Apr 18 200? 14:33 $O0e 20 Ud¥ = APR-18-2887 14:49 Pp STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2003-06631 JERALD JERVIS, D.C., RESPONDENT. ef ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Chiropractic Medicine against Respondent, Jerald Jervis, D.C., and in support thereof alleges: | 1. Petitioner is the state department charged with regulating the practice of chiropractic medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 460, Florida Statutes. 2. At all times material to this Complaint, Respondent was a licensed chiropractic physician within the state of Florida, having been issued license number CH 4760. 1 J:\PSU\Medical\Carol Gregg\Chiropractic Cases\Jervis 2003-06631 Vervis AC 2003-06631.dac APR-18-2087 14:49 Apr 18 2007 14:55 3. Respondent's address of record is 1100 East Lake Silver Drive, Winter Haven, Florida 33881. 4. On or about May 19, 1999 by Final Order filed in Department of Health cases numbered 95-03352, 95-11758, and 97-14796. Pursuant to the terms of the Final Order, Respondent was ordered to pay an administrative fine in the amount of $2,500.00 and investigative costs of $6,800.00 within two (2) years from the date of entry of the Final Order. In addition, Respondent has failed to have his Board approved monitor submit quarterly reports for the last 3 quarters of his probation. 5. As of January 10, 2006, Respondent has mot paid the $2,500.00 administrative fine, the $6,800.00 in investigative costs and he has failed to have his Board approved monitor submit the required quarterly reports. 6. Section 460.413(1)(v), Florida Statutes (2001), (2002), (2003), (2004), and (2005), 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. 7, Respondent violated a lawful order of the Board of Chiropractic Medicine previously entered in a disciplinary hearing in that he failed to 2 4:\PSU\Medical\Carol Gregg\Chiropractc Cases\Jervis 2003-06631 Jervis AC 2003-06631.dac APR-18-2087 14:49 Apr 18 2007 14:55 P.16 comply with the terms of the Final Order of the Board of Chiropractic Medicine entered in DOH cases numbered 95-03352, 95-11758, and 97- 14796 by failing to pay fine and costs within two (2) years from the date of entry of the Order and by failing to submit monitor reports. 8 Based on the foregoing, Respondent violated Section 460.413(1)(v), Florida Statutes (2001), (2002), (2003), (2004), and (2005) by knowingly violating a lawful order of the Board of Chiropractic Medicine previously entered in a disciplinary proceeding. WHEREFORE, the Petitioner respectfully requests that the Board of Nursing 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 3 1:\PSU\Medical\Carol Gregg\Chiropractic Cases\VJervis 2003-06631\Jervis AC 2003-06631.doc APR-18-2087 14:49 Board deems appropriate. SIGNED this 42> day of CLs _ 2006. FILED DEPARTMENT Or HEALTH Di CLERK CLERK co hyd Yt oare___ Sie PCP: pougherty, Glisson PCP Members: 3 30/2006 Apr 18 2007 14:34 M. Rony Francois, M.D., M.S.PH., Ph.D, Secretary, Department of Health (ut R Grr Carol L. Gregg Assistant General Counsel DOH Prasecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar # 181515 (850) 414-8126 (850) 414-1989 FAX 4 J:\PSU\Medical\Carol Gregg\ Chiropractic Cases\lervis 2003-06631\Jervis AC 2003-06631.doc Apr 18 2007 14:34 APR-18-2087 14:58 F 18 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 tecurn 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 shail 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 impesed. 5 J:\PSU\Medical\Carol Gregg\Chiropractic Cases\Vervis 2003-06631\Jervis AC 2003-06631.doc

Docket for Case No: 07-001750PL