BEFORE THE CALIFORNIA BOARD OF ACCOUNTANCY DEPARTMENT OF CONSUMER AFFAIRS

STATE OF CALIFORNIA

In the Matter ofthe Accusation Against:

CHRISTINE LOUISE KUZMA aka CHRISTINE LOUISE KUZMA TORRA PO Box 574 Los Olivos, CA 93441

Certified Public Accountant License No. 39094

Respondent.

Case No. AC-2016-104

OAH No. 2016090577

DECISION AND ORDER

The attached Stipulated Settlement and Disciplinary Order is hereby adopted by the

California Board of Accountancy, Department of Consumer Affairs, as its Decision in this

matter.

This Decision shall become effective on \ --~~---------------

u\tct\ llp-

It is so ORDERED ____n__._\~2CJ=--.LII'----'l(J'--------

FORT CALIFORNIA BOA F ACCOUNTANCY DEPARTMENT OF CONSUMER AFFAIRS

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KAMALA D. HARRIS Attomey General of California THOMAS L. RINAUDJ Supervising Depi1ty Attorney General DESIREE TULLENERS Deputy Attorney General State Bar No. 157464

300 So, Spring Street, Suite 1702 Los Angel~s. CA 90013 Telephone; (213) 897~2578 Facsimile: (213) 897~2804

Attorn~ysfor Complainant

In the Matter of the Accusation Against:

CHRISTINE LOUISE KUZMA aka CHRISTINE LOUlSE KUZMA TORRA PO Box 574 Los Olivos, CA 93441

Certified Puplic 1\,~couutant License :No. 39094 .

Respm1dent.

BEFORE THE CALIFORNIA BOARD OF ACCOUNTANCY DEPARTMENT OF CONSUMERAFFAIRS

STATE OF CALIFORNIA

Case No. AC"20 16-104

OAHNo. 2016090577

STII)ULATED SJ;::TTLEMENT AND DISCIPLINARY ORDER

PARTIES

1. Patti Bowers (Complainant) is the Executive Officer of the daliJ:orniaJ:loatd of

Accountancy (CBA). She brought this action solely in her o.fficial capadty and is represented in

this mattet by Kamala D. Han-is, Attorney General of the State of California, by Desiree

Tulleners, Deputy Attomey GeneraL

2. Respondent Clu-istine LouiseK1.1zma aka Christine Louise Kuzma Torra

(Respondent) is represented in this proceeding by attorney Alat:J. W, Foutz, Esq., whose address is:

Alan W. Foutz The Law Office of Alan W. Foutz 8880 Cal Center Drive, Suite 400 Sacramento, CA 95826

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STIPULATED SETTLEMENT (AC-2016~104)

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3. On or about December 2, 1983, the CBAissued Certified Public Accountant License

No. 39094 to Christine Louise Kuzma aka Cfuistine LouiseKuzma Torra(Respondent). The

Certified Pt1blic Accotuxtant License was in full force and effect at all times relevantto the

charges brought inAccu.sation No. AC~2016-104~ ?ndwill expire on October 31, 2017, \-ll1less

retJ.ewed.

JURISDICTION

4. Accusation No, AC~20 16-104was filed befqre tlw Gl3A, and is c.t1tre1:1tly p!:inding

against Respondent. The Acct.1sation and all other statutorily reqt.ured documents were properly

served on Responde;:nt on August 8, 2016. Respondent timely filed her Notice of Defense

contesting the Accusation.

5. A copy of Apctlsation No. AC-2016-104 is attachecl. as Exhibit A, and incorporated

hereiti by referei1Q'e,

ADVISEMENTAND WAIVERS

6. Responcl.e!1t has caxefully read, f~tlly discttssed With counsel, and understan.ds the

charges and allegations in Accusation No. AC~2016-l04. Respondent has also carefullyread,.

fully disct1ssed·with counsel, and understands the effects ofthis; Stipulated Settlement and

Disciplinary OrQ.er.

7. Respcmdent is fully aware ofhet legal rights in this tnatter1 including the right to a

hearing on.the .charges and allegations in the Accusation; the right·to be represented.by·counsel at

her own expense; the right to confront and cross.;exatni11.ethe witn.esses againsthet; the right to

present evidence and to testify on her own behalf; the right to the issuai1ce ofsubpoenas to

compel the attendance ofwitnesses and the production ofdocuments; the right to reconsideration

and court teview of an adverse decision; and all otherrights accorded by the Calito:r:nia

Administrative Procedure Act and other applicable laws.

