. DOH-02-0965--S Moa FILED DATE - 2 PRACTITIONER | REGULA Nils eae OF FLORIDA Doe BROS falth LEG OARD OF MEDICINE . By: : 200? JUN 28. RIO: 5h Be DEPARTMENT OF HEALTH, 7, ‘. Gr, o Petitioner, BMS F 2 “. MY ed Ula cn "O alo 3 4 Cony SG vs. : CASE NO.: 1999-50180 LICENSE NO.: ME0040663 ROBERT VARNER SIEGEL, M.D., . QO\- Uq2 REL Respondent. 0c A _C los FINAL ORDER THIS CAUSE came before the Board of Medicine (Board) pursuant to Sections 120.569 and 120.57(4), Florida Statutes, on June 7, 2002, in Tampa, Florida, for consideration of a Consent Agreement (attached hereto as Exhibit A) entered into between the parties in the above- styled cause. Upon consideration of the Consent Agreement, the documents submitted in support thereof, the arguments of the parties, and being otherwise advised in the premises, the Board rejected the Consent Agreement and offered a Counter Consent Agreement which Respondent was given 7 days from the receipt of this Order to accept or reject. By letter dated June 14, 2002, counsel for Respondent timely accepted the Counter Consent Agreement. The Counter Consent Agreement incorporates the original Consent Agreement with the following amendments: : 1. Respondent shall submit to the UF CARES evaluation and document compliance with said evaluation within one (1) year from the date this Final Order is filed. 2. Within two(2) years from the date this Final Order is filed, Respondent shall document the completion of 100 hours of community service at the rate of 50 hours per year. Community service shall consist of the delivery of medical services directly to patients, without fee or cost to the patient, for the good of the people of the State of Florida. Affidavits detailing the completion of community service requirements shall be filed with the Board's Probationer’s Committee. IT IS HEREBY ORDERED AND ADJUDGED that the Consent Agreement as submitted be and is hereby approved and adopted in toto and incorporated by reference-herein with the amendments set forth above. Accordingly, the parties shall adhere to and abide by all the terms and conditions of the Consent Agreement as amended. This Final Order shall take effect upon being filed with the Clerk of the Department of Health. DONE AND ORDERED this. C4 day of , 2002. BOARD OF MEDICINE MCPHERSON, JR DIRECTOR For GUSTAVO LEON, M.D. CHAIR-ELECT CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been provided by U.S. Mail to Robert Varner Siegel, M.D., 345 Miracle Strip Parkway SW, Fort Walton Beach, Florida 32548; to Rogelio Fontela, Esquire, Dennis, Bowman, et. al., Post Office Box 15589, Tallahassee, Florida 32317-5589; and by interoffice delivery to Nancy M. Snurkowski, Chief - Practitioner Regulation, and Lisa Pease, Senior Attorney - Appeals, Agency for Health Care Administration, 2727 Mahan Drive, Tallahassee, Florida 32308-5403, on or before 5:00 p.m., ™~ H this -“t> day of 7 , 2002. MAR-12-2022 14:43 RHCA/LEGAL MEDICAL 856 414 1589 STATE OF FLORIDA PRACTITIONER R DEPARTMENT OF HEALTH ~ LEGAL 2002 MAR 19 DEPARTMENT OF HEALTH, ° - Petitioner, vs DOH Case No, 1999-50180 - ROBERT. VARNER SIEGEL, M.D., Respondent, SONSENT AGREEMENT Robert Vamer Siegel, MD., "referred to as the "Respondent," and: the “Department of Health, referred to as "Departinent™ stipulate and agree to the [.! following: cAgreement end to the entry of a Final Order of the Board af Medicine, referred to as "Board," | incorporating the Stipulated Facts and Stipulated Dispostion 4 inthis matter, os eos Mote Petttioner Is the state agency charged with regulating the practice of yo. ‘ - medicine pursuant to Section 20.43, Florida Statutes, Chapter 456, Florida , u nary " Statutes, “and Chapter 458, Florida Statutes. Pursuant to the provisions of 1". Section 20.43(3), Florida Statutes, the Petitioner has contracted with the Agency | “1h Se for Health Care Administration t provide