STATE OF FLORIDA . DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION” =" BOARD OF FUNERAL DIRECTORS AND EMBALMERS ? Jit ot . ae ; il Ig 3 DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, BOARD OF FUNERAL DIRECTORS AND EMBALMERS, “Ay Petitioner, O a O (02h C. vs. DBPR Case Number: 2001-03159 JOSEPH G. QUINN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION (‘Petitioner”) files this Administrative Complaint before the Board of Funeral Directors and Embalmers (“Board”) against JOSEPH G. QUINN (“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 as a funeral director and embalmer in the State of Florida, having been issued license number FE-0003950. 3. Respondent’s address of record is 1551 Northeast 40th Street, Fort Lauderdale, Florida 33334. 4. Respondent is a licensed funeral director for Lynn University. 5. In or around December 2000, Respondent embalmed the body of Ruth Field for which was received from Professional Transport Service. 6. Respondent did not receive the aforementioned body from a licensed funeral establishment. 7. The paperwork confirming the legally indigent status of the aforementioned body was substantially incomplete, including: a. Funeral home is not identified. b. Signature of removal service is illegible. c. Signature of funeral home is blank and undated, d. Respondent’s signature is undated. COUNT I 8. Petitioner realleges and incorporates the allegations set forth in paragraphs one _ through seven, as thongh fully set forth herein. 9, Section 470.036(1)(g), Florida Statutes, provides that fraud, deceit, negligence, incompetence, or misconduct constitute grounds for which disciplinary action may be taken. 10. Based on the foregoing, Respondent committed acts for which disciplinary action may be taken pursuant to Section 470.036(1)(g), Florida Statutes, COUNT I 11. Petitioner realleges and incorporates the allegations set forth in paragraphs one through seven, as though fully set forth herein, 12. Section 470.036( 1)(t), Florida Statutes, states in pertinent part that embalming a deceased human body without first having obtained written or oral permission from a legally authorized person constitutes grounds for disciplinary action. 13. Based upon the foregoing, Respondent has violated Section 470,036(1){t), Florida Statutes, by embalming Ruth Field’s body based solely on the substantially incomplete authorization release form. WHEREFORE, Petitioner respectfully requests the Board of Funeral Directors and Embalmers 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 $5,000 per violation, issuance of a reprimand, placement of the Respondent on probation, assessment of costs association with the investigation, 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. “ze Signed this [0 ~ day of Chief Professions Attorney Florida Bar Number 909289 COUNSEL FOR DEPARTMENT: Laura P, Gaffney Fk \ L E D Assistant General Counsel and Florida Bar Number 437867 at of BUSES CLERK Depa Department of Business and DEPUTY Professional Regulation 1940 North Monroe Street Ppardn . Tallahassee, Florida 32399-2202 CLERK - { | - 2002 (850) 414-8128 DATE GSH:LPG/kms poe 4 AYO

Docket for Case No: 03-000602PL