eae area eae tan eee eta aaah tna, Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 RemotaQSi8- 27850 4544989 AHCA/LEGAL MEDICAL 858 414 1989 PP. STATE OF FLORIDA DEPARTMENT OF HEALTH OO “U T 1 3) PL DEPARTMENT OF HEALTH, ) ; ) PETITIONER, ) ) Vv. ) CASE NO, 1999-51741 ) CHI-SHANG CHEN, M_LD., ) ) RESPONDENT. _—+?) a ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Medicine against Chi- Shang Chen, 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 456, 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. Received Event (Event Succeeded) Date: 41/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remota QS}2- 59850 4444989 AHCA/LEGAL MEDICAL 8528 414 1989 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 0041425, Respondent’s last known address is St. John’s Medical Clinic, 12001 N. Nebraska Ave, Tampa, Florida, 33612. , 3. Respondent is a General Practitioner and is not Board Certified. . 4. Valium contains diazepam, a Schedule IV controlled substance, pursuant to Chapter 893, Florida Statutes. It is indicated for the management of anxiety. A substance in Schedule IV has a low potential for abuse relative to the substances in Schedule Ill and has a currently accepted medical use in treatment in the United States, and abuse of the substance may lead to limited physical or psychological dependence relative to the substances in Schedule II. 5. Lortab contains hydrocodone bitartrate, a Schedule IL Controlled Substance pursuant to Chapter 893, Florida Statutes. Hydrocodone is indicated for the relief of severe to moderate pain. Schedule 1 Controlled Substances have a high potential for abuse and have a currently accepted but severely restricted medical use in treatment in the United States, and abuse of the substance may lead to severe psychological or physical dependence. 6. Xanax contains alprazolam, a Schedule IV controlled substance, pursuant to Chapter 893, Florida Statutes. Alprazolam is indicated for the management of anxiety. A substance in Schedule IV has a low potential for abuse relative to the substances in Schedule [iI ‘and has a currently accepted medical use in treatment in the United States, and abuse of the substance may lead to limited physical or psychological dependence relative to the substances in Schedule III. 7, Librium contains chlordiazepoxide hydrochloride, a Schedule IV controlled substance, pursuant to Chapter 893, Florida Statutes. , It is indicated for the management of anxiety. A substance in Schedule IV has a low potential for abuse relative to the substances in P.@4 Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remote GSiBy-27890 464 4989 AHCAVLEGAL MEDICAL 858 414 1989 Schedule IIT and has a currently accepted medical use in treatment in the United States, and P.@5 abuse of the substance may lead to limited physical or psychological dependence relative to the substances in Schedule U1, 8. Lorcet contains hydrocodone bitartrate, a Schedule II Controlled Substance pursuant to Chapter 893, Florida Statutes. Hydrocodone is indicated for the relief of severe to moderate pain. Schedule II Controlled Substances have a high potential for abuse and have a currently accepted but severely restricted medical use in treatment in the United States, and abuse of the substance may lead to severe psychological or physical dependence. 9 Soma contains carisoprodol, a legend drug, as defined by Section 465.007, Florida Statutes, indicated as an adjunct to rest, physical therapy, and other measures for the relief of discomfort associated with acute, painful musculoskeletal conditions. The effects of Soma and other central nervous system (CNS) depressants may be additive; therefore appropriate caution should be exercised with patients who are taking Soma and other CNS depressants simultaneously. While the risk of dependence is small for the general population, Soma should be prescribed with caution in addiction-prone individuals. 10. Vicoprofen contains hydrocodone bitartrate, a Schedule II Controlled Substance pursuant to Chapter 893, Florida Statutes. Hydrocodone is indicated for the relief of severe to moderate pain. Schedule II Controlled Substances have a high potential for abuse and have a currently accepted but severely restricted medical use in treatment in the United States, and abuse of the substance may lead to severe psychological or physical dependence. Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remota Si: 29840 4444989 AHCA/LEGAL MEDICAL 852 414 1989 P26 TIENT 11. On or about December 30, 1996, Patient C.C., a twenty-nine (29) year old male presented to Respondent with complaints of low back pain off and on, “resulting from an accident last year." Respondent noted tender low back pain with muscle spasm and negative straight leg raise for the physical exam. | Respondent also noted a history of bulging discs. Respondent did not record any further history and did not perform or record any other physical exam, other than obtaining Patient C.C.'s blood pressure, height and weight. Respondent prescribed thirty (30) tablets Valium Smg, and twenty (20) tablets Lortab 5mg. 12. On or about November 10, 1998, Patient C.C. presented to Respondent with complaints of insomnia due to family problems. Respondent’s notes conceming the physical findings for Patient C.C. in the medical record are illegible. Respondent prescribed fifteen (15) tablets Xanax 0.5mg, to be taken at bedtime, 13. On or about January 5, 1999, Patient C.C. presented to Respondent with complaints of insomnia. Respondent’s notes concerning the physical findings for Patient C.C. in the medical record are illegible. Patient C.C. reported to Respondent that he was "in detox due to drug addiction.” Respondent prescribed thirty (30) tablets Librium 25mg, for Patient C.C., and teferred him to a psychiatrist. Respondent diagnosed Patient C.C. with drug addiction. COUNT ONE 14. _ Petitioner realleges and incorporates paragraphs one (1) through thirteen (13), as if fully set forth herein this Count One. 15. Respondent failed to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar 4 Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remota Sia: 2850 6/4 11989 RHCA/LEGAL MEDICAL 85@ 414 1989 conditions and circumstances, in that Respondent failed to obtain an adequate history and perform an adequate physical exam for Patient C.C. and/or failed to pursue other treatment modalities. 16. Based on the foregoing, Respondent has violated Section 458.331(1)(t), Florida Statutes, by failing to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances. COUNT TWO 17. Petitioner realleges and incorporates paragraphs one (1) through thirteen (13) and paragraph fifteen (15) as if fully set forth herein this Count Two. 18. Respondent prescribed, dispensed, administered, mixed, or otherwise prepared a P.O? legend drug, including any controlled substance, other than in the course of the physician’s . professional practice, in that Respondent prescribed legend drugs for Patient C.C. without performing a sufficient evaluation and examination of the patient to determine the etiology of the back problem. 19. Based on the foregoing, Respondent violated Section 458.331(1)(q), Florida Statutes, by prescribing, dispensing, administering, mixing, or otherwise preparing a legend drug, including any controlled substance, other than in the course of the physician’s professional Practice. For the purposes of this paragraph, it shall be legally presumed that prescribing, dispensing, administering, mixing, or otherwise preparing a legend drug, including all controlled substances, inappropriately or in excessive or inappropriate quantities is not in the best interest of Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remote @StB: 27G50 484 11989 AHCA/LEGAL MEDICAL 858 414 1989 the patient and not in the course of the physician’s professional practice, without regard to his intent, COUNT THREE 20, Petitioner realleges and incorporates paragraphs one (1) through thirteen (13), paragraph fifteen (15), and paragraph eighteen (18), as if fully set forth herein this Count Three. 21. Respondent failed to keep legible, as defined by department rule in consultation with the board, medical records that identify the licensed physician or the physician extender and supervising physician by name and professional title who is or are responsible for rendering, ordering, supervising, or billing for each diagnostic or treatment procedure and that justify the course of treatment of the patient, in that Respondent failed to document an adequate history and physical exam for Patient C.C. 22. Based on the foregoing, Respondent violated Section 458.331(1)(m), Florida Statutes (1997), by failing to keep legible, as defined by department rule in consultation with the board, medical records that identify the licensed physician or the physician extender and supervising physician by name and professional title who is or are responsible for rendering, ordering, supervising, or billing for each diagnostic or treatment procedure and that justify the course of treatment of the patient, including, but not limited to, patient histories; examination results; test results; records of drugs prescribed, dispensed, or administered; and reports of consultations and hospitalizations. Based on the foregoing, Respondent also violated Section 458.331(1)(m), Florida Statutes (1996), by failing to keep written medical records justifying the course of treatment of the patient, including, but not limited to, patient histories; examination P.as8 Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remote QSi3- 29850 444 11989 AHCA/LEGAL MEDICAL 858 414 1989 = P.