BEFORE THE MEDICAL BOARD OF CALIFORNIA

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Against: )

Charles R. Cooley, M.D.

Physician's and Surgeon's Certificate No. G 78636

Respondent

) ) ) ) ) ) ) ) )

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Case No. 17-2012-222669

DECISION

The attached Stipulated Settlement and Disciplinary Order is hereby adopted as the Decision and Order of the Medical Board of California, Department of Consumer Affairs, State of California.

This Decision shall become effective at 5:00p.m. on October 4, 2013.

IT IS SO ORDERED: September 4, 2013.

MEDICAL BOARD OF CALIFORNIA

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KAMALA D. HARRIS Attorney General of California ROBERT MCKIM BELL Supervising Deputy Attorney General JOHN E. RITTMAYER Deputy Attorney General State Bar No. 67291 California Department of Justice

300 South Spring Street, Suite 1702 Los Angeles, California 90013 Telephone: (213) 897-7485 Facsimile: (213) 897-9395

Attorneys for Complainant

BEFORE THE

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MEDICAL BOARD OF CALIFORNIA DEPARTMENT OF CONSUMER AFFAIRS

STATE OF CALIFORNIA

11 In the Matter of the Accusation Against:

12 CHARLES R. COOLEY, M.D. 4115 Milton Avenue

13 Culver City, California 90232,

14 Physician's and Surgeon's Certificate Numbero G 78636,

Case No. 17-2012-222669

STIPULATED SETTLEMENT AND DISCIPLINARY ORDER

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Respondent.

18 IT IS HEREBY STIPULATED AND AGREED by and between the parties to the above-

19 entitled proceedings that the following matters are true:

20 PARTIES

21 1. Kimberly Kirchmeyer (Complainant) is the Interim Executive Director of the Medical

22 Board of California, Department of Consumer Affairs (Board). She brought this action solely in

23 her official capacity and is represented in this matter by Kamala D. Harris, Attorney General of

24 the State of California, by John E. Rittmayer, Deputy Attorney General.

25 2. Respondent Charles R. Cooley, M.D. (Respondent) is represented in this proceeding

26 by attorney John J. Duran, whose address is: 9200 Sunset Boulevard, PH2, West Hollywood, CA

27 90069.

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STIPULATED SETTLEMENT-Charles R. Cooley M.D. (17-2012-222669)

3. On or about April 13, 1994, the Medical Board of California issued Physician's and

2 Surgeon's Certifie;ate Number G 78636 to Respondent. The Physician's and Surgeon's Certificate

3 was in full force and effect at all times relevant to the charges brought in Accusation No. 17-

4 2012-222669 and will expire on August 31, 2015, unless renewed.

5 JURISDICTION

6 4. Accusation No. 17-2012-222669 was filed before the Board, and is currently pending

7 against Respondent. The Accusation and all other statutorily required documents were properly

8 served on Respondent on as soon as possible July 17,2013.

9 5. A copy of Accusation No. 17-2012-222669 is attached as Exhibit A and incorporated

10 herein by reference.

11 ADVISEMENT AND WAIVERS

12 6. Respondent has carefully read, fully discussed with counsel, and understands the

13 charges and allegations in Accusation No. 17-2012-222669. Respondent has also carefully read,

14 fully discussed with counsel, and understands the effects ofthis Stipulated Settlement and

15 Disciplinary Order.

16 7. Respondent is fully aware of his legal rights in this matter, including the right to a

17 hearing on the charges and allegations in the Accusation; the right to be represented by counsel at

18 his own expense; the right to confront and cross-examine the witnesses against him; the right to

19 present evidence and to testify on his own behalf; the right to the issuance of subpoenas to compel

20 the attendance of witnesses and the production of documents; the right to reconsideration and

21 court review of an adverse decision; and all other rights accorded by the California

22 Administrative Procedure Act and other applicable laws.

23 8. Respondent voluntarily, knowingly, and intelligently waives and gives up each and

24 every right set forth above.

