Petitioner: DEPARTMENT OF HEALTH, BOARD OF MEDICINE
Respondent: KEITH B. MURRAY, M.D.
Judges: R. BRUCE MCKIBBEN
Agency: Department of Health
Locations: Orlando, Florida
Filed: Oct. 02, 2012
Status: Closed
Settled and/or Dismissed prior to entry of RO/FO on Friday, November 30, 2012.
Latest Update: Dec. 23, 2024
W-\N3
STATE OF FLORIDA
DEPARTMENT OF HEALTH
DEPARTMENT OF HEALTH,
Petitioner,
Vv. CASE NO.: 2011-19788
KEITH B. MURRAY, M.D.,
Respondent.
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ADMINISTRATIVE COMPLAINT
Petitioner Department of Health files this Administrative Complaint
and states:
1. Petitioner is the state agency charged with regulating the
practice of medicine, pursuant to Chapters 20, 456, and 458, Florida
Statutes (2010-2011).
2. At all times material to this matter, Respondent was licensed to
practice as a physician in the State of Florida.
3. Respondent's address of record is 1523 South Orange Avenue,
Orlando, Florida 32806.
4. Atall times material to this matter, Respondent treated patients
Filed October 2, 2012 3:04 PM Division of Administrative Hearings
JH v. Keith B. Murray, M.D.
Case Number: 2011-19788
at the Casselberry Relief Center, a pain management clinic located at 919
State Road 436, Casselberry, Florida, 32707; the Lake Mary Wellness
Center, a healthcare clinic located at 3525 West Lake Mary Boulevard,
Suite 301, Lake Mary, Florida, 32746; and Amerinet Health, a healthcare
clinic located at 305 North Mangoustine Avenue, Suite 100, Sanford,
Florida, 32771 (hereafter collectively referred to as the Clinics”).
5. While practicing at the Clinics, Respondent prescribed
oxycodone, Valium, Xanax, Ambien and/or Soma to Patients AK, JS, BD, EB
and AM.
6. | Oxycodone, an opioid, is commonly prescribed to treat pain.
According to Section 893.03(2), Florida Statutes (2010-2011), oxycodone is
a Schedule II controlled substance.
7. Xanax is a brand of alprazolam (benzodiazepine) and is
prescribed to treat anxiety. According to Section 893.03(4), Florida
Statutes (2010-2011), alprazolam is a Schedule IV controlled substance.
8. Valium is the brand name for diazepam and is prescribed to
treat anxiety. According to Section 893.03(4), Florida Statutes (2010-
2011), diazepam is a Schedule IV controlled substance.
9. Soma is the brand name for carisoprodol, a muscle relaxant
JH v. Keith B. Murray, M.D.
Case Number: 2011-19788
commonly prescribed to treat muscular pain. According to Section
893.03(4), Florida Statutes (2010-2011), carisoprodol is a Schedule IV
controlled substance.
10. Ambien is the brand name for the drug zolpidem, prescribed to
treat insomnia. According to Title 21, Section 1308.14, Code of Federal
Regulations (2010-2011), zolpidem is a Schedule IV controlled substance.
Facts specific to Patient AK
11. On February 4, 2011, Patient AK presented to Respondent with
complaints of lower back and leg pain. Patient AK’s medical records
indicate Patient AK had a history of taking oxycodone 30 mg, oxycodone 15
mg and alprazolam 2 mg. Respondent examined the patient and prescribed
120 tablets of oxycodone 30 mg, 60 tablets of oxycodone 15 mg and 30
tablets of Mobic 15 mg (a nonsteroidal anti-inflammatory drug (NSAID)
used to relieve pain and swelling) to the patient.
12. Patient AK presented to Respondent for follow-up appointments
on March 31 and April 28, 2011. At each visit, Respondent prescribed 100
tablets of oxycodone 30 mg, 60 tablets of oxycodone 15 mg, 30 tablets of
Xanax 1 mg and 30 tablets of Mobic 15 mg.
