May 4 2005 14:03 MAY-24-2885 14:88 ATTY GEN OFC 858-922-6425 P.@3 STATE OF FLORIDA BUREAU OF EMERGENCY MEDICAL SERVICES DEPARTMENT OF HEALTH, Petitioner, 4 vs. Case No. 2002-0656 MICHAEL TAYLOR, p 6 “lly ore Respondent. , / ADMINISTRATIVE COMPLAINT COMES NOW Petitioner, Department of Health, (hereinafter "Petitioner’) by and through its undersigned attorneys and files its Administrative Complaint against Respondent, MICHAEL TAYLOR, (hereinafter "Respondent") and alleges: | NATURE OF THE ACTION 1, This is an action to impose administrative penalties and assess costs related to the investigation and prosecution of the allegations against Respondent pursuant to Sections 401.41 1(1)(f), (g), Florida Statutes. YURISDICTION AND VENUE 2. This tribunal has jurisdiction pursuant to Sections 120.569 and 120.57, Florida Statutes. 3. Venue shall be determined pursuant to Rule 28-106.207, Florida Administrative Code. May 4 2005 14:04 MAY-@4-2885 14:@8 ATTY GEN OFC 858-922-6425 P.04 PARTIES 4. Petitioner is the state agency charged with regulating emergency medical services pursuant to Section 20.43, Florida Statutes, and Chapters 120 and, Florida Statutes. 5. At all times material hereto Respondent has been licensed as a Paramedic having been issued license number 200760 on November 12, 2002. 6. Respondent's last known address is 1680 Myrick Road, Thomasville, GA 31792, FACTS 7. Respondent taught a paramedic course at Thomas Technical Institute, now known as Southwest Georgia Technical College. 8. The paramedic course at Thomas Technical Institute, now known as Southwest Georgia Technical College, was not approved by the State of Florida for an individual to obtain paramedic certification. 9. During the paramedic course, Respondent asked his students, William Bates, Steven R. Box, Stephen B. Thomas, and Matthew A, Williams, to fill out the top half of the Statement of Good Standing Form. Respondent told his students that if they filled out the top half of the Statement of Good Standing Form, then he would obtain the proper signature on their forms from the State of Georgia and would submit their forms to the State of Florida, Bureau of Emergency Medical Services. The Statement of Good Standing Form is needed by applicants to sit for the Florida Paramedic Examination and to obtain a Florida Paramedic certification. May 4 2005 14:04 MAY-B4-2085 14:88 ATTY GEN OFC 858-922-6425 P.@5 10. Respondent gave Bates, Box, Thomas, and Williams’ Statement of Good Standing Forms to State of Georgia, Emergency Medical Services Coordinator Robert Vick. 11. Respondent asked Robert Vick to sign the Statement of Good Standing Forms certifying that Bates, Box, Thomas, and Williams had passed the National Registry Exam and/or were certified in the State of Georgia so that they could take the State of Florida Paramedic Exam. 12. Vick told Respondent that he could not sign the Statement of Good Standing Form as Bates, Box, Thomas, and Williams had not passed the National Registry Exam and were not certified in the State of Georgia. - a 13. Respondent convinced Vick to sign the Statement of Good Standing forms by telling him that the State of Florida, Emergency Medical Services staff told him (Respondent) that Vick should sign the form so that Bates, Box, Thomas, and Williams could take the Paramedic exam and that the State of Florida would hold their exam results until they provided proof that they passed the National Registry Exam from the testing agency. 14. Vick then signed the Statement of Good Standing Forme for Bates, Box, Thomas, and Williams without entering a certification number and expiration date for Respondent. ) 15. Respondent's students, Bates, Box, Thomas, and Williams, completed their Florida applications for examination and certification as paramedics and submitted their applications to the State of Florida, Bureau of Emergency Medical Services. May 4 2005 14:04 MAY-24-2085 14:a8 ATTY GEN OFC 858-922-6425 P.@6 46. In Part | of the Statement of Good Standing Form submitted by Respondent's students with their Florida applications for examination and certification as paramedics, Respondent's students stated that they were requesting Florida certification based on their training and current certification in the State of Georgia or by National Registry of EMTs. 7 4 17, Part ll, A of the Statement of Good Standing Form signed and submitted by an Respondent's students with their Florida applications for examination and certification as paramedics certified that Respondent's students held current and valid paramedic certificates in the State of Georgia and/or the National Registry of EMTs. 18. Respondent's students, Box, Bates, Thomas, and Williams, signed their entire applications, including the Statement of Good Standing Forms, to become Florida certified paramedics under oath on or about December 5, 2000. The oaths signed by Respondent's students stated that the applicants “understand that any fraudulent entry may be considered as cause for rejection or subsequent voiding of certification." 19. When Respondent's students Bates, Box, Thomas, and Williams signed their entire applications under oath, including the Statement of Good Standing Form, they were not certified in the State of Georgia as paramedics. 