8. Respondent voluntarily, knowingly~ and intelligently waives and gives up each and

every right set fmth above.

Ill

Ill

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STIPULATED SETTLEMENT (AC"2016-104)

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STIPULATED SETTLEMENT CAC·2016-1 04)

CULPABILITY

9. Respondent admits the truti1 of each and every charge and allegation in Accusation

No. AC~2016 .. 104.

10. Responclet~t ttgl'ees that her CettitiedPublicAccountantLipei'iSe is subject to

<liscipline-a,t1d she agrees to be bound hy the CBA's probationary tem1s as set forth in the

Disciplinary Otder- below.

CONTINGENCY

LL This stipulation shall be subject to approval by the CBA. Respondent understands

and agtees. that counsel fot Complainant.and the staff ofthe CBA may comlnqnicate directly with

the CBA regarding this stipulationand settlement; 'Withc~t1t notice to or participatiot1 by

Respondent. By signing the stipulation, Respondent understands and agrees that she may not

withdraw her agreement or seek to rescind the stipulation prior to the time the CBA cousiders and

acts upon it. Ifthe CBA fails to adoptthis stipulation as its Decision and Order, the Stipulated

Settleme11t and Disciplinary Orde1' shafl beof110 force or efiect~ except for this paragraph~ it shall

be inadtnissible in. any legaLaction betwee11 the. parlies, and the CBA. shall not be disqualified

from further action by having considered this matter.

12. The parties understand and agree that POrtableDocumentFormat(PDF) and facsimile

copies ofthisStipulatedSettlement andDisciplinary Order, including PDF and facsimile

signatures thereto, shall have the same force and effect as fhe originals.

13. TI1is Stipulated Settlement and Discipliuaty Order is inteuded by the parties to be an

integrated Wtiting representing the complete, .final, and exclusive embodiment oftheir agreement

It supersedes any and all prior or contemporaneous agreements, understandings, discussions,

negotiations, and commitments (wtitten ororal). This Stipulated Settlement and Disciplinary

Order may not he altered, amended, modi±led, supplemented, or otherwise changed except by a

writing executed by an authorized representative of each of the parties.

l4. In consideration of the foregoing admissions and stipulations, the parties agree that

the CBA may, without further notice or forn'ial proceeding, issue and enter the following

Disc.iplinmy Ordet:

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. DISCIPLINARY ORDER

IT IS HEREBY ORDERED that Certified Public Accountant License No. 39094 issued to

Respondent Christine Louise Kuzma aka Christine Louise Kuzma Torra is suspended fbr 120

days. H.owever, the suspension is st~wed and Respondent is placed on probationfor twenty-tout

(24) months on the following terms and conditions. \

1. Obey AU Laws

Respondent shan obey all federal, C~1lifornia} other states 1 and local laws, including those

rules relating to the practice ofpublic ao:countancy ih Califon1ia.

2. CostRehnbursemen:t

Respondent shall reimburse the CBA the SLltn of$4,205 .00 for its hwestiga.tion and

prqsecution costs, The payment shall be made in quarterly payments, due with quarterly written

reports, the final payment being due six Inonths before probation is scheduled to termh1ate.

3. Submit Written Repqrts

Respondent shall submit, within! 0days of<;ompleth:m ofthe quarter1 Written reports to the

Cl3A on aform obtained fr{)m the CBA. Respondent shall submit, under penalty ofperjmy, such

other written reports, declarations, and verification ofacti.ons as are required. These declarations

shall contain statements relative to Respondent's contpiimtce with .an the terms and coi1ditiom:of

probatiol1. RespotJdeitt shall hlrttlediately execute an release ofinformation fo1111s as may be

required by the CBA odts representatives.

4.. Persqnal Appearances

Respondent shall, during the period ofpr.obation, appear in person at interviews/meetings as

directed by the CBA or its designated representatives, provided such notification is accomplished

in atimely manner,

5. Comply With Probation

Respondent shall fully comply with the terms and conditions of the probation imposed by

the CBA and shall cooperate fully with representatives ofthe CBA in its monitoring and

investigation ofRespondent's compliatwe with probation terms and conditions.