JH v. Keith B: Murray, M.D.
Case Number: 2011-19788
13. On May 26, June 23 and July 21, 2011, Patient AK presented to
Respondent for follow-up appointments. At each appointment, Respondent
prescribed between 100 and 110 tablets of oxycodone 30 mg; between 35
and 70 tablets of oxycodone 15 mg; 30 tablets of Xanax 1 mg or Valium 5
mg; and 30 tablets of Mobic 15 mg.
14. On August 17, September 26 and October 24, 2011, Patient AK
presented to Respondent for follow-up appointments. At each
appointment, Respondent prescribed 110 tablets of oxycodone 30 ma,
between 14 and 35 tablets of oxycodone 15 mg and between 28 and 30
tablets of Valium 5 mg.
15. Ata follow-up appointment on November 21, 2011, Patient AK
submitted to a multi-drug urine screen, which was positive for barbiturates
but negative for oxycodone and benzodiazepines, notwithstanding the fact
that Respondent had prescribed oxycodone and benzodiazepines to the
patient. A notation on the drug screen indicates that Patient AK “ran out of
meds”; however, Respondent then discontinued Patient AK’s prescription of
oxycodone 15 mg, increased the prescription of oxycodone 30 mg to 115
tablets and prescribed 28 tablets of Valium 5 mg. The medical records lack
OH v. Keith B. Murray, M.D.
Case Number: 2011-19788
any documentation as to the justification for the alteration in the drug
regimen or consideration of the patient's unexplained drug screen.
16. Patient AK’s medical records indicate that Respondent's initial
treatment plan for the patient included physical therapy, massage and
chiropractic treatment, but there is no indication in the medical records
that Respondent offered any consults with other specialists or treatment
modalities other than the prescribed medications. In addition, there is no
indication that Respondent considered the patient’s discordant drug
screens in relation to the continued prescription of controlled substances.
. 17. An independent medical expert retained by Petitioner opined
that Respondent's treatment of Patient AK fell below the minimum
standard of care in that he prescribed controlled substances without
justification. The expert also opined that Respondent failed to properly
evaluate the patient or refer the patient to utilize other modalities of
treatment.
18. The medical records created by Respondent for Patient AK do
not document a justification for the types and amounts of medications
prescribed by Respondent. In addition, Respondent failed to document a
treatment plan that identified treatment objectives and failed to document
OH v. Keith B. Murray, M.D.
Case Number: 2011-19788
any significant abnormal examinations findings or functional changes in the
patient that would justify the treatment.
Facts specific to Patient JS
19, On March 10, 2011, Patient JS, a 30-year-old male, presented
to the Lake Mary clinic with complaints of right wrist, lower back and upper
back pain. Records indicate that Patient JS disclosed a medication history
consisting of monthly prescriptions of 180 tablets of oxycodone 30 mg and
that he had not received treatment other than pain medications. Dr. TB, a
physician at the clinic, diagnosed chronic wrist pain and lumbar
degenerative disc disease (DDD) and prescribed 112 tablets of oxycodone
30 mg, 28 tablets of Valium 10 mg, 28 tablets of Mobic 15 mg and 28
tablets of Flexeril 10 mg to JS. In addition, Dr. TB referred JS to a
chiropractor and massage therapy, but there are no records indicating that
Patient JS consulted with a chiropractor or massage therapist.
20. On March 31, May 3 and June 2, 2011, Patient JS presented to
Respondent for follow-up appointments. At each appointment, Respondent
prescribed 150 tablets of oxycodone 30 mg, 30 tablets of Xanax 1 mg, 60
tablets of Naproxen 500 mg (NSAID) and 60 tablets of Flexeril 10 mg to
Patient JS. Respondent diagnosed displacement of Jumbar invertebrae;
JH v. Keith B. Murray, M.D.
Case Number: 2011-19788
however, there is no documentation reflecting the extent of the
displacement or any objective examinations to confirm the diagnosis.
