v.- - The Patient Safety League4patientsafety.org/documents/Strydom, Richel Yolandi 2019-05-28.pdf · 1 XAVIER BECERRA Attorney General of California 2 ·ALEXANDRA M. ALVAREZ Supervising

1 XAVIER BECERRA Attorney General of California

2 ·ALEXANDRA M. ALVAREZ Supervising Deputy Attorney General

3 JOSEPH F. MCKENNA III Deputy Attorney General

4 State Bar No. 231195 600 West Broadway, Suite 1800

5 San Diego, California 92101 P.O. Box 85266

6 San Diego, California 92186-5266 Telephone: (619) 738-9417

7 Facsimile: (619) 645-2061

8 Attorneys for Complainant

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BEFORE THE

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. OFFICE OF ADMINISTRATIVE HEARINGS STATE OF CALIFORNIA

KIMBERLY KIRCHMEYER, Executive Director, Medical Board of California, Department of Consumer Affairs, State of California,

v.-Petitioner,

RICHEL YOLANDI STRYDOM, M.D. 9628 Terra Linday Way Calimesa, California 92320-2080

Physician's and Surgeon's Certificate No. Al27315,

Respondent.

Case No. 800-2018-041291

STIPULATION OF THE PARTIES RE INTERIM ORDER IMPOSING LICENSE RESTRICTIONS AND ORDER

22 11-----------------~

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

24 entitled proceedings that the following matters are true:

25 PARTIES

26 1. Kimberly Kirchmeyer (Petitioner) is the Executive Director of the Medical Board of

27 California and is represented in the above-entitled matter by Xavier Becerra, Attorney General of

28 the State of California, and by Deputy Attorney General Joseph F. McKenna III.

1 -------------STIP--UL-A_T_l_O~N OF THE PARTIES RE INTERIM ORDER IMPOSING

LICENSE RESTRICTIONS AND ORDER (800-2018-041291)

2. Respondent Richel Yolandi Strydom, M.D., (Respondent) is representing herself in

2 this proceeding and has chosen not to exercise her right to be represented by counsel.

3 JURISDICTION

4 3. On or about September 10, 2013, the Board issued Physician's and Surgeon's

5 Certificate No. A127315 to Richel Yolandi Strydom, M.D. (Respondent). The Physician's and

6 Surgeon's Certificate was in full force and effect at all times relevant to the charges brought in

7 Interim Suspension Order No. 800-2018-041291, and will expire on April 30, 2021, unless

8 renewed.

9 4. Pursuant to the provisions of California Government Code section 11529, an

10 administrative law judge of the Medical Quality Hearing Panel established pursuant to section

11 11371 may issue an interim order suspending a license, or imposing drug testing, continuing

12 education, supervision of procedures, or other license restrictions. Interim orders may be issued

13 only if the affidavits in support of the petition show that the licensee has engaged in, or is about to

14 engage in, acts or omissions constituting a violation of the Medical Practice Act or the

15 appropriate practice act governing each allied health profession, or is unable to practice safely due

16 to a mental or physical condition, and that permitting the licensee to continue to engage in the

17 profession for which the license was issued will endanger the public health, safety, or welfare.

18 Interim orders may also be issued without notice if it appears from the facts shown by affidavit

19 that serious injury would result to the public before the matter can be heard on notice.

20 FACTUAL BASIS FOR INTERIM ORDER IMPOSING LICENSE RESTRICTIONS

21 5. Respondent admits that Petitioner could estaplish aprimafacie case establishing that

22 Respondent is presently unable to practice medicine safely without restrictions due to a mental or

23 physical condition and that permitting her to continue to practice medieine without restrictions

24 would endanger the public health, safety and welfare. The admissions made by Respondent

25 herein are only for the purposes of this Interim Suspension Order proceeding, and shall not be

26 admissible in any other criminal or civil proceeding.

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2 STIPULATION OF TIIB PARTIES RE IN1ERIM ORDER IMPOSING


6. Respondent agrees to the issuance of an Interim Order Imposing License Restrictions

2 under Government Code section 11529 immediately restricting her Physician's and Surgeon's

3 Certificate No. Al27315 as detailed in paragraph 8, below.

4 7. In exchange for Respondent's admissions, above, Petitioner agrees to file this

5 stipulation in lieu of filing a petition for interim order of suspension and supporting affidavits,

6 with the Office of Administrative Hearings in San Diego, California.

