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New Zealand Health Practitioners Disciplinary Tribunal |
Last Updated: 13 November 2014
Level 13, Mid City Tower, 139 Willis Street, Wellington
6011
PO Box 11649, Manners Street, Wellington 6142, New Zealand
Telephone:
64 4 381 6816 Facsimile: 64 4 802 4831
Email: dgainey@hpdt.org.nz
Website: www.hpdt.org.nz
DECISION NO: 478/Psy12/205P
IN THE MATTER of section 92 of the Health Practitioners
Competence Assurance Act 2003
AND
IN THE MATTER of disciplinary proceedings against LESLIE HUGH GRAY, registered psychologist of Whangarei
BEFORE THE HEALTH PRACTITIONERS DISCIPLINARY TRIBUNAL
TRIBUNAL: Ms K G Davenport (Chair)
Dr M Williams, Ms F Mathieson, Dr J Rucklidge, Mr H O’Rourke (Members)
Miss D Gainey (Executive Officer) Ms H Hoffman (Stenographer)
HEARING: Held in Whangarei on Thursday, 9 August 2012
APPEARANCES: Mr P Radich for the Professional Conduct Committee
Mr D McGill for Mr Gray
Introduction
1. Mr Leslie Hugh Gray is a registered psychologist who faces charges relating to disclosure of confidential and client information. He faces the following charges:
“A Professional Conduct Committee (PCC) of the Psychologists Board appointed under section 71 of the Health Practitioners Competence Assurance Act 2003 (the Act) lays the following charge before the Health Practitioners Disciplinary Tribunal (the Tribunal) under sections 81 and 91 of the Act.
To: Mr Leslie Hugh Gray
30 Pah Road Onerahi Whangarei
The PCC has reason to believe that a ground exists entitling the Tribunal to exercise its powers under section 100 of the Act.
In particular, the PCC has reason to believe that grounds exist for the Tribunal to find that, while a registered psychologist, you have been guilty of professional misconduct because of an act or omission that amounts to malpractice or negligence in relation to the psychologist scope of practice, in that:
1. In or around August 2007, you conducted a telephone interview with your former client, Ms S, in the course of your preparation of a report for the Whangarei Family Court under the Care of Children Act 2004 on Ms S’ nephew (the interview) in circumstances in which Ms S had instructed you, and you had agreed, that the fact of the interview and the information Ms S gave you in the course of the interview would remain confidential and, in the course of a hearing in the Family Court at Whangarei in June 2009 to which your report related, without Ms S’ consent or other lawful justification, you:
(a) divulged the fact of the interview and Ms S’ identity as the interviewee;
and/or
(b) divulged information Ms S had given you during the course of the interview, including the content of notes you had taken of the interview; and/or
(c) disclosed that Ms S had been a previous client of yours; and/or
(d) disclosed that Ms S had seen you for a trauma she had experienced; and/or
(e) said that it was inappropriate for you to talk about Ms S’ “mental state”.
2. Mr Gray pleaded not guilty to the charge.
3. The charge contains two areas of concern:
3.1. Particulars (a) and (b) of the charge relate to an allegation that Mr Gray disclosed information that the Professional Conduct Committee (“PCC”) says was the subject of the agreement that it would remain confidential.
(a) divulged the fact of the interview and Ms S’ identity as the interviewee;
and/or
(b) divulged information Ms S had given you during the course of the interview, including the content of notes you had taken of the interview; and/or
3.2. Particulars (c) to (e) relate to the allegation that Mr Gray made disclosures of a confidential nature about Ms S in Court.
(c) disclosed that Ms S had been a previous client of yours;
and/or
(d) disclosed that Ms S had seen you for a trauma she had experienced;
and/or
(e) said that it was inappropriate for you to talk about Ms S’ “mental state”.
4. There were three witnesses – Ms S, Mr Gray and Mr Richard Smith (Mr Gray’s supervisor).
5. The complaint arose out of the interaction between Mr Gray and Ms S during a custody dispute between Ms S’ brother and sister-in-law. Ms S had previously been a patient of Mr Gray.