@9 results; test results; records of drugs prescribed, dispensed, or administered; and reports of consultations and hospitalizations. INT A.S. 23. On or about October 12, 1998, Patient A.S., a thirty-seven (37) year old female, presented to Respondent with complaints of "neck pain for three to four days." No further history was recorded in the medical record. Respondent noted in his records that Patient A'S. was “tender in neck with muscle spasm, no limitation on movement, arm negative." Respondent recorded Patient A.S.'s blood pressure, weight and height. Respondent did not perform or record any further physical examinations. Respondent prescribed twenty (20) tablets Lorcet Plus, and thirty (30) tablets Soma for Patient A.S. 24, On or about November 25, 1998, Patient A.S. presented to Respondent for a follow-up with complaints of neck pain. Respondent noted in his medical record Patient A.S.’s blood pressure and weight, and that Patient A.S. was tender in the low back with muscle spasms. | The record does not reveal any other physical examination results and no other physical exam ) was performed. Respondent prescribed twenty (20) tablets Xanax 10mg, and thirty (30) tablets Soma for Patient A.S. co FOUR 25. Petitioner realleges and incorporates paragraphs one (1) through ten (10) and paragraphs twenty-three (23) and twenty-four (24), as if fully set forth herein this Count Four. 26. Respondent failed to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remota Sia: 29850 444 11989 AHCAVLEGAL MEDICAL 858 414 1999 conditions and circumstances, in that Respondent failed to obtain an adequate history and perform an adequate physical exam for Patient A.S. and/or failed to pursue other treatment modalities. | 27. Based on the foregoing, Respondent has violated Section 458.331(1)(t), Florida Statutes, by failing to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances. COUNT FIVE 28. Petitioner realleges and incorporates paragraphs one (1) through ten (10), paragraphs twenty-three (23), twenty-four (24), and paragraph twenty-six (26), as if fully set forth herein this Count Five. 29, Respondent prescribed, dispensed, administered, mixed, or otherwise prepared a legend drug, including any controlled substance, other than in the course of the physician’s professional practice, in that Respondent prescribed legend drugs for Patient A.S, without performing 2 sufficient evaluation and examination of the patient to determine etiology of the back and/or neck problem, , 30. Based on the foregoing, Respondent violated Section 458,331(1)\(q), Florida Statutes, by prescribing, dispensing, administering, mixing, or otherwise preparing a legend drug, including any controlled substance, other than in the course of the physician’s professional practice. For the purposes of this paragraph, it shall be legally presumed that prescribing, dispensing, administering, mixing, or otherwise preparing a legend drug, including all controlled substances, inappropriately or in excessive or inappropriate quantities is not in the best interest of 10 P.108 Received Event (Event Succeeded) Date: 41/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remota@Sia--2a850 444 1989 AHCA/LEGAL MEDICAL 850 414 1989 the patient and not in the course of the physician’s professional practice, without regard to his intent. COUNT SIX 31. Petitioner realleges and incorporates paragraphs one (1) through ten (10), paragraphs twenty-three (23), twenty-four (24), twenty-six (26), and paragraph twenty-nine (29), as if fully set forth herein this Count Six. 32. Respondent failed to keep legible, as defined by department rule in consultation with the board, medical records that identify the licensed physician or the physician extender and supervising physician by name and professional title who is or are responsible for rendering, ordering, supervising, or billing for each diagnostic or treatment procedure and that justify