Qo STATE OF FLORIDA - DEPARTMENT OF HEALTH = . Rh DEPARTMENT OF HEALTH, 2 sg ca) Petitioner, ae . co Vs. CASE NO. 00-10222 J 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 456, (formerly Chapter 455, Part II; see Chapter: 2000-160, Laws of Florida), and Chapter 465, Florida Statutes. Pursuant to Section 20.43(3\(g), Florida Statutes, the Department 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 has been at all times pertinent hereto, a duly licensed pharmacy pursuant to Chapter 465, Florida Statutes, having been issued license number PH 0014144. 3. Respondent's last known address is 1441 S.W. 29" Avenue, Pompano Beach, Florida 33069. oe 4. On or about June 27, 2000 an investigation was performed by agents of the Petitioner. As a result, it was discovered that on June 28, 2000 the Respondent dispensed Heartgard to a patient of Veterinarian J.W. without a valid prescription. 5. Based on the foregoing, Respondent's license to practice pharmacy in the State of Florida is subject to discipline pursuant to Section 465.016(1)(e), Florida Statues, by violating any of the requirements of chapter 465, to wit: Section 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 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 attomey time), issuance of a reprimand, placement of the Respondent on probation, and/or any other relief the Board deems appropriate. SIGNED pa shay x yours» , 2000. Robert G. Brooks, M.D. Secretary, Department of Health PARTMENT OF HEALTF { pF DEPUTY CLERK By: Nancy M. Snurkowski “ Chief Attorney CLERK ebi Re On Behalf of the Agency for pate (2 [Sl 22 Health Care Administration COUNSEL FOR AGENCY: Michael P. Sasso, suf &~ Senior Attorney Florida Bar No. 0167363 Agency for Health Care Administration General Counsel's Office - MQA Practitioner Regulation P.O. Box 14229 Tallahassee, Florida 32317-4229 (850) 487-9670 MPS/tt pe: AWS eS ia ¢) peppate: | a1 ~27 © Case Number 00-10222 (Pet Med)

Docket for Case No: 01-000318