oe Se a «Si A. et Sh te oe ~~ ¢ouncils, or boards, as ap a) _ STATE OF FLORIDA RECEIVED < - DEPARTMENT OF HEALTH “CEIVED - LEGAL | OOMARI7 ANTI: 22 DEPARTMENT OF HEALTH, PETITIONER, . 00-1981 “vs. . _-CASENUMBER: 98-03816 _ CHARLES GRAPER, DDS, a : ; > = : So = RESPONDENT. zz > / EGS ew SriD w zne ADMINISTRATIVE COMPLAINT 23 2 COMES NOW, the Petitioner, Department of Health, hereinafter referrdd to Bo paiggher", and files this “Administrative Complaint before the Board of Dentistry against CHARLES GRAPER, 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. 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, 2 Respondent j is, and has been at all times 5 material hereto, z a licensed dentist i in ‘the State of Florida having been issued license number DN 0005385. The Respondent's last known address is 832 N.W. 57" Street, Gainesville, Florida 32605. 3. In or around 1996, Patient RT. presented to the Respondent for implants. 4. In or around 1996, the Respondett Performed implant surgery and d prepared a bridge for Patient R.T. - ws . : ~ 4 - wy, . 5. In or around 1996, the Respondent failed to provide any comprehensive treatment plan for Patient R.T. 6. 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 (09, Florida Statutes, for being guilty. of incompetence or negligence by failing to meet 1 the minimum n standards of performance in diagnosis and treatment when measured against generally prevailing peer performance, including, but not limited to, the undertaking of diagnosis and treatment for which the dentist is not qualified by training or experience or being guilty of dental malpractice. x od WHEREFORE, Petitioner respectfully requests the Board of t Dentistry enter an order ; imposing one or more of the following penalties: revocation or suspension of the Respondent's license, restriction of the Res; ondent's ractice, imposition of an administrative fine, issuance of a ; P Pp ip reprimand, placement of the ¢ Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED wid (A cay of (Nav , 2000. LED DEPARTMENT OF HEALTH DEPUTY CLERK CLERK Webi RELiont pare_2-/3 doe’ COUNSEL FOR PETITIONER: John L. Chaves. Senior Attorney Agency for Health Care _ Administration Mail Stop 39 Post Office Box 14229 Tallahassee, Florida 32317-4229 (004) 4103467 ILChvt FOr FOWL eGR DATE: January 27, 2000 Robert G. Brooks, M.D. Secretary, Department of Hf Oo. ndee © 1) By Oa td BY: Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration peer neem gene ange epee Spee rst memes errr: OP ere meee ep:

Docket for Case No: 00-001581