UW Nw STATE OF FLORIDA 00 JAN 25 P BOARD OF PHYSICAL THERAPY jy), ; SVE DEPARTMENT OF HEALTH, ADMINIS TRAE Petitioner, (O- OY \ 5 Case No. 98-20938 vs. JOHN G. PONDER, Respondent. ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Physical Therapy Practice against John G. Ponder, hereinafter referred to as “Respondent,” and alleges: 1. Petitioner is the state agency charged with regulating the practice of physical therapy pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 486, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration, hereinafter referred to as the “Agency,” to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate, including the issuance of emergency orders of suspension or _ restriction. YU Nw 3. Respondent has been at all times pertinent hereto, a duly licensed physical therapist's assistant pursuant to Chapter 486, Florida Statutes, having been issued license number PT A011207.. 4, Respondent’s last known address is 134 Cedar Dunes New Smyrna Beach, Florida 32169. 5. On or about June 11, 1997, a Final Order Granting Motion to Enter Default was filed by the Kentucky State Board of Physical Therapy against the Respondent, wherein Respondent's physical therapist's assistant certificate was revoked. 6. Respondent stated that he has lived at his current address since April of 1996, but he did not notify the Department until January 1, 1997. COUNT I 7. Based on the foregoing paragraphs, the Respondent's license to practice physical therapy in the State of Florida is subject to discipline pursuant to Section 486.125(1)(g), Florida Statutes, for having a license revoked or suspended; having had other disciplinary action taken against him or her by the licensing authority of another state. COUNTII 8. Petitioner realleges and incorporates by reference paragraphs one (1) through six (6) as if fully stated herein. 9. Respondent's physical therapy assistant license is subject to discipline pursuant to Section 455.717, Florida statutes, for failure to notify the Department in writing of the licensee's current address and place of practice. U YU WHEREFORE, Petitioner respectfully requests the Board of Physical Therapy 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 fine, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this LOM dees of _( lu Yd COUNSEL FOR AGENCY: Christine T. Messana C_.M. Attorney FL Bar # 0153818 Agency for Health Care Administration General Counsel’s Office - MQA Allied Health P.O. Box 14229 Tallahassee, FL 32317 - 4229 (850) 410-3470 CTM/ctm PCP: Ms /\ ma(Sd pate: s[as-| !%%9 , 1999. Robert G. Brooks, M.D. Chief Attorney On Behalf of the Agency for Health Care Administration FILED DEPARTMENT OF HEALTH EPUTY CLERK CLERK 0, Dun DATE AITSS

Docket for Case No: 00-000418