ALJDEC - Licensing
24A-19465-MDX · Arizona Medical Board · 2025-01-28
IN THE OFFICE OF ADMINISTRATIVE HEARINGS
In the Matter of
Gregory L. De Santo, M.D.
Holder of License No. 19465
For the Practice of Allopathic Medicine
In the State of Arizona
Respondent.
No. 24A-19465-MDX
ADMINISTRATIVE LAW JUDGE DECISION
HEARING: December 4, 2024, with the record held open until January 23, 2025, for the purpose of allowing the court reporter’s transcript to be included in the record, and to allow Gregory L. De Santo to supplement the record with Exhibits 1 through 3.
APPEARANCES:
Richard A. Kent, Esq. and Callie P. Maxwell, Esq. appeared on behalf of Gregory L. De Santo, M.D. (hereinafter “Respondent”).
Assistant Attorney General Elizabeth Campbell appeared on behalf of the Arizona Medical Board (hereinafter “Board”).
ADMINISTRATIVE LAW JUDGE: Velva Moses-Thompson
EXHIBITS ADMITTED INTO EVIDENCE: The Board’s Exhibits 1 through 14.
Respondent’s Exhibits 1 through 18.
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FINDINGS OF FACT
Respondent holds license No. 19465 issued by the Board. Respondent is a
board certified obstetrician-gynecologist (OB-GYN) who has practiced in Phoenix, Arizona for over 30 years. Respondent is a physician at Camelback Women’s Health (hereinafter “CWH”).
Respondent has delivered anywhere from 3,000 to 4,000 babies and has
placed thousands of intrauterine devices.
Respondent has performed procedures to remove a fragment of an
intrauterine device (IUD), like a ParaGard, in his office. In some cases, Respondent has taken patients for a hysteroscopy under general anesthesia.
Patient RE had an IUD placed in her uterus.
On August 5, 2022, Patient RE presented to her primary care physician
assistant, Ann Marie Chavez (hereinafter “PA Chavez”), to have the IUD removed and a new IUD placed. PA Chavez removed the IUD. However, an arm of the IUD broke and
became lodged in Patient RE’s uterus. Minimal bleeding occurred when the IUD was removed.
Ms. Chavez referred Patient RE to Respondent for the removal
of the IUD fragment. Ms. Chavez told Patient RE that Respondent had delivered a baby in his office. Ms. Chavez also ordered an ultrasound for Patient RE.
Respondent had Patient RE complete a 3D ultrasound. The 3D ultrasound
report showed that the fragment was in the lower uterus, just right of the endometrium.
Patient RE met with Respondent on the day of her appointment.
Respondent’s encounter note regarding the visit provided, “Review Test Results, Patient States that she is in the office to review pelvic ultrasound results. Patient states she is unsure if you want to remove it today. Patient RE states she wants another IUD.”
Patient RE could not have a new IUD with the fragment in place.
Patient’s recent pap smear showed that she had actinomyces, a bacterial
infection embedded in the IUD. Respondent prescribed Patient RE antibiotics for the infection.
Respondent attempted to remove the IUD fragment with forceps in his
office, but was ultimately unsuccessful.
On August 19, 2022, Respondent performed an hysteroscomy, but was still
unable to remove the IUD fragment.
On February 13, 2023, Patient RE met with OB-GYN, Gregory D. Layton,
M.D., to have the IUD fragment removed. Patient RE denied pain or discomfort during the visit. Dr. Layton was unable to remove the IUD fragment.
On March 28, 2023, CWH issued a bill to Patient RE for the amount of
$635.64, for the medical services provided to Patient RE on August 12, 2022.
On or about April 21, 2023, the Board received a complaint from
Patient RE regarding Respondent’s attempt on August 12, 2022 to remove the IUD fragment. The complaint provided as follows:
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Respondent came in the patient room where Patient RE was waiting and asked “what the issue was, and said he would try to extract the arm immediately.
