Suleman has previously identified Kamrava as her doctor. The document says his patient became pregnant with octuplets. Suleman gave birth to the world's longest-living set of octuplets on Jan. 26, 2009. She already had six other children.
Kamrava is accused of gross negligence in three instances: transferring too many embryos, repeatedly transferring fresh embryos when frozen ones were available, and failing to refer Suleman for a mental health evaluation.
Kamrava is also accused of giving Suleman too much of a hormone while stimulating in vitro fertilization, poor record keeping and "failure to recognize that N.S.'s behavior was outside the norm and that her conduct was placing her offspring at risk for potential harm."
Calls to Kamrava's office Monday were not returned. However, his attorney Peter Osinoff said fertility patients aren't typically screened for mental health problems "unless there is overt evidence of pathology, and there was not overt evidence of pathology, that will be our argument."
He added that Kamrava wants to continue practicing medicine. Dr. Richard Paulson, who heads the fertility program at the University of Southern California, said it sounds like Kamrava did nothing "to prevent this disaster."
"An octuplet pregnancy, in my opinion, is a disaster," said Paulson, who has no role in the case.
Suleman has said she underwent the in vitro treatment that bore octuplets because she didn't want her frozen embryos to go to waste. However, the complaint said Kamrava never used frozen embryos in her pregnancies, and his lawyer said Suleman requested fresh embryos be used to improve chances of success.
A call to Suleman's lawyer, Jeff Czech, was not returned Monday.
The document reveals Suleman underwent a long series of fertility treatments from 1997 to 2008 under Kamrava's care.
She first went to Kamrava's Beverly Hills office at age 21 and underwent artificial insemination using donor sperm. She failed to get pregnant twice using that method.
In 1999, Suleman consulted with Kamrava about in vitro fertilization. She underwent a procedure similar to IVF, but it led to an ectopic pregnancy. She began hormone therapy in 2000, commonly done before IVF to improve the chances of harvesting a healthy, viable egg. Her first child was born in 2001.
Over the next several years, she repeatedly returned to Kamrava for IVF treatment, usually several months after giving birth, and would freeze the unused eggs.
Kamrava had access to frozen eggs but failed to implant them or recommend that Suleman use them, putting her health at increased risk, the complaint said.
The medical board also alleged that Kamrava "failed to exercise appropriate judgment and question whether there would be harm to her living children and any future offspring should she continue to conceive."
Kamrava continues to advertise his services in Los Angeles' large Iranian expatriate community. For the past nine years, he has paid for airtime on Los Angeles' Iranian radio station, KIRN 670AM, where he hosts a live, weekly call-in show.
Kamrava tells listeners he is the inventor of a method that improves chances of pregnancy by using a hysteroscopy to guide the fertilized egg to the uterine lining and adhering it with an "embryo glue."
On a show last year, he said the process allows an embryo to be implanted "precisely each time instead of dropping an embryo blindly into a uterus and hoping it will take, and praying to God it's in the best place."
The document indicates Suleman agreed to undergo that procedure after failing to get pregnant twice from IVF using fresh eggs.
Kamrava transferred "a number of blastocyst embryos far in excess of" the American Society of Reproductive Medicine's recommendations of one or two embryos, the complaint said.
The document does not specify how many embryos were transferred in each pregnancy.
Suleman's difficulties in earlier pregnancies justified the use of more embryos, said Osinoff.
"There were guidelines but not standards, and the reason they were guidelines is that there were different ways of care, different numbers of embryos would be applicable to different patients," he said.
--- AP Science Writer Alicia Chang contributed to this report.
