AMERICAN PAIN by John Temple Page A

specific guidelines that determined what was a legitimate medical purpose and what was not. Instead, courts must analyze the evidence surrounding each case individually, and to be found guilty of unlawful prescribing of controlled substances, a physician’s illegal activity must be “glaring.”
    In 1978, a federal appeals court had created a list of actions commonly taken by doctors who were writing illegal prescriptions, and the DEA policy said that list was still relevant. Bad docs, according to the policy, tended to write lots of scrips for large numbers of pills. They gave no physical exams. They warned patients to fill their scrips at multiple drugstores. They wrote scrips too often. They called drugs by their street names and generally acted like drug dealers.
    The policy gave a few examples of bad doctors—Chris paid close attention to this part—but their practices were way more blatant and crooked than anything South Florida Pain was doing. One doctor in the policy had given a patient seven to ten prescriptions in different people’s names every week . Another physician had gone to the pharmacy to help his sixteen-year-old patient fill a prescription. Another had driven off the road after injecting himself with Demerol.
    Chris reasoned that South Florida Pain’s doctors could easily sidestep some of these problems by following a few simple rules. They would fill out diagnostic paperwork for every patient. They would schedule patient appointments no closer than twenty-eight days apart. And hopefully, his doctors would generally not let on to anybody if they knew what the patients were doing with the pills.
    However, if Chris was going to make big money, Dr. Gittens and Dr. Joseph had to keep writing big and servicing big numbers. And one thing the policy made very clear was that the DEA reserved the right to investigate any doctor or clinic it wanted to investigate. So Chris wanted to know if there was a trigger number that would cause the DEA to red-flag South Florida Pain as a possible pill mill. Dr. Overstreet had said 240 pills per prescription was the magic number, and the health department investigator had seemed to confirm it. The DEA policy was vague, saying “what constitutes ‘an inordinately large quantity of controlled substances’ . . . can vary greatly from patient to patient,” and that cases against doctors “typically involve facts that demonstrate blatant criminal conduct.”
    The policy gave only the following specific example: “(I)f a physician were to prescribe 1,600 (sixteen hundred) tablets per day of a schedule II opioid to a single patient, this would certainly warrant investigation as there is no conceivable medical basis for anyone to ingest that quantity of such a powerful narcotic in a single day.”
    Sixteen hundred pills a day to a single patient! That example was so over-the-top that it was useless as a guideline. Chris wondered if the DEA purposely left certain information ambiguous, so clinics wouldn’t know how to avoid getting busted.

    A few weeks after the health department inspection, a man stuck his head in the patient window and said he was Juan Ortega, a reporter from the Sun-Sentinel . Ortega had heard about South Florida Pain from a man who drove past the clinic on the way to work each morning. The commuter had noticed the growing lines of patients and called the newspaper about it. Ortega had spoken to the owner of the bridal headpiece shop next door and a law firm up the block. The neighbors were complaining about the long lines and disruptive patients in the parking lots. The reporter had also tried to speak to patients in line, but they wouldn’t talk.
    Chris agreed to the interview, didn’t think much about it. He brought Ortega back to his office, where he had multiple security camera monitors showing various angles of the clinic property. He agreed to let the reporter record the interview on a handheld video camera. Ortega pointed the little camera at