Aug 6 2007 3:26 AUIG-B6-2087 HE! 33 ATTY GEN OFC 856-922-6425 Pa? \ STATE OF FLORIDA DEPARTMENT OF HEALTH BUREAU OF EMERGENCY MEDICAL SERVICES DEPARTMENT OF HEALTH, Petitioner, VS. 7 Case No. 2006-14427 GEORGE L. FAUCHER, Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW Petitioner, Department of Health, (hereinafter “Petitioner”) by and through its undersigned attorneys and files its Administrative Complaint against Respondent, GEORGE L. FAUCHER, (hereinafter a “Respondent’) and alleges: 1. Petitioner is the state agency charged with regulating emergency medical services pursuant to Section 20.43, Florida Statutes, and Chapters 120 and 401, Florida Statutes. 2. At all times material hereto Respondent has been licensed as a paramedic, having been issued license number PMD 200207. F:\Users\ADMIN\Raginald Dir 06-14427,crime.rel.prac.rtf EXHIBIT B Aug 6 200P 8:26 AUG-a6-2987 fe:s3 ATTY GEN OFC 858-922-6425 i” P.2B 3. Respondent's address of record is 2700 Firefighter Memorial Drive, « Jacksonville, Florida 32246. Respondent is also believed to be residing at 5911 Regiment Drive, Jacksonville, Florida 32277. COUNT I 4, Petitioner re-alleges the allegations of fact set forth in paragraphs one (1) through three (3) as if fully stated herein. 5. Onor about February 7, 2005, Respondent was involved in a two vehicle motor vehicle accident. The accident resulted in the death of the driver in the other vehicle. 6. As a result of the investigation of the accident, Respondent was prosecuted criminally. 7. Onorabout May 17, 2006, in case no. 16-2005-CF-4802-AXXX-MA, in Duval county circuit court, Respondent entered a plea of nolo contendere to, and was adjudicated guilty of “driving with an unlawful bleod alcohol level or under the influence a lesser included offense”, a first degree misdemeanor, in violation of section 316.193(1)(b), Florida Statutes. 8. Respondent was sentenced to a six (6) month term of imprisonment in Duval county jail, beginning June 14, 2006. F:\Users\ADMIN\Reginald Dixon\EMS Prosecutions\ACs\Individuals\Faucher,06-14427.crlme.rel.prac.rtt 2 Aug 6 2007 3:26 AUIG-B6-2087 HE! 33 ATTY GEN OFC 856-922-6425 P.@9 9. Respondent’s conduct giving rise to the subsequent conviction demonstrates poor judgment on behalf of the Respondent. 10. Paramedics are often placed in high pressure situations where good judgment is essential to the delivery of emergency medical services to patients in compromised medical conditions. 11. Section 401.411(1)(b), Florida Statutes, provides that being found guilty of, or pleading nolo contendere to, regardless of adjudication in any jurisdiction, a crime that relates to practice as an emergency medical technician or paramedic, or to practice in any other occupation, when operating under this part, constitutes grounds for disciplinary action by the Bureau of Emergency Medical Services. 12. Respondent entered a plea of nolo contendere to, and was adjudicated guilty of “driving with an unlawful blood alcohol level or under the . influence a lesser included offense”, a first degree misdemeanor, in violation of section 316.193(1)(b), Florida Statutes, a crime related to the practice as an emergency medical technician or paramedic. 13. Based on the foregoing, Respondent has violated Section 401.411(1)(b), Florida Statutes, by Being found quilty of, or pleading nolo contendere to, regardless of adjudication in any jurisdiction, a crime that F:\Users\ADMIN\Reginaid Dixon\EMS Prosecutions\ACs\Individuals\Faucher.06-14427.crime.rel. prac. tf AUIG-B6-2087 eS: 34 Aug 6 200° 8:27 ATTY GEN OFC 858-922-6425 P.18 relates to practice as an emergency medical technician or paramedic, or to practice in any other occupation, when operating under this part. CLAIM FOR RELIEF WHEREFORE, Petitioner respectfully requests the Bureau of Emergency Medical Services to enter an order imposing one or more of the following penalties upon Respondent pursuant to Section 401.411(1), Florida Statutes: a. b, Revocation or suspension of Respondent's license; Restriction of Respondent's practice; An administrative fine; > A reprimand; Probation; and/or Any other penalty the Bureau deems appropriate. Dated this 21st day of June, 2007. DEPARTMENT OF HEALTH DESUTY CLERK Respectfully submitted, BILL MCCOLLUM CLERK: Rain > DATE___ bo 2507 Assistarit Attorney General Departrnent of Legal Affairs PL-01 The Capitol F:\Users\ADMIN\Reginald Dixon\EMS Prosecutions\ACs\Individuals\Faucher.06-14427.crime.rel.prac.rtt ‘eh Aug 6 200° 8:27 AUIG-G6-2887 Ge:34 ATTY GEN OFC 856-922-6425 ; Pidi an : Tallahassee, Florida 32399-1050 (850) 414-3300 PCP: Pippin, Bailey & Hines DATE: 6-18-07 NOTICE OF HEARING RIGHTS RESPONDENT IS HEREBY NOTIFIED THAT HE/SHE HAS THE RIGHT TO REQUEST AN ADMINISTRATIVE HEARING PURSUANT TO SECTIONS 120.569 AND 120.57, FLORIDA STATUTES. SPECIFIC OPTIONS FOR ADMINISTRATIVE ACTION ARE SET OUT IN THE ATTACHED EXPLANATION OF RIGHTS. ALL REQUESTS FOR HEARING MUST BE MADE WITHIN 21 DAYS OF RECEIPT AND SENT TO REGINALD D. DIXON, ASSISTANT ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, PL-01 THE CAPITOL, TALLAHASSEE, FLORIDA 32399-1050. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy has been served by certified mail this chim of Vine , 200 / to: George L. Faucher, 2700 Firefighter Memorial Drive, Jacksonville, Florida 32246, and 5911 Regiment Drive, Jacksonville, Florida 32277, and Henry M. Coxe, III, Esquire, 101 East Adams Street, Jacksonville, Florida 32202. Assistant Attorney General F:\Users\ADMIN\Reginald Dixon\EMS Prosecutions\ACs\Individuals\Faucher, 06-14427.crime,rel.prac.rtf ; 5 TOTAL P.it

Docket for Case No: 07-003577PL