Jul 28 2005 10:45 JUL-28-2885 18:58 ATTY GEN OFC 856-922-6425 P.a4 a _~ STATE OF FLORIDA aon BUREAU OF EMERGENCY MEDICAL SERVICES 2 fii% -5 ANIC: 3] DEPARTMENT OF HEALTH, Petitioner, vs. F Case No. 2003-0073 3 oi Christopher Bleam, , RECEIVED z , : : Respondent. vit MAY 06 2005 / DEPT. OF LEGAL AFFAIRG Adminisirativie Law Seation ADMINISTRATIVE COMPLAINT COMES NOW Petitioner, Department of Health, (hereinafter “Petitioner’) bs and through its undersigned attorneys and files its Administrative Complaint against “ Respondent, Christopher Bleam, (hereinafter “Respondent’) and alleges: NATURE OF THE ACTION 1. This ig an action to impose administrative penalties and assess costs related to the investigation and prosecution of the allegations against Respondent pursuant to Section 401.411(1)(b),(e),and (f), Florida Statutes, Florida Statutes. JURISDICTION AND VENUE 2. This tribunal has jurisdiction pursuant to Sections 120.569 and 120.57, J : Florida Statutes. 3. Venue shall be determined pursuant to Rule 28-106.207, Florida Adrninistrative Code. JUL-28-2085 10:58 ATTY GEN OFC 8S@-922-6425 P.a5 Jul 28 2005 10:47 oo PARTIES 4. Petitioner is the state agency charged with regulating emergency medical services pursuant to Section 20.43, Florida Statutes, and Chapters 120 and 401, Florida Statutes. 5. At all times material hereto Respondent has been licensed as a emergecny medical technician, having been issued license number 84125 on July 7, 1997. 6. Respondent's last known address is 22 Almond Pass Drive, Ocala, Florida 7 : 34472. GOUNTI 7. The Respondent was convicted of a felony, Shooting at, within or into a 7 Building on December 27, 1995. | 8. On May 23, 1997, the Respondent signed an application under oath for certification after checking on the application that he did not have a felony conviction. 9. The Respondent violated section 401.411(1)(f), Florida Statutes, by procuring a certificate by fakery, fraudulent action or misrepresentation when he signed his application under oath after improperly checking his application that he did not have a felony on May 23, 1997. mo : | COUNT 2 40. On or about January 29, 2003, the Respondent entered a plea of nolo a contendere to the charge of Witness Tampering-Threat/Intimidate/Force. 441. On or about January 29, 2003, the Respondent violated section 401.411(1)(b), Florida Statutes, by pleading nolo contendere to a crime that relates to Jul 28 2005 10:47 JUL-28-2085 16:51 ATTY GEN OFC 856-922-6425 P.@6 _ rN , : practice as an EMT, as an EMT must respond to the scene of emergencies and render aid in the course of his employment. CLAIM FOR RELIEF WHEREFORE, Petitioner respectfully requests the BUREAU OF EMS 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; e 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. vt Dated this 23 day of Lila, 2005. Respectfully submitted, CHARLES J. CRIST, JR. Attorney General I Daniel Biggins Assistant Attorney General Department of Legal Affairs PL-01 The Capitol Tallahassee, Florida 32399-1050 (850) 414-3300 PCP: Bixler, Jenkins, and Mason DATE: April 22, 2005 Jul 28 2005 10:47 JUL-26-2085 18151 ATTY GEN OFC 858-922-5425 P.a? on g™ NOTICE OF HEARING RIGHTS RESPONDENT IS HEREBY NOTIFIED THAT HE/SHE HAS THE RIGHT TO : REQUEST AN ADMINISTRATIVE HEARING PURSUANT TO SECTIONS 120.569 AND Se 120.57, FLORIDA STATUTES. SPECIFIC OPTIONS FOR ADMINISTRATIVE ACTION mt ARE SET OUT IN THE ATTACHED EXPLANATION OF RIGHTS. ALL REQUESTS FOR a HEARING MUST BE MADE WITHIN 21 DAYS OF RECEIPT AND SENT TO DANIEL ve BIGGINS, ASSISTANT ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, PL-01 THE CAPITOL, TALLAHASSEE, FLORIDA 32399-1050. ERTIFIGATE OF SERVICE | HEREBY CERTIFY that a true and correct copy has been served by certified a a mail this 3 day of (Teg , 2005 to ; Christopher Bleam, 22 Almond Pass ey Drive, Ocala, Florida 34472. KE tea” Daniel Biggins - Assistant Attorney General

Docket for Case No: 05-002742PL