eee Oct 31 2008 11:45 10/31/2888 11:40 8504146749 DBPR OGA Pace 12/15 STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, v. Case No. 2006-021850 SCOTT J. LANGTON, D.V.M., Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Department Of Business And Professional Regulation, ("Petitioner"), files this Administrative Complaint before the Board of Veterinary Medicine, against Scott J. Langton, D.V.M., ("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 455 and 474, Florida Statutes. 2. Respondent is and has been, at all times material hereto, a licensed veterinarian in the State of Florida, having been issued license number VM 8037. 3. Respondent's last known address of record was P.O. Box 5115, Winter Park, Florida, 32793. GAOGC Professions Boards\vetcrinary medicine\AC\2007\Langton, Scott 06-021850 (1 (r) 1 Oct 31 2008 11:45 DBPR OGA PAGE 13/15 18/31/2088 11:48 8584146749 4. On or about December 2, 2005, Respondent examined “Cricket,” a horse owned by Amy Lawhead, in order to diagnose and treat lameness in the left front leg. 5. On December 2, 2005, Respondent took nine (9) x-rays. Four (4) views were taken of the foot and five (5) views were taken of the ankle. 6. On December 2, 2005, Respondent diagnosed “Cricket” with exostosis and made no indication that there was any problem with the ankle joint. 7. Respondent reported to the owner that there was no concern with the ankle and that shoes would remedy the lameness problem. 8. The x-rays taken by Respondent indicate that “Cricket” suffered from degenerative joint disease. 9. The failure to identify degenerative joint disease in the ankle ia below the acceptable standard of care for veterinary medicine. 10. Section 474.214(1) (r), Florida Statutes, states that the following shall constitute grounds for disciplinary action: “Being guilty of incompetence or negligence by failing to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent veterinarian ag being acceptable under similar conditions and circumstances.” GAOGC\Professions Boards\veterinary medicine\AC\2007\Langton. Sort 06-021 850 (1 Mr) Oct 31 2008 11:46 / 10/31/2808 11:48 8584146749 DBPR OGA PAGE 14/15 11. Based on the foregoing, Respondent violated Section 474.214(1) (r), Florida Statutes, by failing to diagnose “Cricket” with degenerative joint disease. Respondent is therefore subject to discipline by the Board of Veterinary Medicine pursuant to Section 474.214 (2) . Florida Statutes. WHEREFORE, Petitioner respectfully requests the Board of Veterinary Medicine enter an Order imposing one or more of the following penalties: revocation or suspension of Respondent’s license, restriction of Respondent’s practice, imposition of an administrative fine not to exceed $5,000 per violation, issuance of a reprimand, placement of Respondent on probation, assessment of costs association with the investigation, imposition of any or all penalties delineated within section 455,.227(2), Florida Statutes, and/or any other relief that the Board is authorized toa impose pursuant to chapters 455 and/or 474, Florida Statutes, and/or the rules promulgated thereunder. Signed this t day of ana » 2008. CLERK -\ -2.00 Assistant General Counsel DATE Florida Bar No. 0980404 Department of Business and Professional Regulation Office of the General Counsel 1940 North Monroe Street GAOGC\Professions Boards\veterinary medicinc\AC\Z007\Langion, Scon 06-021850 (1)(r)\new AC doc 3 Oct 31 2008 11:46 he PAGE 15. 18/31/2888 11:48 8584146749 DBPR OGA Tallahassee, Florida 32399-2202 Phone: (850) 487-9648 Facsimile: (850) 414-6749 EFD/xmw p60 4//* GAOGC\Professions Boards\veterinery medicinc\AC\2007Langton, Scon 06-021850 Or)\new AC. doc

Docket for Case No: 08-005458PL