STATE OF FLORIDA DEPARTMENT OF HEALTH - S DEPARTMENT OF HEALTH, 5 Petit 7 ns etitioner, : “ : 66-/77 : Vs. CASE NO. 99-04899 2 BEVERLY ENTERPRISES, D/B/A & GULF COAST CONVALESCENT CENTER, Respondent. ADMINISTRATIVE COMPLAINT ot COMES NOW the Petitioner, Department of Health, and files this Administrative Complaint before the Board of Pharmacy against the Respondent, BEVERLY ENTERPRISES, D/B/A GULF COAST CONVALESCENT CENTER 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. istration, “hereinafter referred to as the "Agency," to provide consumer er complaint, ‘investigative, and prosecutorial services 3 required by the Division of Medical Quality Assurance, councils or board, as appropriate, : including the i issuance of emergency orders of suspension or restriction. 3. . Respondent has been at allt times pertinent hereto, a aduly licensed pharmacy" ‘pursuai lorida Statutes, having been issued license number PH - 0907529. 4, Respondent's last known address is 1937 Jenks Avenue, Panama City, F lorida 32405-4510. 5. On September 9, 1999 an investigation was performed by agents of the Petitioner. As a result, it was discovered that the Respondent had been practicing with a ~ delinquent license from April 11, 1999 to September 24, 1999. 6. The conduct of the Respondent as aforesaid is contrary to the provisions contained in Section 465.023(1)(c) and 465.015(1)(a), Florida Statutes, by operating a pharmacy that is not registered under the provisions of this chapter. 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 wn heey of NQywh, 2000. Robert G. Brooks, M.D. Secretary, Department of Health DEPARTMENT OF HEALT DEPUTY CLERK By: Nancy M. Snurkowski CLERK Yebi RBs Chief Attorney _ On Behalf of the Agency for pate_2-/O-Rovo Health Care Administration ee - COUNSEL FOR AGENCY: Lo Lawrence 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 LFKAt PCP: 7) m/ES Z| -0O meer eure Panne

Docket for Case No: 00-001779