“- STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REG BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, O On / Ss S vs. CASE NO. 99-01136 RICHARD H. UECKER, D.V.M., Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW the Department of Business and Professional Regulation, hereinafter referred to as "Petitioner," and files this Administrative Complaint before the BOARD OF VETERINARY MEDICINE against RICHARD H. UBCKER, D.V.M., hereinafter referred to as “Respondent, " and alleges: 1. Petitioner is the state agency charged with regulating the practice of veterinary medicine, pursuant to Section 20.165, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 474, Florida Stanutes. . | oa Respondent is, | and has been at all times 5 material hereto, a doctor of veterinary medicine it in the State of Florida, having been issued license number VM 0001617. 3, - Respond dent s address of record i is 625 E. Sheridan Street, ‘Dania, Florida 33004. ut t Decem T 18, 1988, Respondent neutered a 23%-year-old m male German Shepard dog, Bentley, belonging to L.J. 5. Bentley was discharged at approximately 4:00 P.M. on or about December 18, 1998, but expired later that evening. : contain ‘the: ad Nd 6. On or about December 19, 1998, a necropsy was performed on Bentley, revealing that the dog’s peritoneal cavity was filled with z an estimated volume of 3 liters of bloody fluid. The necropsy failed to reveal any evidence of any ligatures on either spermatic cord. COUNT I 7. | Respondent failed to ligate the spermatic blood vessels during his neutering of Bentley. 8. Section 474.214(1)(0), Florida Statutes, states that fraud, deceit, negligence, incompetence, or misconduct in or related to the practice of veterinary medicine, shall constitute grounds for which disciplinary actions may be taken. 9. Section 474.214(1)(r), Florida Statutes, states that being guilty of incompetence or negligence by failing to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent veterinarian as being acceptable under similar conditions and circumstances, shall constitute grounds for which disciplinary actions may be taken. 10. Based upon the foregoing, Respondent is in violation of Sections 474.214(1)(0) and (r), Florida Statutes, and is therefore subject to disciplinary actions. COUNT I dent cation, , recor any - - vaccinations administered, complaint or reason for provision of s services, | hisory, ‘Physical \e . . od examination, any present illness or injury noted, provisional diagnosis or health status determination. 14. Section 474. 214(1)(), Florida Statutes, $ states in | part that the violation of any provision of Chapter 474 or part I of Chapter 455, or a rule of the board or the department, ‘shall constitute grounds for which disciplinary actions may be taken. 15. Based upon the foregoing, Respondent is in violation of Section 474.214(1)()), Florida Statutes, to wit: Rule 61G18-18.002(3), Florida Administrative Code, and is therefore — subject to disciplinary actions. " WHEREFORE, Petitioner respectfully requests the Board of Veterinary Medicine for entry of an Order imposing one or more of the following penalties: revocation or suspension of Respondent's license, imposition of probation, imposition of an administrative fine and/or any other relief that the Board ~t s appropriate. SIGNED this aan day of Se. phon yer , 1999, FILED . YA Fi Department of Business and Professional Regulation Thomas G. Thomas DEPUTY CLER "Chief Attorney cere and Prardorll Hie DATE «Tran ag W COUNSEL FOR DEPARTMENT: Charles F. Tunnicliff Senior Attorney Florida Bar #0153831 Department of Business and Professional Regulation Northwood Centre 1940 N. Monroe St. Tallahassee, Florida 32399-0792 (850) 487-9629 CFT/mlh oh 7/23/99 PCP: KJ/CL 8/27/99

Docket for Case No: 00-001315