6. Mr Gray was the Court appointed psychological report writer in the custody dispute.
7. Ms S said that she was supporting Ms Y, her former sister-in-law, in the custody dispute. Ms S agreed to speak to Mr Gray in 2007 because she wanted to assure Mr Gray that Ms Y was telling the truth about certain issues and that Mr Gray should listen to and believe her. She said she made it very clear to Mr Gray that she could only talk to him if the information was kept confidential. She said it would be personally very dangerous for her to be involved as she did not want her family to know that she was giving family information. She said she did not recall Mr Gray telling her he would have to give the Court information if requested to do so under cross examination. She said, however, that she would only have given him very limited information if he had made this clear.
8. Mr Gray claims it was only at the end of the conversation that Ms S withdrew her consent.
9. Ms S said she did not subsequently withdraw her consent during the conversation – she says it was always clear from the beginning.
10. Mr Gray is equally clear that as a matter of practice he would have discussed with Ms S the fact that he might have to disclose their conversation and its contents if cross examined about it in Court. He says that it was only at the end of the conversation that she withdrew consent to have the material used. He says therefore he made no notes and did not refer to her in his report.
11. Sometime after the conversation between Ms S and Mr Gray, Mr Gray was in Court and being cross examined on the custody issue. The Tribunal has a copy of the transcript of the hearing in which Mr Gray spoke of Ms S, his previous relationship with her and something about her history.
12. Mr Gray says when he was questioned about the conversation in Court he assumed he had Ms S’ consent as the questions came from Ms Y’s lawyer. He says he did not volunteer any information about Ms S. He says he simply agreed he had spoken to Ms S but nothing about their conversation. He said that Ms Y’s counsel questioned him in a way that ensured that both Ms S’ identity and the subject matter of the interview would be disclosed. He did not anticipate that Ms Y’s counsel “would push me under cross examination for details of the telephone interview”. (para 40, brief of Gray). He says that in referring to “her mental state” he was not implying anything inappropriate in this – he meant only that none of Ms S’ psychological details could be disclosed. He says that he intended no more than a neutral statement in using these words.
13. Mr Gray said that on day 1 of the hearing he simply referred to Ms S by name as an interviewee. However, on day 2 he was caught by surprise by a voir dire hearing which lasted all morning. When questioning resumed, he says he felt ambushed by Ms Y’s counsel wanting to pursue this line of questioning. He said that he assumed that Ms Y’s counsel was acting ethically in the questioning of him and had Ms S’ consent – so he felt it was acceptable that he discuss Ms S.
14. When cross examined Mr Gray acknowledged with hindsight he could have perhaps asked the Judge for guidance before giving Ms S’ name (and details).
15. Mr Gray denied that he could not remember details of the first call from Ms S as the transcript seems to show. He said he was caught by surprise, as set out in the Family Court transcript at page 366 (page 29 exhibit 1), by the first question. He said he was unprepared at the time for Ms S’ name to be raised. He was puzzled by it and had difficulty in recalling details. However, he told the Tribunal that
he has had time to meditate and recollect the conversation and is now (in 2012)
better able to recall the conversation than in 2009.
16. Mr Radich put to Mr Gray that his evidence on what was said in the telephone conversation was couched as being his usual practice. Mr Gray said this was a completely standard comment for him to make.
17. Mr Gray was asked if he could agree to withhold information. He said there were circumstances when he would agree information would not be put in a report but only on the basis that he would have to tell the truth under cross examination. He continued to assert that he had always made it clear to Ms S that he could have to disclose their conversation if cross examined.
18. He said he saw the Judge as needing ‘straight answers’ and considered his obligation to the Judge over-rode his obligation to Ms S.
19. Mr Radich asked him why he named Ms S on day 1 of the hearing. He said he felt he had to at that time. Mr Radich suggested that this showed a lack of caution by Mr Gray – Mr Gray accepted that he did not try to evade the question.
20. Mr Radich suggested that on day 2 of the hearing Mr Gray should have exercised caution about mentioning Ms S and the information he gave about her. Mr Gray said he agreed in hindsight.
21. Mr Gray said that he had no option but to hand over the notes of his conversation because of his role as report writer for the Court.
22. Mr Gray was asked by the Tribunal as to whether he had learned any lessons from this process. Mr Gray is now retired but said if he was practising, he would obtain written consent and be more mindful of requesting consultation with a Judge in chambers.
