V4 a0 STATE OF FLORIDA LA AUG DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF FUNERAL DIRECTORS AND EMBALMERS 0 DEPARTMENT OF BUSINESS AND YO dy 5, PROFESSIONAL REGULATION, | 88 PR yy, 5 rn a / pha we wht ped Petitioner, P We Vv. Case No. 2001-06308 PREMIER FUNERAL SERVICES AND CREMATIONS, INC., Respondent. : / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION (“Petitioner”), files this Administrative Complaint before the Board of Funeral Directors and Embalmers against PREMIER FUNERAL SERVICES AND CREMATIONS, INC. (“Respondent”), and alleges: 1. Petitioner is the state agency charged with regulating the operation of funeral establishments, pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 470, Florida Statutes. 2. At all times material hereto, Respondent was licensed in the State of Florida as a funeral establishment, license number FH 0002351. 3. Respondent’s address of record with the Department is 1832-A Northwest 28" Street, Oakland Park, Florida 33311. 4, At all times material hereto, Respondent establishment was owned and operated by Gloria Rizzo. 5. On or about June 12, 2001, respondent entered into a stipulation agreement with the State of Florida Board of Funeral and Cemetery Services to avoid a formal hearing regarding Subject’s lack of a Certificate of Authority. COUNT I 6. Petitioner realleges and incorporates paragraphs one through five as if fully set forth herein. 7. Section 470.036 (1)(c), Florida Statutes, states in pertinent part that having a license or registration to practice any activities regulated under this chapter revoked, suspended or otherwise acted against constitutes grounds for disciplinary action. 8. Based on the foregoing, Respondent has violated Section 470.036(1)(c), Florida Statutes. WHEREFORE, Petitioner respectfully requests the Board of Funeral Directors and Embalmers enter an order imposing one or more of the following penalties: revocation or suspension of the Respondent’s license, restriction of the Respondent’s practice, imposition of an administrative fine not to exceed $5,000 per violation, issuance of a reprimand, placement of the Respondent on probation, assessment of costs association with the investigation, imposition of any or all penalties delineated within Section 455.227(2), Florida Statutes, and/or any other relief that the Board is authorized to impose pursuant to Chapters 455 and/or 470, Florida Statutes, and/or the rules promulgated thereunder. Signed this 22d day of y Ya _, 2002. il -Hill Lead Professions Attorney ft | L F D , pe yook toh Department of Busines ard Regulation fcr ; cern tardmt Tichele coer DATE 3 -2$-2002 COUNSEL FOR DEPARTMENT: CHARLES F. TUNNICLIFF Assistant General Counsel Department of Business and Professional Regulation 1940 North Monroe Street Tallahassee, FL 32399-2022 Telephone: (850) 487-9656 Facsimile: (850) 414-6749 GSH:CFT/js PCP:

Docket for Case No: 02-002949