25 CULPABILITY

26 9. Respondent admits the truth of each and every charge and allegation in Accusation

27 No. 17-2012-222669.

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STIPULATED SETTLEMENT -Charles R. Cooley M.D. (17-2012-222669)

10. Respondent agrees that his Physician's and Surgeon's Certificate is subject to

2 discipline and he agrees to be bound by the Board's probationary terms as set forth in the

3 Disciplinary Order below.

4 RESERVATION

5 II. The admissions made by Respondent herein are only for the purposes of this

6 proceeding, or any other proceedings in which the Medical Board of California or other

7 professional licensing agency is involved, and shall not be admissible in any other criminal or

8 civil proceeding.

9 CONTINGENCY

10 12. This stipulation shall be subject to approval by the Medical Board of California.

11 Respondent understands and agrees that counsel for Complainant and the staff of the Medical

12 Board of California may communicate directly with the Board regarding this stipulation and

13 settlement, without notice to or participation by Respondent or his counsel. By signing the

14 stipulation, Respondent understands and agrees that he may not withdraw his agreement or seek

15 to rescind the stipulation prior to the time the Board considers and acts upon it. If the Board fails

16 to adopt this stipulation as its Decision and Order, the Stipulated Settlement and Disciplinary

17 Order shall be of no force or effect, except for this paragraph, it shall be inadmissible in any legal

18 action between the parties, and the Board shall not be disqualified from further action by having

19 considered this matter.

20 13. The parties understand and agree that facsimile copies of this Stipulated Settlement

21 and Disciplinary Order, including facsimile signatures thereto, shall have the same force and

22 effect as the originals.

23 14. In consideration of the foregoing admissions and stipulations, the parties agree that

24 the Board may, without further notice or formal proceeding, issue and enter the following

25 Disciplinary Order:

26 DISCIPLINARY ORDER

27 IT IS HEREBY ORDERED that Physician's and Surgeon's Certificate No. G 78636 issued

28 to Respondent Charles R. Cooley, M.D. (Respondent) is revoked. However, the revocation is

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STIPULATED SETTLEMENT-Charles R. Cooley M.D. (17-2012-222669)

stayed and Respondent is placed on probation for five (5) years on the following terms and

2 conditions.

3 1. CONTROLLED SUBSTANCES -ABSTAIN FROM USE. Respondent shall abstain

4 completely from the personal use or possession of controlled substances as defined in the

5 California Uniform Controlled Substances Act, dangerous drugs as defined by Business and

6 Professions Code section 4022, and any drugs requiring a prescription. This prohibition does not

7 apply to medications lawfully prescribed to Respondent by another practitioner for a bona fide

8 illness or condition.

9 Within 15 calendar days of receiving any lawfully prescribed medications, Respondent

1 0 shall notify the Board or its designee of the: issuing practitioner's name, address, and telephone

11 number; medication name, strength, and quantity; and issuing pharmacy name, address, and

12 telephone number.

13 If Respondent has a confirmed positive biological fluid test for any substance (whether or

14 not legally prescribed) and has not reported the use to the Board or its designee, Respondent shall

15 receive a notification from the Board or its designee to immediately cease the practice of

16 medicine. The Respondent shall not resume the practice of medicine until final decision on an

17 accusation and/or a petition to revoke probation. An accusation and/or petition to revoke

18 probation shall be filed by the Board within 15 days of the notification to cease practice. If the

19 Respondent requests a hearing on the accusation and/or petition to revoke probation, the Board

20 shall provide the Respondent with a hearing within 30 days of the request, unless the Respondent

21 stipulates to a later hearing. A decision shall be received from the Administrative Law Judge or

22 the Board within 15 days unless good cause can be shown for the delay. The cessation of practice

23 shall not apply to the reduction of the probationary time period.

24 Ifthe Board does not file an accusation or petition to revoke probation within 15 days ofthe

25 issuance of the notification to cease practice or does not provide Respondent with a hearing

26 within 30 days of such a request, the notification of cease practice shall be dissolved.

27 2. ALCOHOL - ABSTAIN FROM USE. Respondent shall abstain completely from the

28 use of products or beverages containing alcohol.

