FILED

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Deputy Agency Clerk

CLERK Evette Lawson-Proctor

Dato 4/22/2011

File#

STATE OF FLORIDA

DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION

DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION,

Petitioner,

vs. Case No. 2010-046830

Respondent.

                                                                      /

ADMINISTRATIVE COMPLAINT

The Department Of Business and Professional Regulation ("Petitioner") files this Administrative Complaint before the Board of Veterinary Medicine against Philip Aleong, 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. 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 6466.

3. Respondent's address of record is 4917 Roosevelt Street, Hollywood, FL 33021.

4. Respondent's license to practice veterinary medicine was suspended from July 29, 2010, to August 8, 2010.

   
   

   
   

5. Respondent treated and prescribed medicine to an equine patient on August 7, 2010.

6. Section 474.214(1)(g), Florida Statutes (2009), states: Practicing with a suspended license" is grounds for disciplinary action.

474.214(1)(g), Florida Statutes (2009), when he practiced August 7, 2010, while his license was suspended.

on

WHEREFORE, Petitioner respectfully requests the Veterinary Medicine Board enter an order imposing one or more of the following penalties: suspension or permanent revocation or of Respondent's license, restriction of Respondent's practice, imposition of an administrative fine not to exceed $5,000 for

each count or separate offense,

,-1

issuance of a reprimand,

placement of Respondent on probation subject to specified conditions, corrective action, assessment of costs related to the investigation and prosecution of the case excluding costs

pursuant to Chapters 455 and 474, Florida Statutes, and the rules promulgated thereunder.

Signed this 19th day of April, 2011.

CHARLIE LIEM, Secretary Department of Business and

Professional Regulation

associated with an attorney's time or any other relief that the Florida Board of Veterinary Medicine is authorized to impose

By: !£[iza6etfi Pwtcfier Jfencferson

ELIZABETH FLETCHER HENDERSON

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

PC Found: March 23, 2011

PC Found By: K. Jones and c. Lewis EFH/del

NOTICE OF RIGHTS

Respondent has the right to request a hearing to be 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

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 of an agency pleading,

Respondent waives the right to request a hearing on the facts

I'."

alleged.

NOTICE REGARDING ASSESSMENT OF COSTS

Respondent is pfaced on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 455.227(3)(a), Florida Statutes, the Board, or the Department when there is no Board, may assess costs related to the' nvestigation and prosecution of the case excluding costs assod'iated with an attorney's time, against the Respondent in addition to any other discipline imposed.

Docket for Case No: 12-000003PL