ALJDEC

00A-20000033-BHE · Board of Behavioral Health Examiners · 2000-12-29

IN THE OFFICE OF ADMINISTRATIVE HEARINGS

HEARING: December 12, 2000; 9:10 A.M.; Phoenix, Arizona APPEARANCES: Arizona State Bd. of Behavioral Health Examiners: Mary DeLaat Williams, Esq., Assistant Attorney General Respondent: No Appearance ADMINISTRATIVE LAW JUDGE: George A. Schade, Jr.

This is a proceeding commenced by the Arizona State Board of Behavioral Health Examiners (“Board”), pursuant to Arizona Revised Statutes (“A.R.S.”) § 32-3262, to impose disciplinary sanctions against Respondent Cheryl Lynn Lister, who holds Certificate No. SW-0268I for the Practice of Social Work in the State of Arizona. Based upon the evidence presented at the hearing, Administrative Law Judge (“ALJ”) George A. Schade, Jr. submits this Recommended Decision and Order to the Executive Director of the Board. FINDINGS OF FACT PROCEDURAL BACKGROUND[1] 1. Following a hearing on October 6, 2000, the Board issued Findings of Public Emergency and Order of Summary Suspension summarily suspending Certificate No. SW-0268I held by Respondent Cheryl Lynn Lister. Ms. Lister was not present at the hearing. 2. The summary suspension was to remain in effect until the conclusion of an administrative hearing which would be set within approximately sixty days thereafter. 3. On October 19, 2000, the Board issued a Complaint and Notice of Hearing scheduling a hearing on December 12, 2000, before the Office of Administrative Hearings. 4. The Board mailed a copy of the Complaint and Notice of Hearing to the last known address it had for Ms. Lister. 5. There is no evidence showing that Ms. Lister did not receive her copy of the Complaint and Notice of Hearing or that she was unaware of the scheduled hearing. 6. On October 16, 2000, and on November 30, 2000, ALJ Schade sent letters to Ms. Lister, at her last known address according to the Board’s records, advising among other items of the date and time of the hearing. Neither letter was returned to the Office of Administrative Hearings as being undeliverable. 7. Neither Ms. Lister nor a legal representative appeared at the hearing held on December 12, 2000. The start of the hearing was delayed ten minutes to give Ms. Lister additional time to travel, but she did not appear. The Office of Administrative Hearings did not receive any letters or telephone calls from Ms. Lister or a representative regarding her appearance at the hearing. Assistant Attorney General Mary DeLaat Williams avowed she had been informed by Ms. Lister’s attorney that Ms. Lister would not appear at the administrative hearing. 8. The hearing held on December 12, 2000, lasted 3.5 hours. The Board presented the testimony of Mrs. Lisa Dale Scott Long; Mr. Thomas M. Reininger; Mrs. Deborah Ann Sheppard; Mrs. Maryanne L. Clarke; Mr. Charles Barreras, a detective of the Phoenix Police Department; Ms. Michelle L. Clarke; and, Ms. Patricia E. Reynolds, Deputy Director and investigator of the Board. The Board presented 26 exhibits which were admitted (Numbers 1 through 25, including 11A and 11B). MS. LISTER 9. Ms. Lister holds Certificate No. SW-0268I for the Practice of Social Work in the State of Arizona. 10. Ms. Lister was certified on April 1, 1991, and her certification expires on March 31, 2001. 11. Certificate No. SW-0268I is currently under summary suspension following the Board’s decision made after the hearing held on October 6, 2000. 12. Ms. Lister’s prior disciplinary record with the Board shows two substantiated complaints in 1993, which resulted in the imposition of a $500.00 civil penalty and compliance with ethics education, and two unsubstantiated complaints that were dismissed. The two substantiated complaints, consolidated for resolution, involved two financial loans that Ms. Lister had obtained. 13. Ms. Lister earned a Master of Arts degree in Social Work at the University of Denver (Denver, Colorado) in June 1978. She earned a Bachelor of Arts degree in History at the University of Colorado in May 1974. 14. Ms. Lister was diagnosed as bipolar in 1983. At one time, she was taking medication identified as having been Lithium. 15. During all times relevant to these findings of fact, Ms. Lister practiced under the business name of Center for Psychotherapy, at Suite D- 104 and later D-213, 11225 North 28th Drive, Phoenix, Arizona. THE ACTS AND OMISSIONS OF MS. LISTER A. Lisa Dale Scott Long 16. Mrs. Lisa Dale Scott Long was both a client and a friend of Ms. Lister. In the fall of 1996, Ms. Long, then a single woman, lived with Ms. Lister. Ms. Lister and Mrs. Scott have had a client relationship on an ongoing basis since 1996. 