BA/98 Spd STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, Vv. Case No. 2005-000682 DAVID J. BRYANT, DVM, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioner"), files this Administrative Complaint before the Board of Veterinary Medicine against DAVID J. BRYANT, DVM, ("Respondent"), and alleges: 1 Petitioner is the state agency charged with regulating 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 6323. 3, At all times material hereto, Respondent was licensed to practice as a veterinarian on on racing and waggering facilities regulated by the State of New York Racing and Wappering Board, having been issues license number 1289852-2005. 4. Respondent's address of record is P.O. Box 7228, Garden City, New York 11530. YOO sddd Bp29P Tress BP eT 9bae/Pe/ce BRST 900 Fe a4 5. On or about October 21, 2004, the State of New York Racing and Wagering Board entered NOTICE OF SUSPENSION, REVOCATION, AND/OR FINE number 04-67 against Respondent’s State of New York Racing and Wagering license. 6. The State of New York Racing and Wagering Board fined Respondent $250.00 for failing to keep proper medical records per rule of the Board. 7. The Responded did not report the discipline entered against his State af New York Racing and Wagering veterinary license to the Florida Board of Veterinary Medicine. COUNT ONE 8. Petitioner realleges and incorporates the allegations set forth in paragraphs one (1) through six (6) as though set forth herein. 9. Section 474.214(1)(b), Florida Statutes, states the following shall constitute grounds for disciplinary action “[h]aving a license or the authority to practice veterinary medicine revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of any jurisdiction, including any agency or subdivision thereof. The licensing authority's acceptance of a veterinarian's relinquishment of a license, stipulation, consent order, or other settlement, offered in response to or in anticipation of the filing of administrative charges against the veterinarian's license or authority: to practice, shall be constiued as action against the veterinarian's license or authority to practice.” 10. Based on the foregoing, Respondent violated section 474.214(1)(b), Florida Statutes, by having his license suspended by the State of New York Racing and Wagering Board. Respondent is therefore subject to discipline by the Board of Veterinary Medicine pursuant to section 474.214(1)(b) and (2), Florida Statutes. COUNT TWO YOO sddd Bp29P Tress BP eT 9bae/Pe/ce BRST 900 Fe a4 Ba/éB Sod 10. Petitioner realleges and incorporates the allegations set forth in paragraphs one (1) through six (6) as though set forth herein. 11. Section 474.214(1)Gj), Florida Statutes, states the following shall constitute grounds for disciplinary action “(flailing to report to the board within 30 days, in writing, any action set forth im paragraph (b) that has been taken against the practitioner's license to practice veterinary medicine by any jurisdiction, including any agency or subdivision thereof.” 12. Based on the foregoing, Respondent violated section 474.214(1)(j), Florida Statutes, by failing to report the actions taken by the State of New York Racing and Wagering Board against his license. Respondent is therefore subject to discipline by the Board of Veterinary Medicine pursuant to sections 474.214(1)(j) 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 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 rules promulgated thereunder. Signed this a day of aneres , 2005, FILED Department of Business and Professional Regulation EEE AGENCY CLERK Assistant General Counsel Case # 2005-000682 CK Soils Ae Wescott omy DATE Ba/88 Sod YOO sddd Bp29P Tress BP eT 9bae/Pe/ce BRST 900 Fe a4 Counsel for the Department: Drew F. Winters Assistant General Counsel Florida Bar Number 0679941 Department of Business and Professional Regulation Office of the General Counsel 1940 North Monroe Street Tallahassee, FL 32399-2202 DFWietr 7 March 2005 PCP date - b-B84-85 YOO sddd Bp29P Tress BP eT 9bae/Pe/ce BRST 900 Fe a4 BB/6B Sovd

Docket for Case No: 06-000722PL