oy & . ‘ By AN STATE OF FLORIDA Inkn Hs a Pa DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATIO a.) BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, Vv. Case No. 99-01131 O\-IZAPL LORILYN SEELHOFF RODIRIGUEZ, D.V.M., Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioner"), files this Administrative Complaint before the Board of Veterinary Medicine against LORILYN SEELHOFF RODIRGUEZ, D.V.M. ("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 veterinarian, license number VM 0007107. | 3. Respondent's address of record is 10027 University Blvd., Orlando, Florida 32817. 4. On January 15, Amy BROSWELL was told by Respondent that her dog "Timber" needed to stay overnight at the hospital for “monitoring.” 5. Respondent did not monitor the dog overnight; rather, she left the dog unattended until morning. 6. Section 474.214(1)(0), Florida Statutes, states that fraud, deceit, negligence, incompetency, or misconduct, in or related to the practice of veterinary medicine, constitutes grounds for which disciplinary action may be taken. 7. Based on the foregoing, Respondent violated Section 474.214(1)(0), Florida Statutes. 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 472, Florida Statutes, and/or the rules promulgated thereunder. Signed this 21‘" day of _Dceembe—__, 2000. . A BSS ¢ wt David K. Minacci Assistant General Counsel Counsel for the Department: fF \ L ft D . Joseph W. Malka and Professional Regulation Assistant General Counsel ‘Department He pUTY CLERK Florida Bar Number 0136514 D . Department of Business and ; . , Professional Regulation CLERK Office of the General Counsel \ - Z - 200 \ 1940 North Monroe Street DATE SS Tallahassee, FL 32399-2202 JWM/tas Case #99-01131 . PCP: 12/15/00 - Jones & Lewis RECEiven STATE.OF FLORIDA é DEPARTMENT OF BUSINESS AND tin Hef MAR 3 0 an Re: _Lorilyn S. Rodriguez Case Nos.: Oe at 5,PBP BPR. 0G mn ELECTION OF RIGHTS ‘ange an iy ‘s "ha IZ7Y 6) | have read the attached Explanation of Rights form and understand my options. Sci you do not understand these options, please consult with your attorney or contact the Florida Department of Business and Professional Regulation, (850) 488-0062, before executing this form). 1. () | do not deny the allegations of fact in the Administrative Complaint and wish to be accorded a hearing before the Board of Veterinary Medicine in: which there are no disputed material facts. Pursuant to Section 120.57(2), Florida Statutes, | understand that | will be permitted to challenge the conclusions of law or submit oral and/or written evidence in mitigation of the penalty. * : 2. &) | do dispute the following allegations of fact. in the Administrative Complaint and request this to be considered a petition for an evidentiary hearing pursuant to Section’ 120.57(1), Florida Statutes, before an Administrative Law Judge appointed by the Division of Administrative Hearings. if you select this option, please state below which specific facts you dispute. (Attach additional sheets as necessary) __ 3. () | waive my right to object or be heard conceming this case. The Board of Veterinary Medicine may do as it sees fit concerning this matter. 4. () Settlement Stipulation: (if one is enclosed) | have executed the Settlement Stipulation, having agreed to the terms therein, and am returning same herewith. | understand this Stipulation is subject to approval of the Board of Veterinary Medicine. ° . Pursuant to Sections 120.573 and 455.2235, Florida Statutes, mediation is not available for the violation(s) should seek legal advice before signing. This form must be signed and notarized. Respondent ZS Mrs | Bll . vie. Address x 2 qI7- City State Zip STATE OF FLORIDA . C¢0?) bY F-PUR COUNTY OF ORANGE Telephone The foregoing was acknowledge before me this __ 27 day of _ March , 2000 by i erty Seelhofft Sadr igae% personally known to me or who has produced MICHAEL J. PRESUTTI MY COMMISSION # CC 804693 EXPIRES: January 26, 2003 Bonded Thru Pichard insurance Agency My Commission Expires: PLEASE MAIL FORM TO: Department of Business and Professional Regulation ~# Attn: Dan Blackwell Northwood Centre . 1940 North Monroe Street . Tallahassee, Florida 32399-0792 HE 01} iy Ge HH 10

Docket for Case No: 01-001374PL