STATE OF FLORIDA DEPARTMENT OF HEALTH BUREAU OF EMERGENCY MEDICAL OVERSIGHT DEPARTMENT OF HEALTH, PETITIONER, v. — _.. CASE NO. 2017-10610 WILLIAM J. LITSCH, PMD., . RESPONDENT. ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint against Respondent, William J. Litsch, P.M.D., and in support thereof — i. Petitioner Is the state agency charged with regulating paramedics pursuant to Section 20.43, Florida Statutes (2017); Chapter 401, Florida Statutes (2017); and Chapter 456, Florida Statutes (2017). ) 2. At all times material to this Administrative Complaint, Respondent was certified as a paramedic within the state of Florida, -and was Issued certificate number PMD16223. 3. — Respondent's address of record Is 763 Tumblebrook Drive, Port Orange, Florida 32127. 4, On or about June 16, 2017, the Department received confirmation that Respondent defaulted on a student loan provided by the state or federal goverment. 5. Section 456.072(1)(k), Florida Statutes (2017), provides that failing to perform any statutory or legal obligation placed upon a licensee constitutes grounds for disciplinary action. For purposes of this section, failing to repay a student loan Issued or guaranteed by the state or the Federal Government in accordance with the terms of the loan or falling to comply with service scholarship obligations shall be considered a failure to perform a statutory or legal obligation, and the minimum disciplinary action imposed shail be a suspension of the license until new payment terms are agreed upon or the scholarship obligation is resumed, followed by probation for the duration of the student loan or remaining scholarship obligation period, and a fine equal to 10 percent of the defaulted loan amount. 6. As set forth above, Respondent failed to perform a statutory or legal obligation when he defaulted on a student loan provided by the state or federal government on or about June 16, 2017. Department of Health v. William J. Litech, 2.M.D, 2 Case No. 2017-10618 7. Based on the foregoing, Respondent has violated Section 456.072(1)(k), Florida Statutes, by falling to perform any statutory or legal obligation placed upon a licensee. . WHEREFORE, the Petitioner respectfully requests that the Department enter an order Imposing one or more of the following penalties: permanent revocation or suspension of Respondent's certificate, 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. ) SIGNED this [5 day of _Decowber 20) Celeste Philip, M.D., M.P.H. . { and Secretary Assistant General Counsel Fla. Bar No. 105920 Florida Department of Health FRED Office of the General Counsel DEPARTMENT OF HEALTH 4052 Bald Cypress Way, Bin C-65 CLERK AmberGreene Tallahassee, Fl. 32399-3265 care’ “DEC 1 3 2017 Telephone: (850) 558-9842 Facsimile: (850) 245-4684 Email: Rose.Garrison@fihealth.gov PCP: December 12, 2017 : PCP Members: Steve McCoy Depertment of Health v. Wiliam 3. Utsch, P.MD. Case No. 2017-10610 NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in sccondence with Section £20,500 and 220.37, Horie an ti oe nepregeetad Sy cotneel or ote sunised 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. 5 A request or petition for an administrative hearing must be in writing and must be received by the Department within 21 days from the day Respondent recelved the 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 walves the right to request a hearing on the facts alleged In this Administrative comple 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 the 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 is placed on notice that Petitioner has Incurred | and on the Respondent in addition to any other discipline imposed. Departnent of Health v. Wiliam J. Ltsch, P..D. . 4 Case No, 2017-20610

Docket for Case No: 18-000607PL