I told him that I was very confused as his office told me we were reviewing the ultrasounds and planning for surgery. Given the placement and referral for surgery, I told him the thought of trying to remove it in his office was terrifying. He then asked his nurse to bring him the ultrasound results so he could review the lodged piece. – I told him that I had lost my insurance through my job as we were experiencing cutbacks, and I was worried about setting the surgery and having the piece extracted before my insurance was gone at the end of the month. - Dr. De Santo said it appeared to be stuck, but again, he’d like to attempt to remove the piece in the office to try and save me surgery. I told him I didn’t even get the IUD placed or removed without being prescribed medication to soften the cervix and manage pain beforehand. I told him the thought was making me very uncomfortable. I asked, ‘Won’t that hurt?’ He said, “Hopefully not.” He said it could save me from needing surgery with everything going on. – I felt reassured to try and remove the piece; I would be experiencing a loss in insurance and felt rushed for surgery. With his coaxing and my desperation I agreed reluctantly and was pretty vocal about it. – Dr. De Santo began his attempt to remove the piece blindly. Not long, I was SCREAMING and crying in pain on the table, begging him to stop before he stopped. It was so painful. He told his nurse something I didn’t hear, and she left the room in the middle of it, which was even more uncomfortable as she had to open the door to leave where I was in cloth on the table. He didn’t entirely remove the device inside me; I was shaking and in shock. He told me he was giving me a second and was going to continue. I screamed, ‘NO, absolutely not.’ His nurse returned after that, and he pulled out the clamps and prod without any other word, threw them in the sink, and left. I can’t remember clearly at that point; I assume he or the nurse said I could get dressed again when they left – because that’s what I did.
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Patient RE further alleged the following facts through the complaint:
Patient RE cried uncontrollably in Respondent’s office after the incident.
When Patient RE alleged that when she was calm enough to leave, Tiffany, the office manager, met her at the desk.
Patient RE was in the office for 10 minutes trying to compose herself and Respondent checked on her and asked her if she needed anything. Patient RE told Respondent that she needed something that could help with the cramping and pain and he returned with about “6 Advils.”
In the complaint, Patient RE referred to Respondent’s attempt to extract the
fragment as “absurd”.
At the end of the complaint, Patient RE wrote, “[Respondent] is barbaric
and unethical. What he did to me still affects me emotionally, and I still have physical pain.”
On May 5, 2023, the Board requested that Respondent provide a response
to the complaint, no later than May 22, 2023. The Board also requested that Respondent submit Patient RE’s complete medical chart record.
The Board notified Respondent that the following complaint allegations
were identified by the Board:
Respondent inappropriately attempted an IUD extraction in an office despite surgical extraction recommendation.
Respondent failed to extract the defective IUD.
Respondent inadequately managed Patient RE’s pain.
Respondent made an inappropriate recommendation for a hysterectomy.
Respondent abandoned Patient RE and failed to follow up with Patient RE.
On May 22, 2023, the Board received Respondent’s response.
On February 15, 2024, Roque A. Lanza, M.D., FACOG, the Board’s
consultant, issued a Medical Consultant Report and Summary (Report). Dr. Lanza reviewed the complaint, the medical records provided by Respondent, and Respondent’s response. Dr. Lanza Respondent concluded that the allegations identified by the Board in Patient RE’s complaint were unfounded. Dr. Lanza’s Report provided, in relevant part, as follows:
Respondent’s failure to extract the IUD fragment was not a deviation from the standard of care.
There was no clear evidence that Respondent recommended a Hysterectomy other than a referral for possible vaginal hysterectomy, nor was it indicated in this matter.
There was no evidence of abandonment as the patient had sought second opinions (records were requested) and seen different providers. There was no documented communication between patient and office other than billing queries, after the first surgery. Patient was not denied, nor did she request further follow up with Respondent.
However, Dr. Lanza opined that the medical record should include
documentation that Respondent obtained informed consent from Patient RE.
Dr. Lanza concluded that Patient RE’s medical record should include, “an explanation of what would be involved, risk benefits and alternatives, and assessment patient had an understanding of such, and a consent to proceed.”
On July 30, 2024, Respondent provided a supplemental response
regarding the Board’s investigation.
On or about July 30, 2024, the Board received a letter from Dr. Bruce
Culbertson, an OB-GYN. Through the July 30, 2024 letter, Dr. Culbertson notified the Board that he reviewed Dr. De Santo’s medical records regarding Patient RE, the complaint, Dr. De Santo’s Supplemental Response, and the Staff Investigational Review Committee Report dated May 2, 2024.
Dr. Culbertson opined that Respondent met the standard of care at all
times. Dr. Culbertson opined that Dr. De Santo documented the procedure
in the medical chart, meeting the standard of care, when he wrote, “I briefly attempted to remove the arm with an alligator forces without success. She has [sic] to stop and discomfort.”
