Raa €ey STATE OF FLORIDA DEPARTMENT OF HEALTH BOARD OF HEARING AID SPECIALISTS DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 98-20376 CRAIG SCHUETTE, RESPONDENT. / ADMINISTRATIVE COMPLAINT Awd £1 434 20 COMES NOW, the Petitioner, Department of Health, hereinafter referiai to ass, “Petitioner,” and files this Administrative Complaint before the Board of Hearing Aid Specialists against CRAIG SCHUETTE, hereinafter referred to as “Respondent,” and alleges: 1. Effective July.1, 1997, Petitioner is the state agency charged with regulating the practice of Hearing Aid Dispensing pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 484, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration, hereinafter “Agency,” to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, at all times material hereto, a licensed hearing aid specialist, having been issued license number A.S. 0002553. 6se We C1 Ud 00 wou) C3Alg03Y URSI2 PC a 3. Respondent’s last known address is 11811 68" Avenue North, Seminole, Florida 33772. . . . 4. On or about February 13, 1998, the Respondent on behalf of Audiometric Hearing Centers Inc. dispensed a hearing aid to E.T. . 5. On or about February 18, 1998, within 30 days after delivery, E.T. returned the hearing aid to Audiometric for a refund. 6. E.T. did not receive a refund. COUNT 1 7. __ Petitioner repeats and re-alleges paragraphs | through 6. 8. Based on the foregoing Respondent has violated Section 484.056 (1) (h) Florida Statutes by violating Section 484.0512 (1) (2) Florida Statutes by failing to provide a refund. COUNT I 9. Petitioner repeats and re-alleges paragraphs | through 8. 10. Based on the foregoing, Respondent has violated Section 484.056 (1) (g) Florida Statutes upon proof that the licensee is guilty of fraud or deceit or of negligence, incompetency, or misconduct in the practice of dispensing hearing aids. WHEREFORE, Petitioner respectfully requests the Board of Hearing Aid Specialists 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, issuance of a reprimand, placement of the Respondent on probation, assess costs of investigation and prosecution assess costs of ee oe ae aaa ated ae a ace Se cme roe To werecrer investigation and prosecution and/or any other relief that the Board of Hearing Aid Specialists deems appropriate. SIGNED tis Ma aay of Beak , 2000. Robert G. Brooks, M.D. Secretary, Department of Health Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration i COUNSEL FOR PETITIONER: "Gary L. Asbell, Senior Attorney Agency for Health Care Administration Practitioner Regulation - Legal Building 3, Room 3122 DEPA 2727 Mahan Drive DEMENT Cle AEALTH Tallahassee, FL 32317-4229 CLE nn, : (850) 414-1981 RK UR Ying 23/20 perp - 3l

Docket for Case No: 02-000522PL

Orders for Case No: 02-000522PL