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STIPULATED SETTLEMENT -Charles R. Cooley M.D. (17-2012-222669)

If Respondent has a confirmed positive biological fluid test for alcohol, Respondent shall

2 receive a notification from the Board or its designee to immediately cease the practice of

3 medicine. The Respondent shall not resume the practice of medicine until final decision on an

4 accusation and/or a petition to revoke probation. An accusation and/or petition to revoke

5 probation shall be filed by the Board within 15 days of the notification to cease practice. If the

6 Respondent requests a hearing on the accusation and/or petition to revoke probation, the Board

7 shall provide the Respondent with a hearing within 30 days of the request, unless the Respondent

8 stipulates to a later hearing. A decision shall be received from the Administrative Law Judge or

9 the Board within 15 days unless good cause can be shown for the delay. The cessation of practice

10 shall not apply to the reduction of the probationary time period.

11 If the Board does not file an accusation or petition to revoke probation within 15 days of the

12 issuance of the notification to cease practice or does not provide Respondent with a hearing

13 within 30 days of a such a request, the notification of cease practice shall be dissolved.

14 3. BIOLOGICAL FLUID TESTING. Respondent shall immediately submit to

15 biological fluid testing, at Respondent's expense, upon request of the Board or its designee.

16 "Biological fluid testing" may include, but is not limited to, urine, blood, breathalyzer, hair

17 follicle testing, or similar drug screening approved by the Board or its designee. Prior to

18 practicing medicine, Respondent shall contract with a laboratory or service approved in advance

19 by the Board or its designee that will conduct random, unannounced, observed, biological fluid

20 testing. The contract shall require results of the tests to be transmitted by the laboratory or

21 service directly to the Board or its designee within four hours of the results becoming available.

22 Respondent shall maintain this laboratory or service contract during the period of probation.

23 A certified copy of any laboratory test result may be received in evidence in any

24 proceedings between the Board and Respondent.

25 If Respondent fails to cooperate in a random biological fluid testing program within the

26 specified time frame, Respondent shall receive a notification from the Board or its designee to

27 immediately cease the practice of medicine. The Respondent shall not resume the practice of

28 medicine until final decision on an accusation and/or a petition to revoke probation. An

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STIPULATED SETTLEMENT-Charles R. Cooley M.D. (17-2012-222669)

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accusation and/or petition to revoke probation shall be filed by the Board within 15 days of the

notification to cease practice. If the Respondent requests a hearing on the accusation and/or

petition to revoke probation, the Board shall provide the Respondent with a hearing within 30

days ofthe request, unless the Respondent stipulates to a later hearing. A decision shall be

received from the Administrative Law Judge or the Board within 15 days unless good cause can

be shown for the delay. The cessation of practice shall not apply to the reduction of the

probationary time period.

Ifthe Board does not file an accusation or petition to revoke probation within 15 days ofthe

issuance of the notification to cease practice or does not provide Respondent with a hearing

within 30 days of a such a request, the notification of cease practice shall be dissolved.

4. EDUCATION COURSE. Within 60 calendar days of the effective date of this

Decision, Respondent shall submit to the Board or its designee for its prior approval educational

program(s) or course(s) which shall not be less than 20 hours per year, for the first year of

probation. The educational program(s) or course(s) shall be aimed at correcting any areas of

deficient practice or knowledge and shall be Category I certified. The educational program(s) or

course(s) shall be at Respondent's expense and shall be in addition to the Continuing Medical

Education (CME) requirements for renewal oflicensure. Following the completion of each

course, the Board or its designee may administer an examination to test Respondent's knowledge

of the course. Respondent shall provide proof of attendance for 45 hours of CME in that first year

of probation ofwhich 20 hours were in satisfaction ofthis condition.

5. ADDICTIVE BEHAVIOR SUPPORT GROUPS. Within five days ofthe effective

date ofthe Decision, Respondent shall begin attendance at an addictive behavior support group

(e.g. Alcoholics Anonymous, Narcotics Anonymous, Nurse Support Group, AI-Anon, Gamblers

Anonymous). Verified documentation of attendance shall be submitted by Respondent with each

written report as required by the Board. Respondent shall continue attendance in such a group for

the duration of probation.

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STIPULATED SETTLEMENT -Charles R. Cooley M.D. (17-2012-222669)

STANDARD CONDITIONS

2 6. NOTIFICATION. Within seven (7) days of the effective date of this Decision, the

3 Respondent shall provide a true copy of this Decision and Accusation to the Chief of Staff or the

4 Chief Executive Director at every hospital where privileges or membership are extended to

5 Respondent, at any other facility where Respondent engages in the practice of medicine,

6 including all physician and locum tenens registries or other similar agencies, and to the Chief

7 Executive Officer at every insurance carrier which extends malpractice insurance coverage to

8 Respondent. Respondent shall submit proof of compliance to the Board or its designee within 15

9 calendar days.

