FILED Departnvecn of Business andl ProfWsciuinl MaHkULATIOA Deputy Agency Clerk CLERIC Brenden Nichols Oote 1/25/2010 File iz STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF VETERINARY MEDICINE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, v. Case No. 2009-031732 JEFFREY THOMAS SAUNDERS, D.V.M., Respondent . ADMINISTRATIVE COMPLAINT Petitioner, Department Of Business and Professional Regulation, files this Administrative Complaint before the Board of Veterinary Medicine, against Respondent, Jeffrey Thomas Saunders, D.V.M., and alleges: 1. Petitioner is the state agency charged with regulating the practice of weterinary medicine pursuant to Section 20,165, Florida Statutes, and Chapters 455 and 474, Florida Statutes. 2. At all times material to this complaint, Respondent was licensed to practice veterinary medicine in the State of Florida, having been issued license number VM 3118, 3. Respondent's address of record is 2801 U.8. Highway 27 South, Avon Park, FL 33825. 4. On May 11, 2009, Complainant took their puppy “Mia” to Saunders Veterinary Services in Avon Park, Florida after it had G:\OGC\ Professions Searda\vetarinary medicine\AC\2009\s r : 4 Te ees ¥ cine \AC\ 2009\ Saunders, Jeffrey 09-031732 1 1/20/2010 FOO sda 6pé9oPTpags 26:68 G&Teeé/ST/8e ehipl otoz at Bry éTfER Sod ate the stuffing out of a dog toy, which caused vomiting. Additionally, “Mia” had not been eating or drinking since she ate the stuffing. 5. In the medical records for this visit, Respondent indicated “electrolytes all low’, but according to expert, Or. Jerry Alan Greene, normal saline has no effect on the low potessium levels and vehydration would only lower the electrolyte values lower. Additionally, Respondent failed to indicate the total amount of fluids administered and the time frame of administration. 6. Respondent recommended hospitalization, laboratory testing, and radiographs for “Mia”. The Complainant left the dog in Respondent’ s custody. The Complainant called Respondent's hospital later that day and was told that the tadiographs revealed nothing in the stomach. 7. “Mia” was hospitalized for two days and she vomited during the first day of the care, Respondent administered an injection of Penicillin, an oral antibacterial, a probiotic, and IV fluid therapy. 8, In the medical records from May 12, 2009, Respondent failed to identify the concentration of Cernia and Carafate administered. Additionally, the medical records do not reflect that any additional laboratory work up or follow-up tadiographs were performed. thy tale gestions Boards \vetecinary Medicine\AC\200S\aunders, Jeffrey 09-031742 2 1/20/2020 éT/P@ Fd YOO adad BP29PTPags 42:68 @tec/ST/ee Stitt otoz at Bny 9, “Mia” was discharged on May 13, 2009 and the medical records do not indicate that Respondent performed an examination before discharge. 10. The following day, Respondent called Complainant to follow-up on “Mia” and was told that she still wasn't eating, 11, On May 15, 2009, during a follow-up telephone call, Complainant revealed that “Mia” ate a small piece of chicken and was drinking on her own. Respondent advised Complainant to feed her rice and chicken. 12. On May 16, 2009, Complainant asserted that “Mia” was much better and eating small amounts of dried food. 13. On May 17, 2009, Complainant asserted that “Mia” had vomited the chicken and rice. Respondent advised Complainant to try egg and yogurt. 14. On May 18, 2009, Complainant declared that “Mia's” status remained unchanged and that the vomit was now yellow and foul smelling. 15. On May 19, 2009, Respondent left a message for Complainant to bring the deg in for an update and bariun upper Gastrointestinal Radiographs. Complainant did not return the call until the next day, but reported that “Mia” was not eating and vomited. During this call, Respondent advised Complainant to discontinue “everything” and start over by only offering 2/3 I/D mixed with 1/3 regular diet food and see what happens, It Gi\0GC\ Professions Boards \veteri eldcd oae os © _ > (2) (2) VAG. dee Adwe Wererinacy medicine\AC\2009\Saundees, Jesfrey 09-091732 3 1/20/2010 : GT yaa éT/Sa avd YOO aidga BPLOPTPaSS AIG TAZ /ST/ Stitt otoz at Bny was at this point that the Complainant expressed their concern because “Mia” had lost a considerable amount of weight and they were worried that she would not survive without anything for 24 hours. 