consumer complaint, Investigative, and prosecutorial services required by the Division’ of Medical Quality Assurance, i Gigile ds Be gf * councils, or boards, as appropriate. a ee Peay een ere WaRatabainca tts = ae ae Ln sori esse en 3 : ) PULA - J, ' At all times material hereto, Respondent was a Ikensed physidan inthe " State of Florida having been issued license number ME 0040663 2." Respondent was charged by an Administrative Complaint filed by the ‘Department and properly served upan Respondent with violations of Chapter 458, ' Florida Satutes, and the rules enacted pursuant thereto. 3, Respondent nefther admits nor denies the allegations of fact contained {in ‘the Adthinistrakive Complaint for purposes of these proceedings only, i { 4 STIPULATED CONCLUSIONS OF LAW 1: Respondent ‘admits that,'In His capacity as a licensed physician, “he Js 1 ewes to the provisions of Chaplers 456 and 458, Florida Statutes, and the 4, ‘ + Jurisdiction of the Department and the Board. 2. ‘Respondent admits that the facts set forth in the Administrative Complaint, If proven, woukl constitute violations of Chapter 458, Florida Statutes, Ss ps alleged In the Admintstrative Complaint. 3. Respondent admits that the Stipulated Disposition in this case is fair, eh “appropriate and acceptable to Respondent. MAR-12-2082 14:43 AHCA/LEGAL MEDICAL 850 414 1589 x i ‘ P84 , weet Uae ne the rele Wid dedi tn oe tine QL ome ott wma tee Va -oa oe nee ate le ae othe et MAR-12-2202 14:44 erat rer oe PUTT EE 2 AHCA/LEGAL MEDICAL STIPULATED DISPOSTTION 1. FUTURE CONDUCT, Respordent shall not In the future violate ’ Grapters 456, 458 and 893, Fiorida Statutes, or the rules promulgated pursuant thereto, Prior to signing this agreement, Respondent read Chapters 456, 458, and "893, Florida Statutes, and the Rules of the Board of Medicine, at Section 6488, Florida Administrative Code, "2. ERNE, ‘The Board’ shall liipose an administrative fine in the amount of > | "Bight Thoysand Dollars ($8,000.00) against the Respondent. ‘The fine shall be paid " ‘by the Respondent to the Board of Medicine within one year of Its Imposttion by Final Order of the Board, THE RESPONDENT ACKNOWLEDGES THAT: THE. “TIMELY PAYMENT OF THE FINE IS HIS LEGAL OBLIGATION AND ‘RESPONSIBILITY AND’ THE RESPONDENT AGREES TO CEASE ‘PRACTICING IF THE FINE IS NOT PAID AS AGREED TO IN THES CONSENT AGREEMENT, SPECIFICALLY: IF THE RESPONDENT HAS HOT RECEIVED WRITTEN CONFIRMATION THAT THE FULL AMOUNT OF THE ’ FINE HAS BEEN RECEIVED BY THE BOARD OFFICE WITHIN ONE YEAR’ “OF THE FILING OF THIS FINAL ORDER, THE RESPONDENT AGREES FO “CEASE PRACTICE UNTIL SUCH WRITTEN CONFIRMATION IS RECEXVED BY THE RESPONDENT FROM THE BOARD. (SEE EXHIBIT A, PARAGRAPH. E OF THIS CONSENT AGREEMENT FOR BOARD ADDRESS AND STANDARD . 1 TERMS). : ‘ . 656 414 1589 : ps P, wT Minne 2h ar earn oe ee" tS a Me wee a a ie ae te Pe revariae hen. 4 poten Came meat aR et pt le ek et MAR-12-20@2 14:45 ee AHCA/LEGAL MEDICAL 3. REIMBURSEMENT OF COSTS, In addon to the amount of any "<* fine noted above, the Respondent agrees to reimburse the Department for any i. administrative costs incurred In the Invesdgation and preparation of this case, " indduding ‘costs assessed by the Division of Administrative Hearings, if applicable, “’and by the Board of Medicine office. The agreed upon Agency costs to be ) reimbursed in this case is $2,704.38, The casts shall be pald by the Respondent to the Board of Medicine within sbx months of its imposition by Final Order of the “"y) Board.” THE RESPONDENT ACKNOWLEDGES THAT THE TIMELY PAYMENT ‘OF THE COSTS IS HIS LEGAL OBLIGATION AND RESPONSIBILITY AND - “ty “RESPONDENT AGREES TO CEASE PRACTICING IF THE COSTS ARE NOT: "PAID AS:AGREED TO IN THIS CONSENT AGREEMENT, SPECIFICALLY! TF ‘THE RESPONDENT HAS NOT RECEIVED WRITTEN CONFIRMATION THAT ‘THE FULL AMOUNT OF THE COSTS NoTED ABOVE HAS BEEN RECEIVED ” | "BY THE BOARD OFFICE WITHIN § MONTHS OF THE FILING OF THIS Ty ETMAL ORDER, THE RESPONDENT AGREES TO CEASE PRACTICE UNTIL » FROM THE BOARD. (SEE EXHIBIT A, PARAGRAPH F OF THIS CONSENT " AGREEMENT FOR BOARD ADDRESS AND STANDARD TERMS. 