JAN-@6-2205 14:01 HCA P.@3/@9 STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2003-13930 CHRISTOPHER D. TANNER, M.D., CS C0 TAPL RESPONDENT. | ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Medicine against Respondent, Christopher D. Tanner, M.D., and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 458, Florida Statutes. 2. At all times material to this Complaint, Respondent was a licensed physician within the state of Florida having been issued license number ME 65153. ——— JEN 86-2885 14:81 PRE) P.@4/09 3. Respondent's address of record is 1000 Mar-Walt Dr. Ft Walton Beach, FL 32548. 4. — Respondent is board certified in Emergency Medicine. 3. On or about August 29, 1999, Patient L.K, presented to the Emergency Room of Fort Walton Beach Medical Center with a complaint of right-sided abdominal pain. 6. On or about August 29, 1999, Respondent evaluated Patient L.K. in the Emergency Room of Fort Walton Beach Medical Center. 7. On or about August 29, 1999, Patient L.K. gave a history of recent Dilatation and Curettage and a light menstrual period one week previously, 8. On or about August 29, 1999, Respondent diagnosed Patient L.K.'$ symptoms.as constipation, recommended a laxative and told her to return if her condition did not improve. 9. On or about August 30, 1999, Patient L.K. continued to have abdominal pain, developed severe pain, and suffered a cardiac arrest. 10. On or about August 30, 1999, Patient L.K. was determined to have suffered from a ruptured ectopic pregnancy. 2 Christopher Tanner, M.D., Case # 2003-13930 JAN-G6-2005 14:61 AHCA 11. A reasonably prudent physician under similar conditions and circumstances would have ordered a pregnancy test to rule out the possibility of pregnancy as the origin of the patient’s symptoms. 12. Respondent failed to meet the standard of care in his diagnosis of Patient L.K. 13. Section 458.331(1)(t), Florida Statutes (1999), sets forth grounds for disciplinary action by the Board of Medicine and provides that a physician may be subject to discipline for gross or repeated malpractice or the failure to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances. 14. Respondent failed to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar circumstances, by doing one or more of the following: (a) Falling to order a pregnancy test for Patient L.K., a female of child-bearing age, presenting at the emergency room with abdominal pain. 3 Christopher Tanner, M.D., Case # 2003-13930 mw. P2589 JAN-@6-28@5 14:61 AHCA P,@6/89 (b) Failing to accurately diagnose Patient L.K..'s condition as an ectopic pregnancy. 15. Based on the foregoing, Respondent violated Section 458.331(1)(t), Florida Statutes (1999), by failing to practice medicine with that level of care, skill and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances. WHEREFORE, the Petitioner respectfully requests that the Board of Medicine enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. 4 Christopher Tanner, M.D., Case # 2003-]3930 i JAN-G6-2885 14:82 — HCA an P.B7/89 veneer eee SIGNED this _/i _ day of Novem BEE , 2004. John O. Agwunobi, M.D., M.B.A., M.P.H. me Depart va Health i ‘ Robert E. Pricke FILED Assistant/General Counsel DEPARTMENT OF HEALTH DOH Pr, secution Services Unit (DEPUTY CLERK 4052 Bald Cypress Way, BinC-65 cuenelliithen Colman — Tallahassee, FL 32399-3265 ware. _Yeiseo} Florida Bar #0567027 (850) 414-8126, (850) 414-1991 FAX REF Reviewed and approved by: 2c. (initials) 4 la} acs (date) PCP: ber 12,2004 , < PCP Nembors: Gustave Leon, m. Dour per oi) Peter Larnelas, M.D. and Sohn Beeke > Christopher Tanner, M.D., Case # 2003-33930 JAN-@6-20@5 14:22 nt ntti eer = we een __ AHA cnn ee P.@a/e9 NOTICE OF RIGHTS Respondent has the right, to request a hearing to be conducted in accordance with Section 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing is requested. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 456.072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition to any other discipline imposed. 6 Christopher Tanner, M.D., Case # 2003-13930

Docket for Case No: 05-000073PL