Apr 1 2008 13:41 O4/@1/2088 13:44 8584146749 DEPR OGA PAGE 83/86 STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, v. . CaseNo. 2006-01304 EUGENE LAURENCE GENTSCH, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioner"), files this Adrainistrative Complaint before the Board of Veterinary Medicine against EUGENE LAURENCE GENTSCH ("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 unlicensed as a veterinarian in the State of Florida. 3. Respondent's address of record is 17579 Rockefeller Circle, Ft. Myers, Florida, 33912. 4, On December 29, 2005, Petitioner’s investigator, Josie Kleen, received an anonymous phone cal] alleging that Respondent was performing veterinary functions and representing himself as a licensed veterinarian at Dr. Amy’s Animal Hospital. Apr 1 2008 13:41 ad/o1/2889 13:44 e5ad146749 DEPR OGA PAGE 5. The caller stated to Investigator Josie Kleen that Respondent refers to himself as “Doctor Larry.” 6. On December 30, 2005, Investigator Josie Kleen called Dr. Amy’s Animal Hospital to schedule an appointment to have her puppy’s ears checked for a possible ear infection. 7. Staff for Dr. Amy's Animal Hospital scheduled Investigator Kleen for an appointment on December 30, 2005 with Dr. Larry. 8. The investigator was informed that Dr. Amy was not working that day but Dr. Larry would examine the puppy. 9, Upon arival at Dr. Amy’s Animal Hospital, Investigator J osic Kleen asked to speak with the doctor and Respondent introduced himself as “Doctor Larry.” 10. Section 474.213(1)(a), Florida Statutes, states: “No person shal] lead the public to belicve that such person is licensed as a veterinarian, or is engaged in the licensed practice of veterinary medicine, without such. person holding a valid, active license pursuant to this chapter.” ll. Based on the foregoing, Respondent violated Section 474.213(1)(a), Florida Statutes, when he presented himself as “Doctor Larry” when a veterinary doctor was requested and represented himself as a licensed veterinarian to an investigator. 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 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 a4/a6 Apr 1 2008 13:41 @4/al/2aee 1a:dd 8584146749 DEPR OGA PAGE 85/86 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. inte Signed this| day of , 2007. ae Drew F. Winters Assistant General Counsel Case # 2006-001304 Counsel for the Department: Drew F. Winters , F professional Regulation Assistant General Counsel pepartment of Businesé a CLERK Florida Bar Number 0679941 AGENC Department of Business and Professional Regulation Office of the General Counsel £ [lator K CLER| Su oh : 2 O 0 1940 North Monroe Street pal 2007 DAT! . Tallahassee, FL 32399-2202 DFW/nmw Tune 28, 2007 Pep: CET Thelot

Docket for Case No: 08-001614