J _Lb-bbe fe -- STATE OF FLORIDA P Division of Administrative Hearings | DEPARTMENT OF BUSINESS AND PROFES stolaL REGULATION, i j to BOARD OF VETERINARY MEDIC INE | 4 r i E | PROFESSIONAL REQULAON 4 2-19-02 3 ‘ ie ; Petitioner, : Vv. a Case No. 2001-04175 “ROMANSWIEZY.DVM, ee Respondent. . ADMINISTRATIVE COMPLAINT — Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioner"), files this Administrative Complaint before the Board of Veterinary Medicine against ROMAN SWIEZY, D.V.M. ("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. K 72. At all times material hereto, Respondent was licensed in the State of Florida as an veterinarian, license number VM 0000427. ~ . . 3. Respondent's address of record is 801 Tilton Road, Port St. Lucie, Florida 34952. 4. At all times material hereto, Respondent owned, operated, and was the veterinarian responsible for A Hospital for Animals. 5. Respondent does not have an accurate controlled substance log for A Hospital for Animals. . 6. Respondent does not have a locked secure cabinet for the controlled substances at A Hospital for Animals. . See SRE ten eee pe eee CTEM TEE rR nee oo Speers teers = wees a ed ee a a cae nd ti a 7. Respondent does not have a segregated area for the storage of expired drugs at A Hospital for Animals. 8. Section 474.214(1)(f), Florida Statutes, states that violating any provision of this chapter or a rule of the board or department constitutes grounds for which disciplinary action may be taken. - COUNT I . 9 Petitioner realleges and incorporates paragraphs one through eight as though fully set forth herein. . 10. Rule 61G1 8-15,002(2)(a)S.c., Florida Administrative Code, requires each premises where veterinary medicine is practiced to maintain an accurate.controlled substance log. . 11. Based on the foregoing, Respondent has violated Section 474.214(1)(, Florida Statutes, by failing to comply with Rule 61G18-15.002(2)(a)5.c., Florida Administrative Code. COUNT . 12. Petitioner realleges and incorporates paragraphs one through eight as though fully set forth herein. : 13. Rule 61G18-15.002(2)(a)5.d., Florida Administrative Code, requires each premises * where ‘Veterinary 1 medicine i is practiced to havea locking. secure cabinet | for storage of ‘controlied substances. 14. Based on the foregoing, Respondent has violated Section 474.214(1)(D, Florida Statutes, by failing to comply with Rule 61G18-15.002(2)(a)5.d., Florida Administrative Code. COUNT 15. Petitioner realleges and incorporates paragraphs one through eight as though filly set forth herein. 16. Rule 61G18-15.002(2)(a)5.£, Florida Administrative Code, requires each premises where veterinary medicine is practiced to have a segregated area for the storage of expired drugs. SOR TERE eam ene ea a ee eee Prem remo i i i. i ee el ae tee 2 $5, ‘000 per ‘violation, i issuance of: a reprimand, placement of the Respondent on 1 probatio 17. Based on the foregoing, Respondent has violated Section 474.214( 1)(O, Florida Statutes, by failing to comply with Rule 61G18-15.002(2)(a)5.f,, Florida Administrative Code. - 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 nt of costs association with the investigation, imposition of any or all penalties delineated within 1 Section 455,227(2), Florida Statutes, and/or any other relief that the Board i is authorized to impose pursuant to Chapters 455 and/or 474, Florida Statutes, and/or the rules promulgated thereunder. ; Signed this [ye day of 200L Lead Professions Attorney Counsel for the Department: > _Tiffany A. Short F i] D : ~ Assistant General C6unsel : 3 snes and Professional Regulation usi Florida Bar Number 505994 Department of DEPUTY CLERK Department of Business and Professional Regulation WM: Office of the General Counsel Bnaedn 1940 North Monroe Street CLERK A002. Tallahassee, FL, 32399-2202 . TE: DA TAS/ar Case #2001-04175 PCP: t/y/o3 Forse Blawkrahip + Kestto “gree oor CREE FE STEER ore ca OR ree meee ergs oe bolt AR di

Docket for Case No: 02-000666PL