Mar 31 2008 $:26 Mar 31 2008 7:26 P. 02 % ® STATE OF FLORIDA | DEPARTMENT OF HEALTH ! DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2006-07873 NATALIE S. SOHN, M.D., RESPONDENT. ADMI RA MP COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Medicine against the Respondent, Natalie 5. Sohn, M:D., and in support thereof alleges: : i. 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 71810. J;\PSU\Medical\Allison D\Administrative Camplaints\Sohn (t).doc | Mar 31 2008 $:26 Mar 31 2008 7:26 P.03 ® & 3. Respondent is board certified in obstetrics and gynecology. | 4. Respondent's address of record is 13005 Southern Boulevard, Medical Mall 2, Suite 211, Loxahatchee, Florida 33470. 5. On or about February 17, 2006, Patient E.S., a sixty- three-year-old female presented to the Ambulatory Surgery Unit at Palms West Hospital (PWH). | | / 6. Respondent scheduled Patient E.S. for a dilation and curettage (a surgical procedure that expands the. cervical canal of the uterus so that the surface lining of the uterine wall can be scraped) and a hysteroscopy (inspection of the uterus by use of a special endoscope). | 7. On or about February 17, 2006, Respondent performed the planned procedure on Patient E.S. 8, After completing the procedure, Respondent noted that Patient E.S. suffered a perforation of the uterus which she described as small and benign. J:\PSU\Medical\Allison D\Administrative Complaints\Sohn (t).doc Mar 31 2008 $:26 Mar 31 2008 7:26 P. O04 @ @@ 9. Respondent reported that she conducted a visual inspection ‘using the hysteroscope and noted that there was no evidence of bowel damage or any other problem. 10. Following the procedure, Respondent changed Patient E.S. from out-patient status and placed her on twenty-three hour observation, ) | 11. On or about February 18, 2006 at 2:52 AM, Respondent noted that Patient E.S.’ bowel sounds were hypoactive and noted tenderness. | 12. On or about February 18, 2006 at 2:53 AM, Patient ES. received two Percocet tablets as noted in the Medication Administration Record. : ‘13. On or about February 18, 2006 at 3:45 AM, Patient E,S. began moaning and crying with pain and rated her pain level at 10 on a scale of 1 to 10. 14. On or about February 18, 2006 at 3:45 AM, Respondent ordered 50 milligrams of Demerol for Patient E.S. J:\PSU\Medical\ Allison D\Administrative Complaints\Sohn (t).doc Mar 31 2008 3:27 Mar 31 2008 7:26 P.O5 © @ 15. On or about February 18, 2006 at 6:53 AM, Patient E.S. complained of abdominal pain and Respondent ordered another 50 milligrams of Demerol. ! | 16. Onor about February 18, 2006 at 10:38 AM, Patient E.S, received 50 milligrams of Demerol as noted in the Medication Administration Record. i 17. On or about February 18, 2006 at 11:00 AM, Respondent ordered 30 milligrams of Toradol to be given intravenously to Patient E.S., followed by 10 milligrams of Toradol orally every four hours as needed for pain. | 18. On or about February 18, 2006, Patient E.S. sustained a significant drop in hemoglobin and hemocrit. | : 19. A drop in hemoglobin and hemocrit is strongly suggestive of intra-abdominal bleeding, | 20. On or abut February 18, 2006 at 2:46 PM, Patient E.S. was discharged from PWH. 21. On or about February 19, 2006, Patient E.S. presented to | the emergency department of PWH. J:\PSU\Medical\Allison D\Administrative Complaints\Sohn (t).doc Mar 31 2008 3:27 Mar 31 2008 27 P. 06 ® ® 22. On or about February 19, 2006, Patient E.S. underwent an exploratory laparoscopy and laparotamy which revealed a 3.4 “centimeter defect in the small bowel. | | 23. On or about March 3, 2005, Patient E.S was discharged from PWH. 24. Onor about March 13, 2005, Patient E.S. was readmitted to PWH with pulmonary complications and was eventually discharged on or about March 16, 2005. 25. Section 458.331(1)(t), Florida Statutes (2005), sets forth grounds for disciplinary action by the Board of Medicine for committing medical malpractice as defined in Section 456.50, Florida Statutes (2005). Section 456.50, Florida Statutes (2005) defines medical malpractice as the failure to practice medicine in aotordance with the level of care, skill, and treatment recognized in general law related to health care licensure. ! 26. Respondent committed medical malpractice when she failed to practice medicine with the level of care, skill, and treatment recognized in general law related to health care licensure due to one or more of the following: | 3:\PSU\Maedical\Allison D\Administrative Complaints\Sohn (t).doc Mar 31 2008 3:27 Mar 31 2008 7:27 P.O? % % a. By failing to fully evaluate Patient E.S. when she discovered that she perforated Patient E.S. uterus during the procedure; b. By failing to recognize and evaluate Patient E.S/ significant drop in hemoglobin and hemocrit, an c. By failing to evaluate Patient E.S/’ severe post- operative pain and unusually high need for narcotic and non-narcotic pain medications; d. By failing to order additional procedures and testing to rule-out the possibility of intra-abdominal damage from the uterine perforation; : e, By failing to perform an immediate laparoscopy when she discovered the uterine perforation. | 27. Based upon the foregoing, Respondent violated Section 458.331(1)(t), Florida Statutes (2005), by committing medical ‘malpractice when she failed to practice medicine with the level of care, skill, and treatment recognized in general law related to health care licensure when Respondent failed to fully evaluate Patient E.S. when she discovered that she perforated Patient E.S.’ uterus; and/or | J:\PSU\Medical\Allison D\Administrative Complaints\sohn (t).doc Mar 31 2008 3:27 Mar 31 2008 7:27 P. 08 % % failed to recognize and evaluate Patient E.S,’ significant drop in hemoglobin and hemocrit; and/or failed to evaluate Patient E.S. severe post-operative pain and unusually high need for narcotic and non-narcotic pain medications; and/or failed to order additional procedures and testing to rule-out the possibility of intra-abdominal damage from the uterine perforation; and/or failed to petform an immediate laparoscopy when she discovered the uterine perforation. 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, 1:\P5U\Medicai\Allison D\Adrministrative Complaints\Sohn (t).doc Mar 31 2008 $:28 Mar 31 2008 Pia? P.Og9 ot 6 SIGNED this 2774 day of ____ Avegorehx. _, 2006, M. Rony Francois, M.D., M.S.P.H., Ph.D. Secretary, Department of Health (feuch Mile 4 iiblede Hison M, Dudley Assistant General Counsel DOH, Prosecution Services Unit | 4052 Bald Cypress Way, Bin C-65 FILE ere oe PATH. Tallahassee, FL 32399-3265 CLERK: > Florida Bar # 159913 : pate_'2/287CL2 — (850) 245-4640 x8106 Office (850) 245-4680 Facsimile pcp: _ja-aa- ob . PCP Members: 2 Gehe, Vijeyanasec. 2:\PSU\Medical\Alligon D\ Administrative Complaints\Sohn (t).doc Mar 31 2008 $:28 Mar 31 2008 27 P.10 ° & 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 tecum issued on his or her behalf ifa 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 i in addition to any other discipline imposed. 1:\PSU\Medical\Allison D\ Administrative Complaints\sohn (t).doc

Docket for Case No: 08-001591PL