STATE OF FLORIDA BOARD OF CHIROPRACTIC MEDICINE DEPARTMENT OF HEALTH, PETITIONER, We CASE NO. 2013-05267 WILLIAM ALDEN HALL D.C., RESPONDENT. / ADMINISTRATIVE COMPLAINT The Petitioner, the Department of Health, by and through the undersigned counsel, files this Administrative Complaint against the Respondent, William Alden Hall, D.C., and in support thereof alleges: 1. The Petitioner is the state department charged with regulating the practice of chiropractic medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 460, Florida Statutes. 2. The Respondent is licensed to practice chiropractic medicine in . the State of Florida under license number CH 6817, having been first issued a license on or about July 19, 1994. 3. The Respondent's address of record is 1089 West Granada Blvd., Suite 3, Ormond Beach, Florida, 32174. Page 1 of 10 DOH vy. William Alden Hall, D.C, Case No. 2013-05267 4. On or about January 25, 2013, the Respondent signed a Plea Agreement agreeing to enter a plea of guilty to Count One of the Information, Conspiracy to Commit Money Laundering in violation of 18 U.S.C. Section 1956(a)(1)(A), and 1956(a)(1)(B)(i), and (h), in Criminal Docket Case Number 2:13-cr-00013-UA-DNF-1, United States District Court, Middle District of Florida (Ft. Myers). 5S. On or about February 14, 2013, Respondent pled guilty to Count One of the Information, Conspiracy to Commit Money Laundering in violation of 18 U.S.C. Section 1956(a)(1)(A), and 1956(a)(1)(B)(i), and (h), in Criminal Docket Case Number 2:13-ct-00013-UA-DNF-1, United States District Court, Middle District of Florida (Ft. Myers), 6. On or about February 14, 2013, the Court adjudicated the Respondent guilty of one count of Conspiracy to Commit Money Laundering in violation of 18 U.S.C. Section 1956(a)(1)(A), and 1956(a)(1)(B)(i), and (hy, in Criminal Docket Case Number 2:13-cr-00013-UA-DNF-1, United States District Court, Middle District of Florida (Ft. Myers). 7. The Respondent failed to report his February 14, 2013, guilty plea, and adjudication of guilty, to the Board of Chiropractic Medicine, in writing, within 30 days of the entering of his guilty plea, and being Page 2 of 10. DOH v.William Alden Hall, D.C. — Case No. 2013-05267 adjudicated guilty of Conspiracy to Commit Money Laundering in violation of 18 U.S.C. Section 1956(a)(1)(A), and 1956(a)(1)(B)(i), and (h), in Criminal Docket Case Number 2:13-cr-00013-UA-DNF-1, United States District Court, Middle District of Florida (Ft. Myers). COUNT I — BEING CONVICTED, OR FOUND GUILTY, REGARDLESS OF AJUDICATION, OF A CRIME RELATED TO PRACTICE - 460.413(1)(C) 8. The Petitioner re-alleges and incorporates paragraphs one (1) through six (6), as if fully stated herein. 9. Section 460.413(1)(0), Florida Statutes (2012), subjects a | licensee to discipline for being convicted or found guilty, regardless of adjudication, of a crime in any jurisdiction which directly relates to the practice of chiropractic medicine or to the ability to- practice chiropractic medicine. 10. The Respondent was convicted, and found guilty, of a crime . directly related to the practice of, or the ability to practice, chiropractic medicine on February 14, 2013, when he entered a plea of guilty, and was adjudicated guilty by the court, of one count of Conspiracy to Commit Money Laundering in violation of 18 U.S.C. Section 1956(a)(1)(A), and Page 3 of 10 DOH v.William Alden Hall, D.C. Case No. 2013-05267 1956(a)(1)(B)(i), and (h), in Criminal Docket Case Number 2:13-cr-00013- UA-DNF-1, United States District Court, Middle District of Florida (Ft. Myers). 11. Based on the foregoing, the Respondent violated Section 460.413(1)(0), Florida Statutes (2012), by being convicted or found guilty, — regardless of adjudication, of a crime in any jurisdiction which directly relates to the practice of chiropractic medicine or to the ability to practice chiropractic medicine. | | COUNT IT — PLEADING GUILTY, AND BEING FOUND GUILTY, REGARDLESS OF ADJUDICATION, TO A CRIME RELATED TO PRACTICE — 457.072(1)(C) : 12. The Petitioner’ re-alleges and incorporates paragraphs one (1) through six (6), as if fully stated herein. . 43, Section 456.072(1)(c), Florida Statutes (2012), provides that a. licensee is subject to discipline for being convicted or found guilty of, or entering a plea of guilty or nolo contendere, regardless of adjudication, to a crime in any jurisdiction which relates to the practice of, or the ability to practice, a licensee's profession, 14. The Respondent pled guilty to a crime related to the practice of, or ability to practice, chiropractic medicine on February 14, 2013, when Page4ofi0 ~ DOB v. William Alden Hall, D.C. Case No. 2013-05267 he entered a plea of guilty, to one count of Conspiracy to Commit Money Laundering: in violation of i8 U,S.C. Section 1956(a)(1)(A), and 1956(a)(1)(B)(i), and (h), in Criminal Docket Case Number 2:13-cr-00013- UA-DNF-1, United States District Court, Middle District of Florida (Ft. Myers). 