7, | wo — FILED . STATE OF FLORIDA DEPARTMENT OF HEALTH OOMAYIS PH 1:58 ; DIVISION OF oo ADMINISTRATIVE DEPARTMENT OF HEALTH, . BEARINGS PETITIONER, vs. CASE NUMBER: 98-00153 WAYNE H. HAMMOND, RESPONDENT. ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Pharmacy against WAYNE H. HAMMOND, 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. Pursuant to the authority of Section 20.43 @)@), Florida Statutes, the Petitioner has contracted with the Agency of Health Care Administration to provide consumer complaint, investigative, an and prosecutorial services required byt the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2 "Respondent is, and has been at allt times material hereto, a licensed pharmacist in ae "the State of Florida, having been issued license number PS 0020305. Respondent’s last known address is 33946 St. Joe Road, Dade City, Florida 33525. sae cr ccna ee me, , vy 3. On or about December 30, 1997, an investigation was commenced in response to an article which appeared in the St. Petersburg Times stating that Respondent was arrested for : stealing approximately $100,000.00 of cash and merchandise since 1993 from employer K-Mart. 4. The investigation revealed that on or about December 28, 1997, Respondent was arrested and charged with Scheming to Defraud and Petit Theft by the Zephyrhills Police Department for allegedly stealing over $100,000.00. 5. Respondent admitted to using a system to keep track of the excess money in the cash register at K-Mart and then deprived them of it. He admitted he stole over $100,000.00 in cash and merchandise from K-Mart. COUNT] © 6. Petitioner realleges and reincorporates the foregoing factual allegations as if fully stated herein. . - 7. Based on the foregoing, Respondent is subject to discipline for violating Section 465.016(1)(e), Florida Statutes, by violating any of the requirements of this chapter; or if licensed as a practitioner in this or any other state violating any of the requirements of their respective practice act or violating chapter 499. so COUNTHL Petitioner real ges and reincorporates the foregoing factual allegations as if fully “statedherein. ~ - 9. Based on the foregoing, Respondent is subject to discipline for violating Section 455.624(1)(@), Florida Statutes, by making misleading, deceptive, or fraudulent representations in or related to the practice of the Respondent’s profession. oe t WHEREFORE, Petitioner respectfully requests the Board of Pharmacy 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, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this Nod aay of Aas A850, Robert G. Brooks, Secretary, Department of Health DEPARTMENT OF HE, DEPUTY CLERK CLERK Vechi RMant _— ~2Q¢d 00 Nancy M. Snurkowski OnE £ a & Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: Carolyn Taylor, Attorney Agency for Health Care Administration Allied Health ; P.O. Box 14229 - Tallahassee, FL 32317-4229 (850) 487-9690 CT/mh ; PCP: eeeale a acct anne DATE: HHlIS1O ©

Docket for Case No: 00-002062