Jan 13 2006 15:22 DEPR OGA PAGE 83/06 @1/13/2886 15:16 8584146749 STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, v. Case No. 2005-059473 SCOTT DOUGLAS REED, D.V.M., Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioncr") files this Administrative Complaint before the Board of Veterinary Medicine against SCOTT DOUGLAS REED, DVM, ("Respondent"), and alleges: 1. Petitioner is the state agency charged with re gulating the practice of veterinary medicine, pursuant to section 20.165, Florida Statutes, and chapters 455 and 474, Florida Statutes. 2. At all times material hereto, Respondent was licensed in the State of Florida as a veterinarian, having been issued license number VM $714. 3. Respondent's address of record is 14 Swimming Pen Drive, Middleburg, Florida 32068. 4, On October 22, 2005, Respondent was presented with “Neo” a fourty-six pound male mix-breed dog for examination and health maintenance. 61/13/2686 15:16 8584146749 DEPR OGA Jan 13 2006 15:22 PAGE 84/86 5. During the October 22, 2005 visit, Neo became nervous and slightly frightened as Respondent’s staff attempted to take a blood sample. 6. In order to take the blood sample from Neo, Respondent determined that a sedative should be administered to Neo. 7. During the attempted sedation of Neo, Respondent grabbed Neo by his leash and hung him in the air causing the dog to defecate and urinate on himself. 8. The dog was able to get free from Respondent and subsequently bit Respondent. 9. After Respondent was bitten, Respondent grabbed the dog’s leash and suspended the dog in the air by his collar and leash, 10. Respondent repeatedly kicked “Neo” while he suspended the dog in the air by his collar and leash. 11. Respondent’s physical violence toward “Neo” constitutes misconduct in the practice of veterinary medicine. 12. Section 474.214(1)(0), Florida Statutes, states the following shall constitute grounds for disciplinary action “[f}raud, deceit, negligence, incompetency, or misconduct, in or related to the practice of veterinary medicine.” 13. Based on the foregoing, Respondent violated section 474.214(1)(0), Florida Statutes, by committing misconduct by usin § excessive force and violence toward a patient, Neo. Respondent is therefore subject to discipline by the Board of Veterinary Medicine pursuant to sections 474,214(1)(o) and (2), Florida Statutes, WHEREFORE, Petitioner respectfully requests the Board of Veterinary Medicine enter an order imposing one or more of the following penalties: revocation or suspension of the Jan 13 2006 15:23 DEPR OGA PAGE 85/86 @1/13/2886 15:16 8584146749 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 474, Florida Statutes, and/or the tules promulgated thereunder. Signed this 4 day of _Femaee__, 2005. 7 rew F. Winters Assistant General Counsel Case # 2005-0 59473 Counsel for the Department: F | E p Drew F. Winters Department of Business ond Professional Regulation Assistant General Counsel AGENCY CLERK Florida Bar Number 0679941 Department of Business and Professional Regulation CLERK , Office of the General Counsel Seams 2. Wetn on 1940 North Monroe Strect pate_f t+ 1/9 - 2005 Tallahassee, FL 32399-2202 DFW/Ich 9 December 2005 Pep acta 9-le-OS

Docket for Case No: 06-000166PL