STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Petitioner, v. DOH Case No. 2015-11822 SAYED ARIF ALI JAFFERY, M.D., Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, the Florida Department of Health (hereinafter “Petitioner”), files this Administrative Complaint before the Florida Board of Medicine (hereinafter the “Board”) against Respondent, Sayed Arif Ali Jaffery, M.D. (hereinafter “Respondent”), 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, and Chapters 456 and 458, Florida Statutes. 2. — Atall times material hereto, Respondent was a licensed physician within the state of Florida, having been issued license number ME 91784. 3. | Respondent's address of record is 109 Trotter Road, Egg Harbor Township, New Jersey 08234. 4. Atall times material hereto, Respondent was a licensed physician within the state of New Jersey, having been issued license number 25MA07825500. 5. The licensing authority regulating the practice of medicine in the state of New Jersey is the State Board of Medical Examiners, located within the New Jersey Division of Consumer Affairs, New Jersey Department of Law and Public Safety (hereinafter the “New Jersey Board”). 6. On or about March 11, 2015, the New Jersey Board and Respondent agreed to, and entered into, an Interim Consent Order. 7. The Interim Consent Order, among other things, suspended Respondent's license or authority to practice medicine and surgery in the state of New Jersey. 8. The Interim Consent Order constitutes action by the New Jersey Board against Respondent's license or authority to practice medicine and surgery in the state of New Jersey. 9. Section 458.331(1)(b), Florida Statutes (2014), subjects a licensee to discipline for 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, including its agencies DOH v. Sayed Arif Ali Jaffery, M.D., DOH Case Number 2015-11822 Administrative Complaint 2 or subdivisions. The licensing authority’s acceptance of a physician’s relinquishment of a license, stipulation, consent order, or other settlement, offered in response to or in anticipation of the filing of administrative charges against the physician’s license, shall be construed as action against the physician's license. 10. Based on the foregoing, Respondent violated Section 458.331(1)(b), Florida Statutes (2014), by having his license or authority to practice medicine and surgery in the state of New Jersey suspended and/or otherwise acted against by the licensing authority of the state of New Jersey. WHEREFORE, Petitioner respectfully requests the Board enter an order imposing one or more of the following penalties: 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 the Board deems appropriate. {Signature appears on next page.] DOH v. Sayed Arif Ali Jaffery, M.D., DOH Case Number 2015-11822 Administrative Complaint 3 SIGNED this 2" day of _— AUGUST , 2016. Celeste Philip, M.D., M.P.H. State Surgeon General and Secretary Geoffrey M. —— Esq. Assistant General Counsel Florida Bar No. 0010325 FILED Department of Health rem Prosecution Services Unit aK tngel S 4052 Bald Cypress Way, Bin C-65 even wuG 29 20'6 L- Tallahassee, Florida 32399-3265 a Telephone (850) 245-4640, ext. 4661 Facsimile (850) 245-4684 E-mail Geoffrey.Christian@flheaith.qov Attorney for Petitioner PCP: August 26, 2016 PCP Members: G. El-Bahri, M.D.; J. Orr, Jr, M.D.; Ms. B. Goersch DOH v. Sayed Arif Ali Jaffery, M.D., DOH Case Number 2015-11822 Administrative Complaint 4 DOH V. SAYED ARIF ALI JAFFERY, M.D. DOH CASE NUMBER 2015-11822 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. A request or petition for an administrative hearing must be in writing and must be received by the Department of Health within 21 days from the day Respondent received this Administrative Complaint, pursuant to Rule 28-106.111(2), Florida Administrative Code. If Respondent fails to request a hearing within 21 days of receipt of this Administrative Complaint, Respondent waives the right to request a hearing on the facts alleged in this Administrative Complaint pursuant to Rule 28-106.111(4), Florida Administrative Code. Any request for an administrative proceeding to challenge or contest the material facts or charges contained in this Administrative Complaint must conform to Rule 28-106.2015(5), Florida Administrative Code. Mediation under Section 120.573, Florida Statutes, is not available to resolve this Administrative Complaint. 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 of Medicine shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on Respondent in addition to any other discipline imposed. DOH v. Sayed Arif Ali Jaffery, M.0., DOH Case Number 2015-11822 Administrative Complaint 5

Docket for Case No: 17-002556PL