STATE OF FLORIDA - hy DEPARTMENT OF HEALTH ny 4, 7 DEPARTMENT OF HEALTH, ~ CT, 8. yas Petitioner, DEBBIE H. GELO, Case No. 98-03940 Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Pharmacy against DEBBIE H. GELO, hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of pharmacy pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 465, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes (Supp. 1996), the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate, including the issuance of emergency orders of suspension or restriction. 3. Respondent is, and has been at all times material hereto, a licensed pharmacist, having been issued license number PS 0019415. Ln Se ve Ol-O1330L 4. Respondent’s last known address is 1272 Laurel Court, Marco, Florida 33937-2352. 5. At all times material hereto, Respondent was employed by Walgreens Pharmacy located at University Parkway, Sarasota, Florida. 6. On or about May 24, 1993, the Respondent contacted Physicians Recovery Network, hereinafter referred to PRN. 7. On or about July 24, 1993, the Respondent signed a contract with PRN. 8. The July 24, 1993, report indicated that the Respondent was addicted to crack cocaine. 9. According to PRN records, the Respondent failed to attend required meetings. 10. PRN records further indicate that the last contact they had with the Respondent was on or about December 27, 1997. 11. On or about March 3, 1998, the Agency received a report from the Physician’s Resource Network indicating that the Respondent is not in compliance with her monitoring recommendations and requirements. | 12. On or about March 3, 1998, Dr. Goetz, Director of PRN, advised that in his professional opinion, the Respondent poses a danger to the health, safety, and welfare of the public. COUNT I 13. Petitioner realleges and incorporates by reference the allegations contained in the foregoing paragraphs as if fully stated herein. 14. _ Based on the foregoing, the Respondent’s license to practice pharmacy in the State of Florida is subject to discipline pursuant to Section 465.016(1)(d), Florida Statutes, by being unfit or incompetent to practice pharmacy. COUNT II 15. Petitioner realleges and incorporates by reference the allegations contained in paragraphs one (1) through twelve (12) as if fully stated herein. 16. _ Based on the foregoing, the Respondent’s license to practice pharmacy in the State of Florida 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 use of drugs, narcotics, chemicals, or any other type of material. WHEREFORE, Petitioner respectfully requests the Board of Pharmacy enter an Order imposing one or more of the following penalties: imposition of an administrative fine not to exceed $1,000, issuance of a reprimand, placement of the Respondent on probation, or suspension, or revocation, and/or any other relief that the Board deems appropriate. SIGNED thisX tN day of (X p aaa , 1998. Douglas M. Cook Director y: Nancy M> Chief Attorney On Behalf of the Agency for Health Care Administration FILED R AGENCY: DEPARTMENT OF HEALTH COUNSEL FOR AGENCY: DEPUTY CLERK Yipee W. Files . CLERK dhe Wha eitl Attorney c¥7 DATE } [- )2~ ba Florida Bar Number 0113476 Agency for Health Care Administration General Counsel’s Office - MQA Allied Health P.O. Box 14229 Tallahassee, FL 32317 - 4229 (850) 487-2225 GWF/jeg PCP: = Nya Wo0dSs Date Wras/ox

Docket for Case No: 01-000133PL