Dec 5, 1996

Dr. Humberto Vazquez, President
Tribunal Examinador de Medicos
PO Box 13969
San Juan, PR 00908
 
RE:  Complaint on unethical and incompetent conduct by Migdoel Vazquez-Davis, M.D.

Dear Dr. Vazquez:

INTRODUCTION
It is with great sorrow that events have required that I file this complaint
on unethical and incompetent conduct by Migdoel Vazquez-Davis, M.D., Hospital
Lafayette, PO Box 1319, Patillas, PR at 809-839-3232.  As you will see below,
his immorality and failure to practice medicine according to generally accepted
guidelines -- both most probably in violation of requirements of the Tribunal
Examinador and of the law, have had terrible negative consequences.  Therefore,
I must follow your response to this complaint and pursue this matter to the
fullest extent possible.  My attorneys in Puerto Rico, Vargas & Ramirez (First
Federal Building, Rio Piedras, 751-7485) will join me in following your
investigation and in evaluating your response to me, and you may contact them
directly.

Briefly, the complaint centers on two major areas.  First, the gross and
unethical mismanagement of a highly disturbed patient, my wife, Nilda M. Keene,
M.D., (The Patient) who in violation of the law, has kidnapped, repeatedly
hidden and detained my two children -- James Rogers Keene, then 7, and Grace
Josephine Keene, then 10, on and since Feb. 1, 1995.  Second, the direct
participation of Dr. Vazquez-Davis in the continuing abduction, concealment
and detention of my children, at times, at one or more of his own private
domiciles (e.g., at Palmas del Mar).

BACKGROUND
Here are facts which can be clearly established, without relying on my
statements:

1.  After the marriage and up to the present, The Patient, Nilda, has shown
gradually increasing signs of emotional and mental instability, as evidenced,
for example, by repeated difficulties in work situations in the practice of her
profession as an M.D.  There is a history over years of recurring periods of
mild to moderate depression; of frequent anxiety attacks with tachycardia,
shortness of breath and sweating; of hysterical outbursts of screaming and
weeping with delusional ideation; of suicidal ideation; of frequent nightmares
where dreadful moaning and louder whines of terror can be heard throughout the
house; of periods of confusion and memory loss; of various delusions and
phobias; and of psychiatric care [see psychiatric records and "Nilda Keene:
Personal & Family History, by James Keene, Husband," Feb. 16, 1995; 5 pages;
enclosed herein].  

2.  On Feb. 1, 1995, The Patient, Nilda Margarita Keene (nee Davis-Flores),
abducted our children, James Rogers Keene, 7, and Grace Josephine Keene, 10.

3.  This abduction violated the laws of both the Commonwealth of Dominica and
the United States of America, and included subsequent abductions and
concealments within Puerto Rico and between Puerto Rico and New Jersey.

4.  I, the father, am a United States Citizen and have sole and full custody of
the children now and prior to the abduction.

5.  The abducted (and abused) children have been repeatedly concealed and
detained with the demonstrable assistance of several of Nilda's brothers, of
her sister and of Dr. Vazquez-Davis (as I later learned).
     
6.  The Patient, Nilda, repeatedly reported to me and to others that she was
obtaining medical tests concerning her numerous and varied medical complaints
at the Hospital Lafayette under the supervision of Dr. Vazquez-Davis.  At this
time, The Patient was in such a confused state of consciousness that she could
not even identify the location of Hospital Lafayette, saying it was in "Humacao."

7.  Because of the law violation, on June 28, 1995, the High Court of Justice,
Commonwealth of Dominica, issued Court Order 45, 1995, No. 240, a Writ of Habeas
Corpus Ad Subjiciendum, directing Nilda Keene, the abductor, to produce the
abducted children to the High Court on July 26, 1995, along with the "cause of
their being taken and detained."