I//

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6. Practice Investigation

.Respondent shall be subject to, and shall permit, a practice investigation ofRespondent's

ptofess.ional practice. Sucha.practice investigation shall be conducted by representatives of the

GBA, provided notification ofsuch teview is c;tccomplished ina tirnely manner.

7, Comply With Citations

Respondent shall comply with all tlnal orders resulting from citations issued by the CBA.

8. Tolling ofProbation for Out~of~State ResideJlce/Practice

In the event Respondent should leave Gaiifomia to reside or practice outside this state,

respondent 111'\.lst notify the CBA in writing ofthe dates of departure and return. Periods ofnon­

Californiaresidency or practice otltside the state shall not apply to reduction of the pi'obationary

pedod, ot' of any suspension. No obligation imposed hetein, including requirements to file

writtenr.eportsl reimburse the CBA costs~ and makerestitution·to consun1ers, shall be susp~11ded

or·otherwiseaffected by such periods of out~of~state residency or practice except at th¢ written

direction ofthe CBA.

9. Violation ofProbatio:n

If respondent violates probation in any respect, the CBA; after giving Respondent notice

and an opportunity to be heard,rn.ay revoke probation and carry o1.1t the d1$ciplinary mde.r that

was stayed.. If an accusation or a petition to revoke probatio1i is filed agah1st Respondent during

probation, the. CBA shall have continuing jurisdiction until the matter is final, and the period of

probation shall be extended until the matter i!:; final.

·

The CBA's Executive Officer 1nay issue a citation under CalifO.rnia Code ofRegulations,

Section 95, to a licensee for a violation ofa tenn or condition contained in a decision placing that

licensee on probation.

10. Ethics Continuing Jl:ducation

Within 180 days of the effective date ofthis decision and order, Respondent shall complete

four hours of continuing education in course subject matter pettaining to the fo.Ilowing: a review

of nationally recognized codes of conduct emphasizing how the codes relate to professional

responsibilities; case-based instruction focusing on real-life situational learning; ethical dilemmas

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facing the accounting profession; or business ethics, ethical sensitivity, and consumer

expectations. Courses niust be a minirtrum of one hour as described in California Code of

Regulations Section 88.2. The hours are in addition to the continuing edttcation requireme11ts for

re~Iicensing.

If Respondent fails to complete said courses within the time period provided, Respondent

shall so notify the CBA and shall cease practice until Respon,dent cornplete.:r said courses, has

submitted ptoof of same to the CBA, and haS beei1 notified bythe CBA that she may resume

practice. Failllte to complete the required cotltses within the tin1e petiod provided shall constitute

a violation ofprobation.

11. Regulatory Review Course

Within 180 days oftheeffective date of this decision and order1 Respondent shall complete

a CBA-approved course on the provisions of the CaHfmniaAccountancy Act !lnd the California

Boa1'd ofAccountancy Regulations specific to the practice ofpublic accountancy in California

·emphasizing the provisions applicable to cmTent practice sit11atiorts. The course also will include

an overview of historic and recent disciplinary actions taken by the CBA,highlightitl,gthe

ntisco.nductwhichled to licensees being disciplined~ Th(:J coul'se shall be a minimum of two

hours.. The hours are in addition to the continuing education requirements for re-Hcensing.

IfRespondentfails to complete said courses within the time period provided, Respondent

shall so notify the CBA and shall cease practice until Respondent completes said courses, has

submittedproof ofsame to the CBA, and has been notified by the CBA that he or she may

resume practice. Failure to complete the required courses within the time period provided shall

constitute a violation of probation.

12. Completion ofProbation

Upon successful completion ofprobation, Respondent's license will be fully restored.

13. Active License Status

Respondent shall at all times maintain an active license status with the CBA> including

during any period of suspension. If the license is expited at the tii11.e the CBA's decision becomes

effective, the license must be renewed 'Within.30 days of the effective date of the decision.

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ACCEPTANCE

I'have carefulty read the Stipulated Settlementand DLsqiplinary Ol-der. 1understand the

stipulation a11dthe effectt itwU1 have on my Ce.t'tified Public Accountant License. I enter fnto

this Stipul-ated Settlement and Dfseiplimtry Otdervoluntarily~ knowingly, and intelligently,and

agree to be: bound by the Decision and Order of the California Bqard ofAecountancy,

bATED~ L() -Jl..../54'

t have ~ead and f\llly discussed with Re$pondenrChri"Stine Louise l<.uzma ~ka Chl'istfne

L.ot1ise Kuzma Tob~a the tern1s and, conditions and other mattets eontaine:dit'l the al'>oVe Stipulated

Settlet'lientand Disciplinary 'Order. I approve its form and content.

