On 10/23/2015 we met with our attorney, Tony Park, at the State Court House in Downtown LA, at 9:30 A.M. for a Preliminary Hearing with a Judge for our up coming, December, court hearing.

At 10:00 A.M. we convened for a Settlement Conference with an Administrative Judge and a representative of the California State Attorney General's (AG) office.  After preliminary information, the Judge spent about 60 minutes hearing our side of the story. The Judge than met for about 20 minutes with the AG representative. Upon reconvening there was a brief of negotiation between our Attorney and the AG representative. At that point in time it was highly recommended, by the Judge, to us to take the settlement. A trial would be too costly financially and emotionally.

Summary of State Board of Pharmacy Disciplinary Orders for Inland Compounding Pharmacy, Inc. and Raylene L. Mote, Pharm.D.

1.   INTRODUCTION:  Pharmacy Permit and Raylene's Licenses revoked, but stayed, placed on probation for three (3) years on the following terms and conditions.
     a.   Applicable to permits obtained as a change of location for ICP granted during probation period.
2.   OBEY ALL LAWS:  Obey all state and federal laws and regulations.
      b.  Report in writing, within 72 hours any occurrences, to State Board.
3.   REPORT TO BOARD:  ICP & Raylene has to report to the Board quarterly, in writing by the 10th day following the end of the quarter.  (First report due July 10, 2016)
      a.  Includes Self-Assessments Reports, both Community and Compounding.
      b.  Use prescribed format.
4.   INTERVIEW WITH THE BOARD:  ICP & Raylene may have to appear for a Board Interview, upon request.
5.   COOPERATE WITH BOARD STAFF:  ICP & Raylene must cooperate with Board inspections, etc.
6.   CONTINUING EDUCATION:  Raylene must provide evidence of efforts to maintain skill and knowledge as a pharmacist as directed by board.
7.   NOTICE TO EMPLOYERS: Raylene must notify all present employers and prospective employers of terms and conditions of decision.  Within thirty (30) days for current employers, and fifteen (15) days for a new position, PIC must submit in writing to board that they have read the terms and conditions of the decision.
8.   NO SUPERVISION OF INTERNS OR SERVING AS A CONSULTANT:  Raylene can't supervise interns, or be left alone in the Pharmacy with them.  Raylene can't assume any new ownership or consulting jobs.
9.   REIMBURSEMENT OF BOARD COSTS:  ICP and Raylene to reimburse Board $9,359.50.
      a.  File of Bankruptcy on the part of ICP, Raylene or Gordon does not negate the costs.
10.  PROBATION MONITORING COSTS:  ICP & Raylene to reimburse Board for Monitoring Costs, annually.  Bill to be sent in April.
11.  STATUS OF LICENSE:  ICP & Raylene must maintain current licensure with the Board.
       a.  If business is discontinued the premise license must be surrender to the Board.
       b.  If Raylene cease practice to to retirement or health, or unable to meet terms of probation, she must surrender her license.
12.  NOTIFICATION OF A CHANGE IN NAME, RESIDENCE ADDRESS, MAILING ADDRESS, OR EMPLOYMENT:  Raylene must within ten (10) days notify board of any change in name, address, residence, or employment with supervisor's name.
13.  TOLLING OF PROBATION:  Raylene must be employed in the State of California for a minimum of Forty (40) hours per month.  (Includes vacation time.)
14.  REMEDIAL EDUCATION:  Raylene must, within 60 days, present to the Board an appropriate program of remedial education related to the discipline.  It must consist of at least 10 hours over the next 30 months.
15.  CONSULTANT FOR OWNER OR PHARMACIST-IN-CHARGE:  Raylene must hire an independent consultant, within Thirty (30) days, to review pharmacy operations on a monthly basis for compliance of federal and state laws and regulations and Raylene's obligations as PIC.  Can be reduced upon approval.
16.  NOTICE TO EMPLOYEES:  ICP must ensure that all employees in the operation are aware of all the terms and conditions of the probation, either with a posting or circulation of the notice.  Notice must be given to all new employees, etc. ICP must submit to the Board within Fifteen (15) days that this term has been satisfied.  Any new employees must be made aware of the notice and a notice sent to the board.
17.  OWNERS AND OFFICERS:  KNOWLEDGE OF THE LAW:  Gordon and Raylene must provide a written statement, by April 10, 2016, that they have read and are familiar with State and Federal laws and regulations governing the practice of pharmacy.
18.  POSTED NOTICE OF PROBATION:  ICP to post probation notice provided by the Board in a conspicuous public place for the length of probation.  No other misleading statement can be posted.
19.  COMMUNITY SERVICE:  ICP, within Sixty (60) days must submit a 100 hour Community Service plan for board approval.  Plan must commence within thirty (30) days, with quarterly reports.
20.  SEPARATE FILES OF RECORDS:  ICP shall maintain and make available for inspection all files pertaining to compounding.


1.   PROBATION MONITOR: Trang Song, Pharm.D., RPH, 626.941.5914 (Cell),  She will stop by quarterly, and intermittently unannounced.
2.   ENFORCEMENT ANALYSIS:  Jane Russell, 916.574.7941,
4.   OUTSIDE CONSULTANT:  Jenny Partaridge, Pharm.D., Pear Tree Apothecary, 408.391.8157,

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