Pa UW Oo STATE OF FLORIDA DEPARTMENT OF HEALTH 00-0325 DEPARTMENT OF HEALTH, Petitioner, vs. SCOTT G. KOHN Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter refe! PILED QO JAN 20 PHI2: 23 AOMIES ff, MO TRAY HEARINGS © Case No. 97-11568 rred to as “Petitioner,” files this Administrative Complaint before the Board of Pharmacy against Scott G. Kohn, 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)(f), 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 0024323. Vs U 5. Respondent’s last known address is 1020 Rivermist Drive, Rochester, Michigan 48307. “ 6. On or about October 25, 1995, Respondent’s licens¢ to practice pharmacy in Michigan was suspended for thirty (30) days by the Michigan Board of Pharmacy for distributing controlled substances to clinics without the required license to do so. 7. On or October 25, 1995, Respondent was also assessed a fine in the total amount of One Thousand Dollars and No Cents ($1,000.00) by the Michigan Board of Pharmacy. 8. The acts by the Respondent that resulted in the suspension of his Michigan license constitute a violation of Florida Statutes Chapter 465. COUNT I 9. Petitioner realleges and incorporates by reference the allegations contained in the foregoing paragraphs as if fully stated herein. 10. 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)(h), Florida Statutes, by having been disciplined by a regulatory agency in another state for any offense that would constitute a violation of this chapter of the Florida Statutes. 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, and/or any other relief that the Board deems appropriate. Vv U SIGNED thi A day of ith 199th Douglas M. Cook Director By: Nancy M. Snurkowski Chief Attorney On Behalf of the Agency for Health Care Administration FILED COUNSEL FOR AGENCY: DEPARTMENT OF HEALTH EPUTY| CLERK Susan B. Bodell ft CLERK ft haan D ww Senior Attorney ) ‘ pate___ AI 48 Florida Bar Number 0987859 Agency for Health Care Administration General Counsel’s Office - MQA. Allied Health P.O. Box 14229 Tallahassee, FL 323 17 - 4229 (850) 487-9697 SBB\jeg pcp. OF/AN 1:37 AB

Docket for Case No: 00-000328