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STATE OF FLORIDA DEPARTMENT OF HEALTH
DEPARTMENT OF HEALTH,
PETITIONER,
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WENDY S. COREN, D.C.,
RESPONDENT.
CASE NO. 2009-05148
COMES NOW Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Chiropractic Medicine against Re!=lpondent, Wendy S. Coren, D.C., and in support thereof alleges:
l. Petitioner 19 the state department charged with regulating the practice of Chiropractic Medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 460, Florida Statutes.
At all times material· to this Complaint, Respondent was a Chiropractic F>hyslcian in the State of Florida, having been Issued license number CH 3396, first issued on or about June 6, 1980.
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Respondent's address of record is 10 Brick sehool Drive, West Redding, Connecticut, 06896.
On or about March 5, 2009, and at all other relevant times,
Respondent did n<'.lt, and does not now, hold a license to practice veterinary medicine in the State of Florida.
s. On or about March s, 2009, and <:1t all other relevant time.c;, Respondent was a principle, shareholder, owner and/or employee of Equalign Chiropractic Syst-ems, LLC, ("Equalign").
6. On or about March s, 2009, and at all other relevant times, Equalign maintained its pnneiple mailing address asl0 Brick Sehool Drive, West Redding, Connecticut, 06896.
· 7. On or about March 5, 2009, and at all other relevant times, Equalign owned; leased, operated, and/or maint:ained an Internet wm cite at http://www.cqualign.com•
. 8. On or about March 5, 2009, and at all other relevant times, Respondent offered to provide chiropractic services to animals on tht'! Equalign internet web cite at http://www.equaliqn.com.
On or about March 5, 2009, and at all other relevant times,
Respondent offered t<'.l provide chiropractic services to horses and humans
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on the Equalign internet web cite at http://www.cquc1lign.com, including, but not necessarily limited to, spinal adjustments for horses and humans, and shoulder, hip, and extremity manipulation for horses and humans.
On or about March 5, 2009, and at all other relevant times, Respondent offered to provide chiropractic services to horses and humans at the Palm Beach International Equestrian Center, Palm Beach County, Florida.
Section 460.403(9)(a), Florida Statutes (2008-2009), defines the "practice of chiropractic medicine" as:
....a noncombatlve principle and practice consisting of the science, philosophy, and art of the adjustment, manipulation, and treatment of the humiln body in which vertebral subluxations and other malpositioned articulations and
structures that are interfering with the normal generation, transmission,· and expression of nerve Impulse between the brain, organs, and tissue cells of the body, thereby c.ausing disease, are adjusted, manipulated, or treated, thus restoring the normal flow of nerve impulse which produces normal function and consequent health by chiropractic physicians using specific chiropractic adjustment or manipulation techniques taught in chiropractic colleges accredited by the Council on Chiropractic Education. No person other than a licensed chiropractic physician may render chiropractic services, chiropractic adjustments, ot chiropractic manipulations. (Emphasis added).
Section 456,072(1)(0), Florida Statutes (2008-2009), provides that any person pract:lclng,. or offering to practice, beyond the scope
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permitted by law, or accepting and performing professional responsibilities the licensee knuws, or has reason to know, the licensee is not competent to perform, constitutes grounds for discipline by the Board of Chiropractic Medldne.
Section 450.413(1)(t), Florida Statutes (2008-2009), provides that practtcing, or offering to practice, beyond the soope permitted by law, or accepting and performing professional responsibilities which the licensee
knows, or has reason l-o know, that she or he is not competent to perform, constitutes grounds for discipline by the Board of Chiropractic Medicine.
Based on the forgoing, R.espondent has violated Sections
456.072(1)(0), Florida Statutes (2008-2009), by offering to practic.e chiropractic medicine on animals in general, and horses in particular, over the internet, and at the Palm Beach International EcF-Jestrian Center, Palm Beach County, Florida.
· Based on the forgoing, Respondent has violated Sections
460.413(l)(t), Florida Statutes (2008-2009), by offering to practice chiropractic medicine on animals in general, and horses in particular, over
the internet, and at the Palm Beach International Equestrian Center, Palm Beac::h County, Florida.
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'
WHEREFORE, Petitioner respectfully requests that the Board of Chiropractic 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 the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or ,my other
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relief that the Board deems appropriate.
SIGNED this c...Pa ·. day of_r7-.,p=;.= ,7 _,, 2010.
DEPA NT OF HEAi.Hi
OEPUlY CLERK
CL!AIC:-.,.. • • ,I, . '°''i'r
DATE 7- .;)-'4-/(J
Ana M. Viamonte Ros, M.D., M.P.H.
la,,,.,_:, :Ii:_ .t - tu'
-St-at urgpeon Generak¼ ..,
Tari Rossitto-Van Winkle, R.N., J.D.
Assistant General rnunsel DOH Prosecution Servi,Es Unit
4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar No. 0613908
(850) 245-4640 Ext. 8139
(850) 245-4681 FAX
PCP:
PCP Members:
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NOTICE OF RIGHTS
Respondent has the right to request a hearing to be conducted in accorda1;1ce with Section 12.0,569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evident:e and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tet:um issued on his or her behalf If a hearing is requested. ·
NOTICE REGARDING ASSESSMENT OF COSTS
R_espondent is placed on not:iee 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 di5Clplinary matter, which may include attorney hours and t:osts, on the Respondent ;n addition to any other discipline imposed.
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