10 This condition shall apply to any change(s) in hospitals, other facilities or insurance carrier.

11 7. SUPERVISION OF PHYSICIAN ASSISTANTS. During probation, Respondent is

12 prohibited from supervising physician assistants.

13 8. OBEY ALL LAWS. Respondent shall obey all federal, state and local laws, all rules

14 governing the practice of medicine in California and remain in full compliance with any court

15 ordered criminal probation, payments, and other orders.

16 9. QUARTERLY DECLARATIONS. Respondent shall submit quarterly declarations

17 under penalty of perjury on forms provided by the Board, stating whether there has been

18 compliance with all the conditions of probation.

19 Respondent shall submit quarterly declarations not later than 10 calendar days after the end

20 of the preceding quarter.

21 10. GENERAL PROBATION REQUIREMENTS.

22 Compliance with Probation Unit

23 Respondent shall comply with the Board's probation unit and all terms and conditions of

24 this Decision.

25 Address Changes

26 Respondent shall, at all times, keep the Board informed of Respondent's business and

27 residence addresses, email address (if available), and telephone number. Changes of such

28 addresses shall be immediately communicated in writing to the Board or its designee. Under no

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STIPULATED SETTLEMENT -Charles R. Cooley M.D. (17-20 12-222669)

circumstances shall a post office box serve as an address of record, except as allowed by Business

2 and Professions Code section 202I (b).

3 Place of Practice

4 Respondent shall not engage in the practice of medicine in Respondent's or patient's place

5 of residence, unless the patient resides in a skilled nursing facility or other similar licensed

6 facility.

7 License Renewal

8 Respondent shall maintain a current and renewed California physician's and surgeon's

9 license.

I 0 Travel or Residence Outside California

II Respondent shall immediately inform the Board or its designee, in writing, oftravel to any

I2 areas outside the jurisdiction of California which lasts, or is contemplated to last, more than thirty

I3 (30) calendar days.

I4 In the event Respondent should leave the State of California to reside or to practice

I5 Respondent shall notify the Board or its designee in writing 30 calendar days prior to the dates of

I6 departure and return.

I7 Il. INTERVIEW WITH THE BOARD OR ITS DESIGNEE. Respondent shall be

I8 available in person upon request for interviews either at Respondent's place of business or at the

I9 probation unit office, with or without prior notice throughout the term of probation.

20 12. NON-PRACTICE WHILE ON PROBATION. Respondent shall notify the Board or

2I its designee in writing within 15 calendar days of any periods of non-practice lasting more than

22 30 calendar days and within 15 calendar days of Respondent's return to practice. Non-practice is

23 defined as any period of time Respondent is not practicing medicine in California as defined in

24 Business and Professions Code sections 2051 and 2052 for at least 40 hours in a calendar month

25 in direct patient care, clinical activity or teaching, or other activity as approved by the Board. All

26 time spent in an intensive training program which has been approved by the Board or its designee

27 shall not be considered non-practice. Practicing medicine in another state of the United States or

28 Federal jurisdiction while on probation with the medical licensing authority of that state or

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STIPULATED SETTLEMENT-Charles R. Cooley M.D. (17-2012-222669)

jurisdiction shall not be considered non-practice. A Board-ordered suspension of practice shall

2 not be considered as a period of non-practice.

3 In the event Respondent's period of non-practice while on probation exceeds 18 calendar

4 months, Respondent shall successfully complete a clinical training program that meets the criteria

5 of Condition 18 ofthe current version ofthe Board's "Manual ofModel Disciplinary Orders and

6 Disciplinary Guidelines" prior to resuming the practice of medicine.

7 Respondent's period of non-practice while on probation shall not exceed two (2) years.

8 Periods of non-practice will not apply to the reduction of the probationary term.

9 Periods of non-practice will relieve Respondent of the responsibility to comply with the

10 probationary terms and conditions with the exception of this condition and the following terms

11 and conditions of probation: Obey All Laws; and General Probation Requirements.