“34. Patient JS presented to Respondent for a follow-up
appointment on July 18, 2011, at which time Respondent prescribed 150
tablets of oxycodone 30 mg, 30 tablets of Valium 5 mg and 60 tablets of
Flexeril 10 mg to Patient JS. There is no documentation explaining the
discontinuance of Naproxen.
22. At a follow-up appointment on August 16, 2011, Respondent
prescribed 150 tablets of oxycodone 30 mg and increased the Valium
prescription to 56 tablets of Valium 10 mg. In addition, Respondent
prescribed 10 tablets of Cialis 10 mg to Patient JS to treat complaints of
erectile dysfunction; however, Respondent failed to conduct any erectile
dysfunction-specific medical evaluations, or work-up, including laboratory
and imaging testing.
23. On September 13, October 19 and November 21, 2011, Patient
JS presented to Respondent for follow-up appointments. At each
appointment, Respondent prescribed 140 tablets of oxycodone 30 mg and
56 tablets of Valium 10 mg to Patient JS. At the November 21
appointment, Patient JS submitted to a multi-drug urine screen, which was
OH v. Keith B. Murray, M.D.
Case Number: 2011-19788
negative for benzodiazepines despite his long-term prescriptions of Xanax
and Valium. There is no documentation as to the discordant urine screen.
24. Petitioner's expert opined Respondent's treatment of Patient JS
fell below the minimum standard of care in that he prescribed controlled
substances to JS without justification. The expert also opined that
Respondent failed to properly evaluate the patient or refer the patient for
other modalities of treatment.
25. The medical records for Patient JS’s treatment fail to document
a treatment plan, including objectives that would be used to determine
treatment success, and fail to document a justification for the types and
amounts of medications prescribed. In addition, the records fail to
document any significant abnormal examination findings or functional
changes in the patient that would justify the treatment. Finally, Respondent
failed to document any justification or medical indication for the long-term
benzodiazepine prescriptions.
Facts specific to Patient BD
26. On March 30, 2011, Patient BD, a 22-year-old female,
presented to Respondent with complaints of lower back pain resulting from
an old spinal fracture initially treated surgically. Patient BD had a
JOH v. Keith B. Murray, M.D.
Case Number: 2011-19788
prescription history consisting of hydrocodone and oxycodone prescriptions
from four different healthcare providers during the previous two months.
Respondent prescribed 120 tablets of oxycodone 30 mg, 60 tablets of
oxycodone 15 mg, 60 tablets of gabapentin 300 mg (used to treat seizures
and pain relief) and 60 tablets of Mobic 7.5 mg to the patient; however,
BD’s medical records lack any evidence Respondent conducted a physical
examination of the patient’s back or that Respondent established a
treatment plan for the patient.
27. On April 27 and May 25, 2011, Patient BD presented to
Respondent for follow-up appointments. At each appointment, Respondent
prescribed 120 tablets of oxycodone 30 mg, 60 tablets of oxycodone 15
mg, 30 tablets of Ambien 5 mg, 60 tablets of gabapentin 300 mg and 60
tablets of Mobic 7.5 mg to the patient; however, the patient’s records lack
any indication Respondent conducted or documented an appropriate
physical examination of the patient or established a treatment plan for the
patient.
28. At the April 27, 2011, appointment, Patient BD submitted to a
multi-drug urine screen, which was negative for oxycodone and
benzodiazepines, despite the patient’s current prescriptions for both. The
OH v. Keith B. Murray, M.D.
Case Number: 2011-19788
medical records fail to contain any indication that Respondent considered
this abnormal urine screen in the continued treatment of Patient BD with
controlled substances.
29. Patient BD presented to Respondent for a follow-up
appointment on June 22, 2011, at which time Respondent prescribed 120
tablets of oxycodone 30 mg, 30 tablets of oxycodone 15 mg, 30 tablets of
Valium 5 mg, 60 tablets of gabapentin 300 mg and 60 tablets of Mobic 7.5
mg to the patient; however, the medical records offer no justification for
the discontinuance of Ambien or the prescription of Valium.
