STATE OF FLORIDA . DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, ) PETITIONER, ; v. , 5 CASE NO. 1998-01060 SANATKUMAR M. JANI, M.D., RESPONDENT. 5 . ‘ . ADMINISTRATIVE COMPLAINT. COMES NOW the Petitioner, Department of Health, hereinafter referred to a¢ “Petitioner,” and files this Administrative Complaint before the Board of Medicine against Sanatkumar M. Jani, M.D., hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of medicine pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes, and Chapter 458, Florida Statutes. Pursuant to the provisions of Section 20.43(3), 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, councils, or boards, as appropriate. 2. Respondent is and has been at all times material hereto a licensed physician in the state of Florida; having been issued license number ME 0032113. Respondent’s last known address is 839 Winchester Drive, Westminster, Maryland, 21157-5734. 3. Respondent is a Board Certified Anesthesiologist. 4. On February 12, 1997, the Respondent's | license to practice medicine in the State of Maryland was disciplined by the Maryland Board of Physician Quality Assurance, the physician licensing authority for that state, following allegations of failing to deliver appropriate anesthesia and failing to appropriately document the delivery of anesthesia to sixteen (16) patients during the period of September through November, 1994. 5. The Respondent was placed on monitored probation for three (3) years subject to certain terms and conditions. The Petitioner was iater granted an early termination of this .. probation. | 6. The Respondent failed to notify the Florida Board of Medicine of the action taken ' . against his license to practice medicine in Maryland within 30 days. - col ONE 7. Petitioner realleges and incorporates paragraphs one (1) through six (6), as if fully set forth herein this Count One. 8. On or about February 12, 1997, the Maryland Board of Physician Quality Assurance, the licensing authority for the State of Maryland, took action against the Respondent's license to practice medicine in the State of Maryland based upon allegations of failing to properly deliver and document the delivery of anesthesia to patients. 9. Based on the foregoing, the Respondent violated Section 458.331(1)(b), Florida Statutes, by having a license to practice medicine revoked, suspended, or otherwise acted against by the licensing authority of any jurisdiction, including its agencies or subdivisions. wT ~ C iT TWO -10. . Petitioner realleges and incorporates paragraphs one (1) through six (6) and paragraphs eight (8) and nine (9) as if fully set forth herein this Count Two. 11. Based on the foregoing, the Respondent violated Section 458.331(1)(kk), Florida Statutes, by failing to notify the Florida Board of Medicine of the action taken against his license to practice medicine in Maryland within 30 days. + si 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 assessment of costs related to the investigation and prosecution of this case as provided for in Section 455.624(4), Florida Statutes, and/or any other relief that the Board deems appropriate. SIGNED this /7™ Ora of __¢ Dane , 2000. Robert G. Brooks, M.D., Secretary _ FILED DEPARTMENT OF HEALTH DEPUTY CLERK cuerk Pon. Com DATE thryn L. hief Medical Attorney COUNSEL FOR DEPARTMENT: Kathryn L. Kasprzak Chief Medical Attorney - Agency for Health Care Administration P. O. Box 14229 - Tallahassee, Florida 32317-4229 Florida Bar # 0937819 Igm PCP: June 16, 2000 PCP Members: Ashkar, Zachariah, Rodriguez

Docket for Case No: 00-004036PL