the time | was spending was reasonable, and that some improvement in efficiency was possible, however she also advised against taking time and effort away from the screening portion of enrollment, especially in light of 2 recent cases of protocol violations. She also confirmed that it was not ethical to rush a patient through the informed consent process. Karey McCann and Dr.Sandy McEwan both agreed that | was very efficient and that the time | was spending with patients was appropriate and necessary. In a July 29", 2014 (8:41am) email, Dr.Robert MacEwan stated: “I am convinced that the resources of our team members are not being appropriately used”. | strongly disagreed with this email, as I felt that our resources were being appropriately used, and that monumental efforts had been invested by Karey McCann, Dr.Sandy McEwan and myself, to deliver therapy to our cancer patients, despite the significant limitations within the Diagnostic Imaging Department. Since | wanted to have a better understanding of my workload in the nuclear medicine department, on July 31, 2014 | completed an audit of my work done in the department this year. From January 1, 2014 to July 31, 2014 | had reported 606 PETs and handled 333 therapy patient visits. My audit also revealed that | was overworked (provided more than 1.0 service) on 6 of 114 days (40% of the time), almost exclusively due to inadequate PET/CT support from other physicians. PET/CT physician coverage was chronically inadequate on 44 separate days. | believed that this was a serious patient related problem that needed to be discussed with the entire department. PET/CT service was being chronically compromised in favor of other radiology services (specifically CT service). Dr.Hudson, who can provide both PET/CT and CT services, was being scheduled preferably on CT service. | discussed the results of my audit with Dr.Hudson, who agreed that PET/CT service was being compromised in favor of CT service. Dr.Hudson was willing to provide additional PET/CT service but his requests were being repeatedly denied by Dr.Robert MacEwan. ‘On the morning of August 6, 2014, | spoke to Quinn West about the PET/CT service problems of July 14-22, and we discussed potential improvements in the PET/CT booking process, however Quinn also expressed that he could not really help me with the PET/CT physician coverage problems, as this was specifically a physician resource issue, and | would have to discuss this issue with Dr.Robert MacEwan. vnoo#REF OoS-4 FIRST INCIDENT (August 6, 2014) ‘On August 6, 2014, at approximately 10am, Dr.Robert MacEwan came to my office and closed the door. He began questioning me about my therapy patient work and if | found ways to decrease the time | spend with therapy patients. | described to Dr.MacEwan the discussions Trial its since April 29, 2014, and | explained to him that | was very efficient with my time and that | was not able to decrease the time I spend with patients. | went into great detail as to how my time is spent. | explained that screening a patient for the trial can take 45-60 minutes, consent for therapy can take 45-60 minutes and post therapy image review can take 20-30 minutes. This included all related paperwork and charting. Dr.MacEwan challenged me on these times and | felt | was being interrogated rather than being part of a discussion between colleagues. | had to repeatedly explain why the time | spent was appropriate and necessary. Eventually, Dr.MacEwan agreed that the time | was spending on therapy patient work seemed appropriate. | mentioned to Dr.MacEwan that | did an audit of my work done in the department since January 1, 2014, which revealed that | am chronically overworked and providing more than 1.0 service approximately 40% of the time. He said that he was not aware of this, despite my email to him on February 24, 2014 (9:12am), where | described my imaging and therapy workload and how it is very exhausting, as well as a performance evaluation meeting with him in May 2014, during which | requested 5 half-days of additional PET/CT support from other physicians. He also said that he only recently learned of the amount of work involved with the Lutetium Therapy Clinical Trial. He offered me 4 half-days of PET/CT support by Dr.Hudson instead of 5 (my current schedule has 2 half-days of PET/CT support by Dr.Hudson). | asked Dr.MacEwan for a meeting of all 4 nuclear medicine physicians to discuss the problems facing the nuclear medicine department and to reach a consensus on solutions, but Dr.MacEwan dismissively stated “there is no need for any meeting” and refused. He then told me that | must g0 to him and him alone, with any concerns | have, and that he would decide what to do next. | felt threatened at this point, as this was delivered as an ultimatum and in an aggressive and intimidating manner and tone. He repeated that | must go to him only, and run everything by him first, and that he would determine how to act on my suggestions, so that | would not be “wasting people’s time” by bringing up my concerns at meetings with other physicians. This