Deparioratrt of uatirapis aid Pectenciovial agulation Deputy Agency Clerk STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, Ve Case No, 2009-033843 JAMES R. BUCK, D.V.M., Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Department of Business and Professional Regulation, files this Administrative Complaint before the Board of Veterinary Medicine, against Respondent, James R. Buck, D.V.M., and alleges: 1. Petitioner is the state agency charged with regulating the practice of veterinary medicine pursuant to Section 20.1465, Florida Statutes, and Chapters 455 and 474, Florida Statutes. 2. At all times material to this complaint, Respondent was licensed to practicé veterinary medicine in the State of Florida, having been issued License number VM 1639, 3. Respondent's address of record is 108 Bayou Drive, Satsuma, FL 32189. 4. on June 7, 2008, Inspector Catherine Allison (hereinafter “Allison”) observed Respondent performing limited GAOGC Professions Beardé\weterinary modicine\AC\2010\Buck, Jamey 09-033843 (15.0072) 1 1/25/2010 BE/fER Fd FOO sda 6pé9oPTpags GS-88 Tee /ST/Se Qtipl otoz at Bry veterinary services in the form of vaccinations on dogs and cats at an unregistered clinic location, 5. During a June 7, 2009 inspection om Pet Care A Van, VL 102 (hereinafter Pet Care}, Allison and RPA Sandra Rentfrow observed Respondent as the onsite veterinarian at Walgreens, 12002 MeCormick Road, Jacksonville, FL 32225. 6. DBPR records show that this location is not properly registered with DEPR 7. Rentfrow spoke with John Smith, the husband of the owner of Pet Care, Jacqueline Smith, Mr. Smith stated that Mrs. Smith had claimed that ail Limited Clinic locations had been properly registered. Respondent stated the same information. 8. DBPR received a response letter from Respondent on August 4, 2009, which stated that he was not aware that Attending Veterinarians must inspect individual clinie locations to ensure that they are permitted. 9, No other violations were found during the June 7, 2008 inspection, COUNT ONE 10. Petitioner re-alleges and incorporates the allegations set forth in paragraphs one (1) through nine (9) as though set forth herein. 11, Rule 61G18-15,007(2), Florida Administrative Code, states; “(t]he Limited-Service Permittee shall register each GAOGC\Profeasions Boards\woteringry medivine\AC\2010\Buck, Ji OG-033243 (15.007 KZ; 1/25/2010 me ome ( 3 Bara Fv vOO Maa BPeQpIpase = S5:8a BTAZ/ST/Ea 20:f— otoz oT fy clinic with the Board of Veterinary Medicine by name, address, date of clinic, time and duration, at least 28 days prior to offering a limited-service Clinic. A copy of the limited- service permit shall be clearly visible at each limited-service Clinic held during its hours of operation and posted at the main office where the records are stored.” 12. Based on the foregoing, Respondent violated Rule 61618-15.007(2) when he failed to register a Limited-Service Clinic with the Board of Veterinary Medicine. 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: permanent revocation or suspension of Respondent’s license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of GAOGC|Profasions Boards\weterinury medicinc\ACQO10\Buck, Tamas 09-053843 (15.007\2} 4 1/28/2020 66/Se@ Fd FOO sda 6pé9oPTpags GS-88 Tee /ST/Se 20:f— otoz oT fy Respondent on probation, assessment of costs, corrective action and/or any other relief that the Board deems appropriate. Signed this 9° day of February, 2010. CHARLIE LIEM, Interim Secretary Department of Business and Professional Requlation By: C€heabeth Fletcher Duffy ELIZABETH FLETCHER DUFFY Assistant General Counsel Florida Bar No, 0980404 Department of Business and Professional Requlation office of the General Counsel 1940 North Monroe Street Tallahassee, Florida 32399-2202 Phone: (850) 487-8435 Facsimile: (850) 414-6749 PCP Found: January 13, 2010 PCP Found By: Jones and Lewis EFD/del GAOGC Professions Bourds\vetariaury modicina\ACY2O10\Buok, Jumes 09-033843 (15,0072) 4 1/25/2010 6a/9a Fevd YOO ada 6pl9P pags GGisa alazZ/ST/ea 2Uipl otoz at 6ny NOTICE OF RIGHTS Respondent has the right to request a hearing to he conducted in accordance with Sections 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoenas and subpoenas duces tecum issued on his or her behalf if a hearing is requested, Rule 28-106.111, Florida Administrative Code, provides in part that if Respondent fails to request a hearing within twenty-one (21) days of receipt of an agency pleading, Respondent waives the right to request a hearing on the facts alleged. 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 455.227(3)(a}, Florida Statutes, the Board, or the Department when there is no Board, may assess costs related to the investigation and prosecution of the case excluding costs associated with an attorney's time, against the Respondent in addition to any other discipline imposed. GROG Professions Bourda\vetorinary medicina\AC\20 | O\Fick, James 09-033843 (15.0072) 5 1/2201 6e/48 Fd FOO sda 6pé9oPTpags GS-88 Tee /ST/Se 2Uipl otoz at 6ny

Docket for Case No: 10-007591PL