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HomeMy WebLinkAbout2009/05/12 Additional InformationTheresa Acerro Public Comments 5/12/09 :~~'. '''''.'' " ". E .~; ,.;-~,.._.:~_.:"" ;"" .s::- /1.,;)/09 jJ /7 "" ~ .~~ '"sm~t"'\~ Healthy Outdoor Dining f~ by P;of)!l1i This is a Smoke Free Open Air Dining Patio Ordnance Number ##### ~\\~~~s {. ' , ~0;'2~ \\ ~"""2!)" i '. fl' / ~ , "" ~//,,~q;; -- smo\\t"" Healthy Outdoor Dining r~by.pfQp&9 Smoke-Free Perimeter: No Smoking Within 50 Feet of Open Air Dining Area Ordinance Number ##### Mr. Mendoza Public Comments 5/12/09 /1)1. /YjeA/p02/}- Honorable Mayor, honorable council member's AMi ~I?,1AJ~~ Congratulations are in order to the Chula Vista Police Departments Special Investigation Unit 6)'I..J.jtJ'l for its fine work in cooperation with the Los Angeles Sheriffs Department that led to the sentencing of Bertha Bugarin'to 6 years 8 months in prison. The residents ofChula Vista should be especially grateful for the diligence of Detective Mike Varga and Sergeant Dale Bourgeois that led to the arrest and conviction of Mrs. Bugarin. Bertha Bugarin was the owner of a Medical Clinic chain called "Clinica Medica Para La Mujer De Hoy". She had clinics in Los Angeles and one here in Chula Vista. Mrs. Bugarin was convicted of performing medical procedures with out a license. The story of Mrs. Bugarin and her clinics have been featured recently in various print and television media. The San Diego Reader featured her story in the February 19th edition. The article and California Medical Board Records indicate that these clinics were a haven for doctors cited for gross negligence, substance abuse and sexual misconduct. Mrs. Bugarin became desperate as the doctors who worked for her lost their licenses or left the I clinics to avoid lawsuits. She decided to pose as a doctor and perform medical procedures herself. We witnessed her going into the clinic when no doctors were present. .- While Mrs. Bugarin was being processed through the legal system a financially bankrupt doctor ')' claimed to be the new owner ofthe clinic. He was on probation with the medical board for various acts of gross medical negligence, his license was eventually revoked. The clinic shut down for several months but then reopened with the same phone number but a different name. The doctor currently at this clinic is, not surprisingly, on 5 years probation with the medical board. His probation stipulates that he is prohibited from the solo practice of medicine. That means he is not to be in the clinic without another doctor being present. Yet no doctor except for him has been seen to enter the clinic. The Medical Board put this doctor on probation for various reasons including gross negligent acts that caused harm to patients including one newborns death, making false statements to cover his negligent acts, altering medical records to cover his negligent acts, scaring patients into unnecessary surgeries and having sex with a patient in his office. . Would a clinic like this be tolerated in La Jolla or Del Mar? We think not. Why is it being tolerated in an area of Chula Vista with primarily Hispanic residents? This situation can be remedied by an ordinance requiring that a doctor who wishes to open a clinic have admitting privileges at a local hospital. Currently eleven states and one county have enacted such ordinances to protect their residents. Please honor your duty of protecting the residents of Chula Vista. Thank You. Luis Mendoza 619-300-5563 .. Contact Info for Dr. Andrew Rutlands Probation Violation Investigation California Medical Board Investigator: Dominic Coluso Phone: 714-247-2133 License Holders: Page I of3 Medical Board of California Licensee Name: License Type: License Number: License Status: 2005 Evergreen Street, Suite 1200 Sacramento, CA 95815 Consumer Information Line: (916) 263-2382 Physician Information ANDREW RUTLAND, MD PHYSICIAN AND SURGEON G24947 LICENSE RENEWED & CURRENT Public Record Actions: LIMITS ON PRACTICE PROBA nON JULY 09, 1973 MA Y 31, 2009 177] WEST ROMNEY A DR STE A ANAHEIM, CA 92801 ORANGE Original Issue Date: Expiration Date: Address: County: Public Disclosure To find out what information is and is not available, please click here. Ifinformation is posted in the Administrative/Disciplinary Actions or Administrative