17. In Spring 1998, Mrs. Long learned that Ms. Lister had used Mrs. Long’s name, without consent or permission, to obtain credit through a Discover credit card. Mrs. Long requested Ms. Lister to stop using Mrs. Long’s name to obtain credit. Ms. Lister apologized and stated it would not happen again. 18. In August 1999, Mrs. Long returned to Phoenix and began seeing Ms. Lister both as a client and as a friend. 19. In July 2000, Ms. Lister and Mrs. Long agreed that Mrs. Long would help Ms. Lister with her billings from the Center for Psychotherapy, but according to Mrs. Long, she did not have an employment relationship with Ms. Lister. 20. In July, 2000, Mrs. Long learned that Ms. Lister was again using Mrs. Long’s name and other information to obtain credit cards and loans without consent or permission. 21. Mrs. Long learned that Bank One, through First USA Bank, had issued a credit card to Ms. Lister in the name of “Lisa D. Scott.”[2] Mrs. Long had not applied for this credit card. The total credit line was $5,000.00. When Mrs. Long inquired, she learned that Ms. Lister had applied for this credit card using Mrs. Long’s name. As of July 22, 2000, a total of $6,171.49 had been charged on this credit card, none of it by Mrs. Long. 22. Mrs. Long learned that Ms. Lister had used Mrs. Long’s name to submit an application for a credit card issued by Chase Bank. 23. Mrs. Long discovered that Ms. Lister had made a copy of Mrs. Long’s Arizona Driver’s License, placed a strip of tape to cover Mrs. Long’s home address, inserted Ms. Lister’s home address, and forged Mrs. Long’s signature on the Driver’s License. 24. Ms. Lister obtained a copy of Mrs. Long’s Arizona Driver’s License from Mrs. Long’s client file. 25. Mrs. Long learned that Ms. Lister had placed Mrs. Long’s name on the Renewal of Trade Name for the Center for Psychotherapy that Ms. Lister filed with the Arizona Secretary of State. Mrs. Long has never had any ownership or other interest in Ms. Lister’s business. 26. Subsequently, Mrs. Long learned that Ms. Lister had told Mrs. Deborah Ann Sheppard that Mrs. Long held a one-half ownership interest in Ms. Lister’s professional practice. This statement was false. 27. On June 11, 2000, Ms. Lister forged Mrs. Long’s signature on a business check issued by the Center for Psychotherapy to Harbour Capital Corporation in the amount of $872.96. This payment was related to a lease of office furniture. 28. On June 30, 2000, Ms. Lister forged Mrs. Long’s signature on a business check issued by the Center for Psychotherapy to Cheryl Lister in the amount of $2,000.00. Later, Mrs. Long learned that Ms. Lister had opened a bank account with Bank of America using Mrs. Long’s name. The bank checks of this account show that the account holder is “Center for Psychotherapy, Lisa Scott, 11225 N. 28th Dr. D204, Phoenix, AZ 85029.”[3] Mrs. Long did not open this account. 29. On June 11, 2000 and on June 14, 2000, Ms. Lister forged Mrs. Long’s name and used Mrs. Long’s name to obtain credit for a lease of office furniture for the Center for Psychotherapy. One of the credit references Ms. Lister provided was the bank account that Ms. Lister had fraudulently established at the Bank of America. 30. Ms. Lister forged Mrs. Long’s signature on documents associated with the payments for the loans of the furniture lease. One loan was with Harbour Capital Corporation. The forged signatures were dated June 11, 2000, and June 20, 2000.[4] 31. In July 2000, Mrs. Long learned that American Express had issued a credit card to Ms. Lister in the name of “Lisa Scott,” but using Ms. Lister’s home address.[5] Mrs. Long had not applied for this credit card. When Mrs. Long inquired, she learned that Ms. Lister had applied for this card using Mrs. Long’s name. As of July 25, 2000, the unpaid balance on the card was $15,674.34. Mrs. Long never used the card. 32. On July 22, 2000, in an effort to avoid further problems, Mrs. Long placed a security watch on her social security number with a national credit card agency. 33. According to Mrs. Long, Ms. Lister obtained, without consent or permission, the necessary information to apply for credit from her client file. 34. On August 7, 2000, Mrs. Long filed a report with the Phoenix Police Department. 35. Detective Charles Barreras of the Documents Crimes Detail led the investigation of the Phoenix Police Department. The investigation included three search warrants (at Ms. Lister’s office, house and storage locker). The police report, with the exception of two recent supplements (10 and 11) that are considered to be minor, was admitted into evidence as the Board’s Exhibit No. 23.[6] The police report concludes as follows: “After interviewing the victim, witnesses, and reviewing evidence taken during the search warrant, I have determined that the elements of A.R.S. § 13-2008, taking identity of another person a Class 4 felony, appear to be present.”[7]

