Feb 15 200° 3:23 Feb 15 2007 9:23 P.O & t we wi STATE OF FLORIDA . DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, , ; PETITIONER, Vv. CASE NO. 2002-11713 SOHEIL SOOUDI, M.D., RESPONDENT. / INI VE CO INT COMES NOW, Petitioner, Department of Health, by and through its ) undersigned counsel, and files this Administrative Complaint before the” Board of Medicine against Respondent, SOHEIL SOOUDI, M.D., and in support thereof alleges: . : 1. 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. Y 2. At all times material to this Complaint, Respondent was a licensed: physician within the state of Florida, having been issued license number ME 73258. Page i: Soheil Sooudi, MD (2002-11713) Feb 15 200° 3:23 Feb 15 2007 9:23 P. 02 wy ww 3, Respondent's address of record is 435 Water Street, Celebration, Florida 34747. / 4. Respondent is board certified in radiology. 5. Onor about November 23, 1997, Respondent was charged with Driving Under the Influence, a misdemeanor, in Warner Robbins, Georgia. 6. On or about March 7, 1998, Respondent was charged with Driving Under the Influence, a misdemeanor, in Warner Robbins, Georgia. 7, Onor about June 11, 1998, Respondent was convicted.on both the November 23, 1997 and March 7, 1998 charges. , 8. On or about March 28, 1999, Respondent submitted a practitioner profile questionnaire to the Florida Board of Medicine. 9. Section VIII, the Criminal Offenses section of the practitioner profile questionnaire, asks: “Have you ever been convicted or found guilty, regardless of whether adjudication of guilt was withheld, or pled guilty or nolo contendere to a criminal misdemeanor or felony in any jurisdiction?” In response to the question, Respondent marked the answer no. COUNT ONE 10. Petitioner re-alleges and incorporates paragraphs one (1) through nine (9) as if fully set forth herein. Page2: . Sohell Scoudi, MD (2002-11713) Feb 15 200° 3:23 Feb 15 2007 9:24 P.03 / w/ 11. Section 458.331(1)(h), Florida Statutes (1998), sets forth grounds for disciplinary action by the Board of Medicine and provides that making or filing a report which the licensee knows to be false, intentionally or negligently failing to file a report or record required by state or federal law, willfully impeding or obstructing such filing or inducing another person to do so, constitutes grounds for disciplinary action. 12. Respondent answered the Mandatory Practitioner Profile Questionnaire falsely, thereby making or filing a report, which _the Respondent knew to be false. - ‘13. Based on the foregoing, Respondent has violated Section 458,331(1)(h), Florida Statutes (1998), by. making or filing a report which the licensee knows to be false. WHEREFORE, the Petitioner respectfully 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 of 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° Soheil Sooud!, MD (2002-11713) Feb 15 200° 3:23 Feb 15 2007 9:24 P. O04 ee \e/ SIGNED this mse day of A 24 oct , 2003. John O. Agwunobi, M.D., M.B.A. Secretary, Department of Health FILED DOH Prosecution Services Unit DEPART ERK 4052 Bald Cypress Way, Bin C-65 Catemar Tallahassee, Florida 32399-3265 cuzri ead "Florida Bar # 0112925 DATE (850) 414-8437 Telephone ~ | (850) 414-1991 Facsimile Exbpyrdayor . Reviewed and approved by: DiGE (initials) (4-803 (date) PCP: Augues $F 2003 7 PCP Methibers: Fuad Ashkar: M.D.Cchoirpersen), Manuel. Cote, M.D, and John Beebe, Soheil B. Sooudi, M.D, 2002-11713 Page4d . Soheil Sooudi, MD (2002-11713)

Docket for Case No: 07-000788PL