Citation Issued categories below, documents may be available for review. Please click here to search the public document database. Administrative/Disciplinary Action The Medical Board's public disclosure screens are updated periodically as new information becomes available. Please contact the Central File Room at (916) 263-2525 or at 2005 Evergreen Street, Suite 1200, Sacramento, CA 95815, to obtain a copy of public documents at a minimal charge. Case Number: 20 2006 176260 Description of Action: LICENSE SURRENDERED ON 10/24/02; LICENSE http://www2.dca.ca.gov/pls/wllpub/WLLQRYNA$LCEV2.Query View?P _LICENSE _ NUM... 4/9/2009 . License Holders: Page 2 of3 Effective Date of Action: REINSTATED AND PLACED ON FIVE YEARS PROBATION ON 10/25/07 WITH VARIOUS TERMS & CONDITIONS. DR. RUTLAND IS PROHIBITED FROM ENGAGING IN THE SOLO PRACTICE OF MEDICINE. OCTOBER 25, 2007 Administrative Action Taken by Other State or Federal Government No information available from this agency. Felony Conviction No information available from this agency. Misdemeanor Conviction No information available from this agency. Administrative Citation Issued No information available. Hospital Disciplinary Action No information available from this agency. Malpractice Judgment No information available from this agency. Arbitration Award No information available from this agency. Malpractice Settlements . No information available from this agency. Note: "No information available from this agency" may not indicate none exists; but indicates no information has been reported to the Medical Board of California and/or that the Board is unable to post the information on the Web site by law. Education Medical School: HOWARD UNIVERSITY COLLEGE OF MEDICINE Year Graduated: 1969 This information is updated Monday through Friday - Last updated: APR-08-2009 All information provided by the Department o.fConsumer Affairs on this web page. and on its other web pages and internet sites, is made available to provide immediate access for the convenience of interested persons. While the Department believes the infrmnation to be reliable. human or mechanical error remains a possibility. as does delay in the posting or updating of information. Therefore, the Department makes no guarantee as to the accuracy, completeness, timeliness, currency, or correct sequencing of the i,?f{>rmatiol1. Neither the Department, nor any o{the sources of the i'?formation. shall be responsible fiJr any errors or omissions, orjiJr the use or results obtained.fromthe use (J{ this information. Other specific cawionary notices may be included on other web pages maintained by the Department. All access to and use (){this wcb page and any other web http://www2.dca.ca.gov/pls/wllpub/WLLQR YNA$LCEV2.Query View?P _LICENSE _ NUM... 4/9/2009 .',' ..- ~ .,,:... -... ;:' '----- BEFORE THE DMSION OF MEDICAL QUALITY MEDICAL BOARD OF CALIFORNIA DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA In the Matter of the Accusation Against: Physician's and Surgeon's Certificate #G-24947 ) ) ) ) j ) __'_.n ____ __.)._n. ) ) ) Respondent. ) ) Case No: 18-1999-101122 ANDREW RUTLAND, M.D. DECISION AND ORDER The attached Stipulation for Surrender of Physician and Surgeon's Certificate and Physician Assistant Supervisor License is hereby accepted and adopted as the Decision and Order by the Division of Medical Quality of the Medical Board of California, Department of Consumer Mfalrs, State of California. This Decision shall become effective at S:OO p.rn. on October 24. 2002. - - - - -- - - --- --. ~ --'- -.. '. --. _. .._~. .+. IT IS SO ORDERED Sent_bPI 14 7002 MEDICAL BOARD OF CALIFORNIA ~A/~/;J Steven Rubins, M.D. Panel B Division of Medical Qnality '---"' - . ! 1 '----- 2 3 4 5 6 7 THE OBSTETRICAL P A TffiNTS FIRST CAUSE FOR DISCIPLINE (Gross negligence, repeated negligent acts, incompetence) PATmNT K.B. 12. Respondent is subject to disciplinary action under section 2234 of the Code in that he was grossly negligent, incompetent, and/or committed repeated negligent acts in his care and treatment of patients K.B., T.H., and Medical Record No. 365409. The 8 circumstances are as follows: 9 A. On or about July 22, 1999, K.B. went to the Labor and 10 Delivery Unit of the Martin Luther Hospital to have her first haby. She was 33- 11 " ,Y.cilir&'Oklllt:dlll time. She had a history of congenital neurogenic bladdet, and - '" '" 12 ' ' bI!d twoo~.ations as a child for this condition. She had been a patient of ..' t . .' 