r STATEOF FLORIDA © 004 “H, ne DEPARTMENT OF HEALTH COO AN 25° Pa By DEPARTMENT OF HEALTH, : Divs ; ADM] Isis: RAI ve PETITIONER, HE EARINGS. VE vs. CASE NUMBER: 1998-22889 JON MICHAEL BAUMBAUER, D.D.S. (00-F AAs 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, D.D.S., hereinafter referred to as "Respondent", and alleges: 1. 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. 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 board, as appropriate, including the issuance of emergency orders of suspension or restriction. won 3. 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, Beverly Hills, Florida 34465. a) . ca 4. On October 21, 1998, an Emergency Suspension Order, hereinafter referred to as an ESO, was filed against the Respondent! s license to practice dentistry. “ 5, On or around November 24, 1998, an investigator for the agency phoned the Respondent’s office. - 6. On or around November 24, 1998, the \ woman, who answered the’ phone at the Respondent’s office stated that the phone was located at t the ne Beverly Hills Dental Center, that a new patient exam would cost $49.00, and that any work needed could be performed i in their office. | Beverly Hills Dental Center. 8. On or around December 1, 1998, Winn-Dixie Pharmacy faxed the agency a physician’s profile reflecting several prescriptions written by the Respondent after the ESO date. 9. On or around January 15, 1999, the Respondent was arrested by the Citrus County Sheriffs Department for eight counts of practicing dentistry without a license. 10. On or around October 6, 1999, the Respondent pled no contest to practicing dentistry while license was suspended. 11. Based on the foregoing, the Respondent’s license to practice dentistry in the State of Florida is subject to discipline for violating Section 466.028 (1) (aa), Florida Statutes, for the violation or the repeated violation of chapter 466, part II of chapter 455, or any rule promulgated pursuant to part II of chapter 455 or chapter 466; the violation of a lawful order of the board or department previously entered ina disciplinary hearing; or failure to comply with a lawfully issued subpoena of the board or department. 2 “A search of the Internet revealed ‘the Respondent a as the only dentist working at re a) 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 and costs, __ issuance of a reprimand, placement of the Respondent on probation, and/or any. other. Board deems appropriate, SIGNED this Ag//day of Lyman) 1999. COUNSEL FOR AGENCY Rosanna Catalano GY Senior Attorney Florida Bar #118052 Agency for Health Care Administration Practitioner Regulation-Legal P. O. Box 14229, mail stop 39 Tallahassee, Florida 32317- 4229 (850) 487-9670 . RC/clt PCP: Garcia, Ross, and Powers DATE: May 6, 1999 Jon Michael Baumbauer, DN Case Number: 98-22889 Date: December 9, 1999 Robert G. Brooks, M.D. ___Seoretary, Department of Health BY: ancy M. Snurkowski Chief Attorney Agency for Health Care Administration DEPARTMENT OF HEALTH DEPUTY CLERK CLERK Yahi RA pate_£2./222/77_ ief that the. wet

Docket for Case No: 00-000422