STATE OF ILLINOIS DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION DIVISION OF PROFESSIONAL REGULATION DEPARTMENT OF FINANCIAL AND. ) PROFESSIONAL REGULATION ) (of the State of Minas, ‘Complainant, ¥ No. 2015.05720 ‘ANDREW JOSEPH KAISER Il, D.W.M. ) License No. 090.004608, ‘Respondent, ) COMPLAINT. NOW COMES THE DIVISION OF PROFESSIONAL REGULATION of the DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION of the Stale of ilinois ¢-Department"), by its Chit of Health-Relatd Proseeujns, and a ts Complaint against ANDREW JOSEPH KAISER referred to as “Respondent”, complains as follows: .M USE THESKILL AND CARE IN ‘BY A REASONABLY WELL-QUALIFIED IS AWHCHL TE PRACTICES Deparment. Respondent's license is currently ative. 2 Atall times bereinretevunt, the Department had the legal authority and jurisdiction to investigate complainis and to bring this action pursuant to the Veterinary Medicine ‘and Surgery Practice Act of 2004, 225 ILCS 15/1 et seg, and the administrative rules adopted by the Department in furtherance thereof, 68 Ill, Admin, Code 15005, et seg Page 1 of3. Respondent offers and provides, oc in the past did offer veterinary services within the ‘State of Iino. ‘he Deparment ressved a complaint pacing the ston leged erin ono about aly 7, 2005. 5. AL al simes herein iclewam, Reapondcat was the owner of Katine Read Animal Hospital (Katherine Road”) 6 Patient “Madeline” was brought 10 Katherine Road t be 7. Respondent performed the surgical procedure 1 ad nea ano & a rover, % Respondent also did noi on @ Madeline after the declawing procedure Apply the knowledge and use the skill and care in wating 8 ily used by a reasonably well qualified veterinarian inthe lovality he practves, 11. The foregoing acts andlor omissions are grounds for revocation or suspension of a license to practice asa veterinarian pursuant to 225 ILCS 115/25(1XIhas defined by {68 IL, Admin, Coxe SON SOAK). WHEREFORE, based on these allegations, the Department of Financial and Professional Regulation of the State of Minos, by Danicl Faermark, its Chief of Health-Related Prosecutions, rays that the veterinarias lisense of ANDREW JOSEPH KAISER Ill, D.V.M. be revoked, suspended, placed on probation or otherwise disciplined Page 20f 17couNT (CHANGING POR PROFESSIONAL SERVICES NOT RENDERED, INCLUDING FILING FALSE. STATEMENTS FOR THE COLLECTION OF FEES, FOR WIHICH SERVICES ARE NOT RENDERED, 1-5. The Department restates and realleges Paragraphs one through five (1-5), inclasive, of Count I of this complaint as Paragraphs ane through five (1-5), inclusive, ofthis ‘Count IL as if each were fully restated berein. 6 Onor about February 11, 2014, patent “Nakits" was scheduled to be euthanized and busied by Respondent 7. Nakita’s oomer was charged for both euthunization and burg) before the procedures took place. & Afier Respondent cuthanized Nakita, iakita's body in a ‘durmpett instead af burying the 9. Respondent charged Nakitagowfig for al service of burial and did not renderinat seven. (@) 10. The foregaii 4 are grounds for evocation or suspension of Tense t naran pursuant vo 225 ILCS 118/28(1XL.). WHEREFORE, ‘hese allegations he Department of Financial and Profesional Regulation ofthe State of Hino, by Daniel Facrmar, its Chief of Health Relsted Prosecutions, prays that the veterinarian lieense of ANDREW JOSEPH KAISER Ill, D.V.ML, be revoked suspended, placed on probation or otherwise disciplined Page 30817COUNT FAILURE TO POSSESS AND APPLY THIE KNOWLEDGE AND USE THI SKILL. AND CARE IN “TREATING A CONDMION THAT IS ORDINARILY Use ny a Reasoxamty WetL-QUALIFIED ‘Viermianean a8 rit LocaLtty in WHICH ITE PRACTICES 1S, The Department restates and realleges Paragraphs ene through five ‘of Court I ofthis complaint as Paragraphs one through five (1-5), fnchusve, of this 5}, inclusive, Coun V a if ach wer fly estate bein {6 Omer about August 14,2015, client “IH.