poe STATE OF FLORIDA DEPARTMENT OF HEALTH ba DEPARTMENT OF HEALTH, Petitioner, Ob -| | Wo Vs. CASE NO. 99-03990 LIFE CARE CENTER OF HILLIARD, > Respondent. ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, Department of Health, and files this Administrative Complaint before the Board of Pharmacy against the Respondent, LIFE CARE CENTER OF HILLIARD, and in support thereof would state: 1. Petitioner is the state agency charged with regulating the practice of Pharmacy pursuant to Section 20.43, Florida Statutes, Chapter 455, Florida Statutes; and Chapter 465, Florida Statutes. 2. Forsuant t to » the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner \gency for Health Care Administration, hereinafter referred to as “the "Agency, to provide consumer complaint, investigative, and prosecutorial services a tequired by the Division of Medical Quality Assurance, councils or board, as appropriate, - including the issuance of emergency orders of suspension or restriction. 3, Respondent’ s last known address i is 7911 West 3 Street, Hilliard, Florida - 32046. = pe emer hs Ad 4. An investigation was performed by agents of the Petitioner. As a result, it was discovered that the Respondent was operating as a Class I institutional pharmacy under an expired permit as the Respondent’ Ss pharmacy license number PH 011074, expired on February 28, 1999, and the Respondent was not issued a new permit until June 8, 1999, (number PH 0016664). ; ‘5. The conduct of the Respondent as aforesaid is contrary to the provisions _ Contained in Sections 465.023(1)(c), and 465.015(1)(a), Florida Statutes, by operating a : pharmacy which is not registered under the provisions of this chapter. = = WHEREFORE, Petitionér respectfully requests the Board of Pharmacy to enter an Order imposing one or more of the penalties proscribed by law, together with any other and further relief deemed just under the circumstances. SIGNED thisfilbca day Yusay of MOO 1999. Robert G. Brooks, M.D. Secretary, Department of Health : Nancy M. Snurkowski Chief Attorney _ On Behalf of the Agency for ~~ Health Care Administration . _ DEPARTMENT OF HEALTH ‘DEPUTY CLERK “CLERK Webi RAbion DATE. | 2 w COUNSEL FOR AGENGY: L~Lawrence F. Kranert, Jr. Senior Attorney Florida Bar No. 0171063 Agency for Health Care Administration General Counsel's Office - MQA Practitioner Regulation P.O. Box 14229 ; Tallahassee, Florida 32317-4229 (850) 487-2225 BFK/rt Pcp: L3-/ Us La]}o [AG epee eee eee ge cy ope Spee ee eee ree

Docket for Case No: 00-001165