Nov 7 2005 14:35 NOV-@7-2885 14:33 AHCA/LEGAL MEDICAL 858 414 1989 P. 3 as an STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, oz € é ON O5-U104 CASE NO. 2004-00553 PETITIONER, MOHAMMAD KALEEM, M.D., RESPONDENT. f ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through undersigned counsel, files this Administrative Complaint before the Board of Medicine against Respondent, Mohammad Kaleem, M.D., and In support thereof allages: - 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 materia] to this Complaint, Respondent was a licensed physician within the state of Florida, having been Issued license number ME 78625. Nov 7 2005 14:35 NOUV-@7-2845 14:33 AHCA/LEGAL MEDICAL 85a 414 1989 P,a4 3, Respondent's address of record is 524 Zeagler Drive, Palatka, Florida 32177. 4. At all times material to this Complaint, Respondent was employed as a medical doctor at Putnam Community Medical Center (Center), 5, Respondent ts board certified in internal medicine. 6 On or ahout December 29, 2002, Putnam County EMS responded to the residence of Patient A.R., a 52 year-old female found lying on the floor, wilh complaints of nausea and vomiting, but specifically denying chest pain. 7. Patient A.R, was transported to Center’s Emergency Room (ER). 8. On or about December 29, 2002, at about 3:50 a.m. a laboratory recording of Patient A.R’s CPK (creatine phosphokinase) was 488 (two times normal), the MB fraction and the troponin.levels were reported as within normal ranges. 9. Onor about December 29, 2002, at about 5:29 am, an EKG was done, which showed a 4-mm ST segment elevation in Vi through 2 Mohammad Kaleam, M.D., Case # 2004-00553 J:\PSU\MedicohROB FRICKE\Medleal\Kaleom, Mohammad, MB 04-00553\KsleemAC-04-00552,doc Nov 7% 2005 14:35 NOU-@7-268@5 14:33 AHCA/LEGAL MEDICAL. 858 414 1989 P.@5 ™ V6, and Q waves in V2 lo V4, indicative of non-specific minor abnormalities. 10. On or about December 29, 2002, at approximately 5:50 a.m. Respondent gave orders via telephone for Patient A.R. to be placed in the Center's Intensive care unit (ICU). 11. Qn or about December 29, 2002, at approximately 11:15 a.m.,, Respondent came to the Center’s ER and saw Patient AR. 12. On or about December 29, 2002, at about 12:06 p.m., Respondent ordered Patiant A.R. lo be admitted to ICU. 13. On or about December 29, 2002, at about 12:06 p.m, Respondent dictated a note that “thrombolysis is not indicated at this time.” (Thrombolysis is medication to break up blood Clots.) 14. On or about December 29, 2002, at about 12:35 p.m, laboratory analysis showed Patient A.R.’s creatine phosphokinase (CPK) was 776, the MB (an Isoenzyme of creatinine) was 21.5, and the troponin (intracellular cardiac protain), was 7.59. These values indicate that Patient A.R. had suffered an acute myocardial infarction. —15. On or about December 29, 2002, at about 6:00 pm, a third set of cardiac enzymes showed Patient A.R.'s CPK level was 2553, the * a Mohammad Kaleem, M.D., Case # 2004-00553 VT\PSU\MeriiraROB FRICKE\Mevical\Kaleen.Muliaimiad, MD 04-00553\KaleemAC:04-00553.dec Nov 7 2005 14:36 NOU-@?7-28a@5 14:34 RHCAYLEGAL MEDICAL 858 414 1989 P.@5 rt om troponin-I was 53.6 wilh an MB of 112. This clearly indicated that Patient A.R. had suffered an acute myocardial infarction. 46. On or about December 30, 2002 at approximately 1:30 pm, Patient AR. was transferred to Shands Hospital, 17. At Shands Hospital, Patient A.R’$ admission EKG was compared to her EKG taken at the Center Patient A.R. was Immediately started an a Nitro drip and trealed with Plavix 300 mg by mouth, ; 18. It was determined that Patient A.R. was continuing to have a relalively severe myocardial Infarction and Patient A.R. was taken emergently to the Cath Lab for a heart catheterization. 