Oct 1 2010 14:25 Oct 1 2010 14:21 P. O06 STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT QF HEALTH, PETITIONER, | Vv. CASE NO, 2009-15096 ANTOINETTE LOUISE LLOYD, M.D., : RESPONDENT, ee | ADMINISTRATIVE COMPLAINT Petitioner, Department of Health, by and through undersigned counsel, files this Administrative Complaint before the Board of Medicine against Respondent, Antoinette Louise Lloyd, MD., and in support thereof alleges: : 1. Petitioner is the state department charged with regulating the practice of medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 458, Florida Statutes. 2, At ail times material to this Complaint, Respondent was a licensed physician within the state of Florida, having been issued license number 58238, J:\PSU\Medical\Elana J, Jones\Cases\Lioyd 09-15096\AC-Lloyd (k).doc Oct 1 2010 14:25 Oct 1 2010 14:21 P.O? 3. Respondent's address of record is 664 Kingsley Avenue, Suite 106, Orange Park, Florida 32073, 4, Section 3384 of the Public Health Service Act (42 U.S.C, 2541) authorized the Secretary of Health and Human Services to provide applicants selected to be participants in the National Health Service Corps (NHSC) Scholarship Program with scholarship awards, 5. On or about August 23, 1982, Respondent signed a program contract (hereinafter “contract”) with the NHSC scholarship program for the 1982-1983 school year, | : 6. The contract required Respondent, in return. for the scholarship award, to provide health services ina manner determined by the Secretary for a period of obligated! service equal: to oe year * for each year of scholarship award received, 7. The contract further stated in Section C, 2, that if the applicant fails to. begin or complete the period of obligated service incurred under the contract for any reason other than those is paragraph 1 of the section, the United States shall be entitled to recover an amount equal to three times the scholarship funds awarded, plus interest. J:\PSU\Medical\Elana J, Jones\Cases\Lloyd 09-15096\AC-Lioyd (k).doc Oct 1 2010 14:26 Oct 1 2010 14:21 P. 08 8. On of about May 19, 1983, Respondent signed an Amendment of the NHSC Scholarship contract, which granted Respondent an aclditional scholarship award for the 1983-1964 and 1984-1985 school years. 9. By accepting the additional award, Respondent agreed to comply with the provisions of the initial scnolarship signed on August 23, 1982, , ! 10. Respondent failed to complete her period of obligated service as required by the contract, : 11. On or about duly 29, 1996, the United States Attorney for the Middle District of Florida filed a complaint against Respondent, in Case number 96-814-CIV-3-20, due to her breach of the NHSC contract. : | , 12, Respondent's financial obligation for support received under the NHSC Program totaled $54,331.00 at that time. : 13. Due to Respondent's breach of the NHSC contract, Respondent's indebtedness to the United States was in the amount of $255,862.11 as of June 30, 1996. 14. On or about November 25, 1997, United States District J:\P5U\Medical\Elana J, Jones\Cases\Lloyd 09-15096\AC-Liayd (k).doe Oct 1 2010 14:26 Oct 1 2010 14:22 P.09 Judge of the United States District Court, Middle District of Florida, Jacksonville Division, issued an amended judgment in favor of the Plaintiff, United States of America, against Respondent in the amount of $270,905.57. | 15, On or about December 1, 1997, the United States of America and Respondent entered into a settlement agreement, 16, Pursuant to the agreement, the United States soreed that Respondent would perform 552 days of full-time clinical services asa family practitioner at Springfield Family Health. Center (SFHC) in Springfield, South Carolina ‘in full satisfaction of the judgment: The agreement states that if Respondent fails to complete 552 days of service at the SFHC, the United States will file a partial satisfaction of judgment statement in an amount determined in accordance with paragraph (5) of the agreement, and will immediately commence ~ execution on the remaining judgment amount still owing, | 17. Ina letter dated on or about duly 8, 2009, Cassancira L. Mitchell, Supervisory Paralegal Specialist in the Financial Litigation Unit of the Office of the United States Attorney, informed the Department that Respondent failed to complete required service J:\PSU\Medical\Elana J, Jones\Cases\Lloyd 09-15096\AC-Lloyd {k).doe Oct 1 2010 14:26 Oct 1 2010 14:22 P.10 hours per the NHSC program. As a result, Ms. Mitchell requested that the Department open an investigative repart on Respondent. 18. Respondent currently owes a balance of $430,982.34 on her NHSC debt. : 19. The last payment Respondent made toward her debt was on or about August 20, 2008. 20. In a letter dated on or about July 27, 200¢, the Department notified Respondent that it received information that she defaulted on a student loan that was issued or guaranteed by the State or Federal government, or a service conditional scholarship or loan repayment agreement. The letter further informed Respondent that she was.to send proof that she cbtained new payment terms from her lender within 45 days, or her license to practice medicine may be suspended via an emergency suspension order. 21. Although Respondent. wrote a response to the Department stating that she was attempting to reach a settlement with the Department of Justice, to date, Respondent has not. submitted proof of new payment terms for her defaulted loan and/or a new settlement agreement. J:\PSU\Medical\Elana J. Jones\Cases\Lloyd 09-15096\AC-Lloyd (k).dac Oct 1 2010 14:26 Oct 1 2010 14:22 P.11 22. Section 456. 972¢1)(K), Florida Statutes (2009), provides that failing to perform any statutory or legal obligation placed upon a licensee constitutes grounds for disciplinary action by the Board of Medicine. For purposes of the aforementioned statutory section, failing to repay a student: loan issued or guaranteed by the state or the Federal Government in accordance with the terms of the loan or failing to comply with service scholarship obligations sha be considered a failure to perform a statutory or legal obligation. 23. At some point after August 20, 2008, Respor ident defaulted on her loan resulting from her failure to comply with the service obligations of the NHSC contract signed on August 23, 1982, and May 19, 1983. | 24, Based on the foregoing, Respondent has Violated Section 456.072(1)(k), Florida Statutes (2009), by failing to perform a statutory or legal obligation. WHEREFORE, Petitioner respectfully requests that the Board of | Medicine enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent’s J:\PSU\Medical\Elana J. Jones\Cases\Llayd.09-15096\AC -Lloyd (k).doc Oct 1 2010 14:27 Oct 1 2010 14:22 Pll? license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. DONE and ORDERED this_ <7" cay of ayy ‘ | 2010. VA SLERK: Cengee at Counsel vente I Sp DOH Prosecution Services Unit — 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar # 0678999 850.245.4640 850.245.4681) FAX PCP: PCP Members: ANTOINETTE LOUISE LLOYD, M.D. CASE NO. 2009-15096 2\PSU\Medical\Elana J, Jones\Cases\Lloyd 09-15096\AC-Llayd (k). doc Oct 1 2010 14:27 Oct 1 2010 14:23 P.13 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 ar ument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her be lalf 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 and costs, on the Respondent in addition to any other discipline imposed. J\PSU\Medical\Blana J, Jones\Cases\Lloyd 09-15096\AC-Lioyd (k).dec

Docket for Case No: 10-009418PL