ff STATE OF FLORIDA - 00 4 Ue DEPARTMENT OF HEALTH ~/ DEPARTMENT OF HEALTH, HE, Petitioner, CASE NUMBER: 98-18545 vs. ROBERT J. TUCKER, Respondent. - / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, “Petitioner”, and files this Administrative Complaint before the Board of Pharmacy against the Respondent, Robert J. Tucker, “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, Fla. Stat. (1997) and Chapters 455 and 465, Fla. Stat. (1997). Pursuant to the authority of Section 20.43(3)(g), Fla. Stat. (1997), Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative and prosecutorial services required by the Board of Pharmacy. 2. Respondent is, and has been at all times material hereto, a licensed pharmacist in the State of Florida, holding license number PS 0025646. Respondent’s last known address is 10802 W. Hillsborough Avenue, #605, Tampa FL 33615. , 3. Between January 12, 1998 and May 9, 1998, Respondent was employed as a licensed pharmacist by the Pharmacy at the Target store located at 3625 Gandy Blvd., Tampa FL 33611. 4. Between January and May 1998, inclusive, Respondent dispensed Hydrocodone U | U and Lortab to customer Ermest Moya. This occurred on at least twelve separate occasions, and on each occasion, Respondent knowingly dispensed the drug without any prescription, 5. On June 15, 1998, Respondent was charged by the Tampa Police Department with two counts of trafficking in Hydrocodone. 6. In November 1998, Respondent was charged with ten (10) additional counts of obtaining a controlled substance by fraud. 7. The Respondent’s license to practice pharmacy in the State of Florida is subject to discipline pursuant to Section 456.016(1)(e), Fla. Stat. (1997), by violating Section 893.04(1)(f), Fla. Stat. (1997) in that he dispensed Hydrocodone without a prescription on as many as twelve occasions, WHEREFORE, Petitioner respectfully requests the Board of Pharmacy enter an order revoking the license of the Respondent, or imposing such other discipline and penalties that the Board deems appropriate. SIGNED this>\, pglday or Degtonlos 1999. Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration Counsel for Petitioner: Howard M. Berstein, Senior Attorney FBN: 217979 f Agency for Health Care Administration j cae Fe General Counsel’s Office- MQA DEPARTM LED Allied Health EPUTY Clea OY P.O. Box 14229 CLERK : 0D; Tallahassee, Florida 32317-4229 : 2. tien (850) 410-3466 (Telephone) pate_G- 30 = 6%] (850) 410-1991 (FAX)

Docket for Case No: 00-003123PL