STATE OF ILLINOIS DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION DIVISION OF PROFESSIONAL REGULATION DEPARTMENT OF PROFESSIONAL REGULATION) of the State of Illinois, Complainant, —) ) % ) No, 201400295 _, 2 } = @ BODO E. SCHNEIDER, M. ) 3 + License No, 036071559, Respondent.) 2 _ AMENDED COMPLAINT, es NOW COMES THE DIVISION OF PROFESSIONAL REGULATION §F the: DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION of the State of © Iinois (Deparment), by its Chet of Medical Prosseusions, Laura E, Forester, and as is Fist ‘Amended Complaint agninst Bodo E. Schneider, M.D., Respondent, states as follows: count! Respondent is preseily the holder of a Certificate of Registration as a Physician and Surgeon in the Stat of Illinois, License Number 036 071559, issued by the Department Sai license i presenly in ACTIVE status 2. The Deparment has jursiction to investigate complaints and to bring this action pursuant to 20 ILCS §2108/2105-15)(5) and 225 LCS § 6036 3. On Desember 30, 2002, Respondent's Minois Physician and Surgeon License was REPRIMANDED fr failure to propety teat a diabetic patient in a timely fishion resulting in deat. 4. Onorabout August 17, 2004, the Florida Board of Medicine entered a Final Onder which ‘SUSPENDED Respondent's license to practice medicine and required Respondent to pay a1. five thousand dollar (5000) fine and cost in the amount of five hundred sixty-seven dollars and eighty-one cents ($567.81) within thity (30) days ofthe fling ofthe Order. (On August 19, 2005, the Florida Board of Meine REVOKED Respondent’ license t9 practice medicine subsequent othe aforementioned suspension On October 17, 2005, the Virginia Department of Health Professions SUSPENDED Respondent's license to practice medicine and surgery in the Commonwealth of Virginia based onthe Flecda Onder . . ‘On September 24, 2008, Respondent's Iinois Physician and Surgeon License was placed ‘on probation for one (1) year and fined three thousand dollars ($3000) based onthe Florida Onder [Atal elevant times, Respondent was licensed as a Physician and Surgeon in the State of Minos _Arall ceva times, Respondent was the sole owns of Gateway Enterprises LLC. Gateway Enterprises LLC is registred in he Sat of Colorado, Gateway Enterprises LLC isnot registered in the State of lino Gateway Enterprises LLC does andor has done business in Michigan ands onder the following busines names: Gateways Crtfieation Center, '. Gateways Compassionate Care Clinic; and Pied Peiter Compassionate Care Clinic. Respondent was the co-founder of Gateways Cerifcation Center, located in Ann Asbor, Michigan.4 1s, 16, 1 2. 21 Danielle Castanon is a co-founder of Gateways Certification Cente, located in Ann Arbor, Michigan. Danielle Castanon doesnot hold a professional lense in the state of noi, Gateways Certification Center changed its name to Gateways Compassionate Care Clinic. ‘At all relevant times, Gateways Compassionate Care Clinic operated to provide Medical Marijuana Registry cards to the citizens of Michigan. Gateways Compassionge Care Clinic maintained a website at 7" ‘nips 7gateascertificationcentercom (0n or abou Ianuary 10, 2012, Gateways Compassionate Care Clinic expanded is physical Jocation o Minos, (0 or about January 10,2012, Gateways Compassionate Care Clinic posted the following onthe aboveeferenced website: “January 1, 2014, lino will bepin to accept certifications for paints in Minos er their use of medical marijuana, However, Mlinois being Hines, has put in the regulations that patients can only reeive certification fiom a physician with whom they have an established relationship with and is involved in treating their underying cqualifving condition, So Gateways has established a clinic in Maron. 1L and is accepting new paint to tar this proces. Call Danielle or appointments. A temporary ures in Frankfurt IL has been etblshe.” ‘The Compassionate Use of Medical Cannabis Pilot Program Act (“Medical Cannabis Act’), 410 ILCS § 130, did not take effect until January 1, 2014,