12 13. COMPLETION OF PROBATION. Respondent shall comply with all financial

13 obligations (e.g., restitution, probation costs) not later than 120 calendar days prior to the

14 completion of probation. Upon successful completion of probation, Respondent's certificate shall

15 be fully restored.

16 14. VIOLATION OF PROBATION. Failure to fully comply with any term or condition

17 of probation is a violation ofprobation. If Respondent violates probation in any respect, the

18 Board, after giving Respondent notice and the opportunity to be heard, may revoke probation and

19 carry out the disciplinary order that was stayed. If an Accusation, or Petition to Revoke Probation,

20 or an Interim Suspension Order is filed against Respondent during probation, the Board shall have

21 continuing jurisdiction until the matter is final, and the period of probation shall be extended until

22 the matter is final.

23 15. LICENSE SURRENDER. Following the effective date of this Decision, if

24 Respondent ceases practicing due to retirement or health reasons or is otherwise unable to satisfy

25 the terms and conditions of probation, Respondent may request to surrender his or her license.

26 The Board reserves the right to evaluate Respondent's request and to exercise its discretion in

27 determining whether or not to grant the request, or to take any other action deemed appropriate

28 and reasonable under the circumstances. Upon formal acceptance of the surrender, Respondent

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STIPULATED SETTLEMENT-Charles R. Cooley M.D. (17-2012-222669)

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shall within 15 calendar days deliver Respondent's wallet and wall certificate to the Board or its

designee and Respondent shall no longer practice medicine. Respondent will no longer be subject

to the terms and conditions of probation. If Respondent re-applies for a medical license, the

application shall be treated as a petition for reinstatement of a revoked certificate.

16. PROBATION MONITORING COSTS. Respondent shall pay the costs associated

with probation monitoring each and every year of probation, as designated by the Board, which

may be adjusted on an annual basis. Such costs shall be payable to the Medical Board of

California and delivered to the Board or its designee no later than January 31 of each calendar

year.

ACCEPTANCE

I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

discussed it with my attorney, John J. Duran. I understand the stipulation and the effect it will

have on my Physician's and Surgeon's Certificate. I enter into this Stipulated Settlement and

Disciplinary Order voluntarily, knowingly, and intelligently, and agree to be bound by the

Decision and Order of the Medical Board of Ca ·

DATED: '7·· 23 ~ Z\1 Y3

20 I have read and fully discussed with Respondent Charles R. Cooley, M.D. the terms and

21 conditions and other matters contained in the above Stipulated Settlement and Disciplinary Order.

22 I approve its form and content.

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DATED:

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STIPULATED SETTLEMENT-Charles R. Cooley M.D. (17-2012-222669)

/ENDORSEMENT

2 The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

3 submitted for consideration by the Medical Board of California ofthe Department of Consumer

4 Affairs.

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Respectfully submitted,

KAMALA D. HARRIS Attorney General of California ROBEI\T MCKIM BELL Supervising Dj:puty Attorney General

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Deputy Attorney General Attorneys for Complainant

STIPULATED SETTLEMENT-Charles R. Cooley M.D. (17-2012-222669)

Exhibit A

Accusation No. 17-2012-222669

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KAMALA D. HARRIS Attorney General of California ROBERT MCKIM BELL Supervising Deputy Attorney General JOHN E. Rl1TMA YER

Deputy Attorney General State Bar No. 67291 California Department of Justice

300 So. Spring Street, Suite 1702 Los Angeles, CA 90013 Telephone: (213) 897-7485 Facsimile: (213) 897-9395

Attorneys for Complainant

BEFORE THE MEDICAl. BOARD OF CALIFORKIA

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

11 In the Matter of the Accusation Against: Case No. 17-2012-222669

ACCUSATION 12 CHARLES R. COOLEY, M.D.

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4115 Milton A venue Culver City, California 90232

Physician's and Surgeon's Certificate G 78636,

Respondent.

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18 Complainant alleges:

19 PARTffiS

20 1. Kimberly Kirchmeycr (Complainant) brings this Accusation solely in her official

21 capacity as the Interim Executive Director of the Medical Board of California (Board).

22 2. On or about /\pri113, 1994, the Board issued Physician's and Surgeon's Certificate

23 number G 78636 to Charles R. Cooley, M.D. (Respondent). That Physician's and Surgeon's

24 Certificate was in full force and effect at all times relevant to the charges brought herein and will

25 expire on August 31,2015, unless renewed.

