U WY STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, OO0- 1425 vs. CASE NUMBER: 99-04926 GOOD HEALTH ON THE BEACH, INC. RESPONDENT. ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board o Pharmacy against GOOD HEALTH ON THE BEACH, INC., 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 prosecutdrial 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 is, and has been at all times pertinent hereto, a duly licensed Pharmacy pursuant to Chapter 465, Florida Statutes, having been issued license number, PH 0016670. U YW 4. Respondent's last known address is 1131 71 Street, Miami Beach, Florida, 33141. . 5. During the course of an investigation undertaken by agents and employees of the Petitioner on September 8, 1999, it was discovered that Respondent had/not notified the Board of Pharmacy of its current manager; did not always have a pharmacist on duty when department was open; did not have a license displayed of the current pharmacist; did not have a pharmacist on duty when the department was open; and did not have prescription department open 40 hours week, 6. The conduct of the Respondent as aforesaid is contrary tq the provisions contained in Sections 465.023(1)(c), 465.018, F.S., and 465.19(2)(a), Florida Statutes, by failing to notify the Board of the current manager; FAC. Rule 64B16-27.100, by failing to have a license displayed of the current pharmacist; F.A.C. Rule 64B-28 -102, by failing to have a pharmacist on duty when the department was open; and F.A.C, Rule 64B16-28.404, by failing to have the prescription department open for 40 hours a week. WHEREFORE, Petitioner respectfully requests the Board of Pharmacy enter an order imposing one or more of the following penalties proscribed by Jaw, together with any other and 7m) SIGNED this | CH(rday of. 999. further relief deemed just under the circumstances, Dr. Robert G. Brooks, M.D., Secretary - Department of Health DEPARTMENT OF HEALTH DEPUTY CLERK ~ CLERK Ueki RBM Nancy M. Snurkowski bl oo . Chief Attorney ome Bf 1bfoo Agency for Health Care Administration COUNSEL FOR PETITIONER: Meredith Trammell, Senior Attomey q Florida Bar Number - 086703 Agency for Health Care Administration Practitioner Regulation P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 487-3908 MT/cg per: 1. + WS pate: 2(7]2000

Docket for Case No: 02-001755