36. The Office of the Attorney General is prosecuting the criminal case. 37. On August 15, 2000, Mrs. Long filed a complaint with the Board against Ms. Lister alleging the following: “Cheryl has opened checking accounts, credit card accounts, office furniture lease accounts, cell phone accounts, and loans in my name. I have never given her authority to use my name or my social security number for any purpose. Cheryl provided proof of identity by forging my driver’s license, which she obtained this (sic) from my confidential patient file. She put her address on it and she signed it as Lisa Scott.”[8]

38. Mrs. Long testified that she felt “violated, betrayed, used, taken advantage of” and “stupid for being a victim.” Mrs. Long saw Ms. Lister as a “mentor,” and in fact, Mrs. Long is studying to become a social worker in part due to the mentoring of Ms. Lister. Both Mrs. Long and Mrs. Sheppard testified that Ms. Lister on occasion referred to Mrs. Long as Ms. Lister’s “adoptive daughter.” B. Thomas M. Reininger 39. Mr. Thomas M. Reininger filed a complaint with the Board against Ms. Lister alleging default on financial loans and negligence in professional counseling. 40. In early 1998, Mr. Reininger and his fiancee were seeing Ms. Lister for premarital counseling. 41. On June 17, 1998, at a time when Mr. Reininger was a client of Ms. Lister, Mr. Reininger lent Ms. Lister $30,000.00, after Ms. Lister told him that she needed an emergency medical operation. Ms. Lister asked for this loan from Mr. Reininger during the course of a therapy session. 42. Between June 17, 1998, and October 13, 2000, Mr. Reininger lent Ms. Lister money, and Ms. Lister made some repayments, but as of October 13, 2000, Ms. Lister owed Mr. Reininger $139,043.94 on loans totaling $174,324.39.[9] 43. Ms. Lister made several payments that were not negotiable due to insufficient funds. Mr. Reininger made numerous efforts to obtain prompt repayment from Ms. Lister, but checks bounced, and promises were not kept. 44. On at least three occasions, Ms. Lister endorsed to Mr. Reininger personal checks given to her by clients. Mr. Reininger cashed the checks which totaled $193.88. 45. In October and November 1998, Ms. Lister asked Mr. Reininger to help her financially to purchase a “$300,000 home” (Mr. Reininger’s testimony). Mr. Reininger signed a purchase agreement and paid a deposit of $5,000.00. Ms. Lister asked him to make the initial deposit, but indicated that she would make the house payments. After consulting with his financial advisors, Mr. Reininger canceled this transaction and was able to obtain the return of the $5,000.00 deposit he had paid. His advisors counseled him that this transaction would not be advantageous or proper for him. According to Mr. Reininger, it was the timely advice of his financial advisors that led to the cancellation of this transaction. He testified that he could not understand why Ms. Lister wanted to purchase such an expensive house when she did not have the necessary financial means, and now he understands that she planned to use his credit strength to purchase the house. 46. On June 14, 1999, Ms. Lister filed a petition for bankruptcy under Chapter 13 of the Bankruptcy Code, but on November 18, 1999, the petition was changed to a case under Chapter 7 of the Bankruptcy Code. According to Mr. Reininger, he was not originally listed as a creditor. His attorney is representing him in the bankruptcy matter. 47. Mr. Reininger testified that Ms. Lister’s premarital counseling was unsuccessful, and further, he believes that Ms. Lister undermined his loving relationship with his fiancee by placing them in situations which were not beneficial to them. 48. Mr. Reininger testified that both his fiancee and he were “damaged” as a result of their client relationships with Ms. Lister, he “feels exploited,” and Ms. Lister “has no business [being] in the line of social work.” He plans to file a civil fraud lawsuit against Ms. Lister. C. Deborah Ann Sheppard 49. Mrs. Deborah Ann Sheppard was both a client (beginning in September, 1999) and an employee of Ms. Lister (beginning on January 17, 2000). She and her husband terminated their client relationship when Mrs. Sheppard started working for Ms. Lister as office staff on January 17, 2000. 50. During the time that Mrs. Sheppard worked for Ms. Lister, she saw and overheard Ms. Lister answer telephone calls as “Lisa Scott.” The Center for Psychotherapy received calls for “Lisa Scott,” and Ms. Lister would either answer them or state that she was “Lisa Scott.” 51. While she was an employee, Ms. Lister asked Mr. and Mrs. Sheppard for a $2,000.00 loan. They lent Ms. Lister $2,000.00 for one week. Ms. Lister repaid the money but only after Mrs. Sheppard verbally confronted her. 52. Mrs. Sheppard testified that Ms. Lister would apply for credit on different Internet sites using clients’ information obtained from client files, but using Ms. Lister’s addresses. 53. Mrs. Sheppard testified that a payer, wishing to pay $15.00 by a credit card for the benefit of a client, was billed $1,500.00, and Ms. Lister did not want to return any money to the payer who had strongly contested the overcharged billing. 