23. Mr Richard Charles Douglas Smith gave evidence. He had been Mr Gray’s supervisor for a number of years. He said that sometime during his supervision of Mr Gray he had discussed with him an ethical dilemma where Mr Gray had been asked to contact a woman who had previously been a counselling client of his. During supervision they agreed that it was important that the previous client understood that what she said during any discussion could be included in a report, or that Mr Gray might be required to disclose his previous professional
relationship with her. Mr Smith told the Tribunal that this discussion took place sometime in August 2011. Initially he told the Tribunal that it was most likely on 31 August 2011 but later when re-examined by Mr Radich suggested that it might have been 13 August 2007 but he had no notes of the supervision on that date. Mr Gray completed his report on 17 August 2007. He said even though he took no notes of the matter he remembered the incident clearly because of his need to go back and check the Code of Ethics.
24. That concluded the evidence.
Closing Submissions
25. Mr Radich submitted that the PCC had established the case.
26. Mr Radich submitted that as a psychologist, appointed under section 133 of the Care of Children Act 2004, Mr Gray had an obligation to put the welfare and best interests of the child first. Mr Gray’s submission was that his over-riding duty as an expert witness was to assist the Court impartially. He could not therefore proceed with an interview of any person when preparing a report that could be confidential, nor were there any circumstances in which he could receive information and not use it.
28. In Mr Radich submissions he said:
“12. Mr Gray’s evidence on the point is not entirely clear. But despite his inability, when giving evidence in the Family Court in 2009, to remember exactly what was said on the telephone, in the brief of evidence now filed he professes a far clearer recall. He said in his brief that he cautioned Ms S, as he does with everyone he speaks to in his role as a specialist report writer, that while she may ask that some information be kept confidential and not included in his report, he may not be able to withhold information when cross examined in the Family Court. This, in and of itself, does not align with the obligations of a report writer, as mentioned above.
13. While saying that ‘there is no place in the Family Court process for secret witnesses’ (paragraph 25), Mr Gray goes on in his written evidence to say that Ms S withdrew her consent to disclose the information discussed (paragraph 29) and withdrew her consent for any reference to her appearing in Mr Gray’s report (paragraph 31). In paragraph 32, Mr Gray expressed relief at this withdrawal of consent as saving him from having to include her contribution in his report”
29. Mr Radich also submitted that the disclosures made in the Family Court were significant and that, without needing to, he disclosed Ms S’ name, that Ms S had been referred to him as a client, said that he might have had a conversation with her which was confidential and gave the Court information on her mental state and her state or views on life. Mr Radich submitted that there was no need for Mr Gray to even mention that Ms S was a former client.
30. Mr Radich submitted that there had been a breach of confidence as recognised in
New Zealand in Hosking v Runting [2003] NZHC 416; [2003] 3 NZLR 385.
31. Mr McGill accepted that the law on breach of confidence was as set out in Hosking v Runting, that is that for a breach to be established the PCC must prove that the information given was confidential, was imparted under an obligation of confidence and that there was an unauthorised use or disclosure of the information.
32. Mr Radich also referred to the psychologist’s Code of Ethics and principle 11 of the Privacy Act. He submitted that there were limits on disclosure of personal information as amplified by the Health Information Privacy Code Rule 11. This rule provides that there must be no disclosure of Health Information unless there is consent or it is necessary for the maintenance of law or for the conduct of proceedings. In these circumstances disclosure is only permitted to the extent necessary for the particular purpose.
33. Code of Ethics 1.6.9 and 1.6.10 say:
1.6.9 Psychologists do not disclose personal information obtained from an individual, family, whanau or community group or colleague without the informed consent of those who provided the information, except in circumstances provided for in 1.6.10.
1.6.10 Psychologists recognise that there are certain exceptions and/or limitations to non-disclosure of personal information, and particular circumstances where there is a duty to disclose. These are: .....
34. Mr Radich for the PCC submitted that Mr Gray breached confidence in disclosing to the Court that Ms S had participated in the interview and in the information that she gave about her family. He submitted:
51. Ms S’ expectation of confidence in that situation was increased as a result of her former relationship with Mr Gray. She believed that he would not pass on the information, having built a relationship of trust with him. Mr Gray ought to have been aware of that, and should have taken the undertaking of confidentiality that he gave Ms S very seriously. As it was, however, Mr Gray said in the Family Court proceeding that he did not even recall Ms S’ request for confidentiality (transcript at page
366 to 367). It is disappointing Mr Gray did not attach a greater gravity to Ms S’ request, and to his own undertaking.
