FILED Department of Business and Professional Regulation Deputy Agency Clerk STATE OF FLORIDA cum Og ‘vette Lawson-Proctor DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATY pate 12/14/2011 File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, Vv. Case No. 2011-004922 SCOTT GREGORY, D.V.M., Respondent. ADMINISTRATIVE COMPLAINT The Department Of Business and Professional Regulation (“Petitioner”) files this Administrative Complaint before the Board of Veterinary Medicine against Scott Gregory, 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 5374. 3. Respondent's address of record is 11216 Tamiami Trail #113, Naples, FL 34110. Filed September 21, 2012 9:33 AM Division of Administrative Hearings MATERIAL FACTS 4, On October 21, 2010, the South Carolina Board of Veterinary Medical Examiners filed a Formal Complaint against Respondent. 5. The South Carolina Board of Veterinary Medicine alleged that Respondent’s further practice presents a danger to the public, that Respondent practiced veterinary medicine while under the influence of alcohol or drugs, and that Respondent engaged in unprofessional or unethical conduct. 6. On January 20, 2011, Respondent signed an Agreement to Voluntarily Relinquish License to Practice Veterinary Medicine with the South Carolina Board of Veterinary Medical Examiners. 7. On January 26, 2011, The South Carolina Board of Veterinary Medical Examiners issued an Order of Relinquishment against the Respondent. 8. Respondent failed to report this discipline within thirty (30) days to the Florida Board of Veterinary Medicine. COUNT I 9, Petitioner realleges and incorporates by reference the allegations sel forth in paragraphs one (1) through eight (8) as though fully set forth herein. 10. Section 474,.214(1) (b), Florida Statutes (2009), nv provides: [hlaving a license or the authority to practice veterinary medicine revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of any jurisdiction, including any agency or subdivision thereof” is grounds for discipline. 11. Based upon the facts set forth above, Respondent violated Section 474.214(1) (b), Florida Statutes (2009), when the South Carolina Board of Veterinary Medical Examiners issued an Order of Relinquishment against the Respondent. COUNT IT 12. Petitioner realleges and incorporates by reference the allegations set forth in paragraphs one (1) through ecight (8) as though fully set forth herein. 13. Section 474.214(1) (33), Florida Statutes (2009), uw states: [fJailing to report to the board within 30 days, in writing, any action set forth in paragraph (b) that has been taken against the practitioner's license to practice veterinary medicine by any jurisdiction, including any agency or subdivision thereof” is grounds for discipline. 14. Based upon the facts set forth above, Respondent violated Section 474.214(1) (jj), Florida Statutes (2009), when he failed to report the disciplinary action taken against him to the Florida Board within 30 days. 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, 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 associated with an attorney’s time or any other relief that the Florida Board of Veterinary Medicine is authorized to impose pursuant to Chapters 455 and 474, Florida Statutes, and the rules promulgated thereunder. Signed this 8°" day of December, 2011. KEN LAWSON, Secretary Department of Business and Professional Regulation By: Elizabeth Fletcher Henderson 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) 717-1189 Facsimile: (850) 414-6749 PC Found: November 2, 2011 PC Found By: EFH EFH/maf 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 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 of 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 to 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.

Docket for Case No: 12-003150PL