19. During the catheterization procedure, it was determined that Patient AR. had a fresh thrombus (blood Clot) in one of the arteries. Patient AR. began to experionce shortness of breath and hypotension (low blood pressure). 20, Patient A.R. went into complete heart block at about the Same time procedures were underlaken to address the artery blockage. 21. Patient A.R. continued to worsen and ultimately expired at 6:58 pm. 4 Mohammad Kaleem, M.0., Case 4 2004-uuss4 J:\PSU\Medical\ROBS FRICKF\Mrdical\ Kaleem, Mohammad, MD 04-D0553\KaleemAC-04-00553,duc Nov 7 2005 14:36 NOV-@7-2885 14:34 ARICA/LERAL. MEDICAL 85a 414 1989 P.a? rt 22, On or about December 29, 2002, Respondent did not order a STAT EKG on Patient A.R., even though her CPK was elevated at twice the normal level or higher. 23. On or about December 29, 2002, Respondent dic not examine Patient A.R. in a timely manner, even though he was informed that Patient A.R.'s CPK level was twice the normal level or higher and that her EKG was abnormal. 24. On or about December 29, 2002, Respondent did not refer Patient AR. to Shands Hospital in a timely manner, in light of her continuing abnormal blood lab values which Indicated a serigus heart problem. | 25. Section 458,.331(1)(t), Florida Statutes (2002), pravides that failing to practice medicine with that level of care, skill, and treatment which is recagnized by a reasonable prudent similar physician as being acceptable under similar conditions and circumstances constitutes grounds for discipline by the Board of Madicinc. 26, Responcient failed to act as a reasonable, prudent physician under similar circumstances in that he should have intervened earlier in the series of events to control or limit Patient A.R.’s ongoing cardiac 5 Mahammad Kaleem, M.0., Case # 2004 00553 JAPSU\MedicahROB PRICKE\Medical\Kaleem,! Mohemmad, MD 04-00553\Kalee nAC-04-CO553.uin: Nov 7 2005 14:36 NOU-@?-2885 14:34 AHCA/LEGAL MEDICAL 858 414 1989 P.2B a os emergency by: personally evaluating the patient, timely instituting thrombolysis, and/or transferring the patient to a facility better equipped to aitectively manage the situation. 27, Based un the foregoing, Respondent violated Section 458,331(1)(t), Florida Statutes (7002), 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, Petitioner respectfully requests that the Board of Medicine enter an order impusing one or more of the following penalties: permanent tevocation or Suspension of Respondent's license, restriction of practice, Imposition of an administrative fine, issuance of a reprimand, placement of Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. 6 Mohammad Kaleem, M,D,, Case # 7004-00553 : 4:\PSU\Medical\ROB TRICKE\Medical\ Kaleem, Mohammad, MD 04-Q0553\Kaleamac 04-00553,doc Nov 7 2005 14:3? NOV-@7-2885 14:35 AHCAZLEGAL MEDICAL 85a 414 1989 P.@9 oo on, & A SIGNED this /9 ~_ day of wel 2005, John O. Agwunobi, M.D., M.B.A., M.RH. : Secretary, Department of Health FILED BEPARTMENT OF HEALTH cele trek oon ae pare___f223-bC Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL. 32399-3265 Florida Bar # 0394572 850.410.0623 FAX 850.488.7723 REF/tih Reviewed and approved by: _’ 4- (initials) | hv/oY (date) PCP: August 19,2005 PCP Menibers: :Custavo Leon, M-P.Chairperson) amd Mammen Zachariah MD 7 Mohammad Kaleem, M.D., Case ¢ 2004-00553 Nov 7 2005 14:37 NOU-@7-2085 14:35 AHCA-LEGAL MEDICAL 858 4i4 1989 P.1a oo — 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, te present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued an 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, 8 Mohammad Kaleem, M.0 , Case # 2004-00553 J;\PSU\Medtical\ROB FRICKE\Madical\Kaleem,Mohammad, MD 04-00553\ColeemAC-04-00553.duc TOTAL P.18

Docket for Case No: 05-004104PL