U | U STATE OF FLORIDA FILED DEPARTMENT OF HEALTH 00 IS PH 943, DEPARTMENT OF HEALTH, DIVISION OF ADMINISTRATIVE PETITIONER, HEARINGS vs. CASE NUMBER: 99-51244 “2 JAMES A. DAVIS, D.D.S. O 0 ¢7 7 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 JAMES A. DAVIS, D.D.S. , 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, F lorida Statutes; Chapter 455, Florida Statutes; and Chapter 466, Florida Statutes. Pursuant to the authority of Section 20.43 (3) (g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, - investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, and has been at all times material hereto, a licensed dentist in the State of Florida, having been issued license number DN 0007842. Respondent's last known address is 1700 E. Hayes Street, Pensacgla, Florida 32501. 3. In or around November, 1998, the Department of Health began an official investigation at the Escambia County Health Department. Uo VY 4. The investigation revealed that the Respondent had treated two dental patients for whom no records were available. 5. The Respondent failed to keep dental records or progress notes on either patient. 5. Petitioner realleges and incorporates by reference the foregoing allegations as if fully stated herein. 6 Based on the foregoing, the Respondent’s license to practice dentistry in the State of Florida is subject to discipline pursuant to Section 466.028 (1)(m), Florida Statutes, for failing to keep written dental records and medical history records justifying the course of treatment of the patient including, but not limited to, patient histories, examination results, test results, and X-rays, if taken. 7] Y WHEREFORE, Petitioner respectfully requests the Board of Dentistry enter an order imposing one or more of the following penalties: revocation or suspension of the Respondent's license, restriction of the Respondent's practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. Mu) SIGNED this|Ot _ day of (i 1995 Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy M. Snurko Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: John L. Chaves Senior Attorney Agency for Health Care DEPARTMENT OF HEALTH an . DEPUTY CLERK Administration Wy, . ; Post Office Box 14229 CLERK chi R-EViar Tallahassee, Florida 32317-4229 DATE Zz g d0O (904) 410-3467 JLC/elt PCP: Garcia, Fisher, & Robinson DATE: November 18, 1999

Docket for Case No: 00-002497