SEP-26-2085 11:51 SHCA-LEGAL MEDICAL Sep 26 2005 ~ ASA 414 1989 P5728 STATE OF FLORIDA DEPARTMENT OF HEALTH "DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2004-39235 CARLOS J. GONZALEZ, M.D., RESPONDENT. _ ADMINIST) RATIVE COMPLAINT COMES NOW Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Medicine against Respondent, Carlos 3, Gonzalez, M.D., and in support thereof alleges: 4, Petitioner is the state department charged with regulating the practice of medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 458, Florida Statutes. 2. At all times material to this Complaint, Respondent was @ licensed physician within the State of Florida, having been issued license number ME 30162. SEP-26-2085 11:51 AHCA/LEGAL MEDICAL SEP 26 2000 ee can 958 414 1999 3, Respondent's address of record is 1630 11" Avenue, Sebring, Florida 33870. 4. On or about October 20, 2002, the Board of Medicine filad a Final Order in case number 2000-09888, which rejected a Consent Agreement and presented Counter Consent Agreement, which the Respondent properly accepted. The Final Order required Respondent to complete and provide documentation of completion of fifty (50) hours of community service and complete and provide documentation of completion of the Florida Medical Association ("FMA") medical records course, within one (1) year from the date of the filing of the Final Order. 5. As of April 4, 2005, Respondent has failed to complete and provide documentation of completion of fifty (50) hours of community service and complete and provide documentation of completion of the FMA medical records course. 6. Section 458.331(1)@), Florida Statutes (2004), provides that violating a lawful order of the board or department previously entered in a disciplinary hearing or failing to comply with a lawfully issued subpoena of the department constitutes grounds for discipline by the Board of Medicine. Page 7. JAUSLNMedical\blake\ACs\Gonnelez.C.2004- 1924500) doc P. 6/88 SEP-26-2005 11:52 Sep 26 2005 11:55 PUCALEGAL MEDICAL 856 414 1989 Pa? /a8 7, Respondent failed to comply with the October 20, 2003, Final Order by failing to complete and provide documentation of completion of fitty (50) hours of community service and complete and provide documentation of completion of the FMA medical records course, within the requisite time period. 8. Based on the foregoing, Respondent has violated Section 458,331(1)(x), Florida Stalutes (2004), by violating a lawful order of the Board previously entered in a disciplinary hearing. WHEREFORE, Petitioner raspectfully requests that the Board of Medicine enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement at the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. Page 3 JWSLAMedicaftblake ACs\Gonzalez.C 4-3923 5(x) doe Sep 26 2005 11:53 SEP-26- : 20a5 11:52 PRCA LEGAL MEDICAL 858 414 1989 P88 a wT. SIGNED this 24 7_ day of _, Sunt , 2005, John ©. Agwunobi, M.D., M.B.A., M.PH eC, D ent of Health Blake Hunter 7 DCPARTMENT OF WEALTH sistant General Counsel DEFIITY CLERK DOH Prosecution Services Unit CLERK \ techn Colman 4052 Bald Cypress Way, Bin C-65 fe _Z8 us Tallahassee, FL 32399-3265 pare__(27 $e Florida Bar No. 0570788 (850) 414-8126/(850) 414-1989 FAX PCP:gune 24, 2005 PCP MemberS:z1-nahri, Ondra, Dyches - Reviewed and approved by: cs initials) Y¥-4% 2S (date) NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf If a hearing is requested. NOTICE REGARDING ASSESSMENT OF cosTs Respondent Is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 456.,072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may Include attorney hours and costs, on the Respondent in addition to any other discipline imposed. Page 4 JAPSU\Mediealiblake\ A Ca\Gonzalez () 7004-39235), 000 TOTAL FP. ae

Docket for Case No: 05-003535PL