54. Ms. Lister told Mrs. Sheppard that Ms. Lister had sold “one-half” of the Center for Psychotherapy to Mrs. Long “in exchange for a loan.” This statement was false. 55. Ms. Lister would leave client files, records and credit card slips freely around the office. Ms. Lister made little, if any, effort to secure or safeguard these documents. 56. On occasion, Mrs. Sheppard saw Ms. Lister place strips of tape on documents, type over other names and transmit the forged document by fax. In this manner, the forgery of the document would not show clearly to a recipient. 57. Mrs. Sheppard testified that she “feels angry, very mad,” and Ms. Lister was “very disrespectful,” “mean” and “nasty” to clients and office staff, and she “needs to be punished.” D. Maryanne L. Clarke 58. Mrs. Maryanne L. Clarke first saw Ms. Lister as a client in 1986. She was a client until about 1992, although she has thereafter on occasion seen Ms. Lister as a client. In 1993, Mrs. Clarke began working for Ms. Lister as office staff. Their relationship ended on January 16, 2000. 59. According to Mrs. Clarke, since 1992 (when she made the first loan of $6,000.00) she has lent Ms. Lister approximately $25,000.00, of which “about $1,500.00” has been repaid. Many checks that Ms. Lister gave to Mrs. Clarke were nonnegotiable due to insufficient funds, and promised payments were not made. 60. During 1997 and 1998, Ms. Lister used Mrs. Clarke’s credit card with Household Bank. The credit limit of the card was $5,000.00. Ms. Lister charged items on the card that as of February 22, 1998, reached an outstanding balance of $13,084.87. The charged items were for the benefit of the Center for Psychotherapy (such as office expenses) and for Ms. Lister’s personal travels. According to Mrs. Clarke, she did not authorize or consent to Ms. Lister incurring these expenses on Mrs. Clarke’s credit card. 61. Mrs. Clarke and her daughter Michelle, who worked for Ms. Lister cleaning her house and doing “back-up” office work, resigned on January 16, 2000 (although they were treated as having been terminated), when they learned that Ms. Lister was trying to obtain credit from a financial lender using information obtained from clients. 62. On June 26, 2000, Mrs. Clarke filed for personal bankruptcy after she was not able to pay her credit card, and Ms. Lister’s payments were returned for insufficient funds. Mrs. Clarke was discharged in bankruptcy on October 19, 2000. 63. Mrs. Clarke testified that she knew of a payer, who wishing to pay $15.00 by a credit card for the benefit of a client, was billed $1,500.00, and Ms. Lister did not want to return the money to the payer who had strongly contested the overcharged billing. Another client was charged $2,400.00, although Ms. Lister had not seen the client in two years, and the client had moved to California. To another client, Ms. Lister owed “around $50,000.00” when the client died of cancer, and according to Mrs. Clarke, Ms. Lister made no effort to repay any of the monies owed to the decedent. Another client was charged $4,200.00, although the services were for far lower fees. E. Michelle L. Clarke 64. Ms. Michelle L. Clarke, Mrs. Maryanne L. Clarke’s daughter, was both a client and an employee cleaning Ms. Lister’s house and doing “backup” office work. 65. Ms. Clarke testified as to the accuracy of the incident regarding a payer charged $1,500.00 instead of $15.00, and Ms. Lister was confronted, she did not want to return any of the monies to the payer. 66. Ms. Clarke remembers Ms. Lister answering the office telephone when callers asked for Lisa Scott. 67. Mrs. Sheppard, Mrs. Clarke and Ms. Clarke testified that they were not allowed to open the mail. Only Ms. Lister saw and opened all incoming office mail. 68. Ms. Clarke testified that for a period of time two weekly appointments were reserved for the same client, and two billings were done, but she never saw that person at the office. 69. Ms. Clarke testified that Ms. Lister was “extremely volatile,” “loud,” “absolutely on the edge,” “nothing but a criminal,” and Ms. Lister “needs to do jail time.” F. Patricia E. Reynolds 70. Ms. Patricia E. Reynolds testified that she spoke with a former client of Ms. Lister who related she was charged $1,500.00 instead of $15.00. Ms. Reynolds spoke with two former clients of Ms. Lister who had lent her money and were not repaid. 71. One client lent Ms. Lister $5,000.00 in 1995 and has been repaid $1,000.00. This client stated that Ms. Lister was “a good source of dates;” apparently, Ms. Lister matched this client with others. 72. One former client was owed $7,000.00 of a $10,000.00 loan made to Ms. Lister, who used some of the money for a trip to Hawaii. 73. Ms. Reynolds spoke with a social worker in Colorado who has known Ms. Lister since the 1970’s. Ms. Lister has borrowed money from this individual (in the amounts of $1,700.00 and $170.00), and Ms. Lister has not been an exemplary debtor. CONCLUSIONS OF LAW APPLICABLE STATUTES A.R.S. § 32-3251(9) states that “unprofessional practice” includes: "(b) Use of fraud or deceit in connection with rendering services as a certified behavioral health professional or in establishing qualifications pursuant to this chapter.

