STATE OF FLORIDA po DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION” /, LEp BOARD OF VETERINARY MEDICINE 1 y AN . oy, M2, DEPARTMENT OF BUSINESS AND . ADIN! Sicy egg PROFESSIONAL REGULATION, Me AiR a . Neal VE Petitioner, - ; as y. - CaseNo. 99-0488 C1-OOD3P). CATHY ANN SCOTT, D.V.M., Respondent. ADMINISTRATIVE COMPLAINT | Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioner"), files this Administrative Complaint before the Board of Veterinary Medicine against CATHY ANN SCOTT ("Respondent"), and alleges: 1. Petitioner is the state agency charged with regulating the practice of veterinary medicine, pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 474, Florida Statutes. 2. At all times material hereto, Respondent was licensed in the State of Florida as a veterinarian, license number VM 0005658. 3. Respondent's address of record is 2417 SW Falcon Circle, Pt. St. Lucie, Florida, 34953. 4, At all times material hereto, Respondent was employed by Safe Harbor Animal Rescue Clinic (“Safe Harbor”) located at 185 E. Indiantown Road, Jupiter, Fl., 33458. | 5. On or about October 8, 1998, Dr. Richard Robinson performed a spay on a five-month old Weimaraner puppy, at Safe Harbor. 6. On or about February 12, 1999, the owners brought the puppy back to Safe Harbor, _ “indicating the dog was spotting blood. Respondent treated the dog for cystitis and prescribed antibiotics for.a period of.seven days. 7. On or about February 20, 1999, the puppy was still bleeding, so Dr. Robinson again ; treated the puppy with antibiotics. Dr. Robinson and Respondent advised the owners that exploratory surgery (a “laparotomy” was needed: 8. On or about February 25,.1999, the puppy was still bleeding, so Respondent and Dr. Diane Vastine, also from Safe Harbor, performed the laparotomy in an attempt to find out if any piece of ovary remained. _ 9. Respondent and Dr. Vastine removed a suspected “ovarian remnant.” 10. The sample submitted for histopathology was unlabeled and unidentified as belonging tothe Weimaraner... =" 7 11. On or about August 22, 1999, the puppy began spotting blood again. Complainant took the puppy to a new clinic, where she was examined by Dr. Graves.. The puppy’s estrogen levels were found to be normal, indicating estrous. 12. On or about August 27, 1999, the puppy underwent another laparotomy at the new clinic. Dr. Graves discovered and removed approximately three inches of uterus and a completely intact ovary. = . 13. Respondent’s medical records regarding the Weimaraner puppy were inadequate. 14. Respondent failed to notify the dog’s owners of the laboratory/histopathology reports, or the ramifications of the report. . COUNT I 15. Petitioner realleges and incorporates paragraphs one through fourteen as though fully set forth herein. 16. Based upon the foregoing, Respondent violated Section 474.214(1)(y)(3), Fi lorida Statutes, by failing to maintain records which document patient visits, diagnosis, treatment, and other relevant information required under this chapter. COUNT JI 17. Petitioner realleges and incorporates paragraphs one through fourteen as though fully set forth herein. 18. Rule 61G18-18.002(3), Florida Administrative Code, states that medical records shall be written contemporaneously with any service performed. Rule 61G18-18.002(4), Florida Administrative Code, states that medical records shall include any information pertaining to hospitalization, clinical laboratory reports, and tissue examination reports. . 19. Based upon the foregoing, Respondent violated Section 474. 24a, Florida Statues by violating any provision of this chapter or part 1 of chapter 455, a rule of the board or department. COUNT III 20. Petitioner realleges and incorporates paragraphs one through fourteen as though fully set forth herein. 21. Based upon the foregoing, Respondent violated Section 474.214(1)(1), Florida Statutes, by being guilty of incompetence or negligence by failing to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent veterinarian as being acceptable under similar conditions and circumstances . | WHEREFORE, Petitioner respectfully requests the Board of Veterinary Medicine 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 not to exceed $5,000 per violation, issuance of a reprimand, placement of the Respondent on probation, assessment of costs association with the investigation, imposition of any or all penalties delineated within Section 455.227(2), Florida Statutes, and/or any other relief that the Board is authorized to impose pursuant to Chapters 455 and/or 474, Florida Statutes, and/or the rules promulgated thereunder. a Signed this_) -S~” day of _Ocvebe—__, 2000. Counsel for the Department: Laurie Beth Woodham . Assistant General Counsel Florida Bar Number 0049549 . Department of Business and Professional Regulation _ Office of the General Counsel 1940 North Monroe Street Tallahassee, FL 32399-2202 LBW/kah Case #99-09488 _ PCP: G.A4-2000 Sones and Lesis David K. Minacci ; Lead Professions Attorney ¢ Business and Prt Departement © DEPUTY CLERK

Docket for Case No: 01-000023PL