New York State Department of Health · Office of Professional Medical Conduct

Not medicine in July. Malpractice in November.

The New York State Police had already called the conduct consensual. The state medical board reviewed it and ruled it was not the practice of medicine. Then a New York Times story ran — and that same board reversed itself and filed a 70-page set of charges against Dr. Danielle Roberts that were demonstrably false.

Nothing about the underlying facts changed between July and November 2017. What changed was a headline. What follows is the documented record of how a state medical board was turned into an instrument of the federal prosecution of Keith Raniere — and used to keep a potential defense witness off the stand. Back to the doorway →

1.Not medicine, and not a crime

In July 2017, Sarah Edmondson — a former member of the women’s group DOS — brought a complaint to New York’s Office of Professional Medical Conduct (OPMC) about a personal, consensual procedure performed by Dr. Danielle Roberts, a physician and DOS member. It had nothing to do with the practice of medicine; the New York State Police had already declined a criminal complaint about the same conduct, telling the women it had been consensual. The OPMC reviewed it and, through its Central Intake Unit, closed the matter in writing:

“The issues you describe did not occur within the doctor-patient relationship… are not medical misconduct… should be reported to law enforcement… no further action will be taken.”OPMC #17-07-4422 · July 11, 2017 · Exhibit A

2.The headline

On October 17, 2017, a New York Times article revealed the existence of DOS. It criticized the OPMC for not acting — and noted that a New York State Police investigator had already told Edmondson and two other women that their criminal complaint would not be pursued because the conduct had been “consensual.”

Two days later, the Times followed up, quoting Richard Azzopardi, spokesman for then-Governor Andrew Cuomo, that officials “plan to review why regulators and others did not act.” No new facts had emerged. The pressure was political and public.

3.Malpractice — the smoking gun

Shortly after the Times coverage, the OPMC reversed itself. On or about November 17, 2017, the Bureau of Professional Medical Conduct served an unsigned, undated 70-page Statement of Charges — now treating the same act it had just called non-medical as failed medicine:

Charged with operating in a non-“appropriately sterile environment,” failing to provide “wound care,” failing to refer the patient to a “specialist,” failing to maintain “medical records” — and with having “tortured and physically abused” the patient.Statement of Charges · November 17, 2017 · Exhibit B

Every one of those is a medical duty. They only exist if the act is the practice of medicine — which this office had ruled, in writing, it was not. A tattoo artist keeps no medical records, runs no sterile operating field, and refers no one to a specialist. You cannot commit malpractice performing an act your own agency ruled was not medicine.

The charges were also false on their face. They alleged misconduct toward 25 individuals — including two who had died of natural causes long before the allegations were compiled, and a dozen women it never happened to — among them Nancy Salzman, NXIVM’s 60-plus-year-old president. They claimed Edmondson repeatedly “requested… that Respondent cease” and believed she was getting “only a tattoo” — both contradicted by Edmondson’s own filmed, consented session, which shows no such requests and which she had watched performed on others beforehand.

The rest is confirmation

Everything after November 2017 confirms what the first three beats establish: the proceeding tracked the federal case, not the practice of medicine.

She was a defense witness

This is why it mattered. Dr. Roberts performed the procedure and was a second-line DOS member — positioned alongside the government’s key accuser, with first-hand evidence that the collateral and the procedure were consensual, not coercion. In her sworn declaration she states she had “key information” that could have “dismantle[d] the Government’s theory of sex trafficking and forced labor” — and that she was “threatened and intimidated into silence” after being told her medical-hearing testimony could be used to build a criminal indictment. The seven women subpoenaed through her case invoked the Fifth Amendment. (Declaration of Danielle Roberts · Exhibit E)

The exhibits

Each exhibit below is the source document, split from the OPMC attachment record and OCR’d so the text is searchable.