RECEIven L . STATE OF FLORIDA 97H; L DEPARTMENT OF HEALTH OV~3 py a, ve 4 0 DEPARTMENT OF HEALTH, PETITIONER, ° > vs. CASE NUMBER: 914864 Tl LESLIE PACHTER, D.C. See = 252 > M RESPONDENT. O50 ZO / 2° 5 mn —_ ADMINISTRATIVE COMPLAINT. COMES NOW, the Petitioner, the Department of Health, hereinafter referred to as "Petitioner", and files this Administrative Complaint before the Board of Chiropractic against LESLIE PACHTER, D.C., hereinafter referred to as "Respondent", and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with the regulating the practice of chiropractic pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 460, Florida Statutes. Pursuant to the authority of Section 20.43 (3) (f), Florida Statutes, the Petitioner has contracted with the Agency of Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical.Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, and has been at all times material hereto, a licensed chiropractic physician in the State of Florida, having been issued license number CH 0006224. Respondent's last known address is 3520 Mystic Point Drive, #2308, Miami, FL 33180. 3. On or about May 23, 1994, Patient J.N. completed a patient medical history form provided by the Respondent that provided minimal patient history information. wan y . 4. Respondent failed to record in Patient J.N.’s medical records a minimal standard of history for Patient J.N. . 5. On or about May 23, 1994, the Respondent failed to record in Patient J. N.’s medical records any record of an initial physical examination to include, but not limited to, vital signs, postural evaluation, chiropractic, orthopedic and neurological examination. 6. Respondent failed to record in Patient J.N.’s medical records any record of the content of treatment provided to Patient J.N. from May 23, 1994, through July 19, 1995. 7. Based on the foregoing, the Respondent’s license to practice chiropractic in the State ‘of Florida is subject to discipline for violating Section 460.413 (1)(m), Florida Statutes, by failing to keep written chiropractic records justifying the course of treatment of the patient including but not limited to patient histories, examination results, test results, x-rays, diagnosis of a disease, condition, or injury. Ue | Fi ; Ww] + WHEREFORE, Petitioner respectfully requests the Board of Chiropractic 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, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this) Wy day of Ocflae- 1997. James T. Howell, M.D., M.P. Secretary BY: ancy M. Snurkows Chief Attorney o Agency forHealthCare 5 © Administration Sco gq TN mes 7 COUNSEL FOR PETITIONER Bea co = 235 _ ™ gory W. Files , G20, 2 0 gal Trainee Ss Lt Agency for Health Care “ _ Administration Post Office Box 14229 Tallahassee, Florida 32317-4229 (904) 487-2225 FILED. DEPARTMENT OF HEALTH DEPUTY CLERK GWF/rvj_. ; PCP: CLERK “Rane Comba DATE DATE:

Docket for Case No: 00-003779PL