on ae IORI Sa OEE ee Sok. Aug 18 99 1U:S2a Medical Quality Assurance {(950) 4987-9626 soot yesh STATE OF FLORIDA 32 DEPARTMENT OF HEALTH UlVic: OW pe . ADMINISTRA js DEPARTMENT OF HEALTH, . . HE; ARINGS ve ’ PETITIONER, O 0-24 Vs. - CASENUMBER: 98-10953 JON MICHAEL BAUMBAUER, D.DS. RESPONDENT. / ADMINISTRATIVE COMPLAINT ‘COMES'NOW, the Petitioner, Department of ‘Health, hereinafter referred to as "Petitioner", and files this Administrative Complaint before the Board of Dentistry against Jon Michael Baumbauer, hereinafter referred to as “Respondent", and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of dentistry pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 466, Florida Statutes. _Pursuant to the authority « of Section 20. 43 Oe), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality _ Assurance, councils, or boards, as appropriate. "2. Respondent is, and has been at all times material hereto, a licensed dentist in the State of Florida, having been issued license number DN 0007084. Respondent's last known address is 3591 North Lecanto Highway, Lecanto, Florida 34465. 3. On or about July 15, 1998, Respondent entered a plea of nolo contendere to one | (1) count of unlawfully delivering a controlled substance, to-wit: Hydrocodone, in violation of stall r Aug 18 939 10:S2a Medical Quality Hssurance (yoU) 45/-yDed ae pee ine Section 893.03(2)(a), Florida Statutes and Section $93.13(1)(a)1, Florida Statutes, a second degree felony. 4. _ The aforementioned plea was entered in 1 Case. No. 98. 169- CF-A, in the circuit, court of the Fifth Judicial Circuit, Citrus County, Florida. | The grimina! p prosecution was based - upon allegations that Respondent issued prescriptions for controlled substances for persons who were not Respondent’s patients. 5. Based upon the aforgmentiones lea, adjudication ws was s withheld and Respondent was sentenced to three (3) years probation, eight (8) hours of community service per’ month during the térm of probation, and a fine of five-hundred dollars ($500.00). 6. Respondent pled nolo contendere to (1) count of _ unlewtelly delivering a controlled substance. an aeerrccenoet : - 7. Based on the foregoing, the Respondent s license to practice dentistry in the State of Florida is subject to discipline pursuant to Section 466. 028 (ye), Florida Statutes, by being convicted or found guilty of or entering a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction which relates to the practice of dentistry. Hug 4190 59 ausaca .- WHEREFORE, ’ Petitioner respectfully requests the Board of Dentistry 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 [SEK day of L Donaove f brn __,1998. Douglas M. Cook, Director BY: ancy M. Snurkowski - Chief Attorney _ Agency for Health Care Administration .. COUNSEL FOR PETITIONER: Gregory W. Files Senior Attorney Agency for Health Care Ren Administration oe NT OF HE : . ARTME! Post Office Box 14229 DEPA DEPUTY CLERK Dee Tallahassee, Florida 32317-4229 Qe CLERK, r G S (904) 487-2225 . 7 (904) ATE eit GWF/sdw PCP: DATE: meagicai YQuailby Nssurarive weve ree ee roe

Docket for Case No: 00-000421