* brought his dog to Katherine Road Asia Hospital tobe inocula ant newtered 71. The ptt bit Respondent's pant leg while he was tempting sedate he patient. & Respondent wrapped a feash around the patients sagt and times and tied it in a kos. 9. Respoadent Taft the leash ted and eck during the procedure. 10. Because ofthe k a). 8 snout and peck, Respondent and is em an oxypen mask onto the patient or chesk Nis vil 11. The foreanin Ruane omissions ae gods for revocation or suspension of 2 license to practice as veterinarian pursuant to 225 HLCS L128) a defines by 64M Admin, Code 30.588) WHEREFORE, based on thes alleptins, he Deparment of Finacial and Professonal Regulation ofthe State of lina, by Dan Facrmark is Chief of Healit-Relaed Proseotons prays thatthe veterinarian license of ANDREW JOSEPH KAISER If, D.V.M, be reeked suspended, placed oa probation or otherwise disciplined. Page 4 of 17Faituge To Passess axp APPLY THE KNOWLEDGE AND USE THESKILL AND CARE IN “TREATING 4 CONDITION THAT IS ORDINARILY USED BY A REASONAMLY WELL-QUALIFIED “VREERINARIAN INTHE LOCALITY ay Witici He PRACTICES 1S. The Department restates and realleges Paragraphs one through five (165), inclusive, cof Count I of this complaint as Paragraphs one through five (1-5), inclusive, of this Count IV as if each were fully restated herein. (Ont about July 9, 2013, patient “Roxie” was surrendered for adoption to Katherine Road 7. Oner about Jly 14,2015, Respondent perfore «sui swspay Roxie Aer Respondent performed the procedure, Rox ine fom the inssion pint ofthe procedure. 9. Inanastemptt sop the ng the incision pnt ‘with bandage material and 13. Rawie’s death was the result of respondent's actions, inactions, and instrecton to the stall encenbers 14. Respondent failed to possess and apply the knowledge and use the skill and eare in trexting a condition tha is od ily used by a reasonably well-qualified veterinarian inthe locality in which he practices, Page 5 of 1715, The foregoing acts andor emissions are grounds for revocation or suspension of 2 license to practice asa veterinarian pursuant to 225 ILCS 115/25(1Xf) as defined by 68 I, Admin, Code $00.50 (8). WHEREFORE, based on these allegations, the Department of Financial and Professional Regulation of the State of Elinois, by Dan Fuermark, its Chief of Health-Related Prosecutions, prays that the veterinaras lisense of ANDREW JOSEPH KAISER I, D.V.M, be revoked, suspended, placed on probation or otherwise disciplined COUNTY, [FAILURE TO Possess AND ArrLy THE KAOWLEDGE AND. (of Count I of this complai five (1-5), inclusive, of this Counc ¥ ait 6 Onsea t ive wa admit to Kathrine Road 1 have anal 2. tn adn gland removal, Respondent slso exec foeten (14) ith from Oliver. Respondent did not hve consent from Oliver's owner to extract he teth 9, Respondent did not suture Otiver’s gums after Respondent performed the extraction. 10, Aer the procedure, Oliver was placed on a rag an the floor ofthe treatment room for recovery. 11 Oliver was Heft on the rag. and Respondent id mot check on Oliver's afler the procedure. Page 6.0f 1712 Respondents flre to suture Oliver's guns fed 1 Over bleeding to death 13. After Oliver's death, Respondent placed Ofiver's boty in a plastic bag on the fleor of the treatment om Fr aver bo (2) ays 14 Respondent fale to possess and apply the knowledge and use the skill and care in treating a condition that is ordinarily used by a reasonably well-qualified veterinarian inthe locality in whish he pestoes, 15. The foregving acts andlor omissions are rounds far revocation oc suspension of license o practice asa veterinarian pursue to 225 FLES 115725(1\() as defined by (681, Admin, Code $00,5048(8), WHEREFORE, based on these allegations, the Regulation ofthe State of fino, by Daniel ftb-Related Prosecutions, prays that the veterinarian license of ISER Il, BLV.M,, be revoked, suspended, placed on probat . COUNT VI Faibune 10 AND ALE EQUIPMENT THEREISIN A CLEAN AND SANITARY 15, The Department restates and realleges Paragraphs one through five (1-8), inclusive, of Count 1 of this complaint 2s Paragraphs one through five (15), inclusive, of this Count Vas ifeach were fully resized herein, 6 On or about June 30, 2015, patient “June” vas Brought to Katherine Road from a farm in Missouri. 