the course of treatment of the patient, in that Respondent failed to document an adequate history and physical exam for Patient A.S. 33. Based on the foregomg, Respondent violated Section 458.331(1)(@m), Florida Statutes, by failing to keep legible, as defined by department rule in consultation with the board, medical records that identify the licensed physician or the physician extender and supervising physician by name and professional title who is or are responsible for rendering, ordering, supervising, or billing for each diagnostic or treatment procedure and that justify the course of treatment of the patient, including, but not limited to, patient histories; examination results; test results; records of drugs prescribed, dispensed, or administered; and reports of consultations and hospitalizations. 11 P.11 Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remote RSIB- 27890 64 11989 AHCA/LEGAL MEDICAL 858 414 1989 PATIENT R.R. 34, In or about January 1999, the Hillsborough County Sheriffs Office (hereinafter referred to as HCSO) was informed by one of his former patients that Respondent had been supplying controlled substances to any patient who asked for such drugs. The former patient, Patient R.R., a fifty-one (51) year old male, volunteered to act as a confidential informant to aid the HCSO in their investigation. 35. In or about March, 1999 a detective from the Tampa Police Department met with Patient R.R. regarding Respondent's prescribing practices, Patient R.R. informed the detective that he had recently presented to Respondent's office requesting controlled substances. Patient RR. told Respondent that he would pay for the controlled substances with his Medicaid card. Respondent advised Patient R.R. to return to his office with cash and he would give Patient R.R. whatever controlled substances he wanted. 36. On or about March 26, 1999, Patient RR. returned to Respondent's office while being electronically monitored with an audio recording device by the police. Respondent noted in the medical records that Patient R.R. had severe low back pain off and on, and “history of disc herniation.” The only physical finding Respondent recorded for Patient R.R. was that the patient was "tender in low back with muscle spasm." 37. The police, utilizing the audio recording device, overheard Patient R.R. ask for twelve (12) to fifteen (15) Lortab tablets to help "get him through the day.” Respondent did not obtain any further history or obtain any Prior records for this patient. Respondent did not perform any further physical examination of Patient R.R. Respondent prescribed fifteen (15) tablets Lortab Plus, for Patient R.R. Patient RR. paid thirty dollars ($30.00) in cash for the prescription. 12 P.12 Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 . Sender: 850 414 1989 _ Remota Sia: an590 84 1989 PHCA/LEGAL MEDICAL 850 414 1989 COUNT SEVEN 38. Petitioner realleges and incorporates paragraphs one (1) through ten (10) and paragraphs thirty-four (34) through thirty-seven (37), as if fully set forth herein this Count Seven. 39. . Respondent failed to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances, in that Respondent failed to obtain an adequate history and perform an adequate physical exam for Patient R.R. before prescribing controlled substances and/or failed to pursue other treatment modalities. 40. Based on the foregoing, Respondent has violated Section 458.331(1)(t), Florida Statutes, by failing to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances. COUNT EIGHT 41, Petitioner realleges and incorporates paragraphs one (1) through ten (10), thirty- four (34) through thirty-seven (37), and paragraph thirty-nine (39) as if fully set forth herein this Count Eight. . 42, Respondent prescribed, dispensed, administered, mixed, or otherwise prepared a legend drug, including any controlled substance, other than in the course of the physician’s professional practice, in that Respondent prescribed legend drugs for Patient R.R. without performing a sufficient evaluation and examination of the patient to determine the etiology of the back problem. P.13 Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remote RSH: 2550 454 11989 AHCA/LEGAL MEDICAL e580 414 1989 P14 43. Based on the foregoing, Respondent violated Section 458.331(1)(q), Florida Statutes, by prescribing, dispensing, administering, mixing, or otherwise preparing a legend drug, including any controlled substance, other than in the course of the physician’s professional practice. For