13 reSpondent's since about June 1999. 14 B. K.B. had spontaneous rupture of her membranes when she '------' 15 came to tbe hospital at about 2:50 am. on July 22,1999. 16 C. Respondent made an admitting note at about 9:00 am. on 17 July 22, 1999, and noted his plan to assist labor with Pitocin. K.B. was dilated 18 about 1-2 em. witb the vertex at 0 sta&ion, and she had variable deceleruUl/IIlI with 19 her contractions. ,t'.," .', 1(:;:),'.:: '. . :, . I 20 21 D. E. K.B. received an epidural at about 11:00 a.m.' K.B. made progress in her labor, and was dilated about 3-4 22 em. at 2:05 p.m. The fetal monitor showed some deep variable decelerations (to 23' 80 bpm) witb the uterine contractions and respondent ordered an amnioinfusion. 24 By 3:47 p.m. K.B. was dilated to 6-7 cm. and still having deep variable 25 decelerations. 26 27 ---- I. Neurogenic bladder means that the bladder is in a state of dysfunction due to lesions of 28 the central or peripheral nervous system. 4 : .--" /"- (' 1 nece~sary. Respondent also increased the danger to patient T.H. and her baby by 2 making multiple punctures with the amniocentesis needle. 3 15. Respondent's care and treatment of Medical Record No. 365409 . 4 constituted gross negligence, incompetence, and/or repeated negligent acts as more particularly 5 set forth in this paragraph. 6 A. Respondent induced the patient in the absence of a vertex 7 presentation. 8 B. Respondent ruptured the membrane with the vertex in the 9 pelvis. 10 11 12 13 14 15 16 17 C. Respondent had the patient push at6 cm when she was _. ; 1l1really.bli..ving decelerations. .'....l .' , D. Respondent failed to perform a crash c-section. Respondent tampered with the medical record by ripping E. out fifteen minutes of the fetal monitor strip. SECOND CAUSE FOR DISCIPLINE 16. (Making False Statements) Respondent is subject to disciplinary action under Code section 2261 in 18 that he made false statements regarding his care and treatment ofK.B.,T.H., and MediCal Record 19 No. 365409. The circumstances are as follows: ., . ."~' <'.:: 20 A. PlIllIlP'IIPh 11 of this Accusation is incorporated by 21 reference and is hereby realleged as if set forth in full. 22 PATIENT K.B. 23 'B. Respondent charted that he tried to effect delivery when the 24 vertex was at +2, when in fact it was at +). . 25 c. Respondent charted that the nuchal cord was tight, when in 26 fact it was'loose. 27 1// 28 III 13 ,~ D. Respondent's chart notes for July 22,1999 and July 23, 2 1999~ were placed in the chart at a later time, and that fact was not recorded in the ; 3 chart by respondent. 4 E. Respondent's chart notes for July 22, 1999 and July 23, 5 1999, were made from the nurses notes rather than respondent's own recollection, 6 and that fact was not recorded in the chart by respondent. 7 PATIENTT.H. 8 F. Respondent falsely noted in the record that he was 9 performing the amniocentesis for bradycardia, when in fact the amniocentesis was 10 planned in advance. .~ II 12 : 13 14 G: Respondent falsely stated that there was a fetal abruption, ,',;~ \"':t:h,', " "'\' ,:,' ..::,::~~ ~,both clinically and pathologically there was no evidence of ,':,: ",oO' atlfupti'On. ~ MEDICAL RECORD NO. 365409 ' < 15 H. Respondent falsely documented the patient's desires 16 regarding having an AFP. 17 THIRD CAUSE FOR DISCIPLINE 18 (Alteration of Medical Records) 19 17. Respondent is subject to disciplinary action under ~;~:l~:_ho' ~. ' '..' .. \. I ,20 altered the medical records of his care and treatment of K.B. , and Medical ~'i.r~: i6~: 21 The circumstances are as follows: 22 A. Paragraph II of this Accusation is incorporated by 23 reference and is hereby realleged as if set forth in full. 24 PATIENT K.B. 25 B. On or about July 23, 1999. respondent removed his original r 26 chart notes regarding his care and treatment of K.B. on July 22, 1999, which 27 28 III consisted of approximately one-half page. 14 ! r--.. (' c Respondent replaced his original one-half page of notes 2 with)wo pages of notes he wrote directly from the nurses notes, 3 MEDICAL RECORD NO. 365409 4 D, Respondent removed fifteen minutes from the fetal monitor 5 strip from the patient's records, 6 7 FOURlH CAUSE FOR DISCIPLINE (Failure to maintain adequate records) 18" Respondent is subject to disciplinary action under section 2266 of the 8 9 I 0 Code in that he fiilled to maintain complete, adequate and accurate records of his ClIIC and ! ,.