7. In addition, irteen (13) puppies were brought in with June ‘Upon arrival, nether June nor the puppies had any vaccines or health certificates. Page 7of 17‘Respondent had June and the thirteen (13) puppies placed in an 10. The isolation room in which June and the thirteen (13) puppies were placed is sed for sanine parvovirus eases. 11, Respondent fled to disinfect the room before placiag June and her 13 poppies inthe 12. Subsequently, June and the shimeen (13) puppies contracted the canine parvovirus ‘after being placed inthe infected isolation room by Respondent. 15. The Respondent failed to keep one's premises and all equi therein in a clean and sanitary conliéon. 14, The foregoing acts aloe emissions are ‘or suspension of a cen to prtice asa veteina 182511), WHEREFORE, bust on of Financial and Profesional Regulation of the State of i it Chet of Health-Related Prossstions, rays that he ws i EW JOSEPH KAISER Ill, BAM, be revoked, suspended, placed on bor otherwise disciplined COUNT VI FAILUME TO POSSESS AND AFFLY THE KNOWLEOGE ANDUSE-TIE SKILL ANDCARE IN "TREATING « CONDITION THaT is OxwrvaniLy Useo oy a Reasowan.y Writ-QuaLrieD “VETERINAREAN INTHE LOCALITY 18 WHICH ELE PRACTICES 1-8, The Department restates and realleges Paragraphs one through eight (1-8) inchusive, cof Count VI ofthis complaien as Paragraphs one through eight (1-8), inclusive, ofthis Count ‘each ware Fully restated herein, Page 8 of 179. Respondent foiled to possess and apply the knowledge and use the skill and care in treating & condition that is ordinarily used by a reasonably well-qualified veterinarian in the locality in which he practices, 10. The foregoing acts andlor omissions are grounds for revocation of suspension af & ticense to practice as a veterinarian pursuant to 225 ILCS 115/25(1KI) a5 defined by (681, Admin, Code $00.50aX8), WHEREFORE, based on these allegations, the De Regulation of the State of Hlinois, by Dan Faermark, lated Prosecutions, rays tht the veterinarian license of ANDR TKNOWLEDCE AND USE THESKILL AND CARE IN Ohm vanaty Use ny « REASONAMLY WELL-QUALIFIED te LOCALITY IN WHiCM He PRACTICNS Count I of this complaint as Paragraphs one through five (1-5), inclusive, of this Count VIII ac ifeach were fully restated herein, ‘6, Onor about Deceenber 31, 2014, patient “Coco” was acimited to Katherine Road. 7. On or about January 19, 2015, Cooo was scheduled to undergo a procedure to have a Jump removed. 8. Respondent performed said procedure on Coco, 9. After the procedure, the incision point ef the proceiure continued to hernoerhage. 10, Respondent began continually wrapping the incision point with baedage material an Page 9 of 1711, The incision continued to bemarshage through the bandage materi and owas. 12.lnsead of atiempting to discover why the incision sontoued to hemorrhage, Respondent lef Coc cage and Respndent ef forthe dy. 13. Respondrat hile to possess and apply she knowledge aod use he sil and care in traing a condition that is ordinarily used bya reasonably well-qualified veterinarian in the locality in which he pracies 14. The foregoing ast andor omissions are gzounds for reveeaton or suspension ofa Tints to practice as a veterinarian parma to 225 LCS 11872(1XI) as definad by 681, Admin. Code $0.545x. WHEREFORE, based on these allegations, the De Regulation ofthe Stute of Hlnois, by Daniel Facrpark’ rays that the veterinarian license of ANI ‘Suspended, placed on probation or KNOWLEDGE ANDIUSE THE SKILL AND CARE IN ‘OuprvaniLy USED iy A REASONABLY WELL-QUALIFIED NIN THE LOCaLATY iw Watcn Hr Practices 1}. The Depariment restates and realleges Paragraphs one through five (1), inclusive, ‘of Count I of this complaint as Paragraphs one through five (I-S), inclusive, ofthis ‘Count IX asf each wer fully restated herdin. 