DATI!t):

- ALAN W. F6UTZ; ESQ. Allorneyfor Respondrmt

'ENDORSEMENT

The foregoing Stipulated Settlemettt and Disciplinary Order is hereby respectfi,tl}y

~~tbr't1jtted t(Jt c~si.l:letation by the Oalifontia 'Soa.rc! o:f Acco~nta:ncy. Dated: Respectf\.lllysubmitted,

KAMALA D. HARRl~ Attorney General of Califomia THOMAS L. RINALDI SupervisittgDepl.lty Attorn~y Oenetal

DE:SIREI! TULLENERS Deputy Attorney General Attorneys.for Complalmrnt

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ACC):;:PTANCE

!Have carefully ret-uJ the Stipt!lated Settlementand Disciplinary Order. I undetstand the

stipulation and the eflect it will have on my Certitied PubHc Accotmtant License, l emer b1t(1

this Stipulat¢dSmttletncnt ~;1nd.Disdp!inary·Ordervoluntarily, knowingly~ and in.telligentiy, and

~lgree to be botJnd by the Decision and Order of the CaUfQrnia Board ofAcccnmtancy.

DATE[):

CHRfS'riNf£ LOUTSE KUZMA aka CHRISTINE LOUISE KUZMA TORRA Respondent

l !lave read an~t fully disctlssed with Respondent Christine Louise Knzn'l.a aka Christi11e

Louise .KJ.I:Z:nta 'rotTt'l the ten11s and conditions and other matters c011t:ainedjn the £tbove Stiplllated

Settlement a;nd PisciplitlaryOrdcr. 1approve its form and content.

15 DA'l'ED:

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18 ENDORSEMENT . ' - --- .

19 the foregoing Stipula.t~d .settlement and Disciplinary.Order is hereby respec.tthlly

submitted fqrconsidetation by the California Board ofAccotmtancy. 20

Respectfully. submitted,

KAMALA D. HARRIS AttorneyGeneral of CaUfort1ia 'I MAS L. Rt'NALDI ... upervising Deputy Atto~r:.meral

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~~ DEsiRtmTULLBNERS Deputy Attorney GeneralAttorneysfbr Complainant

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7 -~---~-----~------~~~--------~----------~---·-

STIPULATED SE1TLEMENT (AC<W16-104)

Exhibit A

Accusation No. AC-2016,..104

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KAMALA D. HARlUS Attorney General ofCalifomia LINDAK SCHNEIDER $enior Assistant Attorney General MARcD. GR.EEN:aAUM Supervising Deputy Attorney General State BarNo. 138213

300 So. Spd~1gStreet, Suite 1702 Los Angeles, CA 90013 Telephone: (213) 897-2579 Facsln:rile: (213) 897~2804

AttorneysforComplainant

BEFORE THE CALIFORNIA BOARD OF ACCOUNTANCY DEPARTMENT OF CONSUMERAFFAffiS

STATE OF CALIFORNIA

In the Matter ofthe Accusation Against: Case No. AG·2016~104

CHRISTINE LOUISE. KUZMA, a.k.a. CHRISTINE LOUISE ACCUSATION KUZMATORRA, a.k.a. Cll1USTINE LOUISETORRA P.O.Box574 Los Olivos, CA 93441

Certified Public Accountant License No. 39094

Respondent

Complainant alleges:

PARTIES

1. Patti Bowers (Complainant) brings this Ac.cusation solely in her official capacity as the

Executive Officer ofthe California Board ofAccott,ntancy, Department of Consumer Affairs.

2. On or about December2, 1983, the California Board ofAccountancy issued Certified

Public Accountant License Number 39094 to Christine Louise Kuzma, also known as Christine

Louise Kuzmatorra, also known as Christine Louise Torra (Respondent). The Cettified Public

Accountant License was in fhll force and effect at all titnes relevant to the charges brought in this

Accusation and will expire on October 31, 2017, unless renewed.

·

.