~ _,:. .... ,~\,~~.lIB<l Medical Rcclord No. 365409. The circUlIlSllllK:es are as follows: I ~".:,#>. \; JWtm~1~0(. " .. 12 '. '. ~);~f :ii' ,:~~\,.:t,:,~;~~t ~. ParagrepI1 11 of this Accusation IS mcorporated by .., ... ,- reference'lilld is hereby realleged as if set forth in full. Il 13 14 PATIENT K.B. IS B. Respondent charted that he tried to effect delivery when the 16 vertex was at +2, when in fact it was at + L 17 18 19 20 c. Respondent charted that the nuchal cord was tight, when in fact it was loose. "',, :~ ' t '. ..' .'.....:l...... ..../.: D. Respondent's chart notes for July 22,1999 and, :.I,"~"~~I~ . ,;,)" ~;;~g~ ~..: 1999, _ piactld in tho chart at a !at<< time, and that filet WlI8 not. "., " ii. ~.; ,'N" . . ~ :(\\"\"" . . . ~ " 21 chart by respondent. 22 E. Respondent's chart notes for July 22, 1999 and July 23, 23 1999, were made from the nurses notes rather than respondent's own recollection, 24 . and that fact was not recorded in the chart by respondent. 25 F. On or about July 23, 1999, respondent removed his original 26 chart noteS regarding his care and treatment of K.B. on July 22, 1999, which 27 28 III consisted of approximately one-half page. 15 r'-. G. Respondent replaced his original one-haIf page of notes withJwo pages of notes he wrote directly from the nurses notes. PATIENT T.H. H. Respondent falsely noted in the record that he was performing the amniocentesis for bradycardia, when in fact the amniocentesis was planned in advance. /. Respondent falsely stated that there was a fetal abroption, when in fact both clinically and pathologically there was no evidence of abruption. MEDICAL RECORD NO. 365409 .:;..~~:~,' . ,.. J. . ~p~m1die patient's records. Respondent removed fifteen minutes from the fetal monitor K. Respondent falsely docwnented the patient's desires regarding having an AFP. F1FTII CAUSE FOR DISCIPLINE (Acts of Dishonesty or Corruption) 19. Respondent is subject to disciplinary action under section 2234(f) of the Code in that he committed acts involving dishonesty or corruption substantially reIate4 to.the CI', . ,_ duties of a physician and surgeon in his care and treatment of K.B. , T.H. and~'Recordl . -.1,""',._ 365409. The circumstances are as follows: A. Paragraph i 1 of this Accusation is incorporated by reference and is hereby realleged as if set forth in full. 23 24 PATIENT K.B. B. Respondent charted tl)at he tried to effect delivery when the 25 vertex was at +2, when in fact it was at + I. 26 c. Respondent charted that the nuchal cord was tight, when in 27 fact it was loose. 28 III 16 ~ , r"-- I 2 3 SIXTH CAUSE FOR DISCIPLINE (General Unprofessional Conduct) : 20. Respondent is subject to disciplinary action under section 2234 of the 4 Code in that he committed general unprofessional conduct' in his care and treatment of K.B., 5 T.H., and Medical Record No. 365409. The circumstances are as follows: 6 A. Paragraph II of this Accusation is incorpomted by 7 reference and is hereby realleged as if set forth in full. - 8 B. Paragraphs 12, 13, and 14 of this Accusation are 9 - incorpomted by reference and are hereby realleged as if set forth in full. 10 TIlE GYNECOLOGICAL PATIENTS II SEVENTH CAUSE FOR DISCIPLINE 12 -.. (Gross negligence, repeated negligent acts, incompetence) 13 21. Respondent is subject to disciplinary action .under section 2234 of-the ~-, 14 Code in that he was grossly negligent, incompetent, and/or committed repeated negligent acts in 15 his care and treatment of patients S.G., D.M-G., L.M., J.S.M., M.P., B.P., D.S., J.L.M., A. Y., 16 B.R., J.W., M.A., BJ.G., and V.G. The circumstances are as follows: 17 PATIENTS.G. 18 A. Respondent fmlt saw S.G. on November 27, 1996,.at.~ch 19 time an office sonogmm was done and was found to show "? adenom~,'~'lk - ..; -;/ '\ 20 fibroids." Respondent told the patient she had adenomyosis and that sbO Woiild 21 "burst and bleed to death" if she did not have the surgery respondent 22 recommended right away. Prior to the surgery S.G. went to the Red Cross and 23 donated her own blood in case she needed it for surgery. 