6 On of about May 21, 2015, patent * because Little Boy had difficulty breathing. tle Boy" was admited to Katherine Road 7. Patients that have cificulty breathing are considered critical cases at Katherine Road Page 10 of 17|& When Little Boy was brought to Responéent for evaluation, Respondent told a staff ‘member to put Little Boy in a sage far Respondent to acres later, 9. Respondent left Little Boy in the cage for over two (2) hours befure another staff ‘member noticed that Lite Boy had not been treated. 10. Little Boy should have been Ueatod immediately upon arival and not left in a cage because Little Boy was considered a ertical ease 11. Respondent failed um possess and apply the knowledge and use the skill and care in treating a condition that isondinarly used by a reasonably well-qualified veterinarian in the locality in which be practices 12. The foregoing acts andor omissions are ion of a Ticense to practice as 4 veterinarian (IE) a defined by {68 I, Admin, Code $00.50(8)8) WHEREFORE, based on of Financtal and Professional its Chief of Health-Related Prosecutions, Regulation of the State of prays that the vet EW JOSEPH KAISER Ill, DLV.M, be revoked, saspended, placed on ‘therwise disciplined. count x Uvenorissional Coxpucr 1:8. The Department restates and relleges Paragraphs one trough fe (8), inehsve, of Count 1 ofthis complain x Paragraphs one though ive (1) inclusive, of his Cou X asi each were ily estate erin 6. Onor about Oewber 22,2015, Responder vaccinated pt bal bree dog atthe Ciy of Quincy Asimal Shelter, Paget of 177. Respondent used a eatchpole to contol the dog. 8 Respondent tightened the eatchpole around the dog's neck until it couldn't breathe. 9. Respondent picked the dog up off of the ground with the eatchpole and slammed it ‘down on the floor. 10, The dog's mouth began to bleed from being hiton the floor. 11. Ato time was the dog aggressive towards Dr. Kaiser. 12. The foregoing acts andior omissions are grounds for revocation or suspension of a license to practice asa veterinarian porssant to 225 ILCS 115725(1}(0) WHEREFORE, based on these allegations the Department of ‘and Professional Regulation of the State of Minos, by Daniel Facrmack, is ions, prays that the weterinarian Hieense of ANDREW, 10) | DVM, be revoked, suspended, placed on probation or otherwi @ Se nai ee eee _ eres gaumysacen of Quincy Animal Shelter. 7. The dog was agerssive towards Respondent. 8. Respondent used a caichpate to control the dog. oe gunman anos Page 12 of 1710, Whe Respondet was choking tbe dog hits mouth on the side ofthe Rene breaking sever eth, 11 Respondent hen stepped on the dog's nek nail and euthanize i 12, The foregoing sts andlor omissions are grounds for revocation or suspension of & lceas to practice asa veterinarian pureuant 10225 ILCS 11825(1X0). \WHEREFORE, bused om these allegations the Doparmcst of Financial and Professional Regulation ofthe State of Wins, by Duel Farmar its Chie f Het Reted Prosecsns, ‘prays that the veterinarian license of ANDREW JOSEPH KAISER Il, D.V.M, be revoked, ‘suspended, placed on probation or otherwise disciplined FAILURE To POSSESS AND APPLY THEK, ILA AND CARE IN ‘TREATING a Coxorni0y Thar es ORDIN: “AML WELL-QUALIFIED ‘VETERINARIANIN T ie PRacrices, 1-5, The Departaeat ‘one through five (1-5), inclusive, of Count L ‘ne through five (1-5), inclusive, of this 2015, 8 cat named “Lego” presented to Katherine Road with urethral blockage, 17. Respondent's assistant, Alexis Leibig, who was monitoring anesthesia, repeatedly told Respondent that Lega wasn't breathig, 