Jun 20 2006 14:14 B6/ 26/2086 82:89 8584146749 DEPR OGA PAGE 83/87 STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, v. Case No. 2004-021244 PAUL RB. PLANTE, 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 PAUL R. PLANTE, DVM, ("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, having been issued license number VM 5757. 3. Respondent's address of record is 510 Ocean Boulevard #201, Pompano Beach, Florida 33062. 4. On January 23, 2002 Respondent prescribed and dispensed Sucralfate, Ranitidine, and Doxycyleine to Road Crew, a racehorse stabled at Pompano Park Racetrack. 26/20/2006 92:09 — B6a4145743 Jun 20 2006 14:14 a DEPR OG A PAGE @4/a7 5. On March 12, 2002 Respondent prescribed and dispensed Sucralfate, Ranitidine, Doxycycline, and Epistaxone to Road Crew while the horse was stabled at Pompano Park Racetrack. 6. On March 12, 2002 Respondent prescribed and dispensed Sucralfate, Ranitidine, Doxycycline, and Epistaxone to Tyriffic, a racehorse stabled at Pompano Park Racetrack. 7. On April 9, 2002 Respondent prescribed and dispensed Doxycylcine to Road Crew while the horse was stabled at Pompano Park Racetrack. 8. At no time between January 23, 2002 and April 9, 2002 did Respondent have a professional occupati onal license issued by the Division of Pari-mutuel Wagering pursuant to Chapter 550.105, Florida Statutes. 9. Persons who do not have a professional occupational license jssued by the Division of Pari-Mutuel Wagering pursuant to Chapter 550.105, Florida Statutes, are not permitted to enter Pompaito Park for the purposes of practicing veterinary medicine. 10. Section 474.214(1)(y), Florida Statutes, states the following shall constitute grounds for disciplinary action, “prescribing, or making available medicinal drugs... for use other than the specific treatment of animal patients for which there is a documented veterinarian/client/patient relationship.” 11. Sections 474.214(1)(y)1-3, Florida Statutes, define three criteria that must be present in order for a valid veterinarian/client/patient relationship to exist: (1) Have sufficient nowledge of the animal to initiate at least a general or preliminary diagnosis of the medical condition of the animal, which means that the veterinarian is personally acquainted with the keeping and caring of the animal and has recently seen the animal or has made medically appropriate and timely visits to the premises where the animal is kept. (2) Be available or provide for follow up caré and treatment in case of adverse reactions or failure of the regimen of therapy. (3) Maintain records which document patient visits, diagnosis, treatment, and other relevant information required under this chapter. B64 28/2885 82:89 8584146749 Jun 20 2006 14:14 DEPR OGA PAGE 85/87 12. Respondent was not available to provide follow up care and treatment in case of - adverse teaction or failure of the regime of therapy as he was not permitted to enter on to the srounds of the Pompano Race track where the horses were stabled. 13, Atno time material to this investigation did Respondent have or maintain a valid veterinary/client/patient relationship with Road Crew or Tyriffic. 14. On January 31, 2005, the County Court in and for Broward County Florida entered an order finding that Respondent had provided veterinary services and drugs to James Cummings horses Tytiffic and Road crew stabled at Pormpano Park with a value of $830.00, 15. Based on the foregoing, Respondent violated section 474.214(1)(y), Flonda Statutes, by prescribing medications to both Road Crew and Tyriffic without having a valid veterinarian/client/patient as required by section 474.214(1)(y), Florida Statutes. Respondent is therefore subject to discipline by the Board of Veterinary Medicine pursuant to section 474,214(2), Florida Statutes. WHEREFORE, Petitioner respectfully requests the Board of Veterinaty 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 474, Florida Statutes, and/or the rules promulgated thereunder. B6/ 26/2086 82:89 8584146749 Jun 20 2006 14:14 DEP R OGA PAGE 86/a7 J . Signed this? day of foc 2006. 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 1940 North Monroe Street Tallahassee, FL 32399-2202 DFW/Ich 13 December 2005 Pep aAatur l-co-dU Assistant General Counsel Case # 2004-0212.44 F | Department of Business and Professional Regulation AGENCY CLERK curk Soyuds 2 Loko am ; DATE 4-Q%-2006 A

Docket for Case No: 06-002209PL