Grafilo

*1027 Marc David Wolfsohn, M.D., appeals from an order compelling him to produce the medical records of five of his patients pursuant to a subpoena issued by an investigator with the Medical Board of California (Medical Board), a unit of the Department of Consumer Affairs (DCA). We agree with Wolfsohn that the DCA did not establish good cause for the subpoena and, therefore, reverse.

*1028 FACTUAL AND PROCEDURAL SUMMARY

A. Background

Wolfsohn is a physician specializing in pain management. He has been licensed by the Medical Board to practice medicine since 1977.

In December 2014, the Medical Board received a report from a law enforcement officer that Wolfsohn may be overprescribing controlled substances to patients. The Medical Board opened an investigation and obtained from the Controlled Substance Utilization Review and Evaluation System 1 ("CURES") a report of Wolfsohn's *567 history of prescribing controlled substances for the period between January 30, 2014 and January 30, 2015.

Dr. Shoaib Naqvi is a medical consultant for the DCA with the "responsibility to maintain familiarity with the standard of medical practice in the State of California." Naqvi reviewed the CURES…