Apr 1 2008 13:45 a@4/al/2aee 13:48 8584146749 DEPR OGA PAGE STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, Vv. Case No. 2006-01475 | ELIGENE LAURENCE GENTSCH, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION ("Petitioner"), files this Administrative Complaint before the Board of Veterinary Medicine against EUGENE LAURENCE GENTSCH ("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 453 and 474, Florida Statutes. 2. At all times material hereto, Respondent was unlicensed as a veterinarian in the State of Florida. 3. Respondent's address of record is 17579 Rockefeller Circle, Ft. Myers, Florida, 33912. 4. On of about October 26, 2005, Respondent was presented with “Romeo”, a Chihuahua owned by Sandra Workinger. 5. Respondent administered a rabies vaccination to “Romeo”. 6. Rule 61G18-17.006(3), Florida Administrative Code, states, in pertinent part, that a4/a6 Apr 1 2008 13:45 a@4/al/2aee 13:48 8584146749 DEPR OGA PAGE 85/86 “only a veterinarian may immunize or treat an animal for...Rabies.” 7. Section 474.213(1)@), Florida Statutes, states: “No person shall practice veterinary medicine in this state, unless the person holds a valid, active license to practice veterinary medicine pursuant to this chapter.” 8. Based on the foregoing, Respondent violated Section 474.213(1)(), Florida Statutes, when he administered a rabies vaccination on an animal. Respondent is therefore subject to discipline by the Department of Business and Professional Regulation pursuant to Section 474.213(2), Florida Statutes. WHEREFORE, Petitioner respectfully requests the Secretary of the Department of Business and Professional Regulation enter an order imposing one or more 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 delincated within Section 455.227(2), Florida Statutes, and/or any other relicf that the Board is authorized to impose pursuant to Chapters 453 and/or 474, Florida Statutes, and/or the rules promulgated thereunder. Signed this aay of Se PRI 007 FILED ee ae EE Department of Business and Professional Reguletion a Drew F. Wonters AGENCY CLERK Assistant General Counsel Case # 2006-014751 CURK Son ndy r4 Weston nm : Apr 1 2008 13:45 a@4/al/2aee 13:48 8584146749 DEPR OGA PAGE 86/86 Counsel for the Department: Drew F. Winters Assistant General Counsel Florida Bar Number 067994], Department of Business and Professional Regulation Office of the General Counsel 1940 North Monroe Street Tallahassee, FL 32399-2202 DFWirmw August 29, 2007 MP. q\iz\or © _- T

Docket for Case No: 08-001615