again was stated in an aggressive and intimidating manner. | documented this incident in a letter that I sent to my AHS email account as well as Salima Beattie, on August 11, 2014 at 3am. | also bought a voice recording application for my iPhone out of concern and fear of being threatened or cornered agai with my team and my experiences of enrolling 40 of the 50 Lutetium Therapy Cli | was shocked that | was being prevented from communicating with my colleagues about patient related issues, and that | was refused a meeting of all 4 physicians in the department, where the problems of chronically inadequate PET/CT coverage, revealed by my 4 VM 0073REFOOs-s audit, could be discussed. The 4 nuclear medicine physicians had not met together in a single departmental meeting since | started working at Cross Cancer Institute on August 1, 2013. | was very concerned that the patient related problems that needed to be discussed, would remain undocumented and unknown to most of the members of the department, and that the. solutions that Dr.Robert MacEwan and | had agreed upon, would also remain undocumented. | found it disturbing that Dr. Robert MacEwan had already begun changing the terms of these solutions, by reducing the promised number of additional PET/CT physician support from 5 half- days per week (promised on July 23 and July 24, 2014), to 4 half-days per week (promised on ‘August 6, 2014). ‘SECOND INCIDENT (August 11, 2014, 9:05am) ‘On August 8, 2014 (4:54pm), | wrote an email to Quinn West, the 4 nuclear medicine physicians, PET/CT supervisor Kevin Milner, radiologist schedule supervisor Sharon Gregg, Booking supervisor Leanne Dorn and head technologist Cathy Helps, where | documented the problem of chronically inadequate PET/CT coverage in the department over the past year, and ‘the most critical shortages of physician coverage (that occurred following both previous cyclotron maintenance down times, January 7-13, 2014, and July 14-22, 2014). | also documented the discussions that | had with Dr.MacEwan and Dr.Hudson about changing the radiologist schedule to address this problem, namely the addition of 4-5 half-days of PET/CT support from other radiologists. | felt it was my professional duty to communicate with all of my colleagues, despite having just been pressured by Dr.Robert MacEwan to not communicate ‘my concerns to other members of the department, and despite having just been denied a ‘meeting of all 4 physicians to discuss these patient related issues. ‘On August 11, 2014 (8:26am), | sent an email to the radiologist schedule co-ordinator, ‘Sharon Gregg, in order to implement the changes discussed with Dr.MacEwan, by placing 4 additional PET/CT half-days on the radiologist schedule, starting September 1, 2014. | felt that with this email, and my August 8, 2014 (4:54pm) email, | had succeeded in documenting the problems in our department, in finding a solution that was acceptable to all 4 physicians based ‘on my individual discussions with them, and that we could move forward by implementing this solution as soon as possible, to provide a proper PET/CT and therapy service for our patients, even in the absence of a group meeting of all 4 physicians. ‘On August 11, 2014 (9:05am), Dr.Robert MacEwan responded to my August 8, 2014 (4:54pm) email, which included the following concluding statement: “I would ask that everyone remember that itis a privilege to work at the Cross Cancer Institute and it is a privilege to work with this patient population. Therefore, please work constructively...”. | felt this statement was 5 VM 0074REF OOS-¢ a direct threat against my job at the Cross Cancer Institute, as it was a direct reply to my August ‘8 email where | had documented problems within the department, despite being threatened by Dr-Robert MacEwan on August 6, 2014 to not communicate with anyone except himself about departmental problems. To me, the implications of this statement were very clear. Dr.MacEwan was asking me to remember that it was a privilege for me to work at the Cross Cancer Institute, the implication being that this privilege could or would be removed if | didn’t “work constructively”. ‘The remainder of the email also implied that Dr. MacEwan was still looking for me to decrease the time | spend with therapy patients, and the statement “Once this is completed, | will look at the PET bookings”, implied that Dr. MacEwan had no intention to follow through on his promise of providing the 4 or 5 imaging half-days of PET/CT physician support that he had promised me on July 23, 24 and August 6. | became increasingly uncomfortable with this very public threat to my job, and | approached Quinn West to ask his opinion. | also asked Salima Beattie, via a Monday August 11, 2014 (1:41pm) email, to book an appointment with Dr.Matthew Parliament to report and discuss th incident. THIRD INCIDENT (August 12, 2014) ‘On August 12, 2014, between 8:30-9am, Dr.Robert MacEwan came to my office and asked to discuss the recent events. | had my iPhone voice recording application running and | made it clear to Dr.MacEwan that | did not wish to have any discussions, by refusing several times. Dr.MacEwan insisted, saying “I've asked you not to email before, and you continued to email..”, “the emails you're sending are...they are offensive, and they have to stop...”