. rm HY STATE OF FLORIDA wah. DEPARTMENT OF BUSINESS AND PROFESSIONAL REG TON 5 BOARD OF VETERINARY MEDIO§NE SEP.1'5. Pi bi Ve i U , U ‘ DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, v. Case No. 99-07363 ALL PETS VETERINARY CLINIC, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioner"), files this Administrative Complaint before the Board of Veterinary Medicine against ALL PETS VETERINARY CLINIC ("Respondent"), and alleges: 1. Petitioner is the state agency charged with regulating the practice of veterinary medicine, pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 474, Florida Statutes. 2. At all times material hereto, Respondent was licensed in the State of Florida as a . veterinary establishment, license number VE 0002644. 3. Respondent's address of record is 8149 103 Street, Jacksonville, Florida 32210. 4, At all times material hereto, the responsible veterinarian for Respondent was Tina Parker, D.V.M. 5. On or about 30 August 1999, the Jacksonville Sheriff's Office was contacted regarding a disturbance at All Pets Veterinary Clinic.. 6. Upon arrival, the police officers were met by Carol and Lewis Mennona who advised the police that their dog had been boarded at All Pets and were unable to retrieve their dog. U . VU 7. There was a note on the door stating that the business was closed. 8. Officers entered the facility and observed approximately ten (10) cages with animals in them. 9. None of the animals in cages had water and only three animals had food. 10. A dead cat was observed inside a cage. 11. Animal feces was observed on the floor throughout the kennel. 12. Several of the animals in the cages were laying in fecal matter. 13. Medications, hypodermic needles, and syringes were scattered throughout the kennel, including in the bathroom. 14. The temperature inside the kennel was approximately 130 degrees. 15. Several animals appeared to be in distress from the heat and lack of food and water. 16. Several dead animals were found in the refrigerators and freezers, including the Mennona's dog. COUNT 1 1 V7 Petitioner realleges and incorporates paragraphs one through sixteen as though fully set forth herein. ; : : - 18. Based upon the foregoing, Respondent violated Section 474.214(1)(v), Florida Statutes, by failing to keep the equipment and premises of the business establishment in a clean and sanitary condition constitutes grounds for disciplinary action. COUNT II 19. Petitioner realleges and incorporates paragraphs one through sixteen as though fully set forth herein. 20. Rule 61G18-15.002, Florida Administrative Code, states minimum standards for premises where veterinary medicine is practiced a] ; wy) 21. Based upon the foregoing, Respondent violated Section 474.214(1)(f), Florida Statutes, by violating any provision of this chapter or part I of chapter 455, or a rule of the board or department. WHEREFORE, Petitioner respectfully requests the Board of Veterinary Medicine 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 not to exceed $5,000 per violation, issuance of a reprimand, placement of the Respondent on probation, assessment of costs association with the investigation, imposition of any or all penalties delineated within Section 455.227(2), Florida Statutes, and/or any other relief that the Board is authorized to impose pursuant to Chapters 455 and/or 474, Florida Statutes, and/or the rules promulgated thereunder. y Signed this 30 day of Duae , 2000. , | BSI Fo : David K. Minacci Assistant General Counsel Counsel for the Department: Laurie Beth Woodham ; F | [L E D Assistant General Counsel : f . Florida Bar Number 0049549 © Department of Business and Professional Raguiation Department of Business and DEPUTY CLER Professional Regulation . . WN : Office of the General Counsel cen tard Tichol ‘1940 North Monroe Street - } 3 -_ 2000 Tallahassee, FL 32399-2202 DATE 7-13-2000 LBW/tas Case #99-07363 POP: Tune 20,2000 / Fons laws . { i [ 7 I

Docket for Case No: 00-003858