Aug 31 2009 13:52 fug 31 2009 13:48 P. O06 | _ STATE OF FLORIDA , , DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, , a PETITIONER, vw CASE NO, 2008-21670 JOHN A. KING, D.0, | , , RESPONDENT, / , MINISTRATIVE COMPLAINT COMES ; NOW Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Osteopathic Medicine against Respondent, John A. King, D.O., and in support thereof alleges: | : od. Petitioner is the state department charged with regulating the practice of osteopathic medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida. Statutes; and Chapter 459, Florida Statutes. 2.. At all times material to this Complaint, Respondent was a licensed osteopathic physician within the State of Florida, having been ’ issued license number OS 4982. Aug 31 2009 13:52 fug 31 2009 13:48 P.O? = we 3. Respondent's address of record is 11310 South Orange Blossom Trail, Orlando, Florida 32837. ) 4. The Medical Licensing Board of Indiana (Indiana Board "Yj is the licensing authority regulating the practice of osteopathic medicine in the State 0 of Indiana. : . 5. Onorabout April 13, 2007, the Indiana Board entered an Order which indefinitely suspended Respondent's osteopathic medicine loense. 6. Respondent was disciplined by the Indiana Board for, among other things, falsely indicating ona licensure renewal applications that he has never been denied staff membership Or privileges. in any hospital or health | care facility or have staff membership or privileges revoked, suspended or subjected to any restriction, probation, or other type of - discipline or limitation. 7. The Order entered by the Indiana Board constitutes disciplinary action against the Respondent's license to practice osteopathic medicine i in the State of Indiana. , . | 8. The State of Alabama Medical Licensure Commission (Alabama Commission”) is the licensing authority regulating the Practice of osteopathic medicine i in the State of Alabama, Page 2 JAPSU\Medical\Tobey\Osteo\ACs\King.J.2008-21670(b).doc i: Aug 31 2009 13:52 fug 31 2009 13:48 P. 08 ew wr 9.. On or about September 17, 2008, the Alabama Commission entered an Order which revoked Respondent's license to ! practice ~ osteopathic medicine in Alabama. | 10. Respondent was disciplined for committing unprofessional ‘conduct, practicing medicine or osteopathy in such a mannér as to endanger the health of the patients of the practitioner, committing gross or repeated or gross negligence in the practice of medicine or osteopathy, and being unable to practice medicine or osteopathy with reasonable skill and safety ta patients by reason of a demonstrated lack of basic medical knowledge or Clinical competency. 11. The Order entered by the Alabama Commission constitutes disciplinary action against the Respondent's license to practice osteopathic medicine in the State of Alabama, 12. Section 459.015(1)(b), Florida Statutes (2006)- (2008), provides that having a license or the authority to practice osteopathic medicine revoked, suspended, or otherwise acted against by the licensing authority of any jurisdiction, including its agencies or subdivisions, constitutes grounds for disciplinary action by the Board of Osteopathic Medicine. Page 3 , J:\PSLI\Medical\ Tobey\Osteo\ACs\King.J.2008-21670b).dde ‘ : | Aug 31 2009 13:52 fug 31 2009 13:48 P.09 a Nee! 13. One or more of the: following ‘constitutes disciplinary action against Respondent's osteopathic license in another jurisdiction: | | 1) The Order issued by the Indiana Board which indefinitely suspended his Indiana license. : 2) The order issued by the Alabama Commission revoking Respondent's Alabama license, 14. Based on the foregoing, Respondent has violated Section . 459.015(1)(b), Florida Statutes (2006)-(2008), by having a license or the. authority to Practice osteopathic medicine revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of any jurisdiction, including its agencies or subdivisions: WHEREFORE, Petitioner respectfully requests that the Board of Osteopathic Medicine enter.an order j 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. Page 4 oo JAPSU\Medicall Tobey\Osteo\ACs\King.1.2008-21670(b).doc i Aug 31 2009 13:53 fug 31 2009 13:48 P.10 we Nl SIGNED this_{S""_ day of Lhe. | _, 2009, Ana M. Viamonte Ros, M. D., M, P H, State Surgeon General t - Tobey Séhul Assistant General Counsel ED HEALTH . DOH Prosecution Services Unit — oeranrae CLERK - . 4052 Bald Cypress Way, Bin C-65 Reached BrOOkw Tallahassee, FL 32399-3265 ore i MAY 1.5 2009, Fiorida Bar No. 0542131 (850) 245-4640 x. 8176 | 7 (850) 245-4684 FAX ! PCP:.5 vl yy indies Katinas y fall to , Page 5 J:\PSU\Medical\ Tobey \Osteo\ACs\King.J.2008-21670(b).doc Aug 31 2009 13:53 fug 31 2009 13:49 PTT Nee! 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 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 an costs, on the Respondent in addition to any other discipline imposed. ‘ Page 6 - 3:\PSU\Medical\ Tobay | Osteo\ACs\King.J.2008-21670(b).cloc Li

Docket for Case No: 09-004741PL