Kirchmeyer

I. Background A. Investigation of Dr. Pardo In April of 2020, the U.S. Drug Enforcement Agency (DEA) contacted the Medical Board of California (Medical Board) about a DEA investigation into potential excessive and/or unnecessary prescribing of controlled substances by Dr. Pardo. Prompted by the DEA’s referral to the Board, the DCA (acting on behalf of the Board) initiated an investigation of its own. As part of this investigation, a medical consultant reviewed reports from the DEA and from a statewide database that tracks prescribing and dispensing activity for controlled substances. In the course of his review, the medical consultant identified concerns relating to Dr. Pardo’s prescribing practices. Prompted by these concerns, the DCA reached out repeatedly to six of Dr. Pardo’s patients, requesting their authorization for Dr. Pardo to release their medical records to it. Thus, for example, in June of 2021, the DCA mailed each of the six patients a letter requesting such authorization; in May

2 of 2022, it mailed four of the six patients a second round of such letters; and, in July of 2022, it mailed all six patients a third round of such letters. Accompanying each letter in…