STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, ve CASE NO. 2013-01909 WILLIAM ARNOLD GREENE, P.M.D., RESPONDENT. —— ADMINISTRATIVE COMPLAINT Petitioner, Department of Health, by and through undersigned counsel, files this Administrative Complaint before the Department of Health, Bureau of Emergency Medical Technicians and Paramedics, against Respondent, William Arnold Greene, P.M.D., and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of paramedics pursuant to Section 20.43, Florida Statutes (2012); and Chapter 401, Florida Statutes (2012). 2. At all times material to this Complaint, Respondent was certified to practice as a paramedic within the state of Florida, having been issued certification number PMD 19010. 3. Respondent's address of record is 800 SE Monterey Road, Stuart, Florida 34994. 4. For approximately one-and-one-half years, through December 2012, Respondent molested a minor child. He also solicited the minor child for sex on at least one occasion. 5, On or about January 3, 2013, a Port Saint Lucie Police Department (“PSLPD”) officer interviewed the minor child‘s mother (the mother). The mother stated that on or about January 2, 2013, her minor child told her that Respondent had been touching her vaginal area, breast and buttocks on many occasions, over a period of one-and-one-half years, 6. The minor child also told her mother that Respondent asked her to look at his penis, unzipped his zipper and asked her to have sex with him. 7. The minor child told her mother that five months prior to the interview with PSLPD, Respondent became angry and threatened to kill the child, her mother and her grandmother. The minor child told her mother that Respondent told her that he would go on a “shooting spree” and “kill anyone”. Respondent owns a handgun, a shot gun, a rifle and an AR-15 semi-automatic rifle. 8. Onor about January 3, 2013, PSLPD officers also interviewed the minor child. Her statements were consistent with her mother’s report. The child provided specific details of acts of molestation that Respondent committed and of her protestations and refusals to have sex with him. She also referenced some estimated dates of sexual molestation during the months of September through November of 2012. She stated that the last incident occurred on December 26, 2012, when Respondent kissed her inappropriately. The minor child also wrote a sworn statement summarizing how Respondent touched her on the genitals and the statements that he made towards her. 9. Subsequently, a PSLPD detective conducted a controlled call wherein the minor child called Respondent with her mother and a victim advocate present. The police attached a recording device to the minor child’s cell phone. 10. During the call, Respondent made several incriminating statements. When the minor child summarized what Respondent had done to her and asked him why he did it, Respondent did not deny that the incidents occurred. Instead, he stated repeatedly, “that will never happen again.” He also stated, “I do apologize,” “I have had problems with it,” “I know it’s wrong,” “I can’t explain it,” “If I knew I would tell you,” and “I got carried away.” During the controlled call, Respondent also made reference to committing suicide. 11. On or about January 3, 2013, PSLPD arrested Respondent and charged him with three counts of lewd and lascivious molestation and one count of lewd and lascivious conduct. 12. Respondent has a concealed weapons permit and PSLPD removed a gun from his person and placed it into evidence upon his arrest. 13. As of the date of this Order, criminal charges remain pending again Respondent in the Nineteenth Judicial Circuit of Florida, in St. Lucie County, in Case Number 56201 3CFOQ0046AXXXXX, 14. Section 401.411(1)(k), Florida Statutes (2010-2012), subjects a certified paramedic to discipline for practicing as an emergency medical technician, paramedic, health care professional, or other professional operating under this part without reasonable skill and without regard for the safety of the public by reason of illness, drunkenness, or the use of drugs, narcotics, or chemicals or any other substance or as a result of any mental or physical condition. 15. Respondent practiced as a paramedic without reasonable skill and without regard for the safety of the public by reason of illness or as a result of any mental condition. Respondent’s conduct, namely engaging in acts of molestation and threatening to engage in a “shooting spree,” demonstrate a severe mental disturbance such that Respondent is unable to practice as a paramedic without posing an immediate serious danger to the health, safety, or welfare of the public. WHEREFORE, Petitioner respectfully requests that the Department enter an order imposing one or more of the following penalties: permanent suspension of Respondent’s license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Department deems appropriate. SIGNED this 28> day of _Yarch _, 2013. John H. Armstrong, MD State Surgeon General and Secretary of Health Jertifer L? Friedberg Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 FILED ENT OF HEALTH DEPART PUTY CLERK Tallahassee, FL 32399-3265 CLERK Anes! sens Florida Bar # 0021640 DATE S wo (850) 245 — 4444 x8141 Phone (850) 245 - 4662 Fax PCP: March 28, 2013 PCP Members: Reheadc Cash, Wendy Forkiagon + Richey Sone NOTICE OF RIGHTS Respondent has the right to request or petition for an administrative hearing to be conducted in accordance with Sections 120.569 and 120.57, Florida Statutes. Respondent has the right to be represented by counsel or other qualified representative. Administrative hearings are governed by Rule 28-106, Florida Administrative Code. A request or petition for an administrative hearing must be in writing and must be received by the Agency Clerk within twenty-one (21) days from the day you received this Administrative Complaint. A request or petition for a hearing must be in conformance with Chapter 28-106.2015(5), Florida Administrative Code and must be sent to the Department at the following address: Department of Health Prosecution Services Unit Attention: Jenifer L. Friedberg, J.D. 4052 Bald Cypress Way, Bin #C65 Tallahassee, Florida 32399-1701 Mediation is not available as an alternative remedy. Your failure to submit an a petition or request for a formal hearing (Election of Rights) within 21 days from receipt. of this Administrative Complaint will constitute a waiver of your tight to a hearing, and this complaint will thereby become a final order of the Department.

Docket for Case No: 13-002245PL