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(f) Making use of statements of a character tending to deceive or mislead the public.

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(h) Gross negligence in the practice of a behavioral health profession by a certified behavioral health professional.

(i) Any conduct or practice which is contrary to recognized standards of ethics in the behavioral health profession or which constitutes a danger to the health, welfare or safety of a client.

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(k) Engaging or offering to engage as a certified behavioral health professional in activities which are not congruent with the certified behavioral health professional's professional education, training or experience.

(l) Violating any provision of this chapter or refusing or neglecting to comply with rules adopted pursuant to this chapter or any lawful order of the board or a credentialing committee.”

A.R.S. § 32-3281 states in pertinent part: “On receipt of a credentialing committee report of investigation findings, the board, after a hearing, may issue an order of censure, impose a civil penalty of not to exceed five hundred dollars, impose probation, refuse to issue or renew a certificate or suspend or revoke a certificate for unprofessional practice.”

CONCLUSIONS OF LAW 1. The Board has authority to impose disciplinary sanctions against Ms. Lister, who holds a certificate issued by the Board.[10] The sanctions may include revocation of a certificate issued by the Board.[11] 2. In this proceeding, the Board has the burden of establishing that disciplinary sanctions should be imposed against Ms. Lister, and if so, which would be appropriate sanctions.[12] 3. The standard of proof on all issues is the preponderance of the evidence.[13] A “preponderance of the evidence is such proof as convinces the trier of fact that the contention is more probably true than not.”[14] It “is evidence which is of greater weight or more convincing than the evidence which is offered in opposition to it; that is, evidence which as a whole shows that the fact sought to be proved is more probable than not.”[15] 4. Ms. Lister was notified of the hearing scheduled on December 12, 2000. 5. The acts and omissions of Ms. Lister described in Findings of Fact through 73 violate Ethical Standards 1.01 (Commitment to Clients); 1.06(a), (b) and (c) (Conflicts of Interest); 1.07(a), (b), (c), (d), (e), (l) and (m) (Privacy and Confidentiality); 1.13(a) and (c) (Payment for Services); 4.03 (Private Conduct); 4.04 (Dishonesty, Fraud, and Deception); 4.05(a) (Impairment); and 5.01(a) (Integrity of the Profession), of the Code of Ethics of the National Association of Social Workers (effective January 1, 1997). The Code, which the Board has adopted, sets forth the “values, principles, and standards to guide social workers’ conduct.”[16] 6. The preponderance of the evidence establishes that the acts and omissions of Ms. Lister described in Findings of Fact 16 through 73 constitute “unprofessional practice” in violation of A.R.S. § 32-3251(9) subsections b, f, h, i, k, and l. The evidence shows a flagrant, historic and insidious pattern of deceit, deception, dishonesty, fraud, guile, misrepresentation, and gross negligence not only towards present and former clients but also employees and others. The acts and omissions are contrary to recognized standards