Sarita Shrestha

Complaint template prepared from a public-record review by drtrustmebro.com. The complaint you submit is your own; review and edit every statement before signing. This template is intended for residents or patients of Colorado. It is not legal advice.

In the Matter of:
Sarita Shrestha
License No. [LICENSE NUMBER, IF KNOWN]
1121, Boulder, Colorado, 80306

I. INTRODUCTION

Complainant respectfully submits this complaint to the state licensing board requesting formal investigation and regulatory review concerning Sarita Shrestha (the Respondent), identified in the attached public materials.

The public materials reviewed appear to present representations concerning the identification and management of health conditions, including Treatments for depression, anxiety, other mood disorders, and stress-reduction, Yoga therapy for Heart Disease, Diagnosing and treating psychiatric illness (depression, anxiety), Treating cardiovascular disease (Heart Disease), and Treatments for depression, anxiety, and mood disorders, that may extend beyond the the license held scope in Colorado. The materials also appear to describe paid consultations, care plans, or product sales offered in connection with those representations.

This complaint is based exclusively upon publicly available materials and does not rely upon confidential patient records, privileged communications, or non-public investigative information. The factual observations herein were assembled from an automated public-record review of the Respondent's public website and public registry records, and were reviewed and adopted by the Complainant. All observations are potential, unverified signals from public records; the Board is the sole finder of fact.

The principal public materials reviewed include https://ayurvedicsolutions.com/ and the public registry and license verification sources listed in the exhibit index below.

II. STATEMENT OF FACTS

A. Licensure

Public content appears to address Treatments for depression, anxiety, other mood disorders, and stress-reduction, which the cited rule text suggests may fall outside the listed scope in Colorado. The cited rule treats this as a gray area. Public content appears to address Yoga therapy for Heart Disease, which the cited rule text suggests may fall outside the listed scope in Colorado. The cited rule treats this as a gray area. Public content appears to address Diagnosing and treating psychiatric illness (depression, anxiety), which the cited rule text suggests may fall outside the listed scope in Colorado. The cited rule treats this as a gray area. Public content appears to address Treating cardiovascular disease (Heart Disease), which the cited rule text suggests may fall outside the listed scope in Colorado. The cited rule treats this as a gray area. Public content appears to address Treatments for depression, anxiety, and mood disorders, which the cited rule text suggests may fall outside the listed scope in Colorado. The cited rule treats this as a gray area.

B. Marketing

Publicly posted content appears to make the following representation. QUOTE: "Treatments for depression, anxiety, other mood disorders, and stress-reduction" Publicly posted content appears to make the following representation. QUOTE: "Yoga therapy for Heart Disease" Publicly posted content appears to make the following representation. QUOTE: "Digestive disorders" Publicly posted content appears to make the following representation. QUOTE: "Respiratory disorders (colds, sinus infections, allergies, asthma, etc.)"

C. Clinical Frameworks

Public content appears to address Treatments for depression, anxiety, other mood disorders, and stress-reduction, which the cited rule text suggests may fall outside the listed scope in Colorado. The cited rule treats this as a gray area. Public content appears to address Yoga therapy for Heart Disease, which the cited rule text suggests may fall outside the listed scope in Colorado. The cited rule treats this as a gray area. Public content appears to address Diagnosing and treating psychiatric illness (depression, anxiety), which the cited rule text suggests may fall outside the listed scope in Colorado. The cited rule treats this as a gray area. Public content appears to address Treating cardiovascular disease (Heart Disease), which the cited rule text suggests may fall outside the listed scope in Colorado. The cited rule treats this as a gray area. Public content appears to address Treatments for depression, anxiety, and mood disorders, which the cited rule text suggests may fall outside the listed scope in Colorado. The cited rule treats this as a gray area.

D. Funnel

Public materials appear to describe the following consultation and monetization structure: Kickback/affiliate signals on 1 source(s).

E. Storefront

Public materials appear to describe the following consultation and monetization structure: Kickback/affiliate signals on 1 source(s).

F. Testimonials

Public materials appear to describe the following consultation and monetization structure: Kickback/affiliate signals on 1 source(s).

G. Complainant's Own Experience

[DESCRIBE YOUR OWN EXPERIENCE, IF ANY]

III. AREAS OF CONCERN

COUNT I: PRACTICE BEYOND THE LICENSED SCOPE

Cited authority: the state's professional licensing statutes.

The public materials described in the Statement of Facts above appear to address Treatments for depression, anxiety, other mood disorders, and stress-reduction, Yoga therapy for Heart Disease, Diagnosing and treating psychiatric illness (depression, anxiety), Treating cardiovascular disease (Heart Disease), and Treatments for depression, anxiety, and mood disorders, which the cited rule text suggests may fall outside the the license held scope.

The conduct described above raises substantial concerns under the state's professional licensing statutes and warrants Board investigation.

COUNT II: ADVERTISING AND PUBLIC REPRESENTATION CONCERNS

Cited authority: the state's professional licensing statutes.

The public marketing representations and testimonials described above appear to present the practice's services without consistently identifying the limits of the the license held scope or the practitioner's credentials.

The conduct described above raises substantial concerns under the state's professional licensing statutes and warrants Board investigation.

IV. RELIEF REQUESTED

A. Formal investigation of the conduct described herein, including review of the Respondent's public advertising, website representations, consultation materials, and commercial structures.

B. A determination by the Board of whether the conduct described herein is consistent with the statutes and rules cited above.

C. Such disciplinary action as the Board deems appropriate based on its own investigation and findings, up to the maximum authorized for any violation the Board finds.

D. Corrective relief, where the Board deems appropriate, including requiring the Respondent to correct or remove the specific public representations described above and, if the conduct continues, seeking injunctive relief through a court of competent jurisdiction.

E. To the extent within the Board's authority, review of the revenues derived from the consultations, care plans, and product sales described above, and consideration of restitution for consumers who relied on the representations to their financial or physical detriment.

F. Such other and further relief as the Board deems just and proper to protect the public.

Respectfully submitted,

[YOUR NAME]

[YOUR MAILING ADDRESS]

[YOUR EMAIL AND PHONE]

[DATE]

EDIT BEFORE SENDING

1. Confirm the license number using the license lookup in Exhibit A and fill it in on page 1.
2. Replace every bracketed placeholder with your own information, or delete sections that do not apply.
3. Print and attach dated captures of each exhibit page listed in the exhibit index.
4. Review every factual statement yourself before signing; submit only what you can stand behind.
5. Check the board's current submission rules (online portal, mail, or fax) before sending.

EXHIBIT INDEX