_. STATE OF FLORIDA Ph & DEPARTMENT OF HEALTH 0} ocr 3) DEPARTMENT OF HEALTH, Petitioner, vs. CASE NO. 97-20366 _ MADISON M. ZIEGLER, Respondent. / ee ADMINISTRATIVE COMPLAINT ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, Department of Health, hereinafter referred to as “ Petitioner,” and files this Administrative Complaint before the Board of opticianry against Madison M. . Ziegler, hereinafter referred to as * Respondent, "and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with. regulating the practice of Opticianry pursuant to Florida Statutes (SUPP. 4996); Chapter 455, Florida | 484 ' complaint, " Tnvestigative - “and prosequtorial, ‘red by the Division of Medical Quality Assurance, couréils, or boards, as appropriate. Florida Statutes. pursuant | to the , us o <7 re RS ms) 2. Respondent is, and has been at all times material hereto, a Licensed Optician in ‘the State of Florida, having been issued license number DO 0001684. Respondent’s last known address is 1002 Woodlore circle, Gulfbreeze, Florida 32561. 3. On or about February 22, 1993, the Respondent entered a plea of nolo contendre to one count of Lewd and Lascivious - child under sixteen (16) charge. 4. As a result thereof, the Respondent was placed on two (2) years probation, with terms including but not limited to eleven (11) “months, “€ifteen (15) days county jail time (suspended) , five hundred dollars ($500) court costs, five hundred twenty-four dollars ($524) to Escambia County Sheriff's Department, restitution and psychological evaluation and treatment. 5. Additionally, the Respondent was charged with the April 23, 1986: Obscene ‘communication convicted January 5, 1983: Larceny/grand theft Adjudication withheld April 7, 1986: Sex offense- against child fondling 7 sdication withheld | The facts noted | in “the aforementioned ‘paragraphs relates to the Respondent ‘ s ability to practice opticianry. Se at et at 7. Based upon the foregoing, the Respondent has violated Section 484.014(1) (r), Florida Statutes, by being convicted or found guilty of, or entering a plea of nolo contendere to, regardless of adjudication, in a court of this state or other jurisdiction, a crime which relates to the ability to practice opticianry. WHEREFORE, Petitioner respectfully requests that the Board of Opticianry enter an ORDER imposing one (1) 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’s license on probation for a period of time and subject to terms/conditions, and/or any other relief that the Board deems appropriate. SIGNED this ve ale day of lov YbA 1998. Douglas M. Cook | . Director nurkowski General Counsel's Office-MQA Chief Attorney- Allied Health By: ~ FILED | "DEPARTMENT F HEALTH EPUTY CLERK gob CLERK Q. pate 3/3/78 COUNSEL FOR DEPARTME, Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration P.O. Box 14229 , Tallahassee, Florida 32317-4229 ph. 850/487-9694 fax 850/414-1991 NMS /kmw PCP: PCP date:

Docket for Case No: 01-004258PL