15. The Respondent was found guilty of a crime related to the practice of, or ability to practice, chiropractic medicine on February 14, 2013, when the Court found him guilty of one count of Conspiracy to Commit Money Laundering in violation of 18 U.S.C. Section 1956(a)(1)(A), and 1956(a)(1)(B)(i), and (h), in Criminal Docket Case Number 2:13-cr- 00013-UA-DNF-1, United States District Court, Middle District of Florida (Ft. Myers). | 16. Based on the foregoing, the Respondent violated Section 456.072(1)(c), Florida Statutes (2012), by pleading guilty to, and being found guilty of, regardless of adjudication, a crime in any jurisdiction which relates to the practice of chiropractic medicine or to the ability to practice chiropractic medicine, . Page.5 of 10 DOH v. William Alden Hall, D.C. Case No. 2013-05267 COUNT II — FAILING TO REPORT TO THE BOARD BEING CONVICTED, OR FOUND GUILTY OF A CRIME — 456,072(1)(X) 17. The Petitioner re-alleges and incorporates paragraphs one (1) through seven (7), as if fully stated herein. 18. Section 456.072(1)(x), Florida Statutes (2012), provides that a licensee is subject to discipline for failing to report to the board, or the department if there is no board, in writing within thirty (30) days after the licensee has been convicted or found guilty of, or entered a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction. 19. The Respondent failed to report to the Board, in writing, within 30 days, of February 14, 2013, when he entered a plea of guilty to one count of Conspiracy to Commit Money Laundering in violation of 18 U.S.C. Section 1956(a)(1)(A), and 1956(a)(1)(B)(i), and (h), in Criminal Docket Case Number 2:13-cr-00013-UA-DNF-1, United States District Court, Middle District of Florida (Ft. Myers). 20. The Respondent failed to report to the Board, in writing, within 30 days, of February 14, 2013, when he was adjudicated guilty of one count of Conspiracy to Commit Money Laundering in violation of 18 U.S.C. Section 1956(a)(1)(A), and -1956(a)(1)(B)(i), and (h), in Criminal Docket Page 6 of 10 DOH v. William Alden Hall, D. C. Case No. 2013-05267 Case Number 2:13-cr-00013-UA-DNF-1, United States District Court, Middle District of Florida (Ft. Myers). | 21. Based on the foregoing, the Respondent violated Section 456.072(1)(x), Florida Statutes (2012), when he failed to’ report to the Board, in writing, within 30 days, his guilty plea to, and adjudication of guilt to, one count of Conspiracy to Commit Money Laundering in violation of 18 U.S.C. Section 1956(a)(1)(A), and 1956(a)(1)(B)(i), and (h), in Criminal Docket Case Number 2:13-cr-00013-UA-DNE-1, United States District Court, Middle District of Florida (Ft. Myers). WHEREFORE, the Petitioner respectfully requests that the Board enter an order imposing one or more of the following penalties: permanent revocation or suspension of the 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 Board deems appropriate. Page 7 of 10 DOH v, William Alden Hall, D.C. Case No, 2013-05267 HA SIGNED this /.3 _ day of Ober 2013. John H. Armstrong, MD, FACS Surgeon General and Secretary __ — Tari Rossitto-Van Winkle, R.N., J.D. Assistant General Counsel Florida Bar #06139908 Florida Department of Health Office of the General Counsel 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-1701 Telephone (850) 245-4444 ext. 8139 Facsimile: (850) 245-4681 tari.rossitto-vanwinkle@flhealth.goy FILED DEPARTMENT OF HEALTH DEPUTY CLERK CLERK Angel Sanders pate OCT 1 5 2013 PCP: October 10, 2013 PCP Members: Kevin Fogarty, D.C., & Wayne Wolfson, D.C. . Page 8 of 10 DOH v. William Alden Hall, D.c. : Case No. 2013-05267 NOTICE OF RIGHTS Respondent has the right to request or petition for a formal 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, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a formal administrative hearing is requested. Administrative hearings are governed by Rule 28-106, Florida Administrative Code, A request or petition for an formal administrative hearing must be in writing and must be received by the Department 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: Tari Rossitto-Van Winkle, R.N., 1 D. 4052 Bald Cypress Way, Bin #C65 Tallahassee, Florida 32399-1701 Mediation is not available as an alternative remedy. If your request or petition for a formal administrative hearing is not received by the Department within twenty-one (21) days from your receipt of this Administrative Complaint, that failure will constitute a waiver of your right to a formal administrative hearing, and the Administrative Complaint will be incorporated in — the final order of the Board. - : _ Page 9 of 10 DOH v. William Alden Hall, D.C. Case No. 2013-05267 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. Page 10 of 10. DOH v. William Alden Hall, D.C. Case No. 2013-05267

Docket for Case No: 14-001930PL