the purposes of this paragraph, it shall be legally presumed that prescribing, dispensing, administering, mixing, or otherwise preparing a legend drug, including all controlled substances, inappropriately or in excessive or inappropriate quantities is not in the best interest of the patient and not in the course of the physician’s professional practice, without regard to his intent, COUNT NINE 44. Petitioner realleges and incorporates paragraphs one (1) through ten (10), thirty- four (34) through thirty-seven (37), and forty-two (42), as if fully set forth herein this Count Nine. 45. Respondent failed to keep legible, as defined by department rule in consultation with the board, medical records that identify the licensed physician or the physician extender and supervising physician by name and professional title who is or ate responsible for rendering, ordering, supervising, or billing for each diagnostic or treatment procedure and that justify the course of treatment of the patient, in that Respondent failed to document an adequate history and physical exam for Patient R.R. 46. Based on the foregoing, Respondent violated Section 458.331(1)Gn), Florida Statutes, by failing to keep legible, as defined by department mule in consultation with the board, medical records that identify the licensed physician or the physician extender and supervising Physician by name and professional title who is or are responsible for rendering, ordering, 2 Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 RemotaQSt3- 29850 434 11989 AHCA/LEGAL MEDICAL 850 414 1989 supervising, or billing for each diagnostic or treatment procedure and that justify the course of treatment of the patient, including, but not limited to, patient histories; examination results; test results; records of drugs prescribed, dispensed, or administered; and reports of consultations and hospitalizations. TIENT P.R. 47, On:or about April 6, 1999, Patient P.R. (confidential informant #2), a thirty-four (34) year old female, presented to Respondent’s office while being electronically monitored with an audio recording device by the police and the DEA. Respondent's note for Patient P.R.'s past medical history was lef blank while the sections referencing surgeries, medical diseases and “other” were marked with a "N/A." Respondent recorded a complaint for Patient P.R. of significant back pain off and on, but he did not record in the medical records the nature or character or cause of the pain. Respondent's notation for the physical exam indicates that Patient P.R. was "tender in low back with muscle spasm." Respondent recorded Patient P.R.'s blood pressure, weight, and height. Respondent did not perform any further physical examinations. 48. The DEA's electronic monitoring device recorded Patient P.R. stating to Respondent that she had been taking Vicodin. Patient P.R. also stated that "it gets me through the day and that's basically what I need.” Patient P.R. also suggested that maybe she could get some Lortab or something like that or something that has hydrocodone in it. The recording then revealed that Respondent asked if Patient P.R. had back problems. Patient P.R. Teplied that she did not have any problems. Respondent then wrote a prescription for Patient P.R. for twenty (20) tablets Vicoprofen. Vicoprofen contains hydrocodone bitartrate. 15 P.415 canna annem eee ae eee eet e tenia t iO Ate ete AS OAR NRiaanent Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 RemotaQSia- 27850 454 11989 AHCA/LEGAL MEDICAL 858 414 1989 P.16 49. On or about June 21, 1999, the Tampa Police Department arrested Respondent and charged him with two felony counts of delivery of a controlled substance, in violation of Section 893.13, Florida Statutes. 50, Section 893.13, Florida Statutes, states, in part: ‘ (1)(a) Except as authorized by this chapter and chapter 499, it is unlawful for any person to sell, manufacture, or deliver, or possess with intent to sell, manufacture, or deliver, a controlled substance. Any person who violates this provision with respect to: 1. A controlled substance named or described in s. $93.03(1)(a), (De), (1d), (2)(a), or (2)(b) commits a felony of the second degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084. : 2. A controlled substance named or described in s. 893.03(1)(c), (2)(c), (3), or (4) commits a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084. 