Filing a Notice of Defense in Response to an Accusation or Statement of Issues

by | May 15, 2024 | Administrative Law, Response to an Accusation

When a California Professional Licensing agency such as the CA Department of Consumer Affairs, the CA Medical Board, the CA Dental Board, the CA Board of Pharmacy, the CA Commission on Teacher Credentialing, the CA Board of Registered Nursing, the CA Vocational Nursing Board, the CA Bureau of Real Estate, the CA Physical Therapy Board, the CA Board of Occupational Therapy, the CA Board of Behavioral Sciences, the CA Department of Insurance, the CA Department of Social Services, the CA Office of Real Estate Appraisal, the CA Veterinary Medical Board, etc… seeks to discipline a professional license they will mail out either an Accusation or a Statement of Issues.

When these CA licensing agencies mail out the Accusation or Statement of Issues, it will be accompanied by a Statement to Respondent, Request for Discovery and two copies of a Notice of Defense. The Notice of Defense supplied by these agencies includes space for the licensee or license applicant to include their attorney’s name.

However, if you are a CA medical doctor, nurse, chiropractor, bail bond agent, credentialed teacher, pharmacist, dentist, real estate agent or broker, insurance agent, veterinarian, physical therapist, or other licensed professional or applying for such a license, and you receive an Accusation or Statement of Issues, you should contact an experienced professional license defense attorney like Jonathan Turner right away. The reason is that I, CA administrative law defense attorney Jonathan Turner, will file my own more comprehensive Notice of Defense on your behalf with the applicable board. My Notice of Defense will raise all of the potential defenses that are at your disposal as a CA professional licensee or license applicant.

These defenses included jurisdictional based defenses. For example, a CA professional licensing agency can only deny or discipline a license if it has legal jurisdiction to do so. Licensing agencies generally cannot discipline licenses simply because a person made a mistake or error in judgment. Rather, the misconduct must also have a substantial relationship to the practice of one’s given profession.

There is also statute of limitations and laches defenses available if the agency, as is common for CA professional licensing agencies, drags its feet before issuing the Accusation or Statement of Issues.

There are numerous other possible defenses to CA professional license Accusations and Statements of Issues. If you receive an Accusation or Statement of Issues along with the Statement to Respondent and Notice of Defense, do not panic. Instead, immediately contact CA Professional License Defense Attorney Jonathan Turner.


If you received a denial of a professional license or any threat to your ability to continue practicing your profession, please contact attorney Jonathan Turner using this contact form or call (916) 471-6506 for a personal conversation.

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