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1 (CHRISTINE LOUISE KUZMA, AKA CHRISTINE LOUISE KUZMATORRA, AKA CHRISTINE LODrSE

. . TORRA) ACCUSATION

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JURISDICTION

3. This Accusation is brought before the California Board .of Accountancy ( CBA or

Board), Department of Consurner Affairs, under the authority ofthe following laws. AU section

references are to the Business .and Professions· Code unless otherwise indicated.

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5 4. Section5109 states:

6 "The expiration, cancellation, forfeiture, or suspension ofa license, practic'e privilege, or

other. authol'ity to practice public accountancy by operation of law or by order or decision o.f the

board ora co11rt oflaw, the placement ofa license, on a retired status, or th.evoluntary sun:enderr of

a license by a licensee shall not deprive the board of jurisdiction to commence or p.t'oceed with any

investigation ofor action or dis.ciplinaryproceeding against the licensee, or to render a decision

suspending or .revoking the lice.ns e."

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1.2 STATUTORY AND REGULA,IQRY PRoV'ISloNS.

13 S, Section 490 · of the Code provides,, in pertinent part,, that a board maysuspend or

revoke a liqense on the ground that the licensee has been qonyioted ofa crime substantiallyrelated

to the qu.alifications, functions, or duties .ofthe business •or profession for which the license was

issued.

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17 6. Section.5100 states:

18 ·'' A.iter notice and ht:lating the board .may revoke, st}spend, Qr reftu;e to renew any pennit or

certificate gratited under Article 4 (comrnencingwitb,'81;iotion S070) and Article 5 (commencing

with Section SO8O), or may censurethe holder of that pen:nit. or certificate fw unprofessional

conduct thEJ.t includes, but is not limited to, one or any combination of the following causes:

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22 "(a) Conviction ,ofa11y crime substantially related to the quaU:6.catfons, functions and duties

ofa certified.public accounta11t or a public accountant. 23

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25 n(g) Willful violation of this chapter or any rule or regulation promulgated by the board

under the authority granted under this chapter ... " 26

27 Ill

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2 ( CHRISTINE LOUISE KUZMA, AKA CHRISTINE LOUJSE KUZMA TORRA, AKA CHRISTINE LOUISE

TORRA) ACCUSATION

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7. Section 5100.~ states:

"(a) After notice and heating the board may, for unprofessional conduct, permanently restrict

or limit the practice of a licensee or impose a probationary tenn ot condition on a license, which

prohibits the licensee from performing or engaging in any of the acts or services described in

Section 5051.

'~(c) The authority or sanctions provided by this section axe in addition to any other civil,

crirninaJ, or administrative penalties or sanctions provided by law, and do not supplant, but axe

cumulative to, other disciplinary authority, penaltiesi or sanctions.

"(d) Failure to comply with any restriction or limitation imposed by the board pursuant to

this section is grounds for revocation ofthe license.

"(e) For purposes of this section, both of the following shall apply:

(1) "Unprofessional conduct" includes, but is not linuted to, those grounds for

discipline or denial listed in Section 5100.

(2) "Permanently restrict or limit the practice of' includes. but is ,not limited to, the

prohibition on engaging in or performing any attestation engagement, audits, or

compilations."

8. Section 5106 states:

11A plea or verdict of guilty or a conviction following a plea of nolo contendere is deemed to

be a. convictiop within the meaning ofthis article. The record ofthe conviction shall be conclusive

evidence thereof. The board may order the certificate or pennit suspended or revoked, or may

decline to issue a certificate or permit, when the time for appeal has elapsed, or the judgment of

conviction has been affirmed on appeal or when an order granting probation is made, suspending

the ~position of sentence, irrespective of a subsequent order under the provisions of Section

1203.4 ofthe Penal Code allowing such person to withdraw his plea of guilty and to enter a plea

of not guilty, or setting aside the verdict of guilo/ or dismissing the accusation, infonnation or

indictment.11

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3 (CHRISTINE LOUISE KUZMA, AKA CHRISTINE LOUISE KUZMATORRA, AKA CHRISTINE LOUISE

TORRA) ACCUSATION

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9. Section 5116 states in part:

''(a) The board, .after appropriate notice and an opportunity for hearing, may order any

licensee or applicant for licensure or examination to pay an administrative penalty as provided in

this. article as part ofany discipl:inmy proceeding or other proceeding provided for in this chapter.

.

