STATEOF FLORIDA 2,6, b, a DEPARTMENT OF HEALTH Di. SP “ an Lyte, 4% : . ONG DEPARTMENT OF HEALTH, OO ‘ Teese yO : La Tey 6 2, Petitioner, "in . vs. Case No. 1998-11694 O\- DIVO PL ARTHUR C. HASPEL, D.P.M., Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Department of Health, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Podiatric Medicine against ARTHUR C. HASPEL, D.P.M., hereinafter referred to as “Respondent,” and alleges: . 1, Petitioner is the state agency charged with regulating the practice of podiatric medicine pursuant to Section 20.43, Chapter 456 (formally Chapter 455, Part II; see Chapter 2000-160, Laws of Florida), and Chapter 461, Florida Statutes. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative and prosecutorial services required by the Division of Medical Quality Assurance, councils, - or boards. 2. Respondent is, and has been at all time material hereto, a licensed Podiatrist in the State of Florida, having been issued license number PO 0000649. Respondent's last known address is 1105 East Hallandale Boulevard, Hallandale, Florida 33009. 3. On or about April 15, 1998, Respondent sold approximately six hundred (600) tablets of Dihydrocodeine to an undercover law enforcement officer in the parking lot of - Walgreen's, located at 4901 North Broadway, Knoxville, Tennessee. Respondent / accepted $2,400 from the undercover officer in exchange for the tablets. Dihydrocodeine is a Schedule III controlled substance, pursuant to Chapter 893, Florida Statutes 4. On or about April 15, 1998, the Knox County Sheriff's Department stopped "the Respondent in his motor vehicle shortly after the exchange described above. The officers conducted a search of Respondent’s motor vehicle, and discovered approximately six hundred and fifty (650) tablets of Dihydrocodeine located in several plastic bags (approximately fifty per bag), and approximately forty-one (41) tablets of Codeine, located in a white envelope. Codeine is also a Schedule III controlled substance, pursuant to Chapter 893, Florida Statutes. 5. On or about April 15, 1998, Respondent was arrested by the Knox County Sheriff's Department for one (1) count of sale and delivery of a Schedule II controlled substance, and two (2) counts of possession of a Schedule III controlled substance for resale. COUNT I 6. Petitioner realleges and incorporates by reference the foregoing allegations as if fully set forth herein. _ 7. Based on the foregoing, Respondent's license to practice Podiatric medicine in the State of Florida is subject to discipline pursuant to Section 461.013(1)(o), Florida Statutes, for prescribing, dispensing, administering, mixing, or otherwise preparing a legend drug, including all controlled substances, other than in the course of the podiatrist’s professional practice. : COUNT 1 . 8. Petitioner realleges and incomporates by reference the foregoing allegations in paragraphs one (1) through five (5) as if fully set forth herein. 9. Based on the foregoing, Respondent’s license to practice Podiatric medicine in the State of Florida is subject to discipline pursuant to Section 461.013(1)(z), Florida Statutes for misconduct in the practice of podiatric medicine. WHEREFORE, Petitioner respectfully requests the Board of Podiatric Medicine to 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 and assessment of costs related to investigation and prosecution of this case (including, but not limited to costs associated with attorney time), issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. ; SIGNED this {afvrey of L Vy lney , 2000. Robert G. Brooks, M.D. Secretary, Department of Health FI LED BY: Nartty M. Snurkowski, Chief Attomey Agency for Health Care Administration DEPARTMENT OF HEALTH Office of General Counsel-MQA 7 ae ae "Practitioner Regulation-Legal * pare_1Z-21-OD » .* COUNSEL FOR PETITIONER: David R. Herman, Senior Attorney -. Fla. Bar No: 0113956 4 : Agency for Health Care Administration General Counsel-MQA Practitioner Regulation-Legal P.O. Box 14229 , Tallahassee, Florida 32317-4229 Telephone: (850) 410-0613 | Case No. PO 1998-11694 (Haspel) PCP: Shrick ln) @ 1 PCP Date: ~'D ° \\.20-v0

Docket for Case No: 01-000295PL