Petitioner: DEPARTMENT OF HEALTH, BOARD OF CHIROPRACTIC MEDICINE
Respondent: JEREMY ERIC THOMPSON, D.C.
Judges: W. DAVID WATKINS
Agency: Department of Health
Locations: Orange Park, Florida
Filed: Dec. 10, 2020
Status: Closed
Settled and/or Dismissed prior to entry of RO/FO on Friday, April 2, 2021.
Latest Update: Dec. 23, 2024
STATE OF FLORIDA
BOARD OF CHIROPRACTIC MEDICINE
DEPARTMENT OF HEALTH,
PETITIONER,
Vv. CASE NO. 2019-49606
JEREMY ERIC THOMPSON, D.C.,
RESPONDENT.
ee /
ADMINISTRATIVE COMPLAINT
Petitioner, Department of Health, files this Administrative Complaint
before the Board of Chiropractic Medicine against Respondent, Jeremy Eric
Thompson, D.C. In support, Petitioner alleges:
1. Petitioner is the state agency charged with regulating the
practice of chiropractic medicine pursuant to section 20.43, Florida Statutes;
chapter 456, Florida Statutes; and chapter 460, Florida Statutes.
2. | At all times material to this Complaint, Respondent was licensed
to practice chiropractic medicine in the State of Florida, having been issued
license number CH 9504.
DOH v. Jeremy Eric Thompson, D.C.
Case No, 2019-49606
3. Respondent's address of record is 2062 Club Lake Drive, Orange
Park, Florida 32065."
4. On or about February 10, 2020, upon the order of the
Department, Respondent underwent an independent medical evaluation with
an expert in psychiatry.
5. The expert diagnosed Respondent with amphetamine type
substance use disorder.
6. The expert opined that Respondent is unable to practice
chiropractic medicine with reasonable skill and safety to patients due to his
substance use disorder.
7. Section 460.413(1)(q), Florida Statutes (2019), provides that
being unable to practice chiropractic medicine with reasonable skill and
safety to patients by reason of illness or use of alcohol, drugs, narcotics,
chemicals, or any other type of material or as a result of any mental or
physical condition constitutes grounds for discipline.
8. Respondent is unable to practice chiropractic medicine with
reasonable skill and safety to patients due to his amphetamine type
substance use disorder.
1 Respondent has an additional address of 4071 Eagle Landing Parkway, Orange Park, Florida 32065.
2
DOH v. Jeremy Eric Thompson, D.C.
Case No, 2019-49606
9. Based upon the foregoing, Respondent violated section
460.413(1)(q).
WHEREFORE, the 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 any other relief
that the Board deems appropriate.
DOH v. Jeremy Eric Thompson, D.C.
Case No, 2019-49606
SIGNED this /2"" dayof_ Vadis , 2020.
FILED
LTH
RTMENT OF HEA
CEPA EPUTY CLERK
CLERK Angel benders
paTE MAR 1 2 2020 —
PCP Date: Maren (2, 2026
fod MLC
EE Ee
Kimberly Marshall
Assistant General Counsel
DOH Prosecution Services Unit
Florida Bar Number 123880
4052 Bald Cypress Way, Bin C-65
Tallahassee, Florida 32399-3265
Phone 850-558-9810
Fax 850-245-4684
kimberly.marshall@flhealth.gov
PCP Members: Weingarten and Vogel
DOH v. Jeremy Eric Thompson, D.C.
Case No. 2019-49606
NOTICE OF RIGHTS
Respondent has the right to request a hearing te be conducted
im 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.
A request or petition for an administrative hearing must be in
writing and must be received by the Department within 21 days
from the day Respondent received the Administrative Complaint,
pursuant to Rule 28-106.111(2), Florida Administrative Code, If
Respondent fails to request a hearing within 21 days of receipt of
this Administrative Complaint, Respondent waives the right to
request a hearing on the facts alleged in this Administrative
Complaint pursuant to Rule 28-106.111(4), Florida Administrative
Code. Any request for an administrative proceeding to challenge
or contest the material facts or charges contained in the
Administrative Complaint must conform to Rule 28-106.2015(5),
Florida Administrative Code.
Mediation under Section 120.573, Florida Statutes, is not
available to resolve this Administrative Complaint.
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 shail
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.
DCH v. Jeremy Eric Thompson, D.C.
Case No. 2019-49606
Docket for Case No: 20-005378PL
Issue Date |
Proceedings |
Apr. 02, 2021 |
Order Closing File and Relinquishing Jurisdiction. CASE CLOSED.
|
Apr. 02, 2021 |
Petitioner's Unopposed Motion to Relinquish Jurisdiction filed.
|
Apr. 01, 2021 |
Order Granting Petitioner's Second Motion for Sanctions.
|
Apr. 01, 2021 |
Respondent's Notice of No Objection to Petitioner's Second Motion for Sanctions filed.
|
Mar. 26, 2021 |
Order Accepting Qualified Representative.
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Mar. 25, 2021 |
Petitioners Unopposed Motion to Designate a Qualified Representative (Mr. Hudson Sauls) 20-5378PL filed.
