Feb 24 2006 11:16 2/24/2086 11:48 8564146749 DEPR OGA PAGE 46/09 STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, v Case No. 2003-077382 ' DAVID J. BRYANT, D.V.M., lb 079! PL O . Respondent. / _ ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioner"), files this Administrative Complaint before the Board of Veterinary Medicine ’ against DAVID J. BRYANT, D.V.M., ("Respondent"), and alleges: L. Petitioner is the siate 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, having been issued license number VM 6323. 3. Respondent's address of record is 214 South Union Street, Natchez, Mississippi 39120. 4. The State of New York Racing and Wagering Board (NYRWB) instituted disciplinary action against Dr. Bryant in NWYRB notice number 03-39 on August 3, 2003. Feb 24 2006 11:17 2/24/2886 11:48 8584146749 DEPR OGA PAGE 47/89 5. The Respondent was fined $1,500 on August 3, 2003, for failing to follow proper Lasix procedures in the second race at the Saratoga Race Course on Angust 3, 2003. 6. Respondent failed to report the discipline instituted against his authority to practice veterinary medicine by the NYRWB to.the Board within 30 days of the entering of Notice Number 03-39. 7. Respondent no longer resides at his listed address of record, 214 South Union Street, Natchez, Mississippi 39120, as previous correspondence sent by the Department has been. returned to the Department as “undeliverable as addreased, forwarding order has expired”. g. Respondent failed to report his change of address within 60 days of moving to the Board. COUNT ONE 9. Petitioner realleges and incorporates the allegations set forth in paragraphs one (1) through eight (8) as though fully set forth herein. 10, Section 474.214(1)(b), Florida Statutes, states following shall constitute grounds for which the disciplinary actions may be talcen: 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. The licensing authority's acceptance of a veterinazian's relinquishment of a license, stipulation, consent order, or other settlement, offered in response to or in anticipation 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 or authority fo practice.” ll. Based on the foregoing, Respondent violated section 474.214(1)(), Florida Statutes, by having a disciplinary fine placed against his license by the State of New York Racing aod Wagering Board. Respondent jg therefore subject to disciplinary action by the Board of Veterinary Medicine pursuant to section 474.2 14(1)(b) and (2), Florida Statutes, Feb 24 2006 11:17 92/24/2006 11:08 8564146749 DBPR OGA PAGE 4@6/ 8/89 COUNT TWO 12. Petitioner realleges and incorporates the allegations set forth in paragraphs one (1) through eight (8) as though fully set forth berein. 13. Section 474.214(1)(ij), Florida Statutes, states following shall constitute grounds for which the disciplinary actions may be taken “[fJailing to report to the board within 30 days, in writing, any action set forth in patagraph (b) that has been taken against the practitioner's Hoense to practice veterinary medicine by any jurisdiction, including any agency or subdivision thereof.” ; 14. Based on the foregoing, Respondent violated section 474.214(1)(f, Florida Statutes, by failing to report to the Board the disciplinary action that was taken by the State of New York Racing and Wagering Board. Respondent is therefore subject to disciplinary action by the Board of Veterinary Medicine pursuant to sections 474.214(1)(f8 and (2), Florida Statutes. COUNT THREE 15. Petitioner realleges and incorporates the allegations set forth in paragraphs one (1) through sight (8) as though fully set forth herein. 16. Section 474.214(1)(nn), Florida Statutes, states following shall constitute grounds for which the disciplinary actions may be taken “([fJailing to report a change of address to the board within, 60 days thereof.” 17. Based on the foregoing, Respondent violated section 474,214(1)(n0), - Florida Statutes, by failing to report a change of address to the board within 60 days thereof. Respondent is therefore subject to disciplinary action by the Board of Veterinary Medicine pursuant to sections 474.214(1)(an) and (2), Florida Statutes. Feb 24 2006 11:17 @2/24/2@86 11:88 8594146749 DEPR OGA PAGE 99/89 WHEREFORE, Petitioner respectfully requests the Board of Veterinary Medicine enter at, order imposing one or mote 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 qles promulgated thereunder. Signed this Your dey of__(/az___, 2004. 1LE D 1 Regulation 4-4 fe Husiness and Profession? Drew F, Winters began DEPUTY CLERK Assistant General Counsel . Case # 2003-077382 Counsel for the Department: Drew F. Winters Assistant General Counsel Florida Bar Number 0679941 Department of Business and Professional Regulation Office of the General Counsel 4940 North Monroe Sireet Tallahassee, FL 32399-2202 CFT/etr 6 April, 2004 oup cote 4fas}o%

Docket for Case No: 06-000721PL