7 8. _Based on the foregoing stipulations and agreements, the parties hereby stipulate

8 and agree that an interim order imposing the following license restrictions on Respondent's

9 Physician's and Surgeon's Certificate No. A127315 should be issued forthwith by the Office of

1 O Administrative Hearings, in order to protect the public health, safety and welfare. The parties

11 further stipulate and agree that, once this interim order imposing license restrictions is issued by

12 tlie Office of Administrative Hearings, Respondent shall be required to fully comply with the

13 following license restrictions until issuance of a final decision by the Medical Board of California

14 on an Accusation to be filed against.her, or until further order from the Office of Administrative

15 Hearings:

16 . A. ALCOHOL - ABSTAIN FROM USE.

17 Respondent shall abstain completely from the use of products or beverages

f 8 containing alcohol.

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

20 Respondent shall receive a notification from ~he Board o~ its designee to immediately

21 cease the practice of medicirle. The Respondent shall not resume the practice of

22 medicine until the final decision on an accusation is effective.

23 B. CONTROLLED SUBSTANCES - ABSTAIN FROM USE.

24 Respondent shall abstain completely from the personal use or possession of

25 controlled substances as defined in the California Uniform Controlled Substances Act,

26 dangerous drugs as defined by Business and Professions Code section 4022, and any

27 drugs reql,liring a prescription. This prohibition does not apply to medications lawfully

28 prescribed to Respondent by another practitioner for a bona fide illness or condition.

3 STIPULATION OF THE PARTIES RE INTERIM ORDER IMPOSING


1 Within fifteen (15) caiendar days ofreceiving any lawfully prescribed

2 medications, Respondent shall notify the Board or its designee of the: issuing

3 practitioner~s name, address, and telephone number; medication name, strength, and

4 quantity; and iss1.dng pharmacy name, address, and telephone. number.

5 If Respondent has a confirmed positive biological fluid test for any substance

6 (whether or not legally prescribed) and has not reported the use to the Board or its

7 designee, Respondent shall receive a notification from the Board or its designee to

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

9 practice of medicine until the final decision on an accusation is effective .

10 . C. BIOLOGICAL FLUID TESTING.

11 Respondent shall immediately submit to random biological fluid testing, at

12 Respondent's expense, upon request of the Board or its designee. "Biological fluid

13 testing" may include, but is not limited to, urine, blood, breathalyzer, .hair follicle

14 testing, or similar drug screening approved by the Board or its designee. Respondent

15 shall make daily contact with the Board or its designee to determine whether

16 biological fluid testing is required. Respondent shall be tested on the date of the

17 notification as directed by the Board or its designee. The Board may order a r

18 Respondent to undergo a biological fluid test on any day, at any time, including

19 weekends and holidays. Except when testing on a specific date as ordered by the

20 Board or its designee, the scheduling of biological fluid testing shall be done on a

21 random basis. The cost'ofbiological fluid testing shall be borne by the Respondent. · ·

22 Prior to practicing medicine, Respondent shall contract with a laboratory or

23 service, approved in advance by the Board or its designee, that will conduct random~

24 unannounced, observed, biological fluid testing and meets all of the following

25 standards:

26 (a) Its specimen collectors are either certified by the Drug and Alcohol Testing

27 Industry Association or have completed the training required to serve as a collector

28 for the United States Department of Transportation.

4 · STIPULATION OF THE PARTIES RE INTERIM ORDER IMPOSING


(b) Its specimen collectors Gonform to the current United States Department of

2 Transportation Specimen Collection Guidelines.

3 (c) Its testing locations comply with the Urine Specimen Collection Guidelines

4 published by the United States Department of Transportation without regard to the

5 type of test administered.

6 (d) Its specimen collectors observe the collection oftestirig specimens.

7 ( e) Its laboratories are certified and accredited by the United States Department

8 of Health and Human Services.

9 (:f) Its testing locations shall submit a specimen to a laboratory within one (1)

1 o business day of receipt and all specimens collected shall be handled pursuant to chain

11 of custody procedures. The laboratory shall process and analyze the specimens and

12 provide legally defensible test results to the Board within seven (7) business days of

13 receipt of the specimen. The Board will be notified of non-negative results within

14 one (1) business day and will be notified of negative test results within seven (7)

15 business days.

