ne as Nov & 200? 10:58 Nov 8 2007 11:59 ar, New nee! STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. | | CASE NO. 2004-34867 ABDUL-RAHMAN JARAKI, M.D., RESPONDENT. __ ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Medicine against Respondent, Abdul-Rahman Jaraki, 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. 2. At all times material to this Complaint, Respondent was a licensed physician within the state of Florida, having been issued license number ME 55108. goog 1 AON Nov 8 200P 10:58 Noy 8 2007 11:59 we Nad er P. O04 3, Respondent's address of record Is go20 North West 167" “Terrace, Miami Lakes, Florida 33016. | 4, _ Respondent is board certified by the American Board of Internal Medicine, with a subspecialty certificate in Cardiovascular Disease. 5. On or about August 29, 2004, Patient T.S, a sixty-year-old female, with a history of a coronary artery bypass graft, presented to the emergency room of Park ay Regional Medical Center (PRMC) with status post cardiac arrest. ! 6. On or about August 29, 2004, Patient T.5. was admitted to the PRMC intensive care unit with acute coronary syndrome. Advanced Cardiac Life Support (ACLS) proocal was initiated. The patient was continued on ventilatory and hemodynamic support. 7, On or about August 29, 2004, Respondent performed an insertion ofa pulmonary artery catheter with intra-aortic balloon pump and left femoral vein single lumen catheter on Patient TS. A guide wire was used in this procedure. 8. On or about August 30, 2004, Patient T.S. was transferred to Mount Sinai Medical Center (MSMC) from PRMC. Nov & 200? 10:58 a Nov & 2007 11:59 ~ P.O5 9. It was noted on T.S’s admission to MSMC that Respondent had placed an intra-aortic balloon catheter in the left groin and a subclavian central venous line due to T.S's severely low blood pressure and as a life saving procedure. TS. was also placed on Levophed and Epinephrine. 10,. An *%fay was performed on +S. after admission to MSMC, which revealed a retained guide wire in the area of the right internal jugular vein going into the heart and into the inferior v vena cava. 11. Patient T.S. received a cardiovascular consult, and the family was advised of the patients poor condition. 12, Patient TS. also had a consult with a surgeon because of her cold left lower extremity The surgeon felt that she was not a candidate for a revascularization provedure and that they would only watch the leg. The surgeon also recommended that the balloon pump be removed from ~ Patient T.S’s leg. , | 13. On or about August 30, 2004, patient T.S. was taken to the cardiac catheter lab on mechanical ventilation and placed on vasopressors. 14. respondent performed a cardiac catheterization on Patient T.S. that revealed severe obstructive disease of the coronary arteries. Tt was eee Nov & 200? 10:58 Nov 8 2007 11:59 P. 06 determined that there was no area available for revascularization and no way to salvage the myocardium tissue. 15. On or about August 30, 2005, Respondent removed the retained guide wire from Patient TS. Respondent was able to remove the wire without any dissection or staining. 16. Patient T.S. ‘continued to have ischemia of the left lower extremity and eventually it was recommended that she have an above-the-knee amputation. 17, Onor about September 23, 2004, Patient T.S. was discharged from MSMC with a final diagnosis of acute myocardial infarction, anterior wall; acute renal failure; congestive heart failure; cardiogenic shock; arterial embolism of the left lower extremity; anoxic brain damage, decubitus ulcer, status post above-the-knee amputation; and acute respiratory failure. | 18. Section 456,.072(1)(bb), Florida Statutes (2004), provides that leaving a foreign beady in a patient, such as a sponge, clamp, forceps, surgical needle, or other paraphernalia commonly used in surgical, examination, or other diagnostic procedures, constitutes grounds for disciplinary action by the Board of Medicine. Nov 8 2007 10:58 Nov 8 2007 11:59 P.O? Ne ed 19. Respondent violated Section 456.072(1) (bb), Florida Statutes (2004), by leaving a guide wire in Patient T.S. during 4 surgical procedure Respondent performed on Patient T.S. on oF about August 29, 2004. 20. Based on the foregoing, Respondent has violated Section 456.072(1)(bb), Florida Statutes (2004), by leaving a foreign body in a patient, such as a sponge, clamp, forceps, surgical needle, or other paraphernalia commonly used in surgical, examination, oF other diagnostic procedures. WHEREFORE, the Petitioner respectfully requests that the Board of Medicine enter an order imposing one or more of the following penalties: permanent revocation oF 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. Nov & 200? 10:59 Nov 8 2007 12:00 P. 08 we ws £5 &. SIGNED this lms ay of 2reancbey 1 2008. M. Rony Francois, M.D., M.S.P.H., Ph.D. Secretary, Department of Health FILED Joh E. Terrel DEPARTMENT OF HEALTH Gistant General Counsel Kew OH Prosecution Services Unit CLERK a Me 4052 Bald Cypress Way, Bin C-65 oate__lt |-0S Tallahassee, FL 32399-3265 | Florida Bar #0865036 (850) 414-8126 (850) 414-1989 FAX JET/tge Reviewed and approved by: aor (initials) 1© [30 }°S_ (date) PCP: october 28, 2005 PCP Members: g1-pahri, Fanner, pyches | | ABDUL-RAHMAN JARAKI, M.D. CASE NO. 2004-34867 a Nov § 2007 12:00 Nov & 200? 10:59 P.0g ‘we! ‘ual ABDUL-RAHMAN JARAKI, M.D. CASE NO. 2004-34867 NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordanes with Section 120.569 and 120.57, Florida Statutes, to b represented by counsel or other qualified representative, to pr sent evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum 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 shall 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 imposed.

Docket for Case No: 07-005118PL