"(d) Administrative penalties assessed under this article shall be in addition to any other

penalties or sanctions imposed on the licensee or other person, including, but not limitedto1 license

revocation, license suspension, denial of the application for licensure, denial of the petition for

reinstatement, or denial of admission to the licensing examination. Paytl1ent ofthese administrative

penalties may be included as a condition of probation when probation is ordered<'

10. California Code ofRegulations, title 16, section 99, states:

''For the purposes of denial, suspension, or revocation ofa certificate or permit pursuant to

Division 1.5 (commencing with Section 4 75) of the Business and Professions Code, a crime or act

shall be considered to be substantially related to the qualifications, ftmctions or duties of a certified

public accountant orpublic accountant ifto a substantial degree it evidences present ot potential

unfitness ofa certified public accountant or public accountant to perfonn the ftmctions authorized

by his or her certificate or permit in a .mmmer consistent with the public health, safuty, or welfare,

Such crimes or acts shall include but not be limited to those involving the following:

"(a) Dishonesty, :fraud, or breach of fiduciary responsibility of any kind;

"(d) Violation of any of the provisions of Chapter 1, Division III ofthe Business and

Professions Code or willfhl violation ofany rule or regulation of the board."

COST RECOVERY

11. Section5107, subdivision (a) ofthe Code states:

11The executive officer ofthe board may request the administrative law judge, as part of the

proposed decision in a disciplinary proceedirig, to direct any holder ofa permit or certificate found

to have committed a violation or violations of this chapter to pay to the board all reasonable costs

4 (CHRISTINE LOUISE KUZMA, AKA CHRISTINE LOUISE KUZMATORRA, AKA CHRISTINE LOUISE

TORRA) ACCUSATION

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of investigation and prosecution ofthe case, including, but not limited to~ attorneys' fees. The

board shall not recover costs incurred at the administrative hearing,n

·

FACTUAL BACKGROUND

12. On or aboutJuly21, 2008,in a criminal proceeding entitled The People. ofthe State.

ofCalifornia vs. Christine Louise Kuzmatorra, Case No. 1282724, in Santa Barbara County

Superior Court, Respondent was convicted by plea of no contest of driving under the influence of

alcohol, a misdemeanor. (Veh, Code, §23152, subd. (a).) Specifically, on or about Apri119,

2008, Respondent willfhlly and unlawthlly drove a motor vehicle with a blood alcohol content of

0.15% or higher within the meaning o.fVehicle Code section 23578. the court granted

Respondent three years of unsupervised probation, and ordered Respondent to pay various fines.

13, On or about N ovetnber 23, 2010, in a criminal proceeding entitled The People of

the State ofCalifotaia vs. Christine Louise Kuzmatorra1 a;k.a. Christine Louise Xorra, Case No,

1350971, in Santa Barbara County Superior Court, Respondent was· convicted byplea ofno

contest ofdriving while having a 0.08% or higher blood alcohol c()ntent, a misdemeanor. (Veh.

Cod(7, ·§ 23152, subd. (b).) Spe.cifically, on or about September 28, 2010, Respondent unlawfully

drove a vehicle with ablood alcohol content of0.15% orhighe:r within the meaning of Vehicle

Code section 23578; Respondent was sentenced to countyjaJl for6<) days, granted three years of

supervised probation, ordered to complete an alcohol programforl8 months while refraining from

drinking alcoholfor 18 months, and ordered to pay various fees and firms.

14. On or about February?, 2014, in a cril11inalpro¢eeding entitled The People ofthe

State ofCalifotaia vs. Christine Louise Kuzma, a.ka. Christi11e Louise Torra, Case No. 1449553,

in SantaBarbara County Superior Court, Respondent was convicted by plea ofno contest of

battery upon a peace officer, a misdemeanor. (Penal Code,§ 243, subd. (b).) Specifically, on or

about October 17, 2013, Respondent willfully and unlawfully used force and violence upon an

officer when Respondent knew and reasonably should have known that the officer was engaged in

the performance ofhis duties. Respondent was sentenced to county jail for 90 days, granted three

years of unsupervised probation, and ordered to pay various fees and fines~

5 (CHRISTINE LOUISE KUZMA, AKA CHRISTINE LOUISEKUZMATORRA, AKA CHRISTINE LOUISE

TORRA) ACCUSATION

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15. On or about April13, 2015, in a criminal proceeding entitled The People ofthe

State ofCalifornia vs, Christine Louise Kuzmatorra, a.k.a. Christine Louise Torra, a.k.a.

