“FILED ~ STATE OF FLORIDA ~ ae _ DEPARTMENT OF HEALTH - 00 JN 13. AN Io: 28 DIVISION OF | ; ADHINISTRATIVE DEPARTMENT OF HEALTH, ) -) PETITIONER, ) 00-244 \ ) vs. ) CASE NO. 1995-05273 DOUGLAS J. LOVE, MD., yO Le bie ce in ~)- : RESPONDENT = - oe —) COMES NOW the Petitioner, Department of Health, hereinafter referred to as “Petitioner.” and files this Administrative Complaint before the Board of Medicine against _ Douglas J. Love, M_D., hereinafter referred to as “Respondent, ” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency / charged with h regulating the ; practice of medicine pursuant to Section 20. 43, Florida Statutes; Chapter 455,1 Florida Statutes, and Chapter 458, Florida Statutes. _ Pursuant to the authority of Section 20.43(3), Florida Statutes, ‘the akland Park Boulevard Ft Lauderdale, Florida 33351- 6703. ADMINISTRATIVE Co OMPLAINT — a a a a 4. On or about March 30, 1995, an Information was filed by Melanie Ann Hines, “Statewide Prosecutor for the State of Florida, against Respondent, alleging one-hindred-and- sixty-five (165) separate felony counts including racketeering, conspiracy to. commit racketeering, insurance fraud, unlawful solicitation, and cheating. State of Florida vs. Douglas Jonathan Love, Circuit Court, Broward County Case No. 95-5579CE. “5. The felony counts concerning racketeering and conspiracy allege ‘that t Respondent associated himself with Advanced Orthopedics Medical Center, PA. (a medical § group practice) . for the purpose of engaging in criminal activities. The felony. counts concerning insurance ‘fraud : . allege t that Respondent Participated i in the billing of various insurance companies for medical services that were never authorized. The felony counts concerning unlawful solicitation allege that Respondent, with intent to defraud various insurance companies, solicited certain individuals to go to Advanced Orthopedics Medical Center, P.A. for the purpose of making a Motor Vehicle Tort claim. or claim for Personal Injury Protection. 6. On or + about April 3, 1998, ‘Respondent pled ‘guilty to the counts in the Information moe concerning racketeering, conspiracy to commit racketeering, insurance fraud, and unlawful ; ; solicitation. State of Florida YS. “Dougla J gnathan LOVE, Circuit Court, Broward County Case no. =. 95-5579CF,_ 8. Section 458. 331(1)(6), Florida Statutes provides that the Board of Medicine may ‘take ‘disciplinary action against a licensed physician if the physician is convicted or found ‘guilty of, or has entered a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction which relates directly to the practice of medicine or the ability to practice medicine. 9. _Respondent violated Section 458.331(1)(C), Florida Statutes by being convicted or _ found guilty of, ‘or centering a 1 plea ‘of nolo contendere to, regardless ‘of # adjudication, a crime in = “any yy jurisdiction which directly relates to the ‘practice of medicine or to ‘the ‘ability to practice : “medicine, by pleading g —_ commit racketeering insurance fraud, and unlawful solicitation. S State of Florida vs. Pouslas : ~Jonathan Love, Circuit Court, Broward County Case no. 95- 5S79CE. WHEREFORE, the Petitioner respectfully requests the Board of Medicine enter an order imposing one or more of the following penalties: permanent 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, the 2 assessment of costs. a related 1 to the investi ation and prosecution of this case as provided for i in 1 Section 455. 624(4), ., Florida Statutes, and/or a any other relief that the Board deems appropriate 2a, 2000.» ome! Robert G. Brooks, M.D., Secretary DEPARTMENT OF HEALTH PUTY CLERK CLERK Wb RDint Ho ATE 2 -/-Be¢e Oe ty to and “being adjudicated guilty of ‘tacketeering, conspiracy ” to . cere eppeeeprt eo - | | 1 | | | . COUNSEL FOR DEPARTMENT: __ Kathryn L. Kasprzak - . ~ Chief-Medical Attomey Agency for Health Care Administration - P.O. Box 14229 Tallahassee, Florida 32317-4229 Florida Bar #0937819 PCP: April 24, 2000 won PCP Members: Cerda, Pardue. i 1 1 i i } i ; ree ne aero weer ot

Docket for Case No: 00-002441