20. When Respondent's students Bates, Box, Thomas, and Williams signed their entire applications under oath, including the Statement of Good Standing Form, they had not passed the National Registry examination. 21. Some of Respondent's students took and passed the Florida paramedic examination. May 4 2005 14:05 MAY-~@4-2885 14:89 ATTY GEN OFC 85@-922-6425 P.87 22. As a result of the information provided by Respondent on his students’ licensure applications, Respondent aided his unqualified students, Bates, Box, Thomas, . %, and Williams, obtain Florida paramedic certificates. COUNTI 23. Petitioner re-alleges and incorporates by reference paragraphs one (1) through twenty-two (22). 24. Section 401.411(1)(f of the Florida Statutes provides that the “department may deny, suspend, or revoke a license, certificate, or permit or may reprimand or fine y : any licensee, certificateholder, or other person operating under this part for any of the : following grounds: Knowingly making false or fraudulent claims; procuring, attempting to procure, or renewing a certificate, license or permit by fakery, fraudulent action, or misrepresentation.” § 401.411(1)(f), Fla. Stat. 25. Respondent violated Section 401.411(1)(f) of the Florida Statutes as he attempted to procure paramedic certifications for his students, Bates, Box, Thomas, and Williams, by fakery, fraudulent action, or misrepresentation by making false or fraudulent claims on his students’ licensure applications by persuading Georgia EMS Coordinator Robert Vick to certify on Florida Statements of Good Standing Forms that Bates, Box, Thomas, and Williams, were certified paramedics in the State of Georgia and/or passed the National Registry Examination when at the time of their applications they were not certified paramedics in the State of Georgia and had not passed the National Registry Examination; therefore, Respondent's license is subject to discipline by this Bureau. May 4 2005 14:05 MAY-@4-2085 14:09 ATTY GEN OFC 858-922-6425 P.@8 COUNT It 26. Petitioner re-alleges and incorporates by reference paragraphs one (1) through twenty-five (25). 27. Section 401.411(1)(g) of the Florida Statutes provides that the “department may deny, suspend, or revoke a license, certificate, or permit or may reprimand or fine any licensee, certificateholder, or other person operating under this part for any of the following grounds: Unprofessional conduct, including, but not limited to, any departure from or failure to conform to the minimal prevailing standards of acceptable practice as an emergency medical technician or paramedic, including undertaking activities that the emergency medical technician or paramedic is not qualified by training or experience to perform. 28. Respondent violated Section 401.411(1)(g) of the Florida Statutes by engaging in unprofessional conduct when he attempted to procure paramedic certifications for his students, Bates, Box, Thomas, and Williams, by fakery, fraudulent action, or misrepresentation by making false or fraudulent claims on his students’ licensure applications by persuading Georgia EMS Coordinator Robert Vick to certify on Florida Statements of Good Standing Forms that Bates, Box, Thomas, and Williams, were certified paramedics in the State of Georgia and/or passed the National Registry Examination when at the time of their applications they were not certified paramedics in the State of Georgia and had not passed the National Registry Examination; therefore, Respondent's license is subject to discipline by this Bureau. May 4 2005 14:05 MAY-@4-2885 14:@9 ATTY GEN OFC 85@-922-6425 P.89 CLAIM FOR RELIEF WHEREFORE, Petitioner respectfully requests the BUREAU OF EMERGENCY MEDICAL SERVICES to enter an order imposing one or more of the following penalties upon Respondent pursuant to Section 401.411(1), Florida Statutes: a. Revocation or suspension of Respondent's license; b. Restriction of Respondent's practice; c. An administrative fine; d. A reprimand; e. Probation; and/or f. Any other penalty the Bureau deems appropriate. Dated this LL bay of | Las ch , 2005. Respectfully submitted, ” CHARLES J. CRIST, JR. Attorney General Brian J. Stabley © “~~ cok Assistant Attorney General Department of Legal Affairs PL-01 The Capitol Tallahassee, Florida 32399-1050 (850) 414-3300 PCP: Jenkins, Bixler, and Mason DATE: February 25, 2005 NOTICE OF HEARING RIGHTS RESPONDENT !S HEREBY NOTIFIED THAT HE/SHE HAS THE RIGHT TO REQUEST AN ADMINISTRATIVE HEARING PURSUANT TO SECTIONS 120.569 AND 120.57, FLORIDA STATUTES. SPECIFIC OPTIONS FOR ADMINISTRATIVE ACTION May 4 2005 14:06 MAY-@4-2085 14:18 ATTY GEN OFC 85@-922-6425, . Fi ARE SET OUT IN THE ATTACHED EXPLANATION OF RIGHTS. ALL REQUESTS FOR HEARING MUST BE MADE WITHIN 24 DAYS OF RECEIPT AND SENT TO BRIAN J. STABLEY, ASSISTANT ATTORNEY GENERAL, DEPARTMENT OF LE'GAL AFFAIRS, PL-01 THE CAPITOL, TALLAHASSEE, FLORIDA 32399-1050. CERTIFICATE OF SERVICE mu | HEREBY CERTIFY that a true and correct copy has been served by certified 7 mail this x day of VE, ch , 2005 to : Michael Taylor, 1680 Myrick Road, Thomasville, GA 31792. ia (lee Brian J. Stabley Assistant Attorney General

Docket for Case No: 05-001605PL