4. REPRIMAND. Respondent shall receive a reprimand, 5. MITIGATING FACTORS: In amtving at this disposition the parties fonsidered the following mitigating factors: As part of the discipline in Case Number 3998-13313, the fetts of which occurred around the same time as the {;.. SUCH WRIOTEN CONFIRMATION IS RECEIVED BY THE RESPONDENT - 858 414 15a9 P.@s ‘ | Me is MAR-12-2002 14:46 RHCA/LEGAL MEDICAL 852 414 1689 * facts in the Instant case, Respondent completed the USF Drug course on dlinical, | «legal and ethical issues in prescribing on November 5, 1999 and a Quality " Assurance Review was conducted of Respondent's prescribing practices. The . “report from the Quality Assurance Review was submitted to the Board of Medicine on Octobar 19, 2001. In addition, a fine of $10,000.00 ard) costs were imposed ‘against Respondent and he received a reprimand. Accordingly, due to sanctions “ymposed for similar behavior occurring around the same time, Respondent has. "taken steps to coméct his prescribing practices. 6.. Tt & expressly understood that this Agreement is subject to the approval ‘of the Board and the Department. In this regard, the foregoing * paragraphs (and onty ‘the foregoing paragraphs) shall have no force and effect: unless a Final Order Ienrporaing the terms of'this Agreement Is entered by the . Board. 7. Respondent Shall appear before the Board at the meeting of the. ” “Board where this Agreement is considered, Respondent, in conjunction with the consideretion of this Agreement by the Board, shall respond to questions under oath from the Board, Board Staff or Department Staff, Respondent, shall. be "prepared to explain'the clroumstances involved in this matter and what measures ©, 4 have been taken to prevent a recurrerioe, However, Respondent shall offer no * evidenco,’testimony or argument that disputes or contravenes any stipulated fact ,or condusion of law. ' _ MAR-12-28@2 14:46 RHCA/LEGAL MEDICAL 858 414 1989. 8. ;Should this Agreement be rejected, no statement made in furtherance of " this Agreement by the Respondent may be used as direct evidence against-the- * - : Respondent in any proceeding; however, such starements may be used by the - ‘ Petitionerfor impeachment purposes. 9." Respondent and the Department fully understand thet this joint = “Agreement and subsequent Final Order incorporating same will in no way preclude “additional proceedings by the Board and/or the Department against tha "Respondent for acts or omissions not specifically sct forth in the Adminkstrative.. “Complaint. ce 10. Upon the Board's adoption of this Agreement, Respondent expressly + waives al further procedural steps, and expressly waives all rights to seek judicial I "review off or to atherwise challenge or contest the validity of the Agreement and vthe Final Order of the Board Incorporating said Agreement. 11, ‘ReSpondont ‘Walves thé ight to'scek any attomey's fees or cnsts = from the Department In connection with this matter. 12. This Agreement is executed by the Respondent for the purpose of ‘ “avoiding further administrative action with respect to this causa, In this regard, . Respondent authorizes the Board to review and examine all investigative file materials ;conceming Respondent prior to or in conjunction with consideration of i "the Agreement. Furthermore, should this joint Agreement not be accepted bythe =! oo _ Board, It is agreed that presentation to and consideration of this Agreement and * other documents and matters by the Board shall not unfairly or illegally prejudke | if ! nl AHCA/LEGAL MEDICAL 4? MAR-12-2682 14 858 414 1589 + the Board or any of its members from further