KAMALA D. HARRIS: State of California Attorney General DEPARTMENT OF JUSTICE RONALD REAGAN BUILDING ‘300 SOUTH SPRING STREET, SUITE 1702 LOS ANGELES, CA 90013 Publi: (213) 897-2000 December 10, 2015 Billy Zachery Earley, P.A. 2144 Wembley Lane Corona, CA 92881 Re: COMPLAINT OF NOVEMBER 27, 2015 In the Matter of the Accusation Against: BILLY ZACHERY EARLEY, P.A. OAH NO. 2015030386 Physician Assistant Board Case No. 1E-2011-220507 Dear Mr. Earley: We are counsel for the Physician Assistant Board and represent them in this matter against you. We are in receipt of your complaint which appears to address the Accusation filed against you on December 19, 2014, baseci primarily on the allegation that you prescribed dangerous drugs to six patients without performing an adequate examination and without medical indication. You also complained that the investigators, who investigated the incidents which from the basis for the Accusation, abused their authority, tampered with officiel government documents and created false reports. Addressing your complaint regarding Accusation No. 1E-2011-220507, you have filed a Notice of Defense contesting the allegations contained therein. You, through your attomey, were provided with discovery on December 30, 2014, and a hearing on the matter is scheduled for March 7 through March 11, 2016. A copy of the Notice of Hearing, which was served-on you on March 17, 2015, is attached hereto. At the hearing, you will be permitted to present relevant evidence to contest the allegations set forth in Accusation No. 1B-2011-220507, before an impartial Administrative Law Judge, who will issue a proposed decision after all the evidence of the case has been submitted and the matter concluded. Accordingly, we are unable to comment upon the issues set forth in your complaint of November 27, 2015, at this time Regarding your complaint with the investigators, please be advised that they are employees of the Division of Investigation-Health Quality Investigation Unit. Your complaint has been forwarded to that agency.Billy Zachery Earley, P.A, December 10, 2015 Page 2 Should you have any questions regarding the foregoing, please feel free to call me or Mr. McKenna. Sincerely, JUDITH. ALY. 0 Supervising Deputy Attorney General For KAMALAD. HARRIS Attomey General ITAccg Enclosure cc: Gloria Castro, Senior Assistant Attorney General Joseph F. McKenna, Deputy Attorney General 82014708189