26 JURISDICTION

27 3. This Accusation is brought before the Board under the authority of the following

28 laws. All section references are to the Business and Professions Code unless otherwise indicated.

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Accusation

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4. Section 490 of the Code provides, in pertinent part, that a board may suspend or

revoke a license on the ground that the licensee has been convicted of a crime substantially

related to the qualitl.cations, functions, or duties of the business or profession for which the

license was issued.

5. Section 2004 of the Code states in part:

"The board shall have the responsibility for the following:

7 "(a) The enforcement of the disciplinary and criminal provisions of the Medical Practice·

8 Act.

9 "(b) The administration and hearing of disciplinary actions.

10 "(c) Carrying out disciplinary actions appropriate to findings made by a panel or an

11 administrative law judge.

12 "(d) Suspending, revoking, or otherwise limiting certificates after the conclusion of

13 disciplinary actions.

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15 6. Section 2227 of the Code provides that a licensee who is found guilty under the

16 Medical Practice Act may have his or her license revoked, suspended for a period not to exceed

17 one year, placed on probation and required to pay the costs of probation monitoring, or such other

18 action taken in relation to discipline as the Division deems proper.

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7. Section 2236 of the Code in part states:

"(a) The conviction of any offense substantially related to the qualifications, functions, or

duties of a physician and surgeon constitutes unprofessional conduct within the meaning of this

chapter [Chapter 5, the Medical Practice Act]. The record of conviction shall be conclusive

evidence only of the fact that the conviction occurred.

"

"(d) A plea or verdict of guilty or a conviction after a plea of nolo contendere is deemed to

be a conviction within the meaning of this section and Section 2236.1. The record of conviction

shall be conclusive evidence ofthe fact that the conviction occurred."

8. Section 2237 of the Code states:

2 Accusation

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"(a) The conviction of a charge of violating any federal statutes or regulations or any

statute or regulation of this state, regulating dangerous drugs or controlled substances, constitutes

unprofessional conduct. The record of the conviction is conclusive evidence of such

unprofessional conduct. A plea or verdict of guilty or a conviction following a plea of nolo

contendere is deemed to be a conviction within the meaning of this section.

"(b) Discipline may be ordered in accordance with Section 2227 or the Division of

Licensing may order the denial of the license when the time for appeal has elapsed, or the

judgment of conviction has been affirmed on appeal, or when an order granting probation is made

suspending the imposition of sentence, irrespective of a subsequent order under the provisions of

Section 1203.4 of the Penal Code allowing such person to withdraw his or her plea of guilty and

to enter a plea of not guilty, or setting aside the verdict of guilty, or dismissing the accusation,

complaint, information, or indictment."

CAUSE FOR DISCIPLINE

(Conviction of Drug Crime)

9. Respondent is subject to disciplinary action under sections 490, 2236 and 2237 of the

Code in that he was convicted of a crime of violating a statute regulating controlled substances

which is also a crime which is substantially related to the qualifications, functions or duties of the

Respondent. The circumstances are as follows:

10. On or about August 10,2012, in an action in Los Angeles County Superior Court

titled The People ofthe State ofCal!fornia v. Charles Randall Cooley, case number SA080538,

Respondent was convicted on a plea of nolo contendere of one count of possession of cocaine in

violation of Health and Safety Code section 11350, subdivision (a).

PRAYER

WHEREFORE, Complainant requests that a hearing be held on the matters herein alleged,

and that following the hearing, the Medical Board of California issue a decision:

1. Revoking or suspending Physician's and Surgeon's Certificate Number G 78636,

issued to Charles R. Cooley, M.D.;

2. Revoking, suspending or denying approval of his authority to supervise physician

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Accusaticn

assistants, pursuant to section 3527 of the Code;

2 3. Ordering him, if placed on probation, to pay the Medical Board of California the costs

3 of probation monitoring and

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4. Taking such other and further action as deemed necessary and proper.

6 DATED: July17,2013

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610441 ll.doc

I ' __ i__j_,C' .:• __ ___:_...:__ __________ -1

KIMBf:H1.Y KIRCHMEYER Interim Executive Director Medical Board of California Department of Consumer Affairs State of California

Complainant

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Accusation