30. On July 20 and August 17, 2011, Patient BD presented to
Respondent for follow-up appointments. At each appointment, Respondent
prescribed 120 tablets of oxycodone 30 mg, 30 tablets of Valium 5 mg and
60 tablets of gabapentin; however, the medical records offer no
justification for the discontinuance of the oxycodone 15 mg prescription.
31. Patient BD presented to Respondent for follow-up
appointments on September 19, October 17 and November 21, 2011. At
each appointment, Respondent prescribed 112 tablets of oxycodone 30
mg, 28 tablets of Valium 5 mg and 56 tablets of gabapentin 300 mg to
Patient BD.
10
DH v. Keith B. Murray, M.D.
Case Number: 2011-19788
32. Petitioner’s expert opined that Respondent's treatment of
Patient BD fell below the minimum standard of care in that he prescribed
controlled substances to the patient without justification. The expert also
opined that Respondent failed to properly evaluate the patient or prescribe
other modalities of treatment.
33. The medical records for Patient BD fail to document a
treatment plan for the patient, a physical examination or documentation of
_ previous historical treatments. In addition, the records fail to contain a
justification for the medications prescribed or alterations thereto.
Facts specific to Patient EB
34. On April 14, 2011, Patient EB, a 23-year-old female, presented
to Respondent with complaints of pain regarding her right shoulder, right
hip, right knee, back and neck. Patient EB had a prescription history
consisting of 6 tablets of oxycodone 30 mg per day. Respondent evaluated
the patient and prescribed 120 tablets of oxycodone 30 mg, 60 tablets of
Flexeril 5 mg, 60 tablets of gabapentin 300 mg and 30 tablets of Mobic 15
mg to the patient. Respondent prescribed the same medications to Patient
EB at a follow-up appointment on May 18, 2011.
11
OH v. Keith B. Murray, M.D.
Case Number: 2011-19788
35. On June 5 and July 13, 2011, Patient EB presented to
Respondent for follow-up appointments. At each visit, Respondent
prescribed 120 tablets of oxycodone 30 mg, 60 tablets of Flexeril 5 mg and
60 tablets of gabapentin 300 mg to Patient EB. Records indicate that at the
July 13 appointment, Respondent discussed with Patient EB the tapering of
the medications to begin the following month. )
36. Patient EB presented to Respondent for follow-up appointments
on August 11 and September 8, 2011. Despite the July discussion
regarding the tapering of medications, Respondent prescribed 120 tablets
of oxycodone 30 mg, 60 tablets of Flexeril 5 mg and 60 tablets of
gabapentin 600 mg to Patient EB at each appointment.
37. On October 6, 2011, Patient EB presented to Respondent for a
follow-up appointment, at which time Respondent prescribed 112 tablets of
oxycodone 30 mg, 56 tablets of Flexeril 5 mg and 56 tablets of gabapentin
600 mg to the patient. Similarly, on November 3, 2011, Patient EB
presented to Respondent, at which time Respondent prescribed 112 tablets
of oxycodone 30 mg, 28 tablets of Flexeril 5 mg and: 56 tablets of
gabapentin 600 mg to the patient. The medical records do not document
any basis for the alteration of the medication regimen. A multi-drug urine
12
JH v. Keith B. Murray, M.D.
Case Number: 2011-19788
screen completed on November 3, 2011, was positive for benzodiazepines
despite the fact that no benzodiazepines had been prescribed to the
patient. There is no notation or action by Respondent documented in the
patient’s record concerning this inconsistency.
38. Petitioner's expert opined that Respondent's treatment of
Patient EB fell below the minimum standard of care in that he prescribed
controlled substances to EB without justification. The expert also opined
that Respondent failed to prescribe other modalities of treatment and failed
to refer the patient to consultations with other specialists.