. After asking Dr.Robert MacEwan nine times to not have any discussions at this time, Dr.MacEwan stated “that's not really an option”. After several more refusals to discuss the matter, Dr.Robert MacEwan left. | felt harassed and further threatened, by being told again, to stop sending emails to my colleagues. This event was witnessed and documented by Salima Beattie, whose office is adjacent to mine, and it was also recorded on my voice recording application. | reported the August 6, August 11, and August 12 incidents involving threats and harassment by Dr.Robert MacEwan, to Dr.Matthew Parliament in emails on August 12, 8:32am and 9:44am. During the day on August 12, | asked Quinn West to tell Dr.MacEwan that | did not wish to have any discussions with him in person or over the phone that week. Dr.MacEwan called my office ‘twice at approximately Spm and knocked on my office door shortly thereafter, however | did not respond to either of the phone calls, nor did | answer my door, which | kept locked. ‘On August 12, 2014, | also had a meeting with Quinn West, and he told me that Dr.MacEwan was willing to meet with me and Dr.Hudson to discuss departmental problems, 6 vn 0075REF OOS-F however Dr.Sandy McEwan was being excluded from this meeting. In an August 18, 2014 (11:44am) email, Dr.Robert MacEwan asked for a departmental meeting but once again attempted to exclude Dr.Sandy McEwan from the meeting and did not include him in the email. OTHER INCIDENTS Since | started working at the Cross Cancer Institute, | have witnessed numerous idents where Dr.Robert MacEwan displayed verbally aggressive behavior towards my colleagues, including: Terence Riauka (medical physicist), Karey McCann (therapy nurse), Salima Beattie (personal assistant), Brittany Sammann (technologist) and Jennifer Forer (technologist). ‘These incidents would often involve outbursts of anger and yelling, often the result of Dr.MacEwan’s frustration with the levels of noise in the department (the department is very busy and often noisy) or frustration at mistakes made by technologists, or computer equipment problems. Although | felt these incidents represented inappropriate behaviour, | failed to document them at the time. Currently, three of my technologists: Brittany Sammann, Jennifer Forer and Joanne ‘Snydmiller, refuse to review imaging studies with Dr.Robert MacEwan, apparently due to previous incidents of inappropriate behaviour. There are occasions when both Dr.MacEwan and are in the nuclear medicine department, with Dr.MacEwan doing imaging and myself seeing therapy patients. Even during these times, when | am not providing imaging service, these technologists insist on reviewing imaging studies with me and have asked me specifically not to send them to Dr.Robert MacEwan’s office, to review studies. SUMMARY 1. 1am reporting 3 separate incidents where | felt threatened, intimidated or harassed by Dr.Robert MacEwan, on August 6, August 11 and August 12, 2014, after documenting patient related issues and problems within the nuclear medicine department with Quinn West (Director) on July 24, 2014 and August 8, 2014. 2. 1am reporting additional incidents where | witnessed Dr.Robert MacEwan displaying, verbally aggressive behavior towards my colleagues, including Terence Riauka, Karey McCann, Salima Beattie, Brittany Sammann and Jennifer Forer. 3. 11am reporting that Dr.Robert MacEwan attempted to prevent me from communicating, with other physicians and colleagues about patient related issues, on August 6 and ‘August 12, 2014, 7 VM 0o76REFOOS-B 4, 1am reporting that Dr.Robert MacEwan refused to hold a meeting of all 4 nuclear ‘medicine physicians to discuss patient related issues on August 6, 2014, and attempted to exclude other physicians from proposed departmental meetings on August 12, 2014 and August 18, 2014. 5. 1am reporting that | have been repeatedly pressured and harassed by Dr.Robert MacEwan to reduce the time | spend with therapy patients, as Dr.MacEwan asked of me ‘on July 24 (in person), July 29 (email), August 6 (in person), and August 11 (email), and | feel that these requests are inappropriate, unwarranted and contrary to my professional opinions and professional duties. | strongly feel that reducing the time | spend with therapy patients could jeopardize our Lutetium Therapy Clinical Trial, and patient care. Thank you, Dr.Viliam Makis MD, FRCPC Nuclear Medicine Physician Diagnostic Imaging Department Cross Cancer Institute Edmonton, AB (780) 432-8760 8 VM OOFFQuinn West REF COS From: Robert MacEwan Sent: Sunday, August 23, 2015 4:28 PM To: ‘Quinn West; Matthew Parliament: Bill Anderson Subject: Re: Friday Humor Categories: Rob Mecewan Neither funny nor clever. I think that we (AHS) should strongly consider exploring contract non-renewal and I will begin advocating for same this coming week. Your technology staff need to write everything down. If they will not, then perhaps you / Scott could meet with each of them individually and record each of her/his experiences with Dr. Makis. {'m convinced that this physician ought to be dismissed from the organization ... i's likely the only way forward. Any of his contributions to the dept. / patient care, are far overshadowed by the divisive nature of his character and his consistently unprofessional conduct, which I will remind you, began on day 366 of his employ. .