Dr. Culbertson opined that Respondent thoroughly documented informed
consent in his supplemental response. Dr. Culbertson explained that the complaint shows that Patient RE provided informed consent. Dr. Culbertson wrote, “Given the brevity of this procedure, I am not sure what additional documentation the SIRC was looking for.”
On August 12, 2024, the Board notified Respondent in writing of its intent
to issue a Non-Disciplinary Continuing Medical Education Order.
On August 12, 2024, the Board issued an Order for Continuing Medical
Education (Non-Disciplinary) (hereinafter Order) to Respondent. The Order provided, in relevant part, as follows:
At its public meeting on August 6, 2024, the [Board] voted to issue [Respondent], a non-disciplinary Continuing Medical Education (“CME”) Order for inadequate informed consent and failure to document a procedure, in violation of A.R.S. 32-1401(27)(e) and (r). The Board, pursuant to A.R.S. § 32-1451(E)(2), ordered Respondent to complete the Enhanced Patient Communication Course offered by the Center for Personalized Education for Physicians (“CPEP”) and 5 hours of Board staff pre-approved Category I CME in medical recordkeeping. The CME requirement shall be completed within 6 months of the effective date of this Order. The CME hours shall be in addition to the hours required for the biennial renewal of medical licensure.
On August 20, 2024, Respondent filed an appeal to the CME Order and
provided a response to the August 12, 2024 advisory letter.
On September 17, 2024, Dr. Roque issued a Medical Consultant
Supplemental Report and Summary (Supplement). Through the Supplement,
Dr. Roque opined that Respondent’s August 20, 2024 response shows appropriate documentation of the procedure and of informed consent, beginning at paragraph 4 up until the time that Respondent describes that he stopped the procedure. Respondent’s September 17, 2024 response, provided, at the fourth and fifth paragraphs, as follows:
On August 12, 2022, the patient came to my office to discuss the results of the 3D ultrasound as well as the options for removal. Due to the location of the arm within the uterus, I conveyed to the patient the options of surgical removal versus intra office removal. As I my custom and habit, I discussed both intraoffice removal and surgical removal and the risks and benefits of both options in detail. I want to emphatically stress that, at no time was she pressured or rushed on this decision. I made it clear that the decision on how to proceed was up to the patient. Additionally the patient could have informed me that she was uncomfortable with moving forward with the procedure at any time and the procedure would have been aborted. However, that was not the case. Instead, the patient consented to the procedure and was prepared by the nurse chapereone. Importantly, she willingly and independently got up on the table and was position in the standard lithotomy position. While I admit that I did not have a formal consent form, one is not required and informed consent is clear and evident as the patient willingly positioned herself into the stirrups for the procedure. (Additionally, it is important to note that the patient’s admitted in her Complaint to the Arizona Medical Bard that she consented to the procedure.) Again, had the patient expressed any concern, the procedure would have been aborted (or would not have been initiated in the first place).
Before the procedure began, I explained to the patient what would happen during the procedure, step by step. I also continued to explain what he patient could expect as I was conducting the procedure. As I inserted the speculum, I explained that she may feel pressure and/or cold. I then explained to her that she may feel a pressure sensation with the insertion of the alligator forceps. This is my custom and habit in all types of vaginal/cervical examinations as I do not want my patients to be startled or surprised at any time. After a brief amount of time, the procedure was aborted immediately upon request to the patient due to discomfort. Of course, I promptly complied with the patient’s request for obvious reasons. While medical care is not always a pleasant, I never intend to cause my patient’s discomfort and I only proceed with care when I have informed consent. This is a fact all of the member of my staff can confirm.
Respondent’s appeal was referred to the Office of Administrative
Hearings for an evidentiary hearing.
On September 17, 2024, the Board issued a Notice of Hearing that
provided, in relevant part, as follows:
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YOU ARE HEREBY NOTIFIED that the hearing on your non-disciplinary Continuing Medical education Order has been scheduled to be held before an Administrative Law Judge on November 7, 2024, commencing at 9:00 a.m. at the Office of Administrative Hearings, located at 1740 West Adams Street, Phoenix, Arizona.
The hearing shall be limited to those matters originally presented to the Board for its determination in case MD-23-0380A, including but not limited to inadequate informed consent (including failure to document informed consent) and failure to adequately document a procedure. On August 6, 2024, the Board voted to issue you an Order for Continuing Medical Education in this case based on violations of A.R.S. §§ 32-1401(27)(e) and (r).
