‘FILED ees 00 MAR 23 AM IO: 4g DEPARTMENT OF HEALTH DIVISioN Ee = DEPARTMENT OF HEALTH, Abt INIS Ke VE Petitioner, , O oO -[ ~ 3 $ VS. CASE NO. 99-01288 THOMAS GRIFFIN, R.Ph. 4 Respondent. > ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, and files this Administrative © Complaint before the Board of Pharmacy, against the Respondent, THOMAS GRIFFIN, R-Ph., 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. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration, hereinafter aa prosecutorial services required by the Division of Medical Quality Assurance, council or boards, as appropriate, including the issuance of emergency orders of suspension or 3. Respondent ‘has been at all times pertinent hereto, a , duly licensed pharmacist pursuant to Chapter 465, Florida Statutes, having been issued license number WG aS) PS 0024861. Respondent’s last known address is 255 Mounts Bay Court, Longwood, Florida 32779. . 4. On or about December 11, 1998 an individual known as KS. presented a prescription for her mother to the Respondent, which called for Levothroid 112 mcg. ” 5. In lieu of the medication prescribed, the Respondent filled the prescription in question with Levoxyl 112 mcg. 6. Upon taking the medication in question the individual became ill and had to be hospitalized. 7. The Petitioner is informed and believes and based upon said information and belief alleges that the Levoxyl that was dispensed by the subject pharmacist is not the bioequivalent of the Levothroid prescribed by the individual’s physician. 8. ‘The conduct of the Respondent as aforesaid is contrary to the Provisions contained in ‘Section 465. 025(6, Florida Statutes, by using ina Prescription, or «fusing y: Nancy M. Snurkowski Chief Attorney On Behalf of the Agency for Health Care Administration ( / COUNSEL FOR AGENCY: Lawrence F. Kranert, Jr. Senior Attorney Florida Bar No. 0171063 Agency for Health Care Administration General Counsel's Office - MQA Allied Health P.O. Box 14229 Tallahassee, Florida 32317-4229 (850)487-2225 LFK/mt 11/16/99 PCP:

Docket for Case No: 00-001239