ce te he U \ _ wi : STATE OF FLORIDA ° DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION *™ & BOARD OF VETERINARY MEDICINE * 78 py 2 DNs» . ‘ I3 DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, vs. : DBPR CASE NUMBER 97-21027 SHAWN RAE STANTON, D.V.M,, 0-2 7l0 PL Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Business and Professional Regulation, and files this Administrative Complaint against Respondent, SHAWN RAE STANTON, D.V.M., before the Board of Veterinary Medicine, and alleges: 1. Petitioner is the state agency charged with regulating the practice of veterinary 2. Respondent is, and has been at all times material hereto, a licensed veterinarian in the State of Florida, having been issued license number VM 0006519. 3. Respondent’s last known address is 3211 Leprechaun Lane, Palm Harbor, Florida 34683, 4, On 26 Siembet 1 064, Alice Moss contacted Respondent's office after her horse, Goldie, becairie entangled in a field wire fence. | 5. At that time, Ms. Moss requested that someone come to her home and render treatment to Goldie. _ — 6. On 26 November 1994, Respondent responded to this call and, upon arrival at the Moss residence attempted to repair the damage caused to Goldie's legs. 7. Respondent administered several shots to tranquilize Goldie for treatment, however, Respondent was unable to place Goldie in a sedative state suitable for suturing the lacerations. . 8. Respondent sutured some of the lacerations but was unable to suture all of them because of Goldie's continued movement. 9. Respondent placed Goldie on antibiotics to combat possible infection. 10. Ms. Moss was advised that the wounds should hea! without much scarring, however, Ms. Moss chose to have cosmetic surgery performed to further minimize the scarring. 11. On26 November 1994, Goldie was taken to Outback Animal Hospital so that the cosmetic surgery could be performed. surgery was performed to eliminate the scarring. 13. On28 November 1994, Goldie was picked up from the hospital and returned home. ‘ 14. Between 28 November 1994 ‘and 02 December 1994, several telephone calls were made by members of the Moss family to Respondent regarding Goldie's condition, which included diarrhea, anorexia, and intestinal pain. | | 45. Respondent ci not take Goldie off the antibiotics. 16. Respondent did not go to the Moss residence to examine Goldie until 02 December 1994. 17 . When Respondent arrived at the Moss residence on 03 December 1994, she discovered Mr. Moss attempting to resuscitate Goldie. | 18. Resuscitative efforts were not effective and Respondent advised Mr and Mrs Moss that Goldie was dead. . 19. Based on the foregoing, Respondent violated Section474.214(1)(1), Florida Statutes, by being incompetent or negligent by failing to. practice medicine with the level of care, skill and treatment which is recognized by a reasonably prudent veterinarian as being acceptable under similar conditions. WHEREFORE, Petitioner requests the Board of Veterinary Medicine to enter an Order imposing one or more of the following penalties: revocation or suspension of the Respondent's license, restriction of 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 F i | nat Regulation rimant of Business and Protessic! Depa DEPUTY CLERK ae ci . Chief Attorney Pravdm Michels Florida Bar No. 0865710 ~ CLERK _ Be COUNSEL FOR DEPARTMENT: Charles F, Tunnicliff Senior Attorney ‘Florida Bar No. 0153831 Department of Business and Professional Regulation 1940 North Monroe Street Tallahassee, Florida 32399-0792 (904) 922-8038 CFT/ceh PCP: —_ Jones and Lewis DATE: 19 February 1999 DBPR vs. Stanton DBPR Case No. 98-11685

Docket for Case No: 00-002780PL