Acknowledgement & Undertaking as signed by Dillon J. Richards (Registration #20382) on December 8, 2022

I, Dillon J. Richards (Reg No. 20382), acknowledge and undertake as follows:

  1. In November 2022, a panel of the Inquiries Complaints and Reports Committee referred allegations involving my conduct, including sexual abuse of a patient, to the Discipline Committee for a hearing (College File Number 2022-0057). The allegations included that in the period January and February 2022, I engaged in sexual communications with a patient by social media including the exchange of nude photographs; engaged in verbal sexual communications with a patient during appointments; and engaged in sexual acts, including oral sex and sexual intercourse, with the patient during the patient’s appointments at the Clinic. The allegations further include that I falsified the patient’s clinical record following the patient reporting to the Clinic, and that in March 2022, I contacted the patient and made efforts to discourage the patient from reporting to the College or continuing with her report to the College. 

  2. This acknowledgment and undertaking does not constitute an admission of any professional misconduct, including sexual abuse. 

  3. I undertake to resign my membership and certificate of registration with the College effective December 14, 2022.

  4. I acknowledge and agree that, in exchange for providing an original copy of this Undertaking executed by me to the College, the College will ask the panel of the Discipline Committee to adjourn the hearing in College File Number 2022-0057, sine die. 

  5. I acknowledge that after I resign my membership with the College, I will not be entitled to use the title “physiotherapist”, “physical therapist” or any abbreviation thereof or equivalent in another language. I will not be entitled to hold myself out as a person who is qualified to practice in Ontario as a physiotherapist/physical therapist and I will not be entitled to imply that I am a physiotherapist/physical therapist in Ontario.

  6. I hereby undertake never to apply or re-apply for membership, registration, licensure or similar status with the College as a physiotherapist or for a license to practice physiotherapy in Ontario.

  7. I acknowledge that if I ever apply or re-apply, or attempt to apply or re-apply for membership, registration, licensure or similar status with the College in the future, the College will be entitled to rely upon this undertaking in any registration or other similar proceeding as reason to deny my application. 

  8. I acknowledge that if I attempt to register as a physiotherapist in another jurisdiction and that regulatory body asks for information about this matter, the College will be entitled to disclose the content of its investigation files with the other jurisdiction.

  9. I acknowledge that if I ever apply or re-apply for membership, registration, licensure or similar status as a physiotherapist for a license to practice physiotherapy in Ontario after December 14, 2022, the College shall, in its sole discretion, have the right to proceed with a disciplinary proceeding on the basis of a breach of this undertaking and, if I am successful in being registered, the College shall also be entitled to proceed with the discipline hearing in case numbers 2022-0057. 

  10. In the event of a breach of this undertaking and the College proceeding with discipline hearing in College File Numbers 2022-0057, I hereby agree to bear the risk of any prejudice that the passage of time might cause to my ability to make full answer and defence, and waive the right to seek any remedy on the basis of the passage of time, should the College proceed with the investigation, the discipline hearing, and any allegations that may arise as a result of any future breach of this Undertaking by me. 

  11. I acknowledge that under section 23 of the Health Professions Procedural Code which is Schedule 2 of the Regulated Health Professions Act, the College is required to publish the fact of my resignation and this Undertaking on the College’s public register. This publication is indefinite.

  12. I acknowledge that I have been advised of my right to obtain legal advice prior to entering into this Undertaking and have either availed myself of that right or chosen not to avail myself of that right.

  13. I acknowledge that I am entering into this undertaking freely, voluntarily and without duress.