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1982, petitioners lived in Bristol, Tennessee, where Mr. Rowe
also conducted an oral surgery practice. In 1981, Mr. Rowe
became licensed to practice oral surgery in the State of Florida.
In 1982, Mr. Rowe was suspended by the Board of Dentistry in
Tennessee and, as a result, Mr. Rowe stopped practicing dentistry
in Tennessee. In 1983, petitioners moved to Madisonville,
Kentucky, where Mr. Rowe worked in a dental clinic. In late
1984, petitioners moved from Kentucky to Osceola County, Florida,
where they resided during the years in issue.
From October 1984 through October 1989, Mr. Rowe was
employed as a dentist and oral surgeon by the Central Florida
Dental Association (CFDA) in Kissimmee, Florida, and St. Cloud,
Florida. Mr. Rowe’s annual salary while at the CFDA was
approximately $240,000, and he also shared in the profits of the
business. Dr. Frank Murray (Dr. Murray) was the president of the
CFDA during the years in issue. In 1989, Dr. Murray suspected
that Mr. Rowe was improperly handling payments from clients and
insurance companies. Mr. Rowe’s employment with the CFDA was
subsequently terminated. The local prosecuting attorney was
informed of Dr. Murray’s suspicions regarding the improper
handling of payments, and Mr. Rowe was investigated and
eventually arrested for embezzling funds. Mr. Rowe was indicted
on charges of grand theft and computer fraud; however, the
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