(e) Failing or refusing to maintain adequate records on a patient.
. . .
(r) Committing any conduct or practice that is or might be harmful or dangerous to the health of the patient or the public.
The above referenced case identified informed consent and documentation deficiencies for the in-office procedure you performed on August 12, 2022. The patient complained of inadequate communication and inadequate informed consent. A Medical Consultant (“MC”) who reviewed your care in case MD-23-0380A determined that you deviated from the standard of care by failing to adequately document the patient’s informed consent and by failing to adequately document a description of the procedure.
A hearing was held on December 4, 2024.
At hearing, the Board presented the testimony of Dr. Lanza and Renee
Ditloff, the Board’s Investigator. Respondent testified on behalf of himself and presented the testimony of Dr. Culbertson and Laura Fein, CWH’s office manager, Laura Fein.
Respondent’s Testimony
Respondent explained to Patient RE that he could attempt to remove the
fragment in the office during the visit, or, Patient RE could undergo surgery with general anesthesia. Patient RE was concerned about the costs of a general surgery. Respondent discussed with Patient the risk, benefits, and alternatives associated with the in-office removal of the IUD fragment. Respondent asserted that Patient RE’s own statement shows she knew of the two procedures. It is below the standard of care to give a cervical softener or pain medication unless patient requests.
On August 12, 2022, Respondent presented Patient RE with the option of
having the IUD fragment removed in the office or through a hysteroscopy under general anesthesia. Respondent explained to Patient RE how he would attempt to remove the IUD fragment. Respondent has never performed an exam of a female patient without a medical assistant present. The procedure was less than 15 seconds.
Respondent ended the procedure after Patient RE told
him to stop. Respondent did not recall that Patient RE cried in pain and “begged” him to stop. Respondent denied that he pressured Patient RE to have the in-office procedure done.
Patient RE was morbidly obese. Patients who are morbidly obese
theoretically have considerable risks when undergoing general anesthesia including breathing problems, cardiac problems, and post-operative blood clots. A hysteroscopy is billed more than an office procedure. It was logical to attempt for 15 seconds to try and remove the fragment and avoid general anesthesia.
Patient was referred to Respondent for a second opinion regarding her
IUD fragment.
I find Respondent’s testimony to be credible.
Testimony of Patient RE
Patient RE was prescribed anti-anxiety mediation to be taken three times a
day as needed. The medication was filled on July 28, 2022. However, Patient RE denied at hearing that she was taking regular Xanax medication.
On August 12, 2022, Respondent reviewed the 3D ultrasound. Patient RE
disputed the veracity of Respondent’s encounter note for the visit. Patient RE stated that she was present on August 12, 2022, to allow Respondent to review the ultrasound and schedule Patient RE for surgery. Patient RE alleged that Respondent did not provide her with any alternatives to removing the IUD fragment in the office. Patient RE stated that Respondent told her that he wanted to remove the fragment in the office. Patient RE alleged that she expressed to Respondent that she had concerns about removing the IUD fragment in the office, because she only had one IUD placed and was given medication to soften her cervix. Patient RE alleged that she told Respondent that she was concerned about the pain. Patient RE stated at hearing, “I told him I was concerned that I would be pain. I said that I didn’t even get in or out without medication and I said wouldn’t’ it hurt. And this was the one thing I remember clearly, he goes, well, “Hopefully not.”
Patient RE stated that she felt pressured to have the fragment removed in
Respondent’s office. Patient RE stated at hearing, “...I felt pressured because I had my insurance running out.” Patient RE alleged that Respondent did not explain the procedure. Patient RE alleged at hearing, “I think he just said that he was going to insert the clamp.” Patient RE alleged that she did not hear much conversation when Respondent inserted the clamp. Patient RE explained at hearing that Respondent stopped the procedure after she told him to stop.
Patient RE stated that she described the tenaculum and forceps as
barbaric in the complaint because Respondent used them without giving her medication prior to the procedure.
Patient RE alleged that Respondent did not explain to her that he would
use a tenaculum and forceps. Patient RE testified to the effect that she had no
conversation with Respondent about the potential risks of having an in-office procedure.
Patient RE’s medical records show that she was not prescribed pain
medication nor cervix softener prior to the placement or removal of the IUD. However, Patient RE alleged in her complaint that she told Respondent that she does not have an IUD placed or removed without being prescribed medication to manage the pain and soften the cervix beforehand.