16 (g) Its testing locations possess all the materials, equipment, and technical

17 expertise necessary in order to test Respondent on any day of the week.

18 (h) Its testing locations are able to scientifically test for urine, blood, and hair

19 specimens for the detection of alcohol and illegal and controlled substances.

20 (i) It maintains testing sites located throughout California.

21 G) It maintains an automated 24-hour toll-free telephone system and/or a

22 secure on-line computer database that allows the Respondent to check in daily for

23 testing.

24 (k) It maintains a secure, HIP AA-compliant website or computer system that

25 allows staff access to drug test results and compliance reporting information that is

26 available 24 hours a day.

27 (l) It employs or contracts with toxicologists that are licensed physicians and

28 have knowledge of substance abuse disorders and the appropriate medical training to



interpret and evaluate laboratory biological fluid test results, medical histories, and

2 any other information relevant to biomedical information.

3 (m) It will not consider a toxicology screeri to be negative if a positive result is

4 obtained while practicing, even if the Respondent holds a valid prescription for the

5 substance.

6 Prior to changing testing locations for any reason, including during vacation or

7 other travel, alternative testing locations must be approved by the Board and meet the

8 requirements above.

9 The contract shall require that the laboratory directly notify the Board or its

10 designee of non-negative results within one (1) business day and negative test results

11 within seven (7) business days of the results becoming available. Respondent shall

12 maintain this. laboratory or service contract dming the period of probation.

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

14 proceedings between the Board and Respondent. .

15 If a biological fluid test result indicates Respondent has used, consumed,

16 ingested, or administered to herself a prohibited substance, the Board shall order

17 Respondent to cease practice and instruct Respondent to leave any place of work

18 where Respondent is practicing medicine or providing medical services. The Board

19 shall immediately notify all of Respondent's employers, supervisors and work

20 monitors, if any, that Respondent may not practice medicine or provide medical

21 services while the cease-practice order is in effect.

'22 A biological fluid test will not be considered negative if a positive r~sult is

23 obtained while practicing, even if the practitioner holds a valid prescription for the

24 substance. If no prohibited substance use exists, the Board shall lift the cease-

25 practice order within one (1) business day.

26 After the issuance of a cease-practice order, the Board shall determine whether

27 .. the positive biological fluid test is in fact evidence of prohibited substance use by

28 consulting with the specimen collector and the laboratory, communicating with the

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STIPULATION OF THE PARTIES RE INTERIM ORDER IMPOSING LICENSE RESTRJCTIONS AND ORDER (800-2018-041291)

I licensee, her treating physician(s). other health care provider, or group f'acilitator, as

2 applicable.

3 For purposes of this condition, the terms "biological fluid testing" and "testing"

4 mean the acquisition and chemical analysis of a Respondent's urine, blood, bre~th, or

5 hair.

6 For purposes of this condition, the term "prohibited substance" means an illegal

7 drug, a lawful drug not prescribed or ordered by an appropriately licensed. health care

8 provider for use by Respondent and approved by the Board, alcohol, or any other

9 substance the Respondent has been instructed by the Board not to use, consume,

1 O ingest, or administer to herself.

11 If the Board confirms that a positive biological fluid test is evidence of use of a

12 prohibited substance, Respondent has committed a major violation, as defined in

13 section 1361.52(a), and the Board shall impose any or all of the consequences set

14 forth in section 136 l .52(b ), in addition to ·any other terms or conditions the Board

15 determines are necessary for public protection or to enhance Respondent's

16 rehabilitation.·

17 D. SUBSTANCE ABUSE SUPPORT GROUP MEETINGS;

18 Within seven (7) days of the date of issuance by the Office of Administrative

19 Hearings of this Interim Order Imposing Licerise_Restric.tions, Respondent shall

20 submit to the Board or its designee, for its prior approval, the name of a substance

21 abuse support group which she shall attend for the duration of probation. Respondent

22 shall attend substance abuse support group meetings at least once per week, or as

23 ordered by the Board or its designee. Respondent shall pay .all substance abuse

24 support group meeting costs.