52. There were a number of options open to Mr Gray that would have preserved Ms S’ confidentiality – for example, requesting guidance from the Judge on how to proceed, in chambers. Even if Mr Gray had then been compelled by the Court to disclose Ms S’ name and the information relating to Ms S’ interview, Mr Gray would have satisfied himself that he had observed Ms S’ request for confidentiality and given the Judge an opportunity to address those concerns.
35. Mr Radich submitted that speaking of Ms S’ mental state was also a breach of confidence.
36. Further, Mr Radich submitted that Mr Gray had breached Rule 11 by disclosing health information of Ms S. He submitted there was no requirement to disclose the information to the Court for the purpose of the custody proceedings between Mr S and Ms Y. Mr Radich therefore submitted that Mr Gray was guilty of the charge.
37. Mr McGill submitted that Mr Gray denied the evidence of Ms S and stressed that Mr Gray advised Ms S he could not guarantee the confidentiality of the fact of the interview and the information that Ms S provided, if he was directly questioned under cross examination. Further, Mr McGill submitted that the disclosures made by Mr Gray were not serious enough to justify a charge and even if not best practice, do not amount to professional misconduct.
38. Mr McGill submitted that Mr Gray felt compelled during cross examination to give the answers that he did. He submitted that Mr Gray’s statement about what he said to Ms S in the first conversation should be preferred to that of Ms S because otherwise why would Mr Gray have proceeded to have such a risky discussion with her? He submitted that the threshold for disciplinary findings had not been established because there was no evidence from any expert that the
conduct complained of amounted to professional misconduct. He submitted further that the Tribunal should carefully analyse the evidence and that many of the disclosures complained of in the charge were in fact made by Ms Young, counsel for Ms Y and not by Mr Gray himself.
39. The Tribunal must now consider this evidence and the submissions in the light of the law.
The Law
40. A psychologist may be disciplined if the conduct complained of falls within one of the categories set out in s.100. The sections which are relevant to this case are s.100 (1) (a) and s.100 (1) (b). They are set out below.
“Section 100: Grounds on Which a Practitioner May Be Disciplined
1. The Tribunal may make 1 or more of the orders authorised by Section 101 if, after conducting a hearing on a charge laid under section 91 against a health practitioner, it makes 1 or more findings that:
(a) the practitioner has been guilty of professional misconduct because of any act or omission that, in the judgment of the Tribunal, amounts to malpractice or negligence in relation to the scope of practice in respect of which the practitioner was registered at the time that the conduct occurred; or
(b) the practitioner has been guilty of professional misconduct because of any act or omission that, in the judgment of the Tribunal has brought or was likely to bring discredit to the profession that the health practitioner practised at the time that the conduct occurred; or ......”
a. Amounts to malpractice or negligence in the way that they discharge their professional responsibilities; or
b. The acts or omissions will or are likely to bring discredit to the practitioner’s profession regardless of whether or not they occur within a practitioner’s scope of practice.
42. Malpractice has been described in the Collins English Dictionary1 as being:
“The immoral, illegal or unethical conduct or neglect of professional duty. Any incidence of improper professional conduct.”
43. The 1993 edition of the New Shorter Oxford Dictionary describes malpractice as:
“Improper treatment or culpable negligence of a patient by a physician or of a client by a lawyer.....a criminal or illegal action: common misconduct”.
44. Negligence, in the professional disciplinary context, does not require the prosecution to prove that there has been a breach of a duty of care and damage arising out of this as would be required in a civil claim. Rather, it requires an analysis as to whether the conduct complained of amounts to a breach of duty in a professional setting by the practitioner. The test is whether or not the acts or omissions complained of fall short of the conduct to be expected of a psychologist such as Mr Gray. This is a question of analysis of an objective standard measured against the standards of the responsible body of a practitioner’s peers.
45. As Justice Elias said in B v The Medical Council2:
“The structure of the disciplinary processes set up by the Act, which rely in large part upon judgment by a practitioner’s peers, emphasises that the best guide to what is acceptable professional conduct is the standards applied by competent, ethical, and responsible practitioners. But the inclusion of lay representatives in the disciplinary process and the right of appeal to this court indicates that usual professional practice, while significant, may not always be determinative: the reasonableness of the standards applied must ultimately be for the court to determine, taking into account all the circumstances including not only usual practice but also patient interests and community expectations, including the expectation that professional standards are not to be permitted to lag. The disciplinary process in part is one of setting standards”.