8. Respondent told the assistant to shut up, 9. Lego died under Respondents care, Page 13 of 1710. The foregoing acts andlor omissions are grounds for revocation ot suspension of a license vo practic asa veterinarian pursuant #9225 ILCS 118/25(1}D) as defined by 68 Adin, Code $00.50(a¥8). ‘WHEREFORE, bas on these alleyatios, the Department of Finacial and Professional Regulation ofthe Stat of tins, by Daniel Faermurk, ts Chef of Health-Related Prosecaticns, rays that the veterinarian license of ANDREW JOSEPH KAISER Ill, DIM, be revoked, suspend, placed on prbaiin or eberwisedsciptned. COUNT XIII Panam to Possiss ano APPLY THE KNOWLEDGE AND USE THE! CARE IN “TREATING 4 CONDITION THAT Is ORDINARILY Use ny UALIFIED "VEERINARIAN IN THEE LO ALAPY 1-5, The Department restates and real ugh fve (1-8), inclusive, ff Count I of this complai (Court XII asi @ t 6. Onor abou j fer amputated patient “Hopscotch's” 7 Resp fh scr any pain medication to Hopscoich during or ater the procedure. 8, The foregoing. acts and/or omissions are grounds for revocation or suspension of @ ugh five (1-5), inclusive, of this Vicense to practice ata veterinarian pursuas to 225 ILC’ 115/25(1}\() as defined by (68, Adin, Code $00 5040K8) WHEREFORE, bused on these allegations, the Department of Financial and Professions} Regulation ofthe State of Iinss, by Daniel Fsemmat, its Chie of Health-Related Prosections ‘Pays thatthe veterinarian ierse of ANDREW JOSEPH KAISER Ill, D.V.M. be revoked, ssuspeniied, placed on probation or otherwise disciplined. Page 14 0f 17Count xiv FAMGURE-To Possess AND APPLY Tits KNowasce anoUUSE mie SKILL AND Cam ‘TeEATING 4 Conbrnion Tat IeOuDInanity Ustb By 4 REasawABLy WELL-QLALIPILD ‘Vereninastan ty ttt Locatsryay Wien Ir PRACTICES 145. The Department restates apd realleges Paragraphs one through five (I-S), inclusive, ‘oF Count { of this complaint as Paragraphs ane through five (0 ‘Count XIV as if each were filly restated herein, inclusive, of this 6. On or about September 10, 2015, Respondent performed surgery to remove an allegedly cancerous lump torn patent "Cary Grant.” 7. Respondent fuile to calculate Cory Grant's medications or aceaning tits weight. 4 Respondent seat Cary Grant home belggei , 9. Cary Grant's onner called Re morning to inforrn bien that the patient wasn’t cat 10, Katherine Ros informed Respondent of the owner's 11, Respondent Abbot pohiaet the over, 12, The owner called Respondent nine times between September 1, 2015 and September 15,208 13, Respondent id note any the umes ll. 14, Caty Grant had tobe hospitalized at Klingsle Vet for care for Addonan Css, vonutng. nd dehydaton 15. Cary Grant was hospitalized for eight days at Klingele Vet, Page 15 0f 1716. The foregoing ets andor omissions ae grounds for revocation or suspension of + license to practice ws. veterinarian pcsuot to 225 ILCS 118725(1() as define by BI, Adin, Case $0 54a). ‘WHEREFORE, tase on these allegation, the Department of Financial and Profesional Regulation ofthe State of Linas, y Daniel Farmar, ts Chie of Hea-Related Prosecutions, pays thatthe veterinatan isnse of ANDREW JOSEPH KAISER II, D\V-ML, he revoked, supe, placed on probation reer dicted. 9. Respondent punched the dog inthe hip three or four times. 10. The foregoing ats ander omisions are grounds for revocation or suspension of & cen to practice aa veteiwrian pursuant to 25 ILCS 11525140 \WHEREFORE, based on these alleaons, she Deparineat of Finacial al Profesional Regulation of the State of Minis, by Danie Faermark, its Chief of Health-Related Prosecutions, ‘Peay thatthe veterinron ease of ANDREW JOSEPH KAISER II, DLV.M, be sewaked, sspended, placed on probation or otherwise disciplined Page 16 0f 17DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION, DIVISION OF ‘Alex Cooper ‘Health-Related Prosecuta iinois Department off Division of Profesgal Chicago, IL. 6066 Page 17 of 17