24 B. - On November 13, 1997, respondent saw the patient for 25 right side-pain and was given options of Lupron or "BSO". 26 r-.... , 27 3. General unprofessional conduct is defined as that conduct which breaches the rules or ethical code of a profession, or conduct which is unbecoming a member in good standing of a 28 profession. Shea v. Board of Medical Examiners (1978) 81 Cal.App.3d 564, 578. 18 " -. 1 B. Respondent failed to treat the patient' s co~plaints with a 2 diagnostic laparoscopy. ; 3 C. Respondent lied to the patient about the extent of he 4 endometriosis, lIS the path report showed a minimal to mild case, not an 5 infestation as described by post operatively by respondent 6 D. Respondent scared the patient into having the major 7 surgery by lying about the true nature of her condition. 8 E. Respondent's work. -up of the patient's urinary complaint 9 was inadequate. 10 35. Respondent's care and treatmc;nt ofY.O. constituted gross negligence, 11 ~~:.~.repeated negligent acts as more particularly set forth in this paragraph. . ),,: I . . , ~~ 12 ! !:\';~\,,:,/:. A. Respondent failed to take Y.O. back into surgery given her --' /" '...:; 13 constellation of post operative signs and symptoms. involving an acute abdomen. . ~ 14 15 B. C. Respondent engaged in sexual relations with a patient. Respondent's work-up of the patient's urine loss was 16 inadequate. 17 18 19 20 21 D. Respondent failed to get an intra-operative surgical consult despite the presence of small dense adhesions of the small bowel. EIOlITH CAUSE FOR DISCIPLINE (Dishonest Acts) 36. Respondent is subject to disciplinary action UDder section 2234(e) of the -.: .;-.;!<::.<. " ,I '~f. " '.. t ~ ..1-i~ .1..:fI .' .\.:" 22 Code in that he committed dishonest acts substantially related to the qualifications, functions, or 23 duties of a physician in his care and treatment of patient 8.0., D.M-O., L.M., A. Y., B.R., 1. W., 24 M.A. and B.1.0. The circumstances are as follows: 25 A. Respondent's records for 8.0. falsely indicate the patient 26 refused a transfusion for the December 1996, surgery during which she lost a lot ------- 27 III 28 III 38 ~ 1. Respondent attempted to scare A. Y. into having the surgery recommended by respondent by telling her she would be unable to have children ; with endometriosis, going so far as to recommend she have children out of wedlock. J. Respondent attempted to scare B.R. into having the surgery recommended by respondent by telling her the condition would turn into cancer and that if she did not have the surgery right away it may be too late. K. Respondent scared J. W. into having the major surgery by lying about the true nature of her condition. L. Respondent scared M.A. into having the major surgery by .</,. .JvirUi~.. . ... lllltureofhcrcondition. l~~:\;,: ':i','~~:Dm.w~'.. {'H';' \f,\!'~"J.' \~';1;.:' "'{L'. "\;;{ ,";'" (\~):: . ,::> '\~'i,,;,'~';:r:.f~~~\,~'M; Respondent lied to the patient about the extent of her :',", ~.,..'"' '.;/. '\'1'. '':. .' endOirii:lri6SiS, as the path report showed a minimal to mild case, not an infestation as described by post operatively by respondent. N. Respondent scared the patient into having the major surgery by lying about the true nature of her condition. NIN1lI CAUSE FOR DISCIPLINE (Failure to Mainblin Adequate Records) 37. Respondeo.t is subject to disciplinary action under Code in that he failed to maintBln "CIIoqi~ recorcIa during his care and patients: D.M-G., L.M., J.S.M., M.P., J.t.M., B.R., J.W., M.A., B.J.G., and V.G. The 22 circumstances are as follows: 23 A. Paragraph 19 (A) through (EEEE) is hereby incorporated 24 by reference as if fully set forth. 25 B. It is impossible to determine the degree to which D.M-G. 26 had pelvic relaxation from the paucity of respondent's clinic note. 27 From the December 15. 1998, sonogram performed on c. 28 L.M. there are six unlabeled images. 