of ethics in the behavioral health profession, constitute a danger to the health and welfare of a client, and are not congruent with the certified behavioral health professional’s professional education, training or experience. The incidents are not isolated but extend over several years. Clients and former clients were dishonestly used for pecuniary gains. The amounts are substantial. The unauthorized taking and using of important personal and private financial information, within the context of a client relationship, is heinous. Some witnesses testified to their extreme anger at having been treated in this manner by a professional therapist they deeply trusted. Ms. Lister’s disreputable conduct will not cease unless the severest disciplinary sanction is imposed. 7. The revocation of a certificate is a professional sanction that should be carefully considered. A careful review of the totality and preponderance of the evidence presented at the hearing supports the revocation of Certificate No. SW-0268I as an appropriate disciplinary sanction.[17] “An administrative penalty is excessive only if it is so ‘disproportionate to the offense as to shock one’s sense of fairness’.”[18] Revocation of Ms. Lister’s certificate is neither an excessive sanction nor does it shock one’s sense of fairness. In this case, revocation is the most compelling remedy. RECOMMENDED ORDER It is recommended that the Board revoke Certificate No. SW-0268I for the Practice of Social Work in the State of Arizona held by Respondent Cheryl Lynn Lister. SUBMITTED this 29th day of December, 2000.

George A. Schade, Jr. Administrative Law Judge

The original Recommended Decision and Order of the Administrative Law Judge was delivered on December 29, 2000, for distribution to the parties, to:

Debra Rinaudo Executive Director Arizona State Board of Behavioral Health Examiners 1400 West Washington, Suite 350 Phoenix, Arizona 85007

George A. Schade, Jr. ----------------------- [1] Official notice was taken of those documents necessary to provide this procedural background. [2] Board’s Exhibit No. 1. [3] Board’s Exhibit No. 7. [4] Board’s Exhibits No. 11A and 11B. [5] Board’s Exhibit No. 9. [6] It is recommended that the members of the Board read this report in its entirety. [7] Board’s Exhibit No. 23, p. BHE-35. [8] Board’s Exhibit No. 2, p. 1. [9] An example of Ms. Lister’s audacity was when on May 11, 1999, while Mr. Reininger was out of state on vacation, she called him and asked for a $20,000.00 loan, which Mr. Reininger made to her by a cashier’s check dated May 17, 1999. [10] A.R.S. §§ 32-3251, 32-3253, 32-3261, 32-3262, and 32-3281. [11] A.R.S. § 32-3281. [12] Rule R2-19-119(B)(1) and (B)(2), Ariz. Admin. Code. [13] Rule R2-19-119(A), supra; see Culpepper v. State, 187 Ariz. 431, 436- 438, 930 P.2d 508, 513-515 (App. 1996), review denied (1997). [14] Morris K. Udall, Arizona Law of Evidence, § 5 (1960). [15] BLACK’S LAW DICTIONARY 1182 (6th ed. 1990). [16] Board’s Exhibit No. 25, p. BHE-103. [17] See A.R.S. § 32-3281; see Culpepper, supra. [18] Culpepper, supra, 187 Ariz. at 438, 930 P.2d at 515, citing Schillerstrom v. State, 180 Ariz. 468, 471, 885 P.2d 156, 159 (App. 1994); Bear v. Nicholls, 142 Ariz. 560, 563, 691 P.2d 326, 329 (App. 1984).

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Office of Administrative Hearings 1400 West Washington, Suite 101 Phoenix, Arizona 85007 (602) 542-9826