STATE OF FLORIDA moe my DEPARTMENT OF HEALTH Pho 00 JAN 20 PHI2: 24 DEPARTMENT OF HEALTH, DIVEsiay oF ADMINIS “Bar i HEARINGS © Petitioner, “Case No. 97-11171 jb-337 vs. DEBORAH J. MOEN, Respondent. ADMINISTRATIVECOMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Pharmacy against DEBORAH J. MOEN, hereinafter referred to as “Respondent, » and alleges: Petitioner i is the state e agency ‘charged with regulating the practice of pharmacy pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida S Statutes; and Chapter 65 Fl ida Statutes a ‘complaint, investigative, ‘and prosecutorial services require Assurat ce, ouncils, or boards, as appropriate, including the i issuance e of emergency orders of ceeeeen 3. Respondentis, and has been at all times material hereto, a licensed pharmacist in the State of Florida, having been issued license number PS 0031388. Respondent's last known address is 196 Gray Dove Court, Daytona Beach, FL 32119. 4. On or about May 1996, Respondent was employed by Orange Belt Pharmacy, 112 East New York Avenue, Deland, FL 32724. 5. On or about May 1996, Respondent admitted to drinking a glass of wine before going to work because she was upset from a phone call with her soon to be ex-husband. 6. On or about May 20, 1996, Kenneth Jackson, General Manager of Orange Belt, notified Health Care Consultants (“HCC”), the placement service that procured Respondent’s employment with Orange Belt, that Respondent had made trips to her car during work hours and returned smelling of alcohol. 7. On or about August 30, 1996, Respondent was employed by Nations Health Care (“NHC”), 774 South North Lake Blvd., Altamonte Springs, FL 32701. 8. On or about August 30, 1996, Respondent admitted to drinking a glass of wine before going to work because she was upset from a phone call with her ex-husband. 9.° On or about September 11, 1996, Phil Smart, a pharmacy technician at NHC, notified his supervisor, Beth Little, that he smelled alcohol on Respondent’s breath. 10. | Onor about September 11, 1996, Respondent was evaluated by Dr. Ken Thompson. £ "Dr. Thompson diagnosed Respondent as impaired and stated that she should not be working as a pharmacist. 11. Onor about February, 28, 1997, Respondent signed an Advocacy Contract with the Physician’s Resource Network (“PRN”). 12. On or about June 12, 1997, Dr. Roger Goetz, M.D., Director of PRN, informed Petitioner that Respondent had failed to progress in the monitoring phase of her rehabilitation: since being discharged in March 4, 1997. 13. Based on the foregoing, Respondent is subject to discipline pursuant to section 465.016(1)(m), Florida Statutes, by being unable to practice pharmacy with reasonable skill and safety by reason of illness, use of drugs, n narcotics, chemicals, or any other type of material or as a result of any mental or physical condition A pharmacist affected under this paragraph shall at reasonable intervals be afforded an opportunity to demonstrate that he can resume the competent practice of pharmacy with reasonable skill and safety to his customers. WHEREFORE, Petitioner respectfully requests that the Board of Pharmacy enter an Order imposing one or more of the following penalties: Revocation or suspension of Respondent's license, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. Signed this_-+ YK day of _| 1S ar 1997. Douglas M. Cook ‘Director By: cy M. Snurkowski : Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR PETITIONER: Susan B. Bodell, Senior Attorney Agency for Health Care Administration General Counsel’s Office-MQA Allied Health Post Office Box 14229 Tallahassee, Florida 32317-4229 (904) 487 - 9697 SBB:sb PCP: LN/DF DOM: 10-06-97

Docket for Case No: 00-000333