25 The facilitator of the substance abuse support group meeting shall have a

26 minimum of three (3) years experience in the treatment and rehabilitation of

27 substance abuse, and shall be licensed or certified by the state or nationally certified

28 organizations. The facilitator shall not have a current or former financial, personal, or


LICENSE RESTRICTIONS AND ORDER. (800-2018-041291)

1 business relationship with Respondent within the last five (5) years. Respondent's

2 previous participation in a substance abuse group support meeting led by the same

3 facilitator does not constitute· a prohibited current or former financial, personal, or

4 business relationship. ·

5 The facilitator shall provide a signed document to the Board or its designee

6 showing Respondent's name, the group name, the date and location of the meeting,

7 Respondent's attendance, and Respondent's level of participation and progress. The

8 facilitator shall report any unexcused absence by Respondent from any substance

9 abuse support group meeting to the Board, or its designee, within twenty-four (24)

. IO hours of the unexcused absence.

11 E. PSYCHOTHERAPY.


13 Hearings of this Interim Order Imposing License Restrictions, Respondent shall

14 submit to the Board or its designee for prior approval the name and qualifications of a

15 California-licensed board certified psychiatrist or a licensed psychologist who has a

16 doctoral degree in psychology and at least five years of postgraduate experience in

17 the diagnosis and treatment of emotional and mental disorders. Upon approval,

18 Respondent shall undergo and continue psychotherapy treatment, including any

19 modifications to the frequency of psychotherapy~ until the Board 01: its designee

20 deems that no further psychotherapy is necessary.

21 The psychotherapist shall consider any information provided by the Board or its

22 designee and any other information the psychotherapist deems relevant. and shall

23 furnish a written evaluation report to the Board or its designee. Responds::nt shall

· 24 cooperate in providing the psychotherapist with any information and documents that

25 the psychotherapist may deem pertinent.

26 Respondent shall have the treating psychotherapist submit quarterly status

27 reports to the Board or its designee. The Board or its designee may require

28 Respondent to undergo psychiatric evaluations by a Board-appointed board ce1tified



psychiatrist. If, prior to the completion of probation, Respondent is found to be

2 mentally unfit to resume the practice of medicine without restrictions, the Board shall

3 retain continuing jurisdiction over Respondent's license and the period of probation

4 shall be extended until the Board determines that Respondent is mentally fit to

5 resume the practice of medicine without restrictions.

6 Respondent shall pay the cost of all psychotherapy and ps~chiatric evaluations.

7 F. WORK.SITE MONITOR FOR SUBSTANCE-ABUSING LICENSEE.


9 Hearings of this Interim Order Imposing License Restrictions, Respondent shall

10 submit to the Board or its designee for prior approval as a worksite monitor; the name

11 and qualifications of one or rriore licensed physician and surgeon, other licensed

12 health care professional if no physician and surgeon is available, or, as approved by

13 the Board or its designee, a person in a position of authority who is capable of

14 monitoring the Respondent at work.

15 The worksite monitor shall not have a current or former finan~ial, personal, or

16 . familial relationship with Respondent, or any other relationship that could reasonably

17 be expected to compromise the ability of the monitor to render impartial and unbiased

18 reports to the Board or its designee. If it is impractical for anyone but Respondent's

19 employer to serve as the worksite monitor, this requirement may be waived by the

20 Board or its designee, however, under no circumstances shall Respondent's worksite

21 monitor be an employee or supervisee·of the licensee.

22 The worksite monitor shall have an active unrestricted license with no

23 disciplinary action within the last five (5) years, and shall sign an affirmati?n that he

24 or she has reviewed the terms and conditions of Respondent's disciplinary order and

25 agrees to monitor Respondent as set forth by the Board or its designee.

26 Respondent shall pay all worksite monitoring costs.

27 The worksite monitor shall have face-to-face contact with Resp~ndent in the

28 work environment on as frequent a basis as determined by the Board or its designee,



but not less than once per week; interview other staff in the office regarding

2 Respondent's behavior, ifrequested by the Board or its designee; and review

3 Respondent's work attendance.

4 The worksite monitor shall verbally report any suspected substance abuse to the

5 Board and Respondent's employer or supervisor within one (1) business day of

6 occurrence. If the suspected substance abuse does not occur during the Board's

7 normal business hours, the verbal report shall be made to the Board or its designee

. 8 within one (1) hour of the next business day. A written report that incl~des the date,

