MEDICAL BOARD OF CALIFORNIA DEPARTMENT OF ... › documents › Conley, Gene Raymond...13 12....

BEFORE THE MEDICAL BOARD OF CALIFORNIA

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Against:

GENE RAYMOND CONLEY, M.D.

Physician's and Surgeon's Certificate No. G40586

Respondent

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Case No. 08-2012-223178

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DECISION

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

This Decision shall become effective at 5:00 p.m. on June 19, 2015.

IT IS SO ORDERED: May 20, 2015.

MEDICAL BOARD OF CALIFORNIA

Jamie Wright, J.D., Chair Panel A

1 KAMALA D. HARRIS Attorney General of California

2 JUDITH T. ALVARADO Supervising Deputy Attorney General

3 MEGAN R. O'CARROLL Deputy Attorney General

4 State Bar No. 215479 California Department of Justice

5 1300 I Street, Suite 125 P.O. Box 944255

6 Sacramento, CA 94244-2550 Telephone: (916) 324-5288

7 Facsimile: (916) 327-2247 Attorneys for Complainant

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In the Matter of the Accusation Against:

GENE R. CONLEY, M.D. 1932 Stillwater Dr. Walla Walla, WA

Physician's and Surgeon's Certificate No. G 40586,

Respondent.

Case No. 08-2012-223178

OAH No. 2014070033

STIPULATED SETTLEMENT AND DISCIPLINARY ORDER

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

20 entitled proceedings that the following matters are true:

21 PARTIES

22 1. Kimberly Kirchmeyer ("Complainant") is the Executive Director of the Medical

23 Board of California. She brought this action solely in her official capacity and is represented in

24 this matter by Kamala D. Harris, Attorney General of the State of California, by Megan R.

25 O'Carroll, Deputy Attorney General.

26 2. Respondent Gene R. Conley, M.D. ("Respondent") is represented in this proceeding

27 by attorney Lawrence E. Wayte, Esq., whose address is: 7647 North Fresno Street, Fresno, CA

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STIPULATED SETTLEMENT (08-2012-223178)

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3. On or about August 20, 1979, the Medical Board of California issued Physician's and

Surgeon's Certificate No. G 40586 to Respondent. The Physician's and Surgeon's Certificate was

in full force and effect at all times relevant to the charges brought in Accusation No. 08-2012-

223178 and will expire on February 28, 2017, unless renewed.

JURISDICTION

4. Accusation No. 08-2012-223178 was filed before the Medical Board of California

(Board), Department of Consumer Affairs, and is currently pending against Respondent. The

Accusation and all other statutorily required documents were properly served on Respondent on

May 22, 2014. Respondent timely filed his Notice of Defense contesting the Accusation.

5. A copy of Accusation No. 08-2012-223178 is attached as exhibit A and incorporated

herein by reference.

ADVISEMENT AND WAIVERS

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

charges and allegations in Accusation No. 08-2012-223178. Respondent has also carefully read,

fully discussed with counsel, and understands the effects of this Stipulated Settlement and

Disciplinary Order.

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

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

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

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

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

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

Administrative Procedure Act and other applicable laws.

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

every right set forth above.

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1 CULP ABILITY

2 9. Respondent understands and agrees that the charges and allegations in Accusation

3 No. 08-2012-223178, if proven at a hearing, constitute cause for imposing discipline upon his

4 Physician's and Surgeon's Certificate.

5 10. For the purpose of resolving the Accusation without the expense and uncertainty of

6 further proceedings, Respondent agrees that, at a hearing, Complainant could establish a factual

7 basis for the charges in the Accusation, and that Respondent hereby gives up his right to contest

8 those charges.

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

1 O discipline and he agrees to be bound by the Board's imposition of discipline as set forth in the

11 Disciplinary Order below.

12 CIRCUMSTANCES IN MITIGATION

13 12. Respondent Gene R. Conley, M.D. has never been the subject of any disciplinary

14 action. He is admitting responsibility at an early stage in the proceedings.

15 RESERVATION

16 13. The admissions made by Respondent herein are only for the purposes of this

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

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

19 civil proceeding.

20 CONTINGENCY

21 14. This stipulation shall be subject to approval by the Medical Board of California.

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

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

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

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

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

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

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

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

2 considered this matter.

3 15. The parties understand and agree that Portable Document Format (PDF) and facsimile

4 copies of this Stipulated Settlement and Disciplinary Order, including Portable Document Format

5 (PDF) and facsimile signatures thereto, shall have the same force and effect as the originals.

