‘ed | a) ~~ STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, . . Petitioner, OO ~ | [GY Vs. CASENO. 99-03293 3 CELESTINE O. IZUNOBI, R.PH., Respondent. . ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, Department of Health, and files this Administrative Complaint before the Board of Pharmacy against the Respondent, CELESTINE O. IZUNOBI, R.PH. and 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. Pursuant to the authority of Section 20. 43(3)(e), Florida Statutes, the Petitioner ~ has ‘contracted with the Agency for Health Care Administration, hereinafter referred to as the "Agency," to provide consumer complaint, investigative, and prosecutorial services ‘required t by the Division of: Medical Quality Assurance, councils or board, as appropriate, including the issuance of emergency orders of suspension or restriction. 3. _Respondent has been at all times pertinent hereto, a duly | licensed pharmacist pursuant to Chapter 465, Florida Statutes, having been issued license number PS ~ 33017. 5. On or about April 14, 1999 an inspection was performed by agents of the Petitioner. As a result, it was discovered: _ a. The Respondent failed to have a pharmacist present and on duty during regular operating hours of the pharmacy. b. The Respondent failed to prevent access to the pharmacy department by lock or padlock so that any person other than a registered pharmacist could not enter, nor was a closed sign displayed. 6. The conduct of the Respondent as aforesaid is contrary to the provisions contained in Section 465.016(1)(e), Florida Statutes, and Rule 64B16-28.109, Florida Administrative Code, by operating a pharmacy without a pharmacist present and on duty; Rule 64B16-28.109(4), Florida Administrative Code, by failing to prevent access to the pharmacy department with a lock or padlock so that no one may enter but a Florida registered pharmacist. 4. Respondent's last known address is Post Office Box 170332, Hialeah, Florida . WHEREFORE, Petitioner 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 tif Way of ; 2000. Robert G. B ooks, M.D. Secretary, Department of Health y: Nancy M. Snurkowski Chief Attorney On Behalf of the Agency for Health Care Administration DEPARTMENT OF HEALTH DEPUTY CLERK CLERK Vchi RLliont DATE, B/D ~ COUNSEL FOR AGENGY: ; J taswtence 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 - LFKst Per {ao err En erg

Docket for Case No: 00-001164