participation, a | Lresolutiony of these proceadings. P18 e5@ 414 1589 , 2002. Robert Vamer Siegel, M.D, 13° wy oF 2002. Secretary, Department of Attomey, Medical Section John'Agwunobi, M.D. My Commession Dpo3333g ~4=NOT'ARY PUBLIC Expires September 14 2005 Subscribed before me this . af ‘My Commission Expires: © — \) 05 swom) fo and —Mrnel __, 2002. Mf Eo RHCA/LEGAL MEDICAL s" at Michelle A Lamberth, + APPROVED thi Bay of SIGNED this |3* day of _ 48 : }dentification) and who, under oath, acknowledges that his/her signature appears ; -above, z L =2 RE ga ii MAR-12-2002 14 BL RE ERLE A TIO Te OT EE ET SET IN ETE ES EF EOIN TTR CeO SORE RARE Hat ict 389 MAR-12-2222 14:48 AHCA/LEGAL MEDICAL 8508 414 y Exhibit A " STANDARD TERMS APPLICABLE TO CONSENT AGREEMENTS: E ns) ‘+ The following are the standard terms applicable to all Consent Agreements, | a my A.. PAYMENT OF FINES. Unless otherwise directed by the Consent A i . ‘Agreement, aall fines shall be patd by check or money order and sent to the Board : .'\ adress as sat forth In paragraph E, below, The Board office does not have the : ._. authority to change terms of payment of any fine Imposed by the Board, | 7 B.. COMMUNITY SERVICE AND CONTINUING EDUCATION. UNITS, | ” Untess other wise directed by the Consent Agreement, all community service . Bete ; requirements, continuing education units/courses must be completed, and "documentation oF sich completion ‘submited 45’ the Board of Medidne ‘at the * address st forth below in paragtaph E, WITHIN ONE YEAR OF THE DATE OF | ; THE FINAL ORDER. _ . a 2 . C. ADDRESSES, The Respondent must ‘keep current residence, and “, ¢ + practice addresses on fle with the Board, ‘The Respondent shall notify the Board “within ten (10) days of any changes of sald addresses. Furthermore, if the | 2 “f t 4 4 a F] 7) i ‘4 Respondent's license is on probation, the Respondent shall notify the Board within ten (10) days In the event that the Respondent leaves the active practiée of medicine in Florida. ‘ 3 7. D. COSTE, * Pursuant ‘to Section '458,331(2), Florida Statutes, the | ° Respondent shall pay all costs necessary to tomply with the terms of this Consent , Agreement. Such costs include, but are not limited to, the cost of preparation of eee MAR-12-2022 14:49 RHCA/LEGAL MEDICAL e528 414 1989 Pip eri cn Has . “Investigative Reports detailing compliance with the tema of the Consent ‘Agreement, obtaining supervision or monitoring of the practice, the cost of quality “assurance reviews, and the Board's administrative cost directly assoclated with the A ad : ‘Respondent's probation. | —.. BOARD ADDRESS. Unless otherwise directed by the Board office, al’ fines, and ‘costs shall be sent to Department of Health, HMQAMS/CGlient Services; P.O, Box 6320, Tallahassee, FL 32314 Att: Medica! Compliance . “Officer. Any reports, comespondence, inquiries or communications other than'for | | "the payment of fines and costs shall be sent to: Board of Medicine HMOAMS : « Cllent_Services_Unit/BIn COJ, 4052 Bald Cypress Way, Tallahassoa, te Le bet aa tevals oe! J : F." PROBATION TERMS, if probation was imposed by the Final j . Order of the Board, the follawing provisions are applicable. | nS eee Sew 1. DEF INTTIONS: qe a. INDIRECT SUPERVISION ‘is supervision by @ monitoring = : physician ‘ (monitor) whose responsibilities are set by the Board. Indirect * .supervision does not require that the monitor practice on the same premises as the | an .” Respondent, however, the monitor shall practice within a reasonable geographic "proximity to Respondent, which shall be within 20 miles unless othenise provided eee by the Board and shall be readily available for consultation. The monitor shallbe Board-oertified in the Respondent's specialty area unless otherwise provided By the | Board. ; ae 10 boned tt dr eh i ok alee ne eats eb nee Fee ele Eee acu ce i ee ola Oe maT Ba ote ele 2 