6 16. In consideration of the foregoing admissions and stipulations, the parties agree that

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

8 Disciplinary Order:

9 DISCIPLINARY ORDER

10 IT IS HEREBY ORDERED that Physician's and Surgeon's Certificate No. G 40586 issued

11 to Respondent Gene R. Conley, M.D. (Respondent) is revoked. However, the revocation is

12 stayed and Respondent is placed on probation for four (4) years on the following terms and

13 conditions.

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

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

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

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

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

19 illness or condition.

20 Within 15 calendar days ofreceiving any lawfully prescribed medications, Respondent

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

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

23 telephone number.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

11 use of products or beverages containing alcohol.

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

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

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

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

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

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

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

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

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

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




25 3. BIOLOGICAL FLUID TESTING. Respondent has entered into a monitoring

26 contract with the Washington Physicians Health Program (WPHP), which includes random urine

27 toxicology testing. Respondent shall submit to biological fluid testing as required by the WPHP.

28 Respondent has provided written consent authorizing the WPHP to provide the results of the

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1 biological fluid testing to the Board or its designee, and the WPHP has agreed to provide the

2 results of the biological fluid testing to the Board or its designee. A certified copy of any

3 laboratory test result from the WPHP toxicology screening may be received in evidence in any

4 proceedings between the Board and Respondent.

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

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

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

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

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

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

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

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

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

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

15 probationary time period.




19 4. NOTIFICATION. Within seven (7) days of the effective date of this Decision, the

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

21 Chief Executive Officer at every hospital where privileges or membership are extended to

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

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

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

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

26 calendar days.

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

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1 5. OBEY ALL LAWS. Respondent shall obey all federal, state and local laws, all rules

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

3 ordered criminal probation, payments, and other orders.

4 6. QUARTERLY DECLARATIONS. Respondent shall submit quarterly declarations

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

6 compliance with all the conditions of probation.

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

8 of the preceding quarter.

9 7. GENERAL PROBATION REQUIREMENTS.

IO Compliance with Probation Unit

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

12 this Decision.

13 Address Changes

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

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

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

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

18 and Professions Code section 2021 (b ).

19 Place of Practice

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

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

22 facility.

23 License Renewal

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

25 license.

26 8. INTERVIEW WITH THE BOARD OR ITS DESIGNEE. Respondent shall be

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

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

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1 9. NON-PRACTICE WHILE ON PROBATION. Respondent shall notify the Board or

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

3 30 calendar days and within 15 calendar days of Respondent's return to practice. Non-practice is

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

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

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

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

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

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

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

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

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

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

14 of Condition 18 of the current version of the Board's "Manual of Model Disciplinary Orders and

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

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

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

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

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

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

21 10. COMPLETION OF PROBATION. Respondent shall comply with all financial

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

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

24 be fully restored.

25 11. VIOLATION OF PROBATION. Failure to fully comply with any term or condition

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

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

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

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

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

3 the matter is final.

4 12. LICENSE SURRENDER. Following the effective date of this Decision, if

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

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

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

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

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

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

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

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

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

14 13. PROBATION MONITORING COSTS. Respondent shall pay the costs of probation

15 monitoring each and every year of probation, in the amount of $500.00. Such costs shall be

16 payable to the Medical Board of California and delivered to the Board or its designee no later

1 7 than January 31 of each calendar year.

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1 ACCEPTANCE

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

3 discussed it with my attorney, Lawrence E. Wayte, Esq .. I understand the stipulation and the

4 effect it will have on my Physician's and Surgeon's Certificate. I enter into this Stipulated

5 Settlement and Disciplinary Order voluntarily, knowingly, and intelligently, and agree to be

6 bound by the Decision and Order of the Medical Board of California.

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DATED: ) I ' I /,_ :'.- I ' )

GENf R. CONLEY, M:IY. Respondent

10 I have read and fully discussed with Respondent Gene R. Conley, M.D. the terms and

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

12 I approve its form and content.

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DATED: Lawrence E. Wayte, Esq. Attorney for Respondent

ENDORSEMENT

The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

submitted for consideration by the Medical Board of California. Dated: '-fY"t,d~~·veit I {J

1 ;20t 5 Respectfully submitted,

SA2013310332

KAMALA D. HARRIS Attorney General of California JUDITH T. ALVARADO Supervising Deputy Attorney General

11/( r0~J1j)et ME O'CARROLL Depu y omey General Attorneys for Complainant

28 11725253 doc.docx

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Exhibit A

Accusation No. 08-2012-223178

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KAMALA D. HARRIS Attorney General of California JUDITH T. ALVARADO Supervising Deputy Attorney General MEGAN R. O'CARROLL Deputy Attorney General State Bar No. 215479

