STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, v. Case No. 2005-064424 PHILIP JEROME ALEONG, 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 PHILIP TEROME ALEONG, ("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. Al all times material hereto, Respondent was licensed in the State of Florida as a veterinarian, having been issued license number VM 6466. 3, Respondent's address of record is located at 4917 Roosevelt Street, Hollywood, Florida 33021. 4, On September 9, 2005 the Florida Board of Veterinary Medicine entered Final Order Approving Settlement Stipulation (Final Order) Number BPR-2005-04911 against PIYER SBvd YOO sddd JST OTOz of dy Bp29P Tress 69:01 alaz/Bz/Pa Respondent’s veterinarian nvense, by timely filing the order wa the Department’s Agency Clerk. 5. Final Order BPR-2005-04911 required Respondent to pay an administrative fine in the amount of $5,000.00 and investigative costs in the amount of $479.76 within thirty (30) days from the date of filing the Final Order with the Department’s Agency Clerk. 6. Final Order BPR-2005-04911 placed Respondent's veterinanan license on probation for a period of eighteen months (18) from the date of filing the Final Order with the Agency Clerk’s Office. 7. Final Order BPR-2005-04911 was properly rendered on September 9, 2006, by railing the Final Order to the Respondent by certified mail. 8. Respondent’s compliance with the Final Order was required on or before October 9, 2005. . : 9. Respondent failed to remit payment of the administrative fine and cost required under Final Order BPR-2005-049 11 by October 9, 2005. 710. Respondent failed to remit complete payment of the Administrative Fine as required by Final Order BPR-2005-04911 until January 12, 2006. 11. As of April 17, 2006, Respondent has failed to remit payment of the costs assessed by Final Order BPR-2005-04911. 12, Section 474.214(1)(f, Florida Statutes, states, ‘[tJhe following acts shall constitute grounds for which the disciplinary actions in subsection (2) may be taken: [v}iolating any provision of this chapter or chapter 455, a rule of the board or department, or a lawful order of the board or department previously entered in a disciplinary hearing, or failing to comply with a lawfully issued subpoena of the department.” PI/Pa Abd FOO sda 6pé9oPTpags 65°4 20:97 obToz ag dy Fame 13. Based on ine foregoing, Respondent is in violauon of section 474.214()(0), Florida Statutes, by failing to remit the $5,000 administrative fine, and $479.76 in investigative costs, totaling $5,479.76, within 30 days of filing Final Order BPR-2005-04911, and is thereby subject to discipline by the Board of Veterinary Medicine pursuant to sections 474.214(1)(f and (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 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 penaltics delineated within section 455.227(2), Florida Statutes, and/or any other relief that the. Board is authorized to impose pursuant to chapters 455 and/or 474, Florida Statutes, and/or the rules promulgated thereunder. . deters: a Signed this a | day of. Wane « , 2006. Drew F. Winters Assistant General Counsel Case # 2005-064424 Counsel for the Department: Drew F. Winters Assistant General Counsel . Florida Bar Number 0679941 r | L E D) Department of Business and Professional Regulation Office of the General Counsel Department of Business and Professional Regulation AGENCY CLERK 1940 North Monroe Street Tallahassee, FL 32399-2202 curr DFWiip Soak x. [J oaAoong orey April 18, 2006 par o72lo~Zoo® PC: 5°S-o PT/Se 38d woO Adaa 6pé9oPTpags 6S5°:8T @ 20:91 oOT0z of Jey ewes

Docket for Case No: 10-002389PL