8.  On July 26, 1995, failing to respond to this Court Order -- the Writ of
Habeas Corpus and Notice, served to her in both New Jersey and Puerto Rico,
Nilda Keene did not appear with the children at the High Court, and as a result,
the High Court ordered a warrant to be issued for her arrest.

9.  On Sep. 27, 1995.  "WARRANT OF ARREST" for Nilda Margarita Keene nee
Davis-Flores was issued to "All Police Officers," etc. by the High Court of
Justice, Commonwealth of Dominica.

MISMANAGEMENT OF THE PATIENT
With the foregoing background on The Patient and the participation of Dr.
Vazquez-Davis in the ongoing abduction, concealment and detention of the
children, his mismanagement of The Patient will now be summarized:

1.  On March 1, 1995, I wrote to Dr. Vazquez-Davis to emphasize the extreme
urgency of the situation and to provide information on The Patient and on the
fact that the children had been and continued to be abused by The Patient.
The text of these letters is enclosed.  This was done in the following manner.

2.  I called the Hospital Lafayette indicating to the receptionist that I had
confidential information on a patient, Nilda Keene (Davis-Flores), which could
be useful in her evaluation and treatment.   I asked to send this information
to Dr. Vazquez-Davis by fax.  The receptionist gave to me the fax number:
809-839-4330 and said that I could fax The Patient information to Dr.
Vazquez-Davis.  I then faxed the information and also sent copies by mail.

3.   Later, The Patient told me the following.  First, that unauthorized staff
-- perhaps secretaries or whoever, at Hospital Lafayette -- had read this
confidential information sent to Dr. Vazquez-Davis and had gossiped about it.
An explanation of this breach of confidentiality on patient information is in
order.  Second, that Dr. Vazquez-Davis personally delivered to The Patient the
information that I sent and that The Patient had read it and found it to be
disturbing.

4.  Although I am the husband of The Patient and the father of the children
and Dr. Vazquez-Davis was informed of the gravity of the situation and the
abuse of the children, I have yet to receive any reply from him regarding my
letters, The Patient or his actions.

5.  Specifically, his taking of the information directly to The Patient clearly
qualifies as a psychiatric intervention.  By his actions, he placed himself in
the role of the treating physician of a patient who is his near relative
(cousin), contrary to medical guidelines and the law in many states.
Furthermore, a cover sheet for my March 1 faxes stated that "You may wish to
suggest that the physician supervising the medical tests of Nilda and analyzing
the results be some one who is not a relative or family member, if you have not
already done so."  That is, Dr. Vazquez-Davis was reminded at the time of
correct behavior and appears to have consciously decided to behave incorrectly,
and in this instance, unethically and contrary to the best interests of The
Patient, as later events clearly affirm.

6.  As if this were not enough, Dr. Vazquez-Davis also failed to notify Child
Welfare authorities concerning information clearly raising the question of
child abuse, again as required by medical ethics and law in most states.

Again, I would like to pursue this matter to the fullest extent possible and
request to attend any hearings you might hold so that I might present
convincing evidence supporting and establishing the foregoing statements.
I also request the entire file of Hospital Lafayette on The Patient.  The
gravity of the misconduct of Dr. Vazquez-Davis is such that suspension or
removal of the licence to practice medicine seems warranted.

Sincerely,
James J. Keene, Ph.D.
Professor of Neuroscience, Ross University School of Medicine,
PO Box 266, Roseau, Commonwealth of Dominica

CC:  American Medical Association, attorneys Vargas & Ramirez
Enclosed:
(1)  March 1, 1995 fax and mailed letter to Dr. Migdoel Vazquez-Davis citing
  child abuse.
(2)  March 1, 1995 cover sheet to fax to Dr. Migdoel Vazquez-Davis emphasizing
  urgency.
(3)  "Nilda Keene:  Personal & Family History," sent to Dr. Vazquez-Davis,
  among other documents, on March 1, 1995. 

=====
Copyright © 2002 James J. Keene

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