1300 I Street, Suite 125 P.O. Box 944255 Sacramento, CA 94244-2550 Telephone: (916) 324-5288 Facsimile: (916) 327-2247

Attorneys for Complainant

FILED STATE OF CA1.IFORNIA

MmBOA. ~CAL. IFORNIA SA TOr ,,Z{_'KJ!!/-ay _ . =· . . ... ··--= ANAL YiT

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10

11 In the Matter of the Accusation Against:

12 GENER. CONLEY, M.D. 2615 E. Clinton Ave.

13 Fresno, CA 93703

14 Physician's and Surgeon's Certificate No. G 40586

15 Respondent.

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17 Complainant alleges:

18 PARTIES

Case No. 08-2012-223178

ACCUSATION

19 1. Kimberly Kirchrneyer (Complainant) brings this Accusation solely in her official

20 capacity as the Executive Director of the Medical Board of California, Department of Consumer

21 Affairs.

22 2. On or about August 20, 1979, the Medical Board of California issued Physician's and

23 Surgeon's Certificate Number G 40586 to Respondent Gene R. Conley, M.D. (Respondent). The

24 Physician's and Surgeon's Certificate was in full force and effect at all times relevant to the

25 charges and allegations brought herein and will expire on February 28, 2015, unless renewed.

26 I I I

27 I I I

28 I I I

Accusation (08-2012-223178)

JURISDICTION

2 This Accusation is brought before the Medical Board of California (Board),

3 Department of Consumer Affairs, under the authority of the following laws. All section

4 references are to the Business and Professions Code (Code) unless otherwise indicated.

5 4. Section 2227 of the Code states:

6 "(a) A licensee whose matter has been heard by an administrative law judge of the Medical

7 Quality Hearing Panel as designated in Section 11371 of the Government Code, or whose default

8 has been entered, and who is found guilty, or who has entered into a stipulation for disciplinary

9 action with the board, may, in accordance with the provisions of this chapter:

1 O "(1) Have his or her license revoked upon order of the board.

11 "(2) Have his or her right to practice suspended for a period not to exceed one year upon

12 order of the board.

13 "(3) Be placed on probation and be required to pay the costs of probation monitoring upon

14 order of the board.

15 "( 4) Be publicly reprimanded by the board. The public reprimand may include a

16 requirement that the licensee complete relevant educational courses approved by the board.

17 "( 5) Have any other action taken in relation to discipline as part of an order of probation, as

18 the board or an administrative law judge may deem proper.

19 "(b) Any matter heard pursuant to subdivision (a), except for warning letters, medical

20 review or advisory conferences, professional competency examinations, continuing education

21 activities, and cost reimbursement associated therewith that are agreed to with the board and

22 successfully completed by the licensee, or other matters made confidential or privileged by

23 existing law, is deemed public, and shall be made available to the public by the board pursuant to

24 Section803.l."

25 5. Section 2234 of the Code states, in pertinent part, that:

26 "The board shall take action against any licensee who is charged with unprofessional

27 conduct. In addition to other provisions of this article, unprofessional conduct includes, but is not

28 limited to, the following:

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Accusation (08-2012-223178)

1 "

2 "(f) Any action or conduct which would have warranted the denial of a certificate.

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6. 4 Unprofessional conduct under Code section 2234 is conduct which breaches the rules

5 or ethical code of the medical profession, or conduct which is unbecoming to a member in good

6 standing of the medical profession, and which demonstrates an unfitness to practice medicine.

7 (Shea v. Board of Medical Examiners (1978) 81 Cal.App.3d 564, 575.)

8 7. Section 2238 of the Code states:

9 "A violation of any federal statute or federal regulation or any of the statutes or regulations

1 O of this state regulating dangerous drugs or controlled substances constitutes unprofessional

11 conduct."

