STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO.: 2013-13578 NAINA SACHDEY, M.D., RESPONDENT. ADMINISTRATIVE COMPLAINT Petitioner Department of Health files this Administrative Complaint before the Board of Medicine against Respondent, Naina Sachdev, M.D., and In support thereof alleges: 1. Petitioner is the state agency 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 all times material to this Complaint, Respondent was a licensed medical doctor within the state of Florida, having been Issued license number 113530. 3. Respondent's address of record Is 15524 Village Drive, Lake Oswego, OR 97034. 4. The Oregon Medical Board Is the licensing authority regulating the practice of medicine in the State of Oregon. 5. On or about October 02, 2014, the Oregon Medical Board entered a Final Order which revoked Respondent’s license to practice medicine in Oregon. 6. The October 02, 2014, Final Order entered by the Oregon Medical Board constitutes action against Respondent's license to practice medicine in Oregon. 7, Section 458.331(1)(b), Florida Statutes (2014), sets forth the grounds for disciplinary action by the Board of MedicIne and provides that having a license or the authority to practice medicine revoked, suspended, or otherwise acted against, Including the denial of licensure, by the licensing authority of any jurisdiction constitutes grounds for discipline. 8. Respondent's license to practice medicine in Oregon has been revoked by the Oregon Medical Board. 9, Based on the foregoing, Respondent has violated Section 458.331(1)(b), Florida Statutes (2014), by having had the licensing authority of Oregon revoke her license. WHEREFORE, Petitioner respectfully requests that the Board of Medicine enter an order imposing one or more of the following penalties: DOH v. NAINA SACHDEV M.D, 2 DOH Case No. 2013-13578 permanent ‘revocation or suspension of Respondent's 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. jel aie SIGNED this _/77” _ day of \(_ -ceMER._, 2014. John H. Armstrong, MD, FACS State Surgeon General and Secretary of Health Ct ca Seer Arielle E. Davis Assistant General Counsel FILED Florida Bar No. 88605 DEP AW CLERK DOH-Prosecution Services Unit . . 4052 Bald Cypress Way-Bin C-65 oxen: Suck Contes (850) 245-4444, Ext. 8201 _ cs (850) 245-4684 fax pare /A- 2-201 E-Mail: Arlelle.Davis@flhealth.gov AED PCP: December 19, 2014 PCP Members: Georges El-Bahri, M.D.; Servam Terkonda, M.D.; Joy Tootle DOH v. NAINA SACHDBV M.D, 3 DOH Case No, 2019-13578 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 argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf 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. DOH v, NAINA SACHDEV M.D. 4 DOH Case No, 2013-13578

Docket for Case No: 15-004941PL