39. . Patient EB’s medical records lack a treatment plan, including
objectives that would be used to determine treatment success, and fail to
document a justification for the types and amounts of medications
prescribed or altered. The records also fail to document any significant
abnormal examination findings or functional changes in the patient that
would justify the treatment provided by Respondent.
Facts specific to Patient AM
40. On May 16, 2011, Patient AM, a 28-year-old female, presented
to Respondent with complaints of neck, back and hip pain; anxiety;
headaches; and seizures. Patient AM indicated she currently was taking
13
OH v. Keith B. Murray, M.D.
Case Number: 2011-19788
Mobic 15 mg and Robaxin 750 mg to treat her symptoms.
41. Respondent evaluated the patient but failed to examine or
document key relevant exam findings, namely the patient’s sensation,
reflexes, motor strength or hip range of motion. Respondent prescribed
120 tablets of oxycodone 15 mg, 30 tablets of Valium 5 mg, 30 tablets of
Soma 350 mg, 30 tablets of Mobic 30 mg and 90 tablets of gabapentin 300
mg to Patient AM; however, Respondent failed to document any treatment
plan for the patient.
42, Patient AM presented to Respondent for a_ follow-up
appointment on June 9, 2011. At that time, Respondent prescribed 120
tablets of oxycodone 15 mg, 30 tablets of Valium 5 mg, 30 tablets of Soma
350 mg, 15 tablets of Mobic 30 mg and 90 tablets of gabapentin 300 mg to
Patient AM. Similarly, at a follow-up appointment on July 28, 2011,
Respondent prescribed 120 tablets of oxycodone 15 mg, 30 tablets of
Valium 5 mg, 15 Lidoderm patches, 60 tablets of Flexeril 5 mg, 30 tablets
of Mobic 15 mg and 90 tablets of gabapentin 600 mg to Patient AM.
43. Ata follow-up appointment on August 25, 2011, Patient AM
submitted to a multi-drug urine screen, which was negative for oxycodone,
opiates and benzodiazepines, despite her current prescriptions of
14
DH v. Keith B. Murray, M.D.
Case Number: 2011-19788
oxycodone and Valium. At that appointment, Respondent increased the
oxycodone 15 mg prescription to 150 tablets and prescribed 30 tablets of
Valium 5 mg and 15 tablets of Mobic 15 mg.
44. On September 26 and October 24, 2012, Patient AM presented
to Respondent for follow-up appointments. At each appointment,
Respondent prescribed 150 tablets of oxycodone 15 mg and 28 tablets of
Valium 10 mg.
45. Patient AM submitted to a multi-drug urine screen at a follow-
up appointment on November 21, 2011, at which time she tested positive
for Tetrahydrocannabinol (THC); however, the medical records for the
patient fail to document any consideration by Respondent of the patient's
positive THC result or the discordant results of the August 25, 2011, urine
screen. At that time, Respondent prescribed 150 tablets of oxycodone 15
mg and 42 tablets of Valium 10 mg.
46. THC is the psychoactive ingredient in marijuana, or cannabis.
According to Section 893.03(1), Florida Statutes (2011), THC is a
Schedule I controlled substance.
47. Although records indicate that Respondent expressed an intent
to refer the patient to obtain an orthopedic consultation in January, there is
15
OH v. Keith B. Murray, M.D.
Case Number: 2011-19788
no indication in the medical record that Respondent actually offered or
pursued any consults with other specialists or treatment modalities. In
addition, there was no documented treatment plan or justification for the
Valium prescription.
48. Petitioner's expert opined that Respondent's treatment of
Patient AM fell below the minimum standard of care in that he prescribed
controlled substances without justification. In addition, thé expert opined
that Respondent failed to properly evaluate the patient or refer the patient
to utilize other modalities of treatment.
Count One
49. Petitioner realleges and incorporates paragraphs 1 through 48
as if fully set forth herein.
50. Section 458.331(1)(t)1, Florida Statutes (2010-2011), subjects
a physician to discipline for committing medical malpractice as defined in
Section 456.50, Florida Statutes (2010-2011). “Medical malpractice” is
defined by Section 456.50(1)(g), Florida Statutes (2010-2011), as “the
failure to practice medicine in accordance with the level of care, skill, and
treatment recognized in general law related to health care licensure.”
