May 31 2005 : @6/ 31/2885 89:59 8584146749 DEPR OGA , ane Ee r GE 82/ar STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, v. CaseNo. —-2003-057847 PHILIP JEROME ALEONG, Respondent. _ ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioner"), files this Adrministrative Complaint before the Board of Veterinary Medicine against GREGORY J. MURRAY, ("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 i, the State of Florida as a veterinatian, having been issued license number VM 6466. 3. Respondent's address of record is 4917 Roosevelt Street, Hollywood, Florida 33021. . 4, On Jamuary 9, 2003, Respondent appeared before the Stewards at Gulfstream Park to answer to an alleged violation of rule 61-D-6.008, Florida Administrative Code. May 31 2005 9:57 @6/ 31/2885 89:59 8584146 : 749 DEPR OGA PAGE 83/87 5. On January 9, 2003, Respondent signed a document stating that he waived his right to a formal hearing, did not dispute the facts relating to the violation, and would not appeal the decision handed down by Stewards with regard to the aforementioned violation of rule 61-D- 6.008, Florida Administrative Code. 6. Respondent admitted to falsifying the Veterinarians Report of the Race Day Lasix by signing the aforementioned document. 7. Stewards fined respondent $1000 for the aforementioned violation. 8. Respondent paid the $1000 fine for the aforementioned violation by check, number 3417, dated January 16, 2003. 9. Respondent failed to report to the board within 30 days subsequent to 5 anuary 9, 2003, in writing regarding the action that had been taken against the Respondent's license to . practice veterinary medicine by the Stewards at Gulfstream Park. COUNT ONE 10, Petitioner realleges and incorporates the allegations set forth in paragraphs one through nine as though fully set forth herein. 11. Section 474.214(1)(b), Florida Statutes, states that having a license or the authority to practice veterinary medicine revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of any jurisdiction, including any agency or subdivision thereof constitutes grounds in which disciplinary actions may be taken. The licensing authority's acceptance of a veterinarian's relinquishment of a license, stipulation, consent order, or other settlement, offered in response to or in anticip ation of the filing of administrative charges against the veterinarian's license or authority to practice, shall be construed as action against the veterinarian's license ot authority to practice. May 41 2005 9:58 @6/ 31/2885 89:59 8584146749 DEPR OGA PAGE @4/a7 12. Based on the foregoing, Respondent is in violation of section 474.214(1)(P). Florida Statutes, and is thereby subject to discipline by the Board of Veterinary Medicine. COUNT TWO 13. Petitioner realleges and incorporates the allegations set forth in paragraphs one through nine as though fully set forth herein. 14. Section 474.214(D)(i). Flotida Statutes, states that failing to report to the board within 30 days, in writing, any action set forth in paragraph of section 474.21 4(1)(b), Florida | Statues, that has been taken against the practitioner's license to practice veterinary medicine by any jurisdiction, including any agency OF subdivision thereof constitutes grounds in which disciplinary actions may be taken. 15. Based on the foregoing, Respondent is in violation of section 474.214(1)Gj). Florida Statutes, and is thereby subject to discipline by the Board of Veterinary Medicine. 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 pot 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 roles promulgated thereunder. May 31 2005 9:53 65/31/2685 69:59 8584146749 DEPR OGA PAGE 85/87 Signed this 29 D sey of L? Aileen , 2003. Bake ranwlh Charles F. Tunnicliff Assistant General Counsel Case # 2003-057847 Counsel for the Department: Charles F. Tunnicliff ; Assistant General Counsel 0 Florida Bar Number 0153831 F \t Evora oi Department of Business and. pen smant of ee SUT an ERK Professional Regulation A | Office of the General Counsel 1940 North Monroe Street Puede Tallahassee, FL 32399-2202 CLERK 03 . CFT/gwg \ \ - 9" August 19, 2003 DATE Por tjels Devitfe d feud

Docket for Case No: 05-001971PL