PA Chavez gave Patient RE Xanax when her IUD was removed. Patient
RE alleged at hearing that she did not need cervix softener during the IUD removal because her cervix was soft because she was on her menstrual cycle.
Patient RE did not dispute at hearing that she told Dr. Layton during her
visit in February of 2023, that she was not in pain. However, the complaint shows that Patient RE wrote in or around September of 2024, “What he did to me still affects me emotionally, and I still have physical pain.”
Patient RE asserted at hearing that Respondent did not obtain her
informed consent. However, there are inconsistencies with the medical record and Patient RE’s complaint. Despite Patient RE’s assertion in the complaint that she always has pain medication and cervical prior to an IUD placement or removal, the medical records do not those prescriptions. Furthermore, Patient RE unequivocally stated in her complaint that she was still in “physical pain.” However, she told a physician a few months prior that she was not in any pain. At hearing, Patient RE stated that she did not recall writing in her complaint that she still experienced physical pain. I do not find Patient RE’s complaint to be reliable.
Testimony of Dr. Lanza
Dr. Lanza explained that according to the American College of Obstetrics
and Gynecology (ACOG), informed consent should have been documented in the record.
Dr. Lanza stated that Patient RE’s complaint implies consent, but not a
shared decision making process. Patient RE’s complaint confirms that Respondent discussed the risks, benefits, and alternatives related to the inter-office removal of the IUD fragment. Regarding the Board’s allegation that Respondent failed to adequately document the procedure, Dr. Lanza explained, “Well, it would be nice to know how far he got in the process, at minimum. One of the advantages of documenting a procedure is that, if somebody else has to repeat it, he will know what was successful and what wasn't.” Dr. Lanza explained that it was not clear whether Respondent went into the endometrial cavity. The risk of perforation was .003 percent.
Testimony of Dr. Culbertson
Dr. Culbertson graduated from Virginia Commonwealth University School
of Medicine in 1990. Dr. Culbertson has over 33 years of experience in the medical field.
Dr. Culbertson opined that one of the benefits of removing the fragment in
the office was that the patient continued to bleed and at the time of the appointment, it was unknown how soon surgery could be scheduled. Additionally, Patient RE had an infection with the device present in her body. Dr. Culbertson opined that Respondent obtained informed consent from Patient RE. Patient RE provided consent with a discussion regarding risks, benefits, alternatives. Dr. Culbertson Dr. Culbertson opined that met all standards of care during the procedure.
Testimony of Laura Fein
Prior to receiving Patient’s RE’s complaint that was filed with the Board,
Ms. Fein never received a complaint from Patient RE.
Laura Fein was the office manager for Camelback Women’s Health at the
time of the incident. Ms. Fein’s job responsibilities include, but are not limited to, hiring and firing employees and receiving patient complaints.
On March 28, 2023, Ms. Fein sent a bill to Patient RE regarding the
services that she received from Respondent in August of 2022. Withing a month following the date that the bill was sent to Patient RE filed the complaint with the Board within a month after receiving the bill. Ms. Fein explained that she believes that she was in the office on August 12, 2022. However, Ms. Fein did not have any supporting documentation at hearing. Ms. Fein explained that if a patient were crying and screaming in a patient room it would have been brought to their attention. Ms. Fein stated that she never received a report of a patient crying and screaming on that day. Ms. Fein also stated that such incidents rare occur.
CONCLUSIONS OF LAW
The Board has jurisdiction over Respondent and the subject matter in this
case under Ariz. Rev. Stat. § 32-1451(E)(2).
The Board bears the burden of persuasion. Ariz. Rev. Stat. § 41-
1092.07(G)(3).
The standard of proof on all issues is that of a preponderance of the evidence. Ariz. Admin. Code § R2-19-119.
“A preponderance of the evidence means ‘proof which leads the [trier of
fact] to find that the existence of the contested fact is more probable than its nonexistence.’ In re William L., 211 Ariz. 236, 238 (App. 2005) (quoting Matter of Appeal in Maricopa Juv. Action No. J-84984. 138 Ariz. 282, 283 (1983)).