Section 456.50(1)(e), Florida Statutes (2010-2011), provides that the “level
16
OH v. Keith B. Murray, M.D.
Case Number: 2011-19788
of care, skill, and treatment recognized in general law related to health
care licensure" means the standard of care that is specified in Section
766.102(1), Florida Statutes (2010-2011), which states as follows:
The prevailing professional standard of care for a given health
care provider shall be that level of care, skill, and treatment
which, in light of all relevant surrounding circumstances, is
recognized as acceptable and appropriate by reasonably
prudent similar health care providers.
Section 458.331(1)(t)1., Florida Statutes (2010-2011), directs the Board of
Medicine (Board) to give “great weight” to this provision of Section
766.102, Florida Statutes (2010-2011).
51. Respondent failed to meet the prevailing standard of care in
one or more of the following manners:
a. By prescribing inappropriate types and quantities of
controlled substances to Patients AK, JS, BD, EB and AM without
justification;
b. By simultaneously prescribing two immediate-release
opioids to Patients AK and BD;
c. By failing to refer Patients AK, JS, BD, EB and AM to
receive consultations with other medical providers;
17
DOH v. Keith B. Murray, M.D.
Case Number: 2011-19788
d. By failing to employ other modalities for the treatment of
pain in connection with Patients AK, JS, BD, EB and AM; and
e. By failing to properly monitor Patients AK, JS, BD, EB and
AM regarding their use of controlled substances and _ potential
adverse side effects.
52. Based on the foregoing, Respondent violated Section
458.331(1)(t)1, Florida Statutes (2010-2011).
Count Two
53. Petitioner realleges and incorporates paragraphs 1 through 48
as if fully set forth herein.
54. Section 458.331(1)(nn), Florida Statutes (2010-2011), subjects
a physician to discipline for violating any provision of Chapters 456 or 458,
Florida Statutes, or any rules adopted pursuant thereto.
55. Rule 64B8-9.013, Florida Administrative Code, sets forth the
standards for the use of controlled substances for the treatment of pain, in
part, as follows:
(3) Standards. The Board has adopted the following
standards for the use of controlled substances for pain control:
(a) Evaluation of the Patient. A complete medical history
and physical examination must be conducted and documented
in the medical record. The medical record shall document the
18
JOH v. Keith B. Murray, M.D.
Case Number: 2011-19788
nature and intensity of the pain, current and past treatments
for pain, underlying or coexisting diseases or conditions, the
effect of the pain on physical and psychological function, and
history of substance abuse. The medical record also shall
document the presence of one or more recognized medical
indications for the use of a controlled substance.
(b) Treatment Plan. The written treatment plan shall state
objectives that will be used to determine treatment success,
such as pain relief and improved physical and psychosocial
function, and shall indicate if any further diagnostic evaluations
or other treatments are planned. After treatment begins, the
physician shall adjust drug therapy, if necessary, to the
individual medical needs of each patient. Other treatment
modalities or a rehabilitation program may be necessary
depending on the etiology of the pain and the extent to which
the pain is associated with physical and psychosocial
impairment.
* * *
(e) Consultation. The physician shall be willing to refer
the patient as necessary for additional evaluation and
treatment in order to achieve treatment objectives. Special
attention must be given to those pain patients who are at risk
for misusing their medications and those whose living
arrangements pose a risk for medication misuse or diversion.
The management of pain in patients with a history of substance
abuse or with a comorbid psychiatric disorder requires extra
care, monitoring, and documentation, and may require
consultation with or referral to an expert in the management of
such patients.
(f) Medical Records. The physician is required to keep
accurate and complete records to include, but not be limited to:
1. The complete medical history and a_ physical
examination, including history of drug abuse or dependence,
as appropriate;
19
OH v. Keith B. Murray, M.D.