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8. Section 2239 of the Code states, in pertinent part, that:

"(a) The use or prescribing for or administering to himself ... of any controlled substance;

or the use of any of the dangerous drugs specified in Section 4022 ... to the extent, or in such a

manner as to be dangerous or injurious to the licensee, or to any other person or to the public, or

to the extent that such use impairs the ability of the licensee to practice medicine safely or more

than one misdemeanor or any felony involving the use, consumption, or self-administration of any

of the substances referred to in this section, or any combination thereof, constitutes unprofessional

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

"

21 10. Section 1360, title 16, of the California Code of Regulations states:

22 "For the purposes of denial, suspension or revocation of a license, certificate or permit

23 pursuant to Division 1. 5 (commencing with Section 4 7 5) of the code, a crime or act shall be

24 considered to be substantially related to the qualifications, functions or duties of a person holding

25 a license, certificate or permit under the Medical Practice Act if to a substantial degree it

26 evidences present or potential unfitness of a person holding a license, certificate or permit to

27 perform the functions authorized by the license, certificate or permit in a manner consistent with

28 the public health, safety or welfare. Such crimes or acts shall include but not be limited to the

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Accusation (08-2012-223178)

1 following: Violating or attempting to violate, directly or indirectly, or assisting in or abetting the

2 violation of, or conspiring to violate any provision of the Medical Practice Act."

3 FIRST CAUSE FOR DISCIPLINE

4 (Use of Controlled Substances)

5 11. Respondent has subjected his Physician's and Surgeon's Certificate No. G 40586 to

6 disciplinary action under sections 2227 and 2234, as defined by section 2239, subdivision (a), of

7 the Code, in that he has used controlled substances, as more particularly alleged hereinafter:

8 12. Respondent has a life-long history of drug and alcohol abuse that began in high

9 school. He sought treatment and achieved sobriety in between 1981 and 1990. Between 1990

10 and 2000, he developed a pattern of consuming prescription opioid medications at night to help

11 him sleep. In 2000, he sought treatment again, participating in a 90 day treatment program, which

12 helped him achieve another lengthy period of sobriety.

13 13. Beginning on or about June of 2009, and over the following approximate 18 month

14 period, Respondent experienced a series ofrelapses during which took Vicodin, Percocet and

15 Demerol at night to help him sleep and to reduce anxiety. He did not seek treatment for his

16 anxiety or insomnia, or obtain prescriptions, before taking these medications.

17 14. At sometime before June 2009, Respondent obtained a vial of Demerol from a

18 relative. The relative was not a medical provider, and neither the relative nor Respondent had a

19 prescription for the Demerol. On or about June of2009, Respondent began injecting himself with

20 the Demerol. Between June of 2009 and October of2010, he injected himself with Demerol

21 approximately 10-15 times. During this time, he also took Vicodin and Percocet that he obtained

22 from relatives, without a prescription. Respondent obtained approximately 1500 tablets of

23 Percocet from a relative, without a prescription.

24 15. Toward the end of the year 2009, Respondent sought treatment for his drug use, but

25 he continued to relapse. Respondent sought treatment from a physician specializing in addiction

26 medicine. This physician referred Respondent to a treatment program that included drug testing.

27 On or about October of 2010, Respondent tested positive for opioids. Respondent reported to the

28 treatment program that he had injected himself with Demerol.

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Accusation (08-2012-223178)

16. Following his positive drug test in October 2010, Respondent voluntarily admitted

2 himself into intensive drug treatment program, Talbots Recovery Center, in Georgia. Respondent

3 claims to have maintained his sobriety since being discharged from Talbots in January 2011.

4 SECOND CAUSE FOR DISCIPLINE

5 (General Unprofessional Conduct)

6 17. Respondent has further subjected his Physician's and Surgeon's Certificate No.

7 G 405 86 to disciplinary action under sections 2227 and 2234, as defined by section 2234, of the

8 Code, in that he has engaged in conduct which breaches the rules or ethical code of the medical

9 profession, or conduct which is unbecoming a member in good standing of the medical

1 O profession, and which demonstrates an unfitness to practice medicine, as more particularly alleged

11 in paragraphs 11 through 16, above, which are hereby incorporated by reference and realleged as

12 if fully set forth herein.

13 PRAYER

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

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

16 1. Revoking or suspending Physician's and Surgeon's Certificate No. G 40586, issued to

17 respondent Gene R. Conley, M.D.;

18 2. Revoking, suspending or denying approval ofrespondent Gene Conley, M.D. 's

19 authority to supervise physician assistants, pursuant to section 3527 of the Code;

20 ,.., .J. Ordering respondent Gene Conely, M.D. to pay the Medical Board of California the

21 costs of probation monitoring, if placed on probation; and

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

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24 DATED: May 22. 2014

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27 SA2013310332

28 31973558.doc

Executive Dir or Medical Board of California Department of Consumer Affairs State of California Complainant

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Accusation (08-2012-223178)

MEDICAL BOARD OF CALIFORNIA DEPARTMENT OF ... › documents › Conley, Gene Raymond...13 12....

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