Nn, a Or, ee me fet hie eee tials anion ve ae Se A eee, b. DIRECT SUPERVISION Is supervision by a supervising physidan ; (supervisor) whose responsibilites are set by the Board. Direct . Supervisign requires that the supervisor and Respondent work in the seme office. ‘ . ‘The supervising Physician shall be board-certified in the Respondent's specialty area unless otherwise provided by the Board. : c PROBATION COMMITTEE or “committee” is members of ‘the Board of Medicine Gesigrated by th the Chalrman of the Board to serve as the i "Probation Commitee, 2. REQUIRED SUPERVISION, a if the terms of the consent agreement Indlude inditect - monitoring of the licensee's practice (MONITORING) or direct monitoring of the * * ‘licensee's: practice (SUPERVISION), the Respondent shal not practice medicine * without an approved monttor/supervisor, as spected by the Consent Aareomerny fa , | unless otherwise ordered by the Board. b. “The ‘ monitor/supervisar must be a licensee under: "') Chapter 458, Florida Statutes, in good standing and without restriction or limitation +0 his Tioanse, In’ addition, the Board or Committee may reject any proposed :monitor/supervisor on the basis that he has previously been subject to any "1 disciplinary action against his medical license in this or any other jurisdiction, ts ‘currently under Investigation, or Is the subject of a pending disciplinary action, me Monitor/supervisor must be actively engaged in the same or similar specialty ” area unless otherwise provided by the Board or Committee and be practicing Ba] MAR-12-2mB2 14:59 RHCA/LEGAL MEDICAL 858 414 1389 MAR-12-2082 14:54 RPHCA/LEGAL MEDICAL B58 414 1989 i alt te “within a tpasonable distance of the Respondent's practice, a distance of no Tore . than twerity (20) miles unless otherwise specifically provided for in the consent agreement. The Board or Committee may also reject any proposed | * -Monitor/supervisor for good cause shown. ‘c. MECHANISM FOR APPROVAL OF MONTTOR/SUPERVISOR: , TEMPORARY APPROVAL ‘The Board cinfars i." authortty ‘on the Chairman of the Board's Probation Committee to temporarity ‘approve Respondent's ‘imonitor/supénisor, To obtain this temporary approval, "Respondent shall submit to the Chairman of the Probation Committee. the name on and curiadum vitae of the proposed monitor/supervisor at the time this ;agreement Is considered by the Board, Once a:Final Order adopting’ this . . Agreement is filed, Respondent shall not practice medicine without an "approved monitor /supervisor. Temporary approval shall only remain in "effect until the next mecting of the Probation Committee, i, FORMAL APPROVAL ~ Respondent shall have” the: : -mmonitar/stpervisor with him at his first probation appearance before the Probation Hee *. Commithse. Prior to consideration of the monitor/supervisor by Ure Committee, the 7 Respondent shall provide tn the monitor/supervisor @ copy of the Administrative Complaint, and Final Order in this case. Respondent shall submit a current ‘srg, GumTculum vitae and @ description of current. practice trom the proposed "1" monttor/supervisor to the Board office'no later than fourteen days befsre the 3 $ ‘ ‘Respondehtts first scheduled pribattion . appearance. Respondent's wae Same OW Banta cm eewSe mwas thie ane eon tte eel ie 8 Bs eileen dace a Te ee ete ee po Ween 2a tihee tree, of twee “Teak! ote 8 Re ful abedenseried She ede thats MAR“12-2282 14:52 AHCA/LEGAL MEDICAL 65a 414 1989 . ; or testo _ monitor/supervisor shall also eppear before the Probation Committee at such other _ times as directed by the Committee. It shall be Respondent's responsibility to ensure that the appearance of his monitor/supervisor as directed. Failure of the monitor/supervisor to appear as directed shall constitute a violation of the terms of this Stipulation and shall subject the Respondent to disciplinary action. d. ‘CHANGE