STATE OF FLORIDA ory DEPARTMENT OF HEALTH Qe My & 1) DEPARTMENT OF HEALTH, Dp /0 by “Oh Sly 4: 46 PETITIONER, Sat Op ‘ as Ve vs. CASE NUMBER: 2000-01998 RICHARD ODOM, D.M.D. RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as "Petitioner", and files this Administrative Complaint before the Board of Dentistry against, Richard Odom, D.M.D, referred to as "Respondent", and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of Dentistry pursuant to Section 20.43, Florida Statutes, Chapter 456, Florida Statutes, (formerly Chapter 455, Part II; see Chapter 2000-160, Laws of Florida), and Chapter 466, Florida Statutes. Pursuant to Section 20.43(3)(g), Florida Statutes, the Department 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. 2. Respondent is, and has been at all times material hereto, a licensed dentist in the State of Florida, having been issued license number DN 0005855. Respondent's last known address is 5001 SW 20" Street, Apt. #303, Ocala, Florida 34474, 3. On or about February 24, 1998, Patient D.T. presented to the Respondent for dental treatment, which consisted of, but was not limited to, the extraction of fifteen (15) of Patient D.T’s teeth as well as a fitting for dentures. Respondent did not take a complete series of x-rays of Patient D.T’s teeth. . 4. From on or about March 28, 1998, Patient D.T. went to a subsequent dentist at the American Denture Clinic for repair of her dentures because it was cracked. 5. On or about August 20, 1998, Patient D.T. presented to the subsequent dentist who examined Patient D.T’s mouth and determined that Patient D.T. needed alveoloplasty surgery. However, Patient D.T. decided to postpone the alveoloplasty surgery. 6. * According to Department Expert, Respondent failed to meet the minimum standards of performance in his treatment of Patient D.T. by extracting fifteen (15) of Patient D.T’s teeth and inserting of an immediate denture without taking a complete series of x-rays. 7. According to the Department Expert, Respondent also failed to keep one or more of the following for Patient D.T.: a patient history, examination results, test results, and x-rays. COUNT ONE 8. Petitioner realleges and incorporates paragraphs one (1) through seven (7) as if fully set forth herein this Count One. 9. Respondent failed to meet the minimum standards of performance in his treatment of Patient D.T. by extracting fifteen (15) of Patient D.T’s teeth and inserting of an immediate denture without a complete series of x-rays. 10. Based on the foregoing, Respondent violated Section 466.028(1)(x), Florida Statutes, Florida Statutes, being guilty of incompetence or negligence by failing to meet the minimum standards of performance in diagnosis and treatment when measured against generally prevailing peer performance, including, but not limited to, the undertaking of diagnosis and treatment for which the dentist is not qualified by training or experience or being guilty of dental malpractice. COUNT TWO 11. Petitioner realleges and incorporates paragraphs one (1) through seven (7) and nine (9) as if fully set forth herein this Count Two. 12: Respondent failed to keep written dental records consisting of one or more of the following for Patient D.T.: a patient history, examination results, test results, and x-rays. 13. Based on the foregoing, Respondent violated Section 466.028(1)(m), Florida Statutes, Florida Statutes, failing to keep written dental records and medical history justifying the course of treatment of the patient including, but not limited to, patient histories, examination results, test results, and x-rays, if taken. WHEREFORE, Petitioner respectfully requests the Board of Dentistry 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 and costs, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this OMA cay oF ule , 2001. Robert G. Brooks, M.D. Secretary, Department of Health BY: ancy M. Snurkowski Chief Attorney Agency for Health Care Administration COUNSEL FOR AGENCY gPaula Milam, Senior Attorney Bar # 0135925 Agency for Health Care Administration Practitioner Regulation Fi LED A J DEPARTMENT OF HEALTEY: P. 0. Box 14229, Mail Stop 39 Tallahassee, Florida 32317-4229 aaa, ‘4; yh (850) 488-0598 ouRK 2 fe DATE if Bie / PM/cab PCP: FG WR INGE DATE: =} 13101

Docket for Case No: 02-001949PL