9 time, and location of the suspected abuse; Respondent's actions; and any other

1 O information deemed important by the worksite monitor shall be submitted to the

11 Board or its designee within forty-eight (48) hours of the occurrence.

12 The worksite monitor shall complete and submit a written report monthly or as

13 directed by the Board or its designee which shall include the following: (1)

14 Respondent's name and Physician's and Surgeon's Certificate number; (2) the

15 worksite monitor's name and signature; (3) the worksite monitor's license number, if

16 applicable; (4) the location or location(s) of the worksite; (5) the dates Respondent

17 had face-to-face contact with the worksite monitor; (6) the names of worksite staff

18 interviewed, if applicable; (7) a report of Respondent's work attendance; (8) any

19 change ill Respondent's behavior an~or personal habits; and (9) any indicators that

. 20 can lead to suspected substance abuse by Respondent. Respondent shall complete

21 any required consent forms and execute agreements with the approved worksite

22 monitor and the Board, or its designee, authorizing the Board, or its designee, am;l

23 worksite monitor to exchange information.

24 If the worksite monitor resigns or is no longer available, Respondent shall,

25 within five (5) calendar days of such resignation or unavailability, submit to the

26 Board or its designee, for prior approval, the name and qualifjcations of a

27 replacement monitor who will be assuming that responsibility within fifteen (15)

28 calendar days. If Respondent fails to obtain approval of a replacement monitor within

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STIPULATION OF THE PARTIES RE INTERIM ORDER L.\1POSING LICENSE RESTRICTIONS AND ORDER(800-2018-041291)

1 sixty (60) calendar days of the resignation or unavailability of the monitor,

2 Respondent shall receive a notification from the Board or its designee to cease the

3 practice of medicine within three (3) calendar days after being so notified. ·

4 Respondent shall cease the practice of medicine until a replacement monitor is

5 approved and assumes monitoring responsibility.

6 G. NOTIFICATION.


8 Hearings of this Interim Order Imposing License Restrictions, the Respondent shall

9 provide a true copy of the Interim Order Imposing License Restrictions to the Chief

1 O of Staff or the Chief Executive Officer at every hospital where privileges or

11 membership are ·extended to Respondent, at any other facility where Respondent

12 engages in the practice of medicine, including all physician and locurn tenens

13 registries or other similar agencies, and to the Chief Executive. Officer at every

14 insurance carrier which extends malpractice insurance coverage to Respondent.

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

16 fifteen (15) calendar days.

17 This condition shall apply to any change(s) in hospitals, other facilities or

18 insurance carrier.

19 H. VIOLA TION(S) OF INTERIM ORDER IMPOSING LICENSE

20 RESTRICTIONS.

21 Any violation of this Interim Order Imposing License Restrictions by

22 Respondent shall constitute unprofessional conduct and grounds for disciplinary

23 action.

24 9. Any motion to vacate the Interim Order Imposing License Restrictions issued in

25 this case shall be filed in accordance with the provisions of Title 1, California Code of

26 Regulations, sections 1006 and 1022. However, no such motion may be heard on an ex parte

27 basis and any motion to vacate the Interim Order Imposing License Restrictions issued in this

28 case shall be served on Respondent's counsel and filed with the Office of Administrative



1 Hearings no less than thirty (30) business days prfor to any hearing on the motion. Once served

2 and filed, no such motion shall be decided without first affording the parties the opportunity to

3 · present oral argument.

4 WAIVERS

5 10. Respondent is fully aware of all of her rights under California Government Code

6 section 11529, subdivision (d), to a noticed hearing on the issue of whether an interim order of

7 license restrictions should be issued in the above-entitled matter, and all other rights accorded her

8 under California Government Code section 11529, subdivision (d), at which she is entitled, at a

9 minimum, to all the following rights:

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(a) To be represented by counsel.

(b) To have a record made of the proceedings, copies of which may be obtained by

12 the licentiate upon payment of any reasonable charges associated with the record.

13 ( c) To present written evidence in the form of relevant declarations, affidavits, and

14 documents. The discretion of the administrative law judge to permit testimony at the

15 hearing conducted pursuant to this section shall be identical to the discretion of a superior

16 court judge to permit testimony at a hearing conducted pursuant to Section 527 of the

17 Code of Civil Procedure.

18 ( d) To present oral argument.