40 : . .' ~ , 1 2 3 TENTH CAUSE FOR DISCIPLINE ; (General Unprofessional Conduct) 38. Respondent is subject to disciplinary action under section 2234 of th~ 4 Code in that he committed general unprofessional conduct during his care and treatment of the 5 following patients: S.G., D.M-G., L.M., M.P., A.Y., B.R.,J.W., M.A., and B.J.G., The 6 circumstances are as follows: . ~, 7 8 9 10 Il 12 13 14 15 16 17 18 19 I 20 21 22 23 24 25 26 27 28 III (" A. Paragraph 19 (A) through (EEEE) is incorporated by rcference herein as if fully set forth. B. Respondent attempted to scare S.G. into agreeing to undergo surgery by telling her she would "burst and bleed to death" if she did not . ..have tIIl:t'8ll1'gery respondent recommended, -, ",. C. Respondent refused to take telephone calls from S.G. + during the time the patient was receiving hormone replacement. D. Respondent told D.M-G. she had a tumor on each of her ovaries that could become cancerous despite the fact there is no evidence that such. tumors existed. E. Respondent told D.M-G. the only. way her inSurance company would pay for bladder surgery was if she had a hysterectomy, which agreed to have in October 1997. F. Respondent told L.M. that the problem with her Cervix could turn into cancer in 5 weeks. When she told respondent she wanted a second opinion he expressed the hope she had enough time. The problem with L.M. 's cervix is often left untreated by Ob-Gyns without dire consequences. G. In January 2000, respondent told L.M. she needed immediate surgery to remove a right ovarian tumor. Although!l cancer specialist, Dr. M., did not see any tumor and offered to due an ultrasound within the week, respondent scared L.M. into having the surgery immediately. 42 , " I H. Respondent told patient M.P. she could bleed out if she did .~ 2 not h;lve the recommended surgery right away. . 3 I. Respondent attempted to scare A.Y. into having the surgery 4 recommended hy respondent by telling her she would be unable to have children 5 with endometriosis, going so far as to recommend she have children out of 6 wedlock. 7 1. Respondent attempted to scare B.R. into having the surgery 8 recommended by respondent by telling her the condition would turn into cancer 9 and that if she did not have the surgery right away it may be too late. 10 K. Respondent scared 1. W. into having the major surgery by II lyOW about. the true nature ofher condition. 12 L. Respondent scared M.A. into having the major surgery ,by 13 lying about the true nature of her condition. 14 M, Respondent lied to BJ.G. about the extent of he ;-.... 15 endometriosis, as the path report showed a minimal to mild case, not an 16 infestation as desCribed by post operatively by respondent. 17 N. Respondent scared BJ.G. into having the major surgery by 18' lying about the true nature of her condition. 19 20 21 ELEVENTH CAUSE FOR DISCIPLINE ..'. 39. (Excessive Prescribing) Respondent is subject to disciplinary action under section 725 of the Code . ','::J::' ~:~:~ I: 22 in that he excessively prescribed medication to J .LM. during his Care and treatment of her. The 23 circumstances are as follows: 24 A. Paragraph 19 (WW) through (ZZ) is hereby incorporated by 25 reference as if fully set forth. ~ 26 27 B. Between April 19 and October 4, 1999, respondent prescribed J.L.M. 386 Vicodin tablets, in addition to prescribing her Phentermine 28 in September. 43 .---. 11 12 13 :----. 14 15 16 17 18 19 I 20 21 22 23 r , I 2 3 TWELFTH CAUSE FOR DiSCIPLINE (Sex With a Patient) 40. . Respondent is subject to disciplinary action under section 726 of the Code . 4 in that he had sexual rolations with V.G. at a time when she was his patient. Paragraph 19 5 (AAAA) through (EEEE) is incorporated by reference as if fully set forth herein. 6 PRAYER 7 WHEREFORE, Complainant requests that a hearing be held on the matters herein 8 alleged, and that following the hearing, the Division of Medical Quality iSsue a decision: 9 1. Revoking or suspending Physician's and Surgeon's Certificate 10 No. G 24947, issues to Andrew Rutland, M.D.; . .,.!,!f:..",,:;:,t::::< ~.:\;~,.::Revoking, suspending, or denying approval of Andrew Rutllllid, M.D.'s \\';.C'.: J,\~'.I,.,~: -. .;1\ ,...., .:~~:aiI~phYSiCian's assistants, pursuant to section 3527 of the Code; .3. Ordering respondent Andrew Rutland, M.D. to pay the Division of Medical Quality the reasonable costs of the investigation and enforcement of this case, and, if placed on probation, the costs of probation monitoring; 4. Taking such other and further action as deemed necessary and proper. -- DATED: ~~ ?1!: ?~'-< ~. . ~ecutive . tor ~ MediCal Board of California Department of Consumer Affairs State of California Complainant ;;.;. ,'. 24 25 26 03S7316Q..S0200IAD0241; Second Amended Accusation SHZ:pll 27 28 44