46. Section 100(1)(b) of the Act requires that the Tribunal determine whether or not the act or omission has brought, or is likely to bring discredit to the profession.
1 2nd Edition
2 HC, Auckland, HC 11/96, 8 July 1996, Elias J
The Nurses Act 1977 contained a similar clause and this was considered by the
Gendall J in Collie v Nursing Council of New Zealand3. He said:
“To discredit is to bring harm to the repute or reputation of the profession. The standard must be an objective standard with the question to be asked by the Council being whether reasonable members of the public, informed and with knowledge of all the factual circumstances, could reasonably conclude that the reputation and good-standing of the nursing profession was lowered by the behaviour of the nurse concerned.”
47. Gendall J also made comment on the definition of negligence and malpractice
[s.100(1)(a)]. He said at paragraph 21:
“Negligence or malpractice may or may not be sufficient to constitute professional misconduct and the guide must be standards applicable by competent,, ethical and responsible practitioners and there must be behaviour which falls seriously short of that which is to be considered acceptable and not mere inadvertent error, oversight or for that matter carelessness. ...”
48. The provisions contained in s.100 of the Act sit within the body of earlier well established case law on professional discipline. The statements made by Judges such as Gendall J in Collie (supra) and those set out below, still apply when considering the definition of malpractice and negligence.
49. Justice Jeffries described professional misconduct in Ongley v The Medical
Practitioners Disciplinary Tribunal4 as the answer to the following question:
“Has the practitioner so behaved in a professional capacity that the established acts under scrutiny would be reasonably regarded by his colleagues as constituting professional misconduct? With proper diffidence, it is suggested that the test is objective and seeks to gauge the given conduct by measurement against the judgment of professional brethren of acknowledged good repute and competency...”
50. Justice Venning in McKenzie v The MPDT5 described the test of professional misconduct as follows:
(Paragraph 71)
3 HC, Wellington AP 300/99, 5 September 2000
4 [1984] NZHC 102; [1984] 4 NZAR 369 at 375
5 HC Auckland, CIV 2002-404-153-02;12/06/03
“In summary, the test for whether a disciplinary finding is merited is a two-stage test based on first, an objective assessment of whether the practitioner departed from acceptable professional standards and secondly, whether the departure was significant enough to attract sanction for the purposes of protecting the public. However, even at that second stage it is not for the Disciplinary Tribunal or the Court to become engaged in a consideration of or to take into account subjective consideration of the personal circumstances or knowledge of the particular practitioner. The purpose of the disciplinary procedure is the protection of the public by the maintenance of professional standards. That object could not be met if in every case the Tribunal and the Court was required to take into account subjective considerations relating to the practitioner.”
51. Decisions such as these and other cases under the Medical Practitioners Act 1995 and its predecessor the Medical Practitioners Act 1968 established a 2 stage test for determining professional misconduct. The test provides:
(a) Was the conduct complained of such that a psychologist in the same vocational area as the psychologist charged think that the conduct fell (significantly) short of the conduct that was to be expected of a reasonably competent psychologist? and;
(b) If the answer to 1. is “yes”; then did this finding warrant the imposition of a disciplinary sanction for the purpose of protecting the public and or maintaining standards and or punishing the psychologist?
Discussion
52. The Tribunal accepts that there are legal obligations on a psychologist to protect confidential information both to clients and those who give information in confidence. Even to mention a person has been a patient, let alone why, breaches these obligations.
53. We set out below the exchanges between Mr Gray and counsel from the Family
Court transcript. This is the most useful tool for the Tribunal’s analysis.
54. At page 357 of the Family Court transcript Mr Gray answered questions from
Ms Young.
[Not for publication]
On page 358 of the Transcript:
[Not for publication]
On page 364 of the Transcript:
[Not for publication]
On Page 365 of the Family Court transcript:
[Not for publication]
On page 366 of the Family Court transcript:
[Not for publication]
On page 367 of the transcript:
[Not for publication]
On page 439-440 of the Family Court transcript:
[Not for publication]
The Tribunal considered this evidence.