Chrtstine Lo~tise Kuzma, a.k.a, Christine L. Torra, Case No. 1456018, in Santa Barbara County

Superior Court, Respondent was convicted by plea ofno contest of driving while having a 0.08%

or higher blood alcohol content, a misdemeanor. (Veh. Code, § 23152, subd. (b).) Specifically,

on or about ·March 1, 2015, Respondent unlawfully drove a vehicle with a blood alcohol content of

0.15% or higher within.the meaning ofVehicle Code section 23578. Respondent was sentenced to

county jail for 120 days, granted three years of supervised probation, ordered t9 complete an

alCohol program for 18 months, ordered to refrain :from drinking alcohol at all, and ordered to pay

various. fees and fines.

FIRST CAUSE FOR DISCIPLINE (Conviction of a Substantially Related Crime) (Bus, & Pro:t: Code,§§ 490; 5100, subd. (a))

16. Respondent has subjected her license to disciplinttry action tmdet section 5100,

subdivision (a), in that she was convicted of a crime substantially related to the qualifications,

functions, and duties ofa certified public accountant or public acco~tant as defined in California

COde ofRegulations, title 16, section 99. (Bus. & Pro£ Code, §§ 490; and 5100, ·subd. (a); Code

ofRegs., tit. 16, § 99.) The circumstances .of Respondent's convictions are set forth in paragraphs

12 through 15, above.

SECOND CAUSE FOR DISCIPLINE (Willful Violation. ofAccmmtancy Act, or a Rule ot RegQ.lation Promulgated by the Board)

(Bus. & Prof. Code,§ 5100, s1.1bd. (g))

17. Respondent has subjected her license to disciplinary action under section 5100,

subdivision (g), in that she failed to repoli in h~r license renewal applications for prior years her

criminal convictioll$ which were substantially related to the qualifications, fhnction, and duties of a

certified public accountant or public accountant as defined in California Code ofRegulations, title

16, section 99. (Bus. & Prof. Code, § 5100, subd. (g); Code of Regs., tit. 16, § 99,) The

circumstances of Respondent's convictions are set forth in paragraphs 12 through 15, above.

Ill

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6 (CHRISTINE LOUISE KUZMA, AKA CHRISTINE LOUISE K.UZMATORRA, AKA CHRISTINE WUISE

. TORRA) ACCUSATION

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PRAYER

WHEREFORE, Compla~nt requ~sts tha:t a hearing be held on the matters alleged in this

Accusation, and thatfo11owing :the hearing, the California Board ofAccount&:i'!CY is~ue a decision:

1. Revoking;, s,uspen.ding, restrictmg, Emiting, or otherwise 1mpos~gdi$ciplirieupon

Cerl:~d Pl,lhlio Accountant License Number 39094, ~sued to .Qhrlstme.Louh,leKuzma~ also

known as Cbti$tfu~ LouiseJ(uzmatorra1, also known as Christine Lo1,1ise Tol':r'a;

2. Ordering Cbtistine Louise. Kuzma, also known as ~title Louise Kt.lZlx.lator:ra, also

known a~ CbristinQ Louise, Totra, to pay the California Board ofAccoutitancy the reasonable costs

offue investigation and' enforcement ofthis case, pursuanttQ Susiness and Pro:fessions Code

section 5107;

3.. OrderW.g bhdstme Lo:uise Ku~. also known.~ Christine :Lo'uise l<.u~torra, also

knowtl>as Cbtiat:ine I..<.l1dse Torra to pay the California Boatd o(A,ccouman.cy ~ adtninistra.tive

penalty pu~u:tmtto l3u$lness and Professions Code sectiott5lt6;an<l

4. T~~ such otherandthrther action as deemed necessarya:nd ptbp&:r.

I,>A:rnti: D»qul Y,7!Jh PATTIB S Ex~cutive Otlicer California Board.nfAc<:o:untancy Department ofCO$'UJner Affaits State ofCalifotnii;t Complainant

LA20 I6600979 90656029.doc

7. (CHRISTINE LOUISE KUZMA, AI<;A CHRISTINE LOUISE KUZMATORRA, AKA CHRISTINE LOUISE

tO~) ACCUSATION