03/05/2014 03:56 EST | Updated 05/05/2014 05:59 EDT

Eve's Laser Clinic clients' allegations detailed in affidavit

An Ottawa woman who performed surgeries at her laser clinic without a medical licence "traumatized" one patient and gave several beers to another while performing a Botox procedure, according to an affidavit filed by an investigator with a Toronto court.

Eve Stewart continues to run Eve’s Laser Clinic out of her west Ottawa home, but the College of Physicians and Surgeons of Ontario will be in court on Thursday in an attempt to get a court order to stop her from giving Botox injections, or performing facelifts and surgeries.

Court documents obtained by CBC News show the extent of the college's investigation into Stewart’s clinic by Heather Carroll, who has been an investigator for the college since 1998.

Carroll said the college, which regulates the medical profession in Ontario, first became aware of Stewart’s clinic in November 2012 but was unable to confirm she had performed a rhinoplasty and a facelift until last month.

The affadavit Carroll filed with the court says another investigator from the college contacted Stewart on March 5, 2013, asking her to immediately stop performing surgeries and injections. She was also asked if she was being helped by a registered medical professional and where she was getting injectable substances.

After a back-and-forth with a lawyer who said he was representing Stewart on a “limited basis,” Carroll said she got permission to start an official investigation June 15, 2013.

As part of that investigation, Carroll said she went to Eve’s Laser Clinic on Sept. 27, 2013, with a private investigator, referred to as Ms. Martin in the affidavit, to ask if she could get a Botox treatment.

Billed for Botox

“Ms. Stewart observed my face in relation to my inquiry and stated she could start with injections to my forehead area. I advised her I would make a decision about Botox following Ms. Martin's Botox injections,” Carroll says in her affadavit.

“During this visit, I observed Ms. Stewart preparing to inject Ms. Martin with a syringe. Just before Ms. Stewart injected the syringe into Ms. Martin's face, I advised Ms. Stewart that I was an investigator with the college and told her she would not be administering this injection.”

Carroll said she asked Stewart to identify the physician who was supervising her, which she said she would only do if she got a letter saying the physician wouldn’t be “harassed, threatened or have his/her licence revoked.”

The investigator says she sent a letter to Stewart asking her to stop performing injections and surgeries and again requesting the name of her supervising doctor. In her reply, Stewart repeated that she would only share the name of the doctor if the physician was protected from the college’s “mafia-like wrath.”

The affidavit also indicates Stewart sent an invoice for the Botox treatment requested but not performed during Carroll’s visit with Ms. Martin.

Patient allegedly given beer

The affidavit also states that on Feb. 10 investigators received an email from an Ottawa doctor saying a colleague from a walk-in clinic told him somebody named “Eve” had performed a rhinoplasty surgery and the patient was looking for antibiotics as “Eve” couldn’t provide them.

Carroll said she got in contact with the patient, whose name wasn’t included in the court document, who told her she met Stewart at a store and she told her that she could fix her “nose problem.”

The affidavit says the woman went to Eve’s Laser Clinic on Feb. 6 for the procedure, which was done by Stewart with the help of her assistant and her son, neither of whom have medical licences. The patient said she was given an “oxygen tube” but there was no heart or blood pressure monitor. The woman told Carroll she felt “a little bit scared” and “traumatized” after the procedure.

Another of Stewart’s former patients called the college on Feb. 13, according to the affidavit, saying she got Botox from Stewart at her clinic about five years ago after hearing about her through a neighbour.

The affidavit said she now has two bumps inside her mouth and lines on her face following the procedure.

She also alleges Stewart “pushed” the injections on her and was given three beers to drink while she had the injections.

Records suggest products illegally imported

Carroll also details in the affadavit the conversations she had with Health Canada about Stewart’s use of Botox.

The document says on March 1, 2013, a Health Canada worker gave Stewart written notice that she couldn’t sell Botox. Stewart responded that she would not be complying with the request.

On Feb. 14 of this year, Carroll said she spoke to a representative from the health-care company Allergan, who said the company sent 12 vials of Botox to Stewart in 2009 with the understanding she was being supervised by a doctor.

The affidavit says the doctor Stewart had named told investigators he had never bought Botox, nor supervised anyone using it.

Carroll says in the affidavit another drug company, Merz, said their records indicated lot numbers found at Eve’s Laser Clinic did not match the numbers for their Canadian inventory and therefore would have to have been illegally imported.

None of these allegations have been proven in court.

Stewart not worried about allegations

Stewart said Wednesday she is not worried about the college's action against her, saying it has no jurisdiction over her.

"I'm not licensed through them," she said.

She also told CBC News she had suffered a brain injury and has had problems with short-term memory, but said that her recovery has given her an "aptitude for medicine."

She also said she has no malpractice insurance, but isn't worried about anything going wrong.

"If I weren't sure 100 per cent what I was doing is right and good, I would be worried. But I'm not worried because what I'm doing is so good," she said.

Ottawa Public Health has issued a temporary cease and desist order for Stewart’s clinic that bans her from using instruments and items that require sterilization, but doesn’t cover single-use instruments that are thrown out after one use.

Ottawa’s Chief Medical Officer of Health Dr. Isra Levy said last week that communication breakdowns happened between the various bodies investigating Eve’s Laser Clinic. He said his office only learned of the investigations being carried out by Health Canada and the College of Physicians and Surgeons of Ontario in February.

On mobile? Click here to read the allegations against Eve Stewart from a College of Physicians and Surgeons of Ontario inspector.