cee mop STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, vs. : CASE NUMBER: 1998-20819 DAVID C. SUNDEEN JR., D.D.S. 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, DAVID C.SUNDEEN JR., 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 coe ee meee epee ee sae pe ge ete emcee 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. 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 0010649. Respondent's last known address is 1810 S. Tuttle Avenue, Sarasota, Florida 34239. 3. In or around May 1998, Patient W.B., presented to the Respondent for consultation on dentures. Binge oe aw 4. In or around July 1998, W.B. received the dentures and had them, fitted, completing the procedure. | 5. In or around July 1998, WB. informed the Respondent she could not use the dentures. . 6. In or around August 1998, W.B. again informed the Respondent she could not use the dentures and asked for a refund. 7, In or around October 1998, W.B. requested in writing a copy of her dental records. . | 8. Subsequently, in or around October 1998, W. B. requested via certified mail a copy of her dental records. 9. The Respondent failed to promptly provide Patient, W.B., with a copy of her dental records 10. Petitioner realleges and incorporates by reference the foregoing allegations as if fully stated herein. 11. 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 (1)(n), Florida Statutes, for failing to make available to a patient or client, or to her or ‘his legal representative or to the department if authorized in writing by the patient, copies of documents in the possession or under control of the licensee which relate to the patient or client. meee ere Py 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 his PQ day of Bev Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy M. Snurkowski ' °. Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: oa John L. Chaves / ; 7 - , | , FILED Senior Attorney : DEPARTMENT OF H ~ Agency for Health Care | DEPUTY, st ronlh Administration Kinber Looe Post Office Box 14229 , ‘ > j Tallahassee, Florida 32317-4229 pare__[—2Y-90 (850) 410-3467 re JLC/eit PCP: CPELIRA) KOSS . DATE: GWG /? F David C. Sundeen Jr., D.D.S. Case Number: 1998-20819 Date: October 22, 1999 ce paper tere in seep ae

Docket for Case No: 00-000781