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Mar. 22, 2021 |
Petitioner's Notice of Taking Deposition Testimony via Video Teleconference (Heather S. Luing, M.D.) filed.
|
Mar. 19, 2021 |
Petitioner's Second Motion for Sanctions filed.
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Mar. 18, 2021 |
Petitioner's Fourth Notice of Intent to Serve Subpoena Duces Tecum on Non-Party (Cipriano and Johnson) filed.
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Mar. 17, 2021 |
Order Granting Petitioner's Unopposed Motion for Disclosure of Respondent's Medical Records Obtained or Created Through a Substance Abuse Service in Accordance with Section 397.501(7)(A)5, Florida Statutes.
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Mar. 17, 2021 |
Medical Records Sent by Sunrise Detox filed. (Records not available for viewing).
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Mar. 11, 2021 |
Notice of Serving Petitioner's Second Set of Interrogatories filed.
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Mar. 09, 2021 |
Order Granting Petitioner's Unopposed Motion for Sanctions and for Order Commanding Respondent to Appear and Undergo the Mental and Physical Examination as Scheduled.
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Mar. 08, 2021 |
Petitioner's Unopposed Motion for Sanctions and for Order Commanding Respondent to Appear and Undergo the Mental and Physical Evaluation as Scheduled filed.
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Mar. 03, 2021 |
Petitioner's Unopposed Motion for Disclosure of Respondent's Medical Records Obtained or Created Through a Substance Abuse Service in Accordance with Section 397.501(7)(a)5, Florida Statutes filed.
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Feb. 24, 2021 |
Petitioner's Second Notice of Rescheduling Mental and Physical Examination of Respondent filed.
|
Feb. 22, 2021 |
Notice of Court Reporter filed.
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Feb. 12, 2021 |
Petitioner's Third Notice of Intent to Serve Subpoena Duces Tecum on Non-Party (Dr. James W.Fetchero) filed.
|
Feb. 12, 2021 |
Notice of Serving Petitioner's Responses to Respondent's First Set of Discovery Requests filed.
|
Feb. 04, 2021 |
Petitioner's Notice of Rescheduling Mental and Physical Examination of Respondent filed.
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Feb. 03, 2021 |
Order Granting Extension of Time.
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Feb. 03, 2021 |
Petitioner's Emergency Response to Respondent's Motion for an Extension of Time filed.
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Feb. 03, 2021 |
Respondent's Motion for Extension of Time filed.
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Feb. 01, 2021 |
Order Granting Amended Motion for Respondent to Undergo a Mental and Physical Examination.
|
Jan. 29, 2021 |
Petitioner's Second Notice of Intent to Serve Subpoena Duces Tecum on Non-Party (ARCpoint Labs) filed.
|
Jan. 28, 2021 |
Petitioner's Notice of Taking Deposition Testimony via Video Teleconference (Lisa Caudle) filed.
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Jan. 28, 2021 |
Subpoena Duces Tecum (Petitioners Notice of Taking Deposition Testimony via Video Teleconference; Lisa Caudle) filed.
|
Jan. 22, 2021 |
Petitioner's Notice of Taking Deposition Testimony via Video Teleconference (Deborah Thompson) filed.
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Jan. 22, 2021 |
Petitioner's Notice of Intent to Serve Subpoenas Duces Tecum on Non-Parties (Sunrise, Lakeview, Harden) filed.
|
Jan. 21, 2021 |
Petitioner's Notice of Taking Deposition Testimony via Video Teleconference (Alexis Thompson Lee) filed.
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Jan. 21, 2021 |
Respondent's Notice of Taking Deposition Testimony via Video Teleconference filed.
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Jan. 21, 2021 |
Petitioner's Amended Motion for Respondent to Undergo a Mental and Physical Examination filed.
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Jan. 20, 2021 |
Order Granting Continuance and Rescheduling Hearing by Zoom Conference (hearing set for April 20 and 21, 2021; 9:00 a.m., Eastern Time).
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Jan. 19, 2021 |
Petitioner's Motion for Respondent to Undergo a Mental and Physical Examination filed.
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Jan. 19, 2021 |
Joint Motion to Continue Final Hearing filed.
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Jan. 14, 2021 |
Notice of Serving Respondent's First Request for Admissions, First Request for Production of Documents, and First Set of Interrogatories filed.
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Jan. 11, 2021 |
Petitioner's Notice of Rescheduling of Taking Deposition Testimony via Video Teleconference (Thompson) filed.
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Jan. 07, 2021 |
Petitioner's Notice of Taking Deposition Testimony via Video Teleconference (Jeremy Thompson) filed.
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Dec. 21, 2020 |
Order of Pre-hearing Instructions.
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Dec. 21, 2020 |
Notice of Hearing by Zoom Conference (hearing set for February 17 and 18, 2021; 9:30 a.m., Eastern Time).
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Dec. 18, 2020 |
Joint Response to Initial Order filed.
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Dec. 16, 2020 |
Notice of Serving Petitioner's First Request for Admissions, First Request for Production of Documents, and First Set of Interrogatories filed.
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Dec. 11, 2020 |
Initial Order.
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Dec. 10, 2020 |
Respondent's Answer to Administrative Complaint filed.
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Dec. 10, 2020 |
Administrative Complaint filed.
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Dec. 10, 2020 |
Agency referral filed.
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