STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Petitioner, vs. CASE NO.: 99-01882 07 Lid PATERNO MONTAYRE, 6 Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Physical Therapy against PATERNO MONTAYRE, hereinafter referred toas “Respondent,” and alleges: 1. Effective July 1, 1997, 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. Pursuant to the authority of Section 20.43 (3)(g), 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. WW ws] 2. Respondent is, and has been at all times material hereto, a licensed Physical Therapist in the state of Florida, having been issued license number PT 0005475. 3. Respondent’s last known address is 4886 Keysville Avenue, Spring Hill, Florida, 34608. 4. Pursuant to a Final Order issued by the Florida Board of Physical Therapy-in case number 97-12570, Respondent was required to pay a $500 citation within 30 days and complete continuing education hours within the audit period. 5. Respondent failed to pay the $500 citation and complete the : continuing education hours as required by the Board. 6. Based on the foregoing, the Respondent has violated Section 486.125(3)(h), Florida Statutes, by violating a lawful order of the Board. WHEREFORE, Petitioner respectfully requests that the Board of Physical Therapy to enter an order imposing one or more of the followifig penalties: revocation or suspension of Respondent’s license, restriction of Respondent’s practice, imposition of an administrative fine, issuance of a reprimand, placement of Respondent’s license on probation for a period of * time and subject to terms and/or conditions, and/or other relief which the Board deems appropriate. SIGNED this CAY/,_ day of _K noe _, 1999. Robert G. Brooks, M.D. Secretary, Department of Health ney M. Snurkows Chief Attorney . General Counsel’s Office-MQA Practitioner Regulation-Legal COUNSEL FOR PETITIONER: Shannon R. Fleming, Senior Attorney Florida Bar Number 0166677 Agency for Health Care Administration Practitioner Regulation-Legal ‘ Post Office Box 14229 Tallahassee, Florida 32317-4229 FILED | Phone: (850) 487-9694 DEPARTMENT OF HEALTH , EPUTY CLER SRF/sgw . CLER =RK K . - 09/30/99 , rns DaTe_ 11-15°S IS SF

Docket for Case No: 00-000672