Feb 26 2007 8:22 g2/26/ 2887 88:18 8584146749 DEPR OGA PAGE @5/@8 STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, ve Case No. 2004-035107 DAVID R. SACHS, D.V.M., Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioner"), files this Administrative Complaint before the Board of Veterinary Medicine against DAVID R. SACHS, D.V.M., ("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 6187, 3. Respondent’s address of record is 11252 Northwest 71" Court, Parkland, Florida 33076. 4, On or about January 2, 2002, The New York State Racing and Wagering Board indefinitely suspended and revoked Respondent's New York State license to practice veterinary medicine at New York State race tracks, Feb 26 2007 8:22 g2/26/ 2887 88:18 8584146749 DEPR OGA PAGE 86/88 5. On November 13, 2003, The Supreme Court of New York, Appellate Division, Third Department, affirmed the NYSR&WB suspending and revoking Respondent's New York’s veterinarian occupational license indefinitely. 6. Respondent failed to notify the Board of Veterinary Medicine of the State of Florida of New York State’s disciplinary action against him. COUNT ONE 7. Petitioner realleges and incorporates the allegations set forth in paragraphs one (1) through six (6) as though fully set forth herein. 8. Section 474.214(1)(b), Florida Statutes, states in pertinent part that “(having 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...” constitutes grounds for which disciplinary action may be taken. 9. Based on the foregoing, Respondent violated section 474.214(1)(b), Florida Statutes, by having his New York veterinarian license suspended and revoked. Respondent is therefore subject to disciplinary action pursuant to sections 474.214(2), Florida Statutes. COUNT TWO 10, Petitioner realleges and incorporates the allegations set forth in paragraphs one (1) through six (6) as though fully set forth herein. 11. Section 474.214(1)Gj), Florida Statutes, states in pertinent part that “(flailing to report to the board within 30 days, in writing, any action set forth in paragraph (b) that has been taken against the practitioner's license to practice veterinary Feb 26 2007 $:23 g2/26/ 2887 88:18 8584146749 DEPR OGA PAGE a7 iis) medicine by any jurisdiction, including any agency or subdivision thereof’ constitutes grounds for disciplinary action. 12, Based on the foregoing, Respondent violated section 474.214(1)Gj). Florida Statutes, by failing to notify the Board of the disciplinary action taken against his license by the State of New York. Respondent is therefore subject to disciplinary action by the Board of Veterinary Medicine in the State of Florida pursuant to section 474,214(2), Florida Statutes. WHEREFORE, Petitioner respectfully requests the Bo ard of Veterinary Medicine enter an order imposing one or moré 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 D4 day of YVia.icn 2006 CEE Drew F. Winters Assistant General Counsel Case # 2004-035 107 Counsel for the Department: mimics E D PUTY cLepntta Rogulatn Drew F, Winters CLE } Assistant General Counsel Ri SY ' DATE 3 ~- , Feb 26 2007 $:23 g2/26/ 2887 88:18 8584146749 DEPR OGA PAGE @8/ae Fla. Bar No. 679941 Department of Business and Professional Regulation, 1940 N. Monroe St. Tallahassee, FL 32399-2202 Phone: (850) 487-3197 Fax: (850) 414-6749 DFW/ihg December 22, 2004 PoP cocte- A-13-08

Docket for Case No: 07-000980PL