19 11. Respondent hereby knowingly, intelligently, freely and voluntarily waives and gives

20 up each and every one of the rights set forth and/or referenced in paragraph 10, above.

21 12. Respondent is fully aware of all of her rights under Government Code section

22 11529, subdivisions (f) and (g), which state as follows:

23 "(f) In all cases in which an interim order is issued, and an accusation is not

24 filed and served pursuant to Sections 11503 and 11505 within 30 days of the date

25 on which the parties to the hearing on the interim order have submitted the matter,

26 the order shall be dissolved. Upon service of the accusation the licensee shall

27 have, in addition to the rights granted by this section, all of the rights and

28 privileges available as specified in this chapter. If the licensee requests a hearing



1 on the accusation, the board shall provide the licensee with a hearing within 30

2 days of the request, unless the licensee stipulates to a later hearing, and a decision

3 within 15 days of the date the decision is received from the administrative law

4 judge, or the board shall nullify the interim order previously issued, unless good

s cause can be shown by the Division of Medical Quality for a delay.

6 "(g) If an interim order is issued, a written decision shall be prepared within 15

7 days of the hearing, by the administrative law judge, including findings of fact and

8 a conclusion articulating the connection between the evidence produced at the hearing and

9 the decision reached."

1 o 13~ Respondent hereby knowingly, intelligently, freely and voluntarily waives and gives

11 up each and every one of the rights set forth and/or referenced in paragraph 12, above.

12 ADDITIONAL PROVISIONS

13 14. The parties hereby stipulate that all proceedings in the above-entitled Interim Order

14 hnposing License Restrictions matter shall be conducted at the Office of Administrative

15 Hearings located in San Diego, Califoi;nia.

16 15. The parties further stipulate that copies of this "Stipulation of the Parties Re Interim

J 7 Order Imposing License Restrictions," including copies of signatures appearing thereon, may be

18 used in lieu of originat documents and signatures and, further, that such copies and signature·s

19 shall have the s · e for e and effect as originals.

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XAVIER BECERRA Attorney General of California ALEXANDRA M. ALVAREZ Supervising Deputy Attorney General

~~-=<:::~-, -L. JOSEPHF. MCKENNA III · Deputy Attorney General Attorneys for Petitioner

14

STIPULATION OF THE PARTIES RE INTERIM ORDER IMPOSING LICENSE RESTRICTIONS AND ORDER (800-2018-041291)

INTERIM ORDER IMPOSING LICENSE RESTRICTIONS

2 Based on the foregoing stipulations and agreements, an Interim Order Imposing License ',

3 Restrictions is hereby issued immediately imposing license restrictions on Physician's and

4 Surgeon's Certificate No."Al27315, heretofore issued by the Medical Board of California to

5 Respondent Richel Yolandi Strydom, M.D., and, accordingly, Respondent is hereby immediately

6 ordered to comply with all of the terms, conditions and license restrictions contained in paragraph

7 8, above. This Interim Order Imposing License Restrictions shall remain in full force and effect

8 until issuance of a final decision by the Medical Board of California on an Accusation to be filed

9 against Respondent, or until further order from the Office of Administrative Hearings. Any

10 motion to vacate this Interim Order Imposing License Restrictions shall be filed in accordance

11 with the provisions of Title 1, California Code of Regulations, sections 1006 and 1022. However,

12 no such motion may be heard on an ex parte basis and any motion to vacate this Interim Order

13 Imposing License Restrictions shall be served on Petitioner's counsel and filed with the Office of

14 Administrative Hearings no less than thirty (30) business days prior to any hearing on the motion.

15 Once served and filed, no such.motion shall be decided without first affording the parties the·

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opportunity to present oral argument.

IT IS SO ORDERED this]/_ day of 677< , 2019.

-;£&--f.Hli.JI tJ(' ADMINISTRATIVE LAW JUDGE

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STIPULATION OF THE PARTIES RE INTERIM ORDER IMPOSING LICENSE RESTRICTIONS AND ORDER (800-2018-041291)

Documents

v.- - The Patient Safety League4patientsafety.org/documents/Strydom, Richel Yolandi 2019-05-28.pdf · 1 XAVIER BECERRA Attorney General of California 2 ·ALEXANDRA M. ALVAREZ Supervising