16. On May 21, 2009, “Mia” was admitted to Saunders Veterinary Services for an examination, Respondent provided three options for Complainant: referral for endoscopy, an upper GI series, or continued home care, The Complainant elected for the home care. ‘The medical records from this visit reflect that “Mia” had lost 10% of her body weight since she was first seen on May 11, 2009 and the issue is never addressed by Respondent. 17, Respondent called Complainant for a follow-up the following day and was told that the dog had not improved and Complainant was upset that a bariwn series was not performed. 18. Over the next week, Respondent made several phone calls to check-up on "Mia”, but there was no progress, 19. On May 28, 2008, Complainant took the dog to Thomasville Animal Hospital in Thomasville, Georgia. A hard Mass was discovered in the dog’s abdomen, Surgery was performed and revealed a linear foreign body, the String from the dog toy, which had cut through the mesenteric surface of the intestinal tract. The intestinal tract was too damaged so the Complainant elected euthanasia. G:\OGC* brefessions Boards \veterinary medi cine\AC\ 2008\ Saunders, Jegirey Q9-031732 4 (1) (4) \AC. doo 1/20/2g10 FOO sda 6pé9oPTpags 26:68 G&Teeé/ST/8e ehipl otoz at Bry éT/98 Sav 20. According to expert Dr. Jerry Allan Greene, Respondent failed to recognize the severity of “Mia's condition and provided inadequate care. It is Dr, Greene’s belief that Respondent was ultimately responsible for “Mia” having to he euthanized. 21. Section 474.214(1) (r), Florida Statutes, States “(bleing 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 as being acceptable under similar conditions and circumstances” constitutes grounds for disciplinary action. 22. Based on the foregoing, Respondent violated Section 474.214(1) (ry), Flerida Statutes, when he failed provide an acceptable standard of care for his patient. 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: permanent revocation or suspension of Respondent's license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of G=\OGC\* Professions Boarde\ veterinary medicine\Ac\ 2009\ Saunders, Jeffrey 09-031732 5 (1) (5) \ac doc 1/20/2019 FOO sda 6pé9oPTpags 26:68 G&Teeé/ST/8e 6Pitl otoz oT Bny éT/4@ SBM Respondent on probation, assessment of costs, corrective action and/or any other relief that the Board deems appropriate. Signed this 14" day of January, 2010, CHARLIE LIEM, Interim Secretary Department of Business and Professional Regulation By: Elizabeth Fletcher Duffy ELIZABETH FLETCHER DUFFY | Assistant General Counsel Florida Bar No. 0980404 Department of Business and Professional Regulation Office of the General Counsel 1940 North Monroe Street Tallahassee, Florida 32399-2202 Phone: : (850) 487-8435 Facsimile: (850) 414-6749 PCP Date: January 13, 2010 PCP Members: Jones and Lewis EFD/j 1m Cay ee Bape eset ong Bourda\vetorinacy medicine \AC\2909\ Saunders, Jeffrey 09-0917432 é 1/20/2010 2T/8@ Sod FOO dad Bredp Tress 42°68 &iae/ST/88 6ripl otoz at Bry NOTICE OF RIGHTS Respondent has the right to request a hearing to he conducted in accordance with Sections 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 subpoenas and subpoenas duces tecum issued on his or her behalf if a hearing is requested, Rule 28-106.111, Florida Administrative Code, provides in part that if Respondent fails to request a hearing within twenty-one (21) days of receipt af an agency pleading, Respondent waives the right to request a hearing on the facts alleged, 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 te Section 455.227(3) (a), Florida Statutes, the Board, or the Department when there is no Board, may assess costs related to the investigation and Prosecution of the case excluding costs associated with an attorney's time, against the Respondent in addition to any other discipline imposed. tein Boards \veterinary medicdne\AC\2009\Saunders, Jaftcey 09-9917%2 7 1/26/2010 "Ba =ATae /ST/8e éT/68 38d FOO sda 6pé9oPTpags #66) /ST/ 6Pitl otoz oT Bny

Docket for Case No: 10-007593PL