55. The Tribunal finds that there was a discussion between Ms S and Mr Gray in August 2007 about the S family, at which time Ms S made it clear to Mr Gray that this information had to be kept confidential to him. However, the Tribunal does not think that the PCC has established, on the balance of probabilities that Mr Gray did not provide Ms S with a caution about cross examination. There is simply not enough evidence for it to be satisfied that the discussion did not take place. Ms S herself acknowledged he might have said this.
56. However the Tribunal considers that during the course of the Family Court case, Mr Gray disclosed far more information than he was required to do. He volunteered the name of Ms S without being asked to do so and then after having a night to consider this fact, he then provided more information, namely that she had seen him for a trauma that she had suffered and other information which was completely unnecessary for the custody case. He volunteered to read the notes out of the telephone conversation when he could (and we think should) have said to the Judge “I have concerns about the confidentiality of these notes” and at least had a discussion with the Judge about whether it was necessary to produce them. As the transcript is read, it is clear that he simply had no filter as to the
information he gave out about Ms S. He had agreed that Ms S wished to keep this information private but nonetheless he appeared to be prepared to disclose quite a lot of information.
57. The Tribunal rejects Mr Gray’s suggestion that he believed he had consent because Ms Y’s counsel was asking him about it. He had an obligation to Ms S as a former client to protect her confidentiality.
58. The Tribunal therefore finds in respect of the particulars as follows.
(a) Divulged the fact of the interview and Ms S’ identity as the interviewee.
The Tribunal finds particular (a) is not established. Mr Gray did refer to Ms S by name twice during the interview (see above) but as we have found that the PCC have not proved that there was an absolute guarantee of confidentiality we do not think that this particular has been made out.
(b) Divulged information Ms S had given you during the course of the interview, including the content of notes you had taken of the interview.
The Tribunal finds particular (b) established. Mr Gray acknowledges that there was a discussion about confidentiality and regardless of whether there was a limitation on this (ie a discussion about cross examination), he disclosed far more information about Ms S than he should have consistent with his obligations of confidentiality (see particularly page 365 of the Transcript). However as we have found that we do not have sufficient evidence to determine whether Mr Gray and Ms S did agree that the conversation was completely confidential we consider that this particular on its own would not be sufficiently serious to amount to professional misconduct. However as set out below we consider that taken cumulatively with particulars (c) and (d) professional misconduct is established.
(c) Disclosed that Ms S had been a previous client of yours.
The Tribunal finds particular (c) established. Mr Gray did disclose to the Court that Ms S had been a previous client without being required to do so. This is set out at page 365 of the Transcript. Psychologists know that it is an important part of their Code of Ethics not to disclose that a person has been a client except in limited circumstances which do not apply.
(d) Disclosed that Ms S had seen you for a trauma she had experienced;
The Tribunal finds particular (d) established. Mr Gray disclosed confidential information about Ms S in breach of his obligations as a psychologist. There was no reason why Mr Gray had to tell the Court this information.
(e) Said that it was inappropriate for you to talk about Ms S’ “mental state”.
The Tribunal finds particular (e) not established. The Tribunal does not find that use of the word “mental state” implied any adverse connotations about Ms S and is a phrase a psychologist might use.
59. The Tribunal is obliged to consider whether the threshold for disciplinary action has been met for particulars (b), (c) and (d). The Tribunal considers that client confidentiality is vital and a very important part of a health professional’s role. This is especially true when the client is receiving trauma counselling. The Tribunal finds Mr Gray breached this duty of confidence without any justifiable cause. Mr Gray may well have felt under pressure to disclose client information and this may be reflected in the penalty, but the obligation on a health professional to protect client confidentiality (in particular) is strong and Mr Gray does not appear to have realised this. Accordingly the Tribunal finds Mr Gray’s conduct in these particulars does meet the threshold for disciplinary action. The Tribunal considers that particulars (b), (c) and (d) when taken cumulatively amount to professional misconduct. On their own particulars (c) and (d) would also amount to professional misconduct. The charge is therefore established.
60. The Tribunal invites submissions as to penalty. The PCC is to file its submissions on penalty within 10 days of the date of this decision, Mr Gray 10 days thereafter and the PCC (strictly in reply) 3 days thereafter.
DATED at Auckland this 20th day of September 2012
................................................................ K G Davenport
Deputy Chair
Health Practitioners Disciplinary Tribunal
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