2325 COM Cover Letter re Zinnia Health Objection w Exs

-4- client constituted a violation of, among other things, federal and state law, Zinnia’s licensing obligations, Zinnia’s internal policies, and governing professional standards. 17. As Rodgers was bound by patient confidentiality but also knew Costa’s conduct to be a serious ethical breach and a violation of applicable law (in addition to being a threat to her client’s sobriety, treatment and well-being), Rodgers was obligated to report Costa’s misconduct, including pursuant to the terms of her own license and in accordance with Zinnia’s internal policies. 18. In light of these competing ethical and legal obligations and Rodgers’ good faith belief that laws had been and were being violated on an ongoing basis and her patient’s treatment and care was being compromised, Rodgers reached out to Rahman, her direct supervisor and a fellow certified and licensed therapist having responsibility for the relevant patient’s care, for advice on how to handle the matter. 19. After receiving the report about Costa and Rodger’s patient and their ongoing relationship, Rahman told Rodgers to go back to her office because he was supposedly receiving an important call. 20. Rodgers worked at her desk for a few more hours on December 26 but received no response from Rahman. 21. Rodgers returned to Rahman’s office at the end of the day because it was the week between Christmas and New Years and Rodgers was scheduled to be out on vacation for the next three days, but Rahman had already left the office for the day without following up with her about Costa and Rodger’s patient.ESX-L-004622-23 07/19/2023 2:53:48 PM Pg 4 of 13 Trans ID: LCV20232124530