~- that has always been a telling sign for me. Chat this week Quinn, Quinn and I will fill you in on Monday Bill. Matt, | am hopeful that you have time to meet this week (sorry to have sent a work email during your vacation last week). He's been unprofessional enough in his many attacks on me over the last year; however, to be so unprofessional toward the technologists is another level altogether. Thave never seen anyone behave like this in the profession. 1 feel badly for the technologists who have to work closely with him. I wouldn't be surprised if we lose staff because of him. Thave thought about it over the last 48 hours and I don't believe that I'm over-reacting. Thanks Rob Sent from my iPhone On Aug 21, 2015, at 6:47 PM, Quinn West wrote: Exactly. A joke? Really you haven't been serious Viliam, Very funny but clever no. Sent from my iPhone ‘On Aug 21, 2015, at 6:44 PM, Robert MacEwan wrote: It only became a joke once he realized what he had done and people's reaction ... he's a disgrace to the profession. Sent from my iPhone VM 0OF8On Aug 21, 2015, at 6:16 PM, Quinn West REFOOG-2 wrote: Sent from my iPhone Begin forwarded message: From: Viliam Makis Date: August 21, 2015 at 2:44:47 PM MDT To: Quinn West Subject: Friday Humor Come on Quinn, lighten up, it's Friday. twas a joke. Here's the link if you ever want to use it yoursett. httos:/www pint ri 7 ‘btw, I talked to Cathy and offered to be present at the next tech meeting. But only if everyone is in agreement. wont’ mind either way. Tevansmssion or cher decosur ssc prohited. you have recaived te message in ‘ror pase not the Seneer mmecatey and nen delle ine orginal message TRAMK You VM oc732EFoOFR-1 ‘30000 TELUS © < Messages Tech CC! - Brittany fr aug a8, 46 AMA Just a heads up! | did not say anything bad or put in a formal complaint or any of that shit but both rob and Quinn talked to me. | do not want to be part of this just thought id let u know and please don't say | told u anything basa Yup I'd rather not txt and | don't wanna go in your office while robs here 7 Details ‘90000 TELUS © < Messages Tech CCI - Brittany 42 PM 7/7 Details Yeah I'm fine just makes me uncomfortable and feel like I'm part of the conflict when | want nothing to do with it I hate being put on the spot! shouldn't be put on Ormeau et itcuntae ean ee meme na Yup but if my name comes up again I'm fucking quitting like seriously VM 0080REFOOF-2 ‘s0000 TELUS © < Messages Tech CCI - Brittany Details Yeah cuz | don't enough already lol 'm sure Just silly and stupid now Like | feel I'm gonna get glared at if | go near you or your office tol Fine I'll stop it'll give me wrinkles a2 PM 7 eis 9 VM 008!‘rre016 Prin ‘Subject: 9/3/2015 Documentation - Brittany Sammar From: William Maks (makisw79@yahoo.com) To: makisw79@yahoo.com; makisw79@gmail.com; Date: Thursday, September 3, 2015 3:02 PM REFOO?-3 9/3/2015 Documentation - Brittany Sammann Attachments + 2015-09-03 - Brittany Sammann.doc (22.00KB) VM 0082 nREroor-4 September 3, 2015 1:40-2:00pm Conversation with Brittany Sammann Makis office Rm 1211 © Brittany stated that she was upset that she was being involved in issues she didn’t want to be involved in, and was being dragged into offices and questioned by MacEwan and Quinn West. She didn’t know why she was being asked questions ‘or why her name had come up. ‘© She was upset that she was pulled into Rob’s office a few days ago and confronted. Rob asked her if she had any issues with Makis and if she wanted to document anything, promising that it could be kept anonymous. She said she did not wish to document anything and that she had no issues with Makis. ‘© She stated that Rob told her if Makis was ever abusive towards her emotionally, ‘mentally, physically, or sexually, to let him know. © Rob asked what Brittany saw on the day of the Joanne incident. She said she didn’t see anything, only relating what Joanne told her, that Joanne made it seem. like Makis had refused to review studies. She also told Rob that Joanne has a short temper. ‘* Rob asked why Makis was sending people to look for him, stating that “it’s none of his fucking business where I am”. Brittany stated “well, actually, it is our business to know where he is, since we need to know who to go to, to review”. She said that she assumed that Makis was simply letting the techs know that Rob was on the schedule as well. ‘© Brittany also said that Rob “drove away Dr.Francois Buteau” and that although Francois had other issues, Rob’s behaviour toward him contributed to his leaving. ‘* Brittany asked me to promise not to tell anyone that she talked to me. VM00g3