Case Number: 2011-19788
2. Diagnostic, therapeutic, and laboratory results;
3. Evaluations and consultations;
4. Treatment objectives;
* * *
56. Respondent failed to meet the standards for the use of
controlled substances for the treatment of pain in one or more of the
following manners:
a. By failing to document an adequate treatment plan for
Patients AK, JS, BD, EB and AM.
b. By failing to conduct or document an adequate physical
examination of Patients BD and AM;
Cc. By failing to justify the prescriptions of controlled
substances to Patients EB, AM, AK, JS and BD;
d. By failing to appropriately monitor, or document
appropriate monitoring of, Patients AK, JS, BD and AM for drug
diversion or drug abuse; and
e. By failing to document an indication for the Valium and/or
Xanax prescriptions to Patients AM, AK, JS and BD.
57. Based on the foregoing, Respondent violated Section
458.331(1)(nn), Florida Statutes (2010-2011).
20
WHEREFORE, Petitioner respectfully requests the Board of Medicine
enter an order imposing one or more of the following penalties upon
Respondent: permanent revocation or suspension of license, restriction of
practice, imposition of administrative fine, issuance of reprimand;
placement of Respondent on probation, corrective action, refund of fees
billed or collected, remedial education, or any other relief the Board deems
appropriate.
Signed this 1S day of _\ nay} , 2012.
ENT C HEALTH
EPARTMENT OF
° DEPUTY CLERK
cLeRK .Angel Sanders
DATE MAY 29 2012
Date: 5/25/12
JOHN H. ARMSTRONG, MD
Surgeon General and Secretary of Health
ERA Caps SOUSANE Be
DANIEL HERNANDEZ
Chief Legal Counsel
Florida Bar No. #176834
Florida Department of Health
Office of the General Counsel
4052 Bald Cypress Way Bin-C-65
Tallahassee, Florida 32399-3265
Telephone: (850) 245-4640
Fascimile: (850) 245-4662
Email: Daniel_Hernandez@doh.state.fl.us
PCP Members: Dr. Miguel, Dr. Stringer & Mr. Levine
21
NOTICE OF RIGHTS
Respondent has the right to request a hearing to be
conducted in accordance with Section 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 subpoena and subpoena
duces tecum issued on his or her behalf if a hearing is requested.
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 456.072(4), Florida Statutes, the Board shall
assess costs related to the investigation and prosecution of a
disciplinary matter, which may include attorney hours and costs,
on the Respondent in addition to any other discipline imposed.
-15-
Docket for Case No: 12-003249PL
Issue Date |
Proceedings |
Nov. 30, 2012 |
Order Closing File and Relinquishing Jurisdiction. CASE CLOSED.
|
Nov. 29, 2012 |
Agreed Motion to Relinquish Jurisdiction filed.
|
Nov. 19, 2012 |
Petitioner's Motion to Compel Responses to Petitioner's Pending Discovery Requests and to Deem Matters Set Forth in Petitioner's First Request for Admissions Admitted filed.
|
Nov. 07, 2012 |
Notice of Taking Deposition (of M. Bobek) filed.
|
Nov. 07, 2012 |
Notice of Taking Deposition (of K. Murray) filed.
|
Oct. 23, 2012 |
Notice of Transfer.
|
Oct. 16, 2012 |
Order of Pre-hearing Instructions.
|
Oct. 16, 2012 |
Notice of Hearing (hearing set for December 3 and 4, 2012; 9:00 a.m.; Orlando, FL).
|
Oct. 15, 2012 |
Unilateral Response to Initial Order filed.
|
Oct. 09, 2012 |
Notice of Serving Petioner's First Request for Production, First Request for Interrogatories, and First Admissions to Respondent filed.
|
Oct. 04, 2012 |
Initial Order.
|
Oct. 02, 2012 |
Agency referral filed.
|
Oct. 02, 2012 |
Election of Rights filed.
|
Oct. 02, 2012 |
Administrative Complaint filed.
|