51. On or about June 21, 1999, Respondent voluntarily surrendered his controlled substances privileges to representatives of the Drug Enforcement Administration. i COUNT TEN 52. Petitioner realleges and incorporates paragraphs one (1) through ten (10) and forty-seven (47) through fifty-one (51), as if fully set forth herein this Count Ten. 53, Respondent failed to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances, in that Respondent failed to obtain an adequate history and perform an adequate physical exam for Patient P.R. and/or failed to pursue other treatment modalities. 16 aaa ne Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 RemoteGSips-27890 414 1989 PHCA-LEGAL MEDICAL 850 414 1989 = P.17 54. Based on the foregoing, Respondent has violated Section 458.331(1)(t), Florida Statutes, by failing to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances. COUNT ELEVEN 4 55. Petitioner realleges and incorporates paragraphs one (1) through ten (10), forty- seven (47) through fifty-one (51), and paragraph fifty-three (53) as if fully set forth herein this Count Eleven. 56. Respondent prescribed, dispensed, administered, mixed, or otherwise prepared a legend drug, including any controlled substance, other than in the course of the physician’s professional practice, in that Respondent prescribed legend drugs for Patient P.R. without performing a sufficient evaluation and examination of the patient to determine etiology of the back problem. 57. Based on the foregoing, Respondent violated Section 458.331(1)(q), Florida Statutes, by prescribing, dispensing, administering, mixing, or otherwise preparing a legend drug, including any controlled substance, other than in the course of the physician’s professional practice. For the purposes of this paragraph, it Shall be legally presumed that prescribing, dispensing, administering, mixing, dr otherwise preparing a legend drug, including all controlled substances, inappropriately or in excessive or inappropriate quantities is not in the best interest of the patient and not in the course of the physician’s professional practice, without regard to his intent. 17 Received Event (Event Succeeded) Date: 11/29/00 Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remote Si: 27890 44 11989 AHCA-LEGAL MEDICAL 858 414 1989 CO’ VE 58. Petitioner realleges and incorporates paragraphs one (1) through ten (10), forty- seven (47) through fifty-one (51), fifty-three (53), and paragraph fifty-six (56), as if fully set forth herein this Count Twelve. P.18 59. Respondent failed to keep legible, as defined by departrnent rule in consultation with the board, medical records that identify the licensed physician or the physician extender and supervising physician by name and professional title who is or are responsible for rendering, ordering, supervising, or billing for each diagnostic or treatment procedure and that justify the course of treatment of the patient, in that Respondent failed to document an adequate history and physical exam for Patient P.R. 60. Based on the foregoing, Respondent violated Section 458.331(1)(m), Florida Statutes, by failing to keep legible, as defined by department rule in consultation with the board, medical records that identify the licensed physician or the physician extender and supervising physician by name and professional title who is or are responsible for rendering, ordering, supervising, or billing for each diagnostic or treatment procedure and that justify the course of treatment of the patient, including, but not limited to, patient histories; examination results; test results; records of drugs prescribed, dispensed, or administered; and reports of consultations and hospitalizations. 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, placernent of the Respondent on probation, the assessment of costs 16 18 a a a Received Event (Event Succeeded) Date: | 11/29/00 , Time: 9:05 AM Pages: 22 Sender: 850 414 1989 Remota@SiB: 27650 444 11989 AHCA/LEGAL MEDICAL 858 414 1989 P19 related to the investigation and prosecution of this case as provided for in Section 456.072(4), Florida Statutes, and/or any other relief that the Board deems appropriate. SIGNED this PULA day of —Budiad 2000 Robert G. Brooks, M.D., Secretary Kathryn L. Kasprzak 1 Chief Medical Attorney ot COUNSEL FOR DEPARTMENT; : Kathryn L. Kasprzak ‘ Chief Medical Attorney . Agency for Health Care Administration DEPARTMENT OF HEALTH P.O. Box 14229 DEPUTY CLERK : Tallahassee, Florida 32317-4229 CLERK Wohi, Keron Florida Bar # 937819 KLK/JET pate__¥ 95 [oreo geeo PCP: August 18, 2000 PCP Members: Ashkar, Leon, Rodriguez 19

Docket for Case No: 00-004778PL