Mounts

Facts Dignity hired appellant, an orthopedic surgeon, to work in a spine surgery practice at the San Luis Obispo French Hospital Center. Dignity contends that concerns regarding appellant’s clinical competence arose almost immediately. At the same time, appellant complained that he was not getting staff support or adequate time in the operating room to perform complex surgeries. Dignity put appellant’s complex surgeries “on hold” and required him to complete a previously scheduled surgery with a second surgeon he had not worked with before. Disputes regarding appellant’s practice continued. In December 2015, Dignity’s Chief of the Medical Staff, Chief of

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2 Anesthesiology, Vice President of Medical Affairs and the Chair of the Surgery Department requested that appellant refrain from operating until they completed a Focused Professional Practitioner Evaluation (FPPE) review. Appellant agreed to this restriction. Two days later, Dignity’s Medical Executive Committee (“MEC”) sent appellant a letter notifying him that Dignity would be required to submit a report to the Medical Board of California under…