IN MONITOR/SUPERVISOR. In the event that Respondent's monitor/supervisor ts unable or unwiliing to fulfil his responsibilties "gs a motitor/supervisor as described above; the Respondent shall immediately” advise the Board of this fact. Respondent shall immediately submit to the “Chairman of the Board's Probation Committee the name of a temporary ” \monitor/supervisor for consideration, Respondent shall not practioe pending approval of this temporary monitor/supervisor by the Chaitman of the Probation “)* Committee. Furthermore,” Respondent shall make arrangements wtth ‘his " tamporary monitor/supervisor to appear before the Probation Committee 23, Its “next regularty scheduled meating for consideration of the monitor/supervisor by ! the Committee, Respondent shall only practice under the auspices of the temporary monitor/supervisor (approved by the Chairman) until the next regutarty ‘scheduled meeting of the Probation Committee whereat the issua of tha _‘ Commillee's approval of the Respondent's new monitor/supervisor shall be 13 rE in hee ete 44) 3) A ed ACY LOGAL Mic M Qow tas aes reid a. TOLLING PROVISIONS. In the event the Respondent 1 Jeaves the State of Florida for a period of thiy days or more or otherwise does not” 27" engage In the active practice of medicine in the State of Florida, then certain (+ provisions of Respondents probation (and only those provisions of the probation) | shall be tolled as enumerated below and shall remein in @ tolled stats, until - “ Baa ae a lente: rae Respondeht retums to active practice in the State of Florida: . . i. The time period of probation shall be tolled: - “AL- The provisions regarding supervision whether | “direc on Indirect by another physician and required reports from. the ; monttor/suparvisor shall ba tolled, afl cea the denen Sne aece then Le Ste Sbve ron re eat canara oh ii, The provisions regarding preparation of " sinvestigative reports detalling compliance with this Stipulation shall be tolled, | lv. Any provisions regarding community sérvicn | fate edh Lainie dane ere b. wee Tew ACTIVE PRACTICE. In the event that Respondent ' rc ’ . leaves the active practice of medkine for a period of one year or more, the i ; ‘ Probation. Cammittee may require Respondent to appear before the Probation ! 4 we «Committe and demonstrate his abilty to practice medicine with sill and safety to. | * 4 : -patlents prior to resuming the practice of medicine in this State, \ . : iM = 7 1 ANF a TOTAL P.16 STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH BOARD OF MEDICINE DEPUTY CLERK CLERK Veh kh. Keron DEPARTMENT OF HEALTH, clo Petitioner, pare_Y [te Joz v. DOAH Case No. 01-4928PL DOH Case No. 1999-50180 ROBERT VARNER SIEGEL, M.D., Respondent. ee | NOTICE OF SCRIVENER’S ERROR Notice is hereby given that a scrivener’s error appears on the first page of the Administrative Complaint in this case. The reference in paragraph 3 states that the Respondent is board-certified in psychiatry and neurology. It should read, “The Respondent is not board certified.” Attached hereto is the corrected page for substitution. The parties have discussed the matter herein and agreed that a correction would be submitted. ~ Respectfully submitted, athryn E. Price/Fla. Bar. No. 850860 Attorney for Petitioner Agency for Health Care Administration Practitioner Regulation Legal Medical Building #2, Mail Stop Code 39A P.O, Box 14229 . Tallahassee, FL 32317-4229 Tel: (850) 414-8126 CERTIFICATE OF SERVICE Thereby certify that a true copy of the foregoing was served by facsimile and regular U.S. mail on Rogelio Fontela, Dennis & Bowman, Martin, Jackson & Fontela, 2367 Centerville Road, Post Office Box 15589, Tallahassee, Florida 32317-5589, this DYfaay of 2002. STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Petitioner, v. DOH CASE NO: 99-50180 ROBERT VARNER SIEGEL, M.D., Respondent. —SSSSSSSSSSSSSSSSSSSSSSSS ADMINISTRATIVE COMPLAINT NOW COMES Petitioner, the Department of Health, by ‘and through the Agency for Health Care Administration, and for its Complaint against Dr. Robert Siegel, states as follows: PARTIES 1. The Department of Health is the state agency charged with regulating the practice of medicine under Florida Law. 2. The Respondent, whose last known address is 345 Miracle Strip Parkway S.W., Ft. Walton Beach, Florida 32548, is an individual who is licensed to practice medicine in the State of Florida, having been issued license number ME 0040663 in 1962. 