Ariz. Rev. Stat. §§ 32-1451(A) and (E)(2) provide, in relevant part, as
follows:
The board on its own motion may investigate any evidence that appears to show that a doctor of medicine is or may be medically incompetent, is or may be guilty of unprofessional conduct or is or may be mentally or physically unable safely to engage in the practice of medicine. On written request of a complainant, the board shall review a complaint that has been administratively closed by the executive director and take any action it deems appropriate. Any person may, and a doctor of medicine, the Arizona medical association, a component county society of that association and any health care institution shall, report to the board any information that appears to show that a doctor of medicine is or may be medically incompetent, is or may be guilty of unprofessional conduct or is or may be mentally or physically unable safely to engage in the practice of medicine. The board or the executive director shall notify the doctor as to the content of the complaint as soon as reasonable. Any person or entity that reports or provides information to the board in good faith is not subject to an action for civil damages. If requested, the board shall not disclose the name of a person who supplies information regarding a licensee's drug or alcohol impairment. It is an act of unprofessional conduct for any doctor of medicine to fail to report as required by this section. The board shall report any health care institution that fails to report as required by this section to that institution's licensing agency.
E. If, after completing its investigation, the board finds that the information provided pursuant to subsection A of this section is not of sufficient seriousness to merit disciplinary action against the license of the doctor, the board or a board committee may take any of the following actions:
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2. Require the licensee to complete designated continuing medical education courses.
3. File an advisory letter. The licensee may file a written response with the board within thirty days after receiving the advisory letter.
B. Ariz. Rev. Stat. §§ 32-1401(27) provides "Unprofessional conduct"
includes the following, whether occurring in this state or elsewhere:
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(e) Failing or refusing to maintain adequate records on a patient.
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(r) Committing any conduct or practice that is or might be harmful or dangerous to the health of the patient or the public.
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Ariz. Rev. Stat. § 32-1401(2) provides:
“Adequate records” means eligible medical records, produced by hand or electronically, containing, at a minimum, sufficient information to identify the patient, support the diagnosis, justify the treatment, accurately document the results, indicate advice and cautionary warnings provided to the patient and provide sufficient information for another practitioner to assume continuity of the patient's care at any point in the course of treatment.
The Board has failed to establish by a preponderance of the evidence that
Respondent failed to obtain informed consent from Patient RE before attempting to remove the IUD fragment in his office. Respondent provided credible testimony that he thoroughly explained to Patient RE the risks, the benefits, and the alternatives to removing the IUD in his office. Patient RE made allegations in the complaint that were inconsistent with the medical records. Patient RE’s complaint included statements that were inconsistent with Patient RE’s testimony at hearing.
However, the Board has established by a preponderance of the evidence
that Respondent failed to maintain adequate records for Patient RE when he failed to document in the medical chart that he obtained informed consent and when he failed to document the in-office attempt to remove the IUD fragment. Dr. Lanza opined that Respondent should have explained how far he moved into the endometrial cavity to alert another physician as to what procedures were unsuccessful.
The Administrative Law Judge concludes that Respondent has committed unprofessional conduct as defined in Ariz. Rev. Stat. § 32-1401(27)(e) and (r).
Because Respondent has committed unprofessional conduct, the Administrative Law Judge concludes that the Board has authority to require that Respondent complete continuing medical education courses.
RECOMMENDED ORDER
Based upon the foregoing,
IT IS ORDERED that the Board’s August 12, 2024 Continuing Medical Education Order is modified to reflect that the basis of the Order is Respondent’s failure to adequately document informed consent and a medical procedure.
IT IS ORDERED that in all other respects the appeal is denied.
Pursuant to A.R.S. § 41-1092.08(I), the licensee may accept the Administrative Law Judge Decision by advising the Office of Administrative Hearings in writing not more than ten (10) days after receiving the decision. If the licensee accepts the Administrative Law Judge Decision, the decision shall be certified as the final decision by the Office of Administrative Hearings.
In the event of certification of the Administrative Law Judge Decision by the Director of the Office of Administrative Hearings, the effective date of the Order will be forty (40) days from the date of that certification.
Done this day, January 28, 2025.
/s/ Velva Moses-Thompson
Administrative Law Judge
Transmitted by either mail, e-mail, or facsimile to:
Patricia E. McSorley, Executive Director
Arizona Medical Board
Richard A. Kent, Esq.
Callie P. Maxwell, Esq.
Kent & Wittekind PC
[email redacted]
[email redacted]
Gregory L. De Santo, M.D.
[email redacted]
Elizabeth A. Campbell, Esq.
Office of the Attorney General
Licensing & Enforcement Section
[email redacted]
[email redacted]
By: OAH Staff