~ oo wd . RECEIVED - STATE OF FLORIDA LEGAL DEPARTMENT OF HEALTH OO MAR 21: Pig 53 aT ; hee DEPARTMENT OF HEALTH, oO . ‘Ty Petitioner, . 3 3 [Pe %, Vs. CASE NO. 99-04504 nm ROBERT P. ADAMS, R.PH., Respondent. / O O - a 3g 03 ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, Department of Health, and files this Administrative Complaint before the Board of Pharmacy against the Respondent, ROBERT P. ADAMS 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 ith the Agency for Health Care Administration, hereinafter referred to as the “Agency,” to , provide consumer complaint, investigative, and prosecutorial services ae required by the Division of Medical Quality Assurance, ‘councils or board, as appropriate, oc 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 0026631. i‘) a iw) . 4. Respondent's last known address is 3191 Harrison Street, Avalon Beach, Florida 32583. 5. Onor about August 2, 1999, an investigation was performed by agents of the Petitioner. As a result, it was discovered: a. On February 9, 1999 the Respondent misfilled a prescription submitted by E.C. by dispensing Lindane shampoo instead of the presribed Selenium Sulfate 2.5% shampoo. 6. The conduct of the Respondent as aforesaid is contrary to the provisions contained in Section 465.016(1)(e) and 465.016(1)(g), Florida Statutes, by furnishing upon prescription, an ingredient or article different in any manner from the ingredient or article prescribed, except as authorized in s. 465.019(6) or 465.025. 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 this] Uffaay of (Y\AAC IK , 2000. Robert G. Brooks, M.D. Secretary, Department of Health DEPARTMENT OF HE, DeDGNT OF HEALTH averk Yahi DATE By: Nancy M. Snurkowski RMitot 7 ' Chief Attorney (4) On Behalf of the Agency for Health Care Administration COUNSEL FOR AGEN( 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 LFK/rt pcp: 3-/- 0°

Docket for Case No: 00-002303