& ? Ap “ gy DEPARTMENT OF HEALTH Oi i, MZ ” Ig DEPARTMENT OF HEALTH TRAE ie PETITIONER, vs’ CASE NUMBER 2000-04328 JACK KRAUSER, D.MD., RESPONDENT. / ADMINISTRATIVE COMPLAINT Petitioner, Department of Health, hereinafter referred to as “Petitioner”, files this . Administrative Complaint before the Board of Dentistry, against JACK KRAUSER, D.M.D., 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 and Chapters 455 and 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 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 7727. Respondent’s last known address is 824 U.S. Highway One, Suite 370, North Palm Beach, Florida 33408. \w/ / 3. On or about October 28, 1 998, a Final Order by the Board of Dentistry was filed in DOH/AHCA Case No. 93-03179 against the Respondent. 4. The Final Order required the Respondent to complete ten (10) hours of continuing education in surgical implant placement and five (5) continuing education hours in radiology. The continuing education requirements were to be successfully completed within one (1) year of the filing of the Board’s Final Order, which would have been on or about October 28, 1999. The Respondent was required to submit proof of completion to the Board of Dentistry Office. 5. The Respondent failed to submit proof of successful completion of the required continuing education coursework as required. COUNT ONE 6. The Petitioner realleges and incorporates by reference the foregoing allegations as if fully stated herein. 7. 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)(aa), Florida Statutes, for the violation of a lawful order of the board or department previously entered in a disciplinary hearing. WHEREFORE, Petitioner respectfully requests the Board of Dentistry to 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 and costs, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. Y \a Signed this day of { l ae , 2000. Robert G. Brooks, M.D. Secretary, Department of Health Nancy M. Snurkowski Chief Attorney : Agency for Health Care Administration . Office of General Counsel Ctohn L. Chaves Senior Attorney Agency for Health Care Administration Office of the General Counsel DEPAR P.O. Box 14229, Mailstop #39 MENT OF Hear), Tallahassee, Florida 32317-4229 Gerace’ CLERK (850) 410-3467 are a Reo Jack Krauser =O Case No. 2000-04328 May 4, 2000 | COUNSEL FOR PETITIONER: ; . =) Per : Slarere hele nd ~~ Date : L/z/200 2

Docket for Case No: 00-003534PL