wt, . ‘w) a & M STATE OF FLORIDA y S DEPARTMENT OF HEALTH poy, 9 DEPARTMENT OF HEALTH, CUE Oo Q: oo Ais PETITIONER, O00 2M2\ OS he vs. CASE NUMBER: 98-20905 DEBORAH DAVIS, D.D.S., RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as "Petitioner", and files this Administrative Complaint before the Board of Dentistry against DEBORAH DAVIS, D.DS., hereinafter referred to as "Respondent", and alleges: 1. Petitioner is the state agency charged with regulating the practice of dentistry pursuant to Section 20.43, Florida Statutes, Chapter 455, Florida Statutes; and Chapter 466, Florida Statutes. 2. Pursuant to the authority of Section 20.43 (3) (g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration, hereinafter referred to as the “Agency,” to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils or board, as appropriate, including the issuance of emergency orders of suspension or restriction. - . 3. Respondent is, and has been at all times material hereto, a licensed dentist in the State of Florida, having been issued license number DN 0012301. Respondent's last known address is 327 Plaza Real #305, Boca Raton, Florida 33432. 4, On or about July 24, 1998, Patient R.H. presented to the Respondent for a new patient exam and cleaning. 7 o ~ . . 5. On or about July 24, 1998, Patient R.H. was examined by the Respondent’s dental assistant but at no time was the patient examined by: the Respondent. 6. . On or about July 24, 1998, the Respondent’s dental assistant took x-rays and assessed the condition of Patient R.H.’s mouth. 7. On or about July 24, 1998, after reviewing Patient R.H.’s x-rays and considering only the dental assistant’s asessment of Patient R.H.’s mouth, the Respondent made a treatment diagnosis of Stage II petiodontal disease, without examining Patient R.H. 8. On or about July 24, 1998, the Respondent designed a treatment plan consisting of two (2) deep cleanings for Patient RH. | 9. On or about July 24, 1998, the Respondent required that the Patient R.H. sign her dental record indicating Patient R.H. had periodontal disease. 10. Based on the foregoing, the Respondent's license to practice dentistry in the State of Florida i is subject to discipline pursuant to Section 466. 028 0 @? Florida Statutes, for being guilty of incompetence or negligence by filing to meet the minimum standards of performance in diagnosis and treatment when measured against generally prevailing peer performance, in including, but not limited to, the undertaking of diagnosis and treatment for which the dentist is not qualified . by training or r experience or being guilty of dental malpractice. tae ws e 7S ww WHEREFORE, Petitioner respectfully requests the Board of Dentistry enter an order imposing one or more of the following penalties: revocation or suspension of the Respéndent's license, restriction of the Respondent's practice, imposition of an administrative fine and costs, ". issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED thig AH day o ‘Ast 2000. COUNSEL FOR AGENCY John L.Chaves Senior Attorney Agency for Health Care Administration Practitioner Regulation P.O. Box 14229, mail stop 39 Tallahassee, Florida 32317-4229 (850) 410-3467 JLC/relt/rvt “Pe PCP: “Garcia, Robinson, & Fisher DATE: January 27, 2000 Deborah Davis, DN Case Number: 98-20905 Date: January 25, 2000 Robert G. Brooks, M.D. Secretary, Department of Heali BY: Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration DEPARTMENT OF HEALTH DEPUTY CLERK cuerk Webi Rion DATE Se

Docket for Case No: 00-002421