3. The Respondent is not board-certified. GENERAL ALLEGATIONS 4, At all times material to this Complaint, the Respondent was a licensed medical physician within the State of Florida. 5. _ From about January 5, 1998 through about June 4, 1998, the Respondent treated Patient CY, a 37-year-old male, for. complaints including neck pain, back pain, stress, and narcotic withdrawal. “6. Beginning on or about January 5, 1998, and through about June 4, 1998, | the Respondent prescribed 1,360 Percocet pills to Patient C.Y., as follows: DATE pRUG © AMOUNT’ (A)__January 5, 1998 __ Percocet __ 60 pills (B)__January 12, 4998 Percocet 60 pills (C)___ January 15, 1998 Percocet 60 pills (D)__ January 26, 1998 Percocet 60 pills (E) February 3, 1998 _Percocet 20 pills February 6, 1998 ercocet__ 30 pills (G)__February 21, 1998 Percocet __ 40 pills (H)__ March 4, 1998 Percocet___40 pills (D)__March 23, 1998 Percocet 60 pills (J)__March 30, 1998 Percocet _-60 pills April 2, 1998 Percocet 60 pills April 8, 1998__ Percocet 69 pills ™ : wD April 15, 1998. Percocet’_60 pills (N)__April 17; 1998 ’ ‘Bercocet__ 60 pills (0) _Aprit 21, 1998 Percocet 60 pills (P)_Apiil 23. 1998 __ Percocet__60 pills (Q) April 27, 1998 Percocet 60 pills (R)_May 1, 1998 percocet___ 60 pills | 001 , John 0. Agwunobl, M.D. . Secretary, Department of Heal ° NANCY M. SNURKOWSII Chief Attorney, Practitioner eguiation COUNSEL FOR DEPARTMENT: , Shirley J. Whitsitt, FLA. Bar No. 40525 . FILED- CALTH - 2727 Mahan Dr., Mallstop 39-A DEPARTMENT one ' Tallahassee, Florida 32308 . PCP: November 9, 2001 PCP Members: Ashkar, Glotfelty & Rodriguez 15

Docket for Case No: 01-004928PL

Issue Date	Proceedings
Aug. 16, 2002	Final Order filed.
Mar. 15, 2002	Order Closing File issued. CASE CLOSED.
Mar. 14, 2002	Motion to Relinquish Jurisdiction (filed by Petitioner via facsimile).
Feb. 25, 2002	Joint Medical Records Stipulation (filed via facsimile).
Feb. 19, 2002	Respondent, Robert Varner Siegel, M.D.`s, Notice of Propounding Expert Witness Interrogatories to Petitioner filed.
Feb. 13, 2002	Respondent`s Notice of Service of Unverified Answers to Petitioner`s First Set of Interrogatories filed.
Feb. 13, 2002	Respondent`s Responses to Petitioner`s Request for Admissions filed.
Feb. 13, 2002	Respondent`s Responses to Petitioner`s Request for Production of Documents filed.
Jan. 14, 2002	Notice of Appearance (filed by Respondent).
Jan. 11, 2002	Order of Pre-hearing Instructions issued.
Jan. 11, 2002	Notice of Hearing issued (hearing set for March 18 through 22, 2002; 10:00 a.m.; Shalimar, FL).
Jan. 10, 2002	Amended Joint Response to Initial Order (filed via facsimile).
Jan. 07, 2002	Joint Response to Initial Order (filed via facsimile).
Jan. 04, 2002	Petitioner`s First Interrogatories to Respondent filed.
Jan. 04, 2002	Petitioner`s First Request for Production of Documents to Respondent Siegel filed.
Jan. 04, 2002	Notice of Serving First Interrogatories filed by Petitioner.
Jan. 04, 2002	Petitioner`s First Request for Admissions to Respondent filed.
Dec. 31, 2001	Initial Order issued.
Dec. 28, 2001	Notice of Appearance (filed by K. Price via facsimile).
Dec. 28, 2001	Administrative Complaint (filed via facsimile).
Dec. 28, 2001	Election of Rights (filed via facsimile).
Dec. 28, 2001	Agency referral (filed via facsimile).