DA-~AGBI Pe STATE OF FLORIDA a DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION 5 py BOARD OF FUNERAL DIRECTORS AND EMBALMBBS), _* a 23 DEPARTMENT OF BUSINESS AND , PH 1:59 PROFESSIONAL REGULATION, he “ao Petitioner, vs. DBPR Case Number: 2001-08463 LAWRENCE MICHAEL LOMBARDI, Respondent. ADMINISTRATIVE COMPLAINT. Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION (hereinafter “Petitioner”), files this Administrative Complaint before the Board of Funeral Directors and Embalmers (hereinafter “Board”) against LAWRENCE MICHAEL LOMBARDI, (hereinafter “Respondent”), and alleges: 1. Petitioner is the state agency charged with regulating the practice of funeral directing and embalming, pursuant to section 20.165, Florida Statutes, and chapters 455 and 470, Florida Statutes. | 2. At all times material hereto, Respondent was licensed in the State of Florida as a funeral embalmer, license number EM 0003144. 3. Respondent’s address of record is United State Prison - Allenwood, Post Office Box 3500, White Deer, Pennsylvania 17887. 4. On or about September 2001, Respondent was convicted and sentenced to life imprisonment for planting explosives on the Florida A. & M. University (FAMU) campus. 1 of 3 GAOGC Funeral Board\ACs\Lombardi 2001-08463 AC rev eci.doc 5. Section 470.036(1)(d), Florida Statutes, states that being convicted or found guilty of acrime in any jurisdiction which directly relates to the practice of, or the ability to practice, any of the activities regulated under chapter 470, Florida Statutes, constitutes grounds for disciplinary action. 6. Based upon the foregoing and pursuant to section 470.036(1)(d), Florida Statutes, Respondent is subject to disciplinary action for being convicted and being found guilty of planting explosives on the FAMU campus. WHEREFORE, Petitioner respectfully requests the Board enter an order imposing one or more of the following penalties: revocation or suspension of Respondent's license, imposition of an administrative fine not to exceed five thousand dollars ($5,000.00) for each count or separate offense, issuance of a reprimand, placement of Respondent on probation, restriction of Respondent’s authorized scope of practice, assessment of costs associated with investigation and prosecution, 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 470, Florida Statutes, and/or the rules promulgated thereunder. Signed this ZZ 4_ day of ee 2002. GaifSqott-Hill Chief Professions Attorney Florida Bar Number 0909289 COUNSEL FOR DEPARTMENT: Ff | L E D CHARLES F. TUNNICLIFF @ a of Business and Professional Regulation Florida Bar Number 0153831 Dea OE PUTY CLERK Department of Business and , ; Professional Regulation {2 L iV, Suidelt CLERK 2of3 -28-200, GAOGC\Funeral Board\ACs\Lombardi 2001-08463 AC rev eci.doc DATE - d 2f>tpa PO ew 1940 North Monroe Street Tallahassee, FL 32399-2022 Tel. (850) 487-9656 Fax (850) 414-6749 GSH:CFT/kms:eci PCP: 2/21/02, JD, JR, and ABC 3 of 3 GAOGC\Funeral Board\ACs\Lombardi 2001-08463 AC rev eci.doc

Docket for Case No: 02-002931PL