a . . %G ae STATE OF FLORIDA yy 7, DEPARTMENT OF HEALTH BBC O o 7g OOS 4, “4 Py Os “ DEPARTMENT OF HEALTH, Gi a Petitioner, Vs. CASE NO. 00-01060 . Ol-Cluebo PL PET MED EXPRESS, Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, Department of Health, and files this Administrative Complaint before the Board of Pharmacy against the Respondent, PET MED EXPRESS 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 referred to as the "Agency," to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils or board, as appropriate, including the issuance of emergency orders of suspension or restriction. 3. Respondent has been at all times pertinent hereto, a duly licensed pharmacy pursuant to Chapter 465, Florida Statutes, having been issued license number PH 0014144. 4. Respondent's last known address is 1441 $.W. 29" Avenue, Pompano Beach, Florida 33069. 5. On or about March 3, 2000 an investigation was performed by agents of the Petitioner. As a result, it was discovered that on November 6, 1999 the Respondent dispensed Revolution to T.P. for her pet without a prescription. 6. In addition on March 3, 2000 the investigator requested copies of the daily printout for prescriptions filled and began making telephone calls regarding the verification of prescriptions. Four of the six persons contacted denied ever providing authorization to Pet Med Express, or ever having received the call. Another individual stated the person who supposedly verified the prescription was not working on the day of the verification. 7, On March 8, 2000 printouts of verified prescriptions were obtained and - checked by the investigator, there were three instances that there were no calls made to the veterinarians for verification of a prescription. 8. The conduct of the Respondent as aforesaid is contrary to the provisions contained in Section 465.023(1)(c), Florida Statutes, and Rule 465.015(2)(c), Florida Statutes, by dispensing medication without a valid prescription. 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 thi ay of _{ f LA ue od , 2000. Robert G. Brooks, M.D. Secretary, Department of Health 7 —L By: Nancy M. Snurkowski Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR AGENCY: © Lawrence F. Kranert, Jr . Senior Attorney OEP EMENT OF HEALTF Florida Bar No. 0171063 2” CLERK Agency for Health Care Administration CLERK Ueki R Kean General Counsel's Office - MQA DATE 9 Practitioner Regulation P.O. Box 14229 Tallahassee, Florida 32317-4229 (850) 487-2225 vat 07/25/00 ; LFK/stt . PCP:

Docket for Case No: 01-000166