memantine seen ae teanemnenene FAIRE MEE fi amr BM MENS ft STATE OF FLORIDA DEPARTMENT OF HEALTH Thorn i oda cae a Feve 2 DEPARTMENT OF HEALTH, 03 JUL 23 PH 3:43 Petitioner, wALIVE vs. CASE NO. 99-0H8277/NGS | ARLENE VERIZZO, R.PH. D 2 270 cv PL Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, and files this Administrative Complaint before the Board of Pharmacy, against the Respondent, ARLENE VERIZZO, R-PH., 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 2000-160, Florida Statutes; and Chapter 465, Florida Statutes. 2. Effective July 1, 1997, Petitioner is the state agency charged with ‘regulating the practice of phermacy pursuant to Section 20.43, Florida, Statutes, Chapter 456, Florida Statutes, (formerly Chapter 455, Part Il; see Chapter 2000-160, Laws of Florida), 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, as appropriate. 3. Respondent has been at all times pertinent hereto, a duly licensed pharmacist pursuant to Chapter 465, Florida Statutes, having been issued license number PS 0014994. In addition to the pharmacist license the Respondent formerly held a consulting pharmacist’s license which is presently null and void. 4, The Respondent’s last known address is 813 Exmoor Street, Sarasota, Florida 34243, 5. At all times material to the allegations of this complaint the Respondent was employed as “floater” pharmacist with the Wal green Company. 6. On March 27, 1999 a routine weekly inventory was taken of Class II Controlled Substances. It was discovered that a one hundred (100) count bottle Methylphenidate 10 mg. was missing from the store shelves. 7._ In addition to the above it was discovered that a box containing RDS returns of Class II Controlled Substances appeared to have been tampered with and twenty eight (28) capsules of Dexedrine Spansule 5 mg. tablets had been taken from one of three bottles located in the return box. 8. On July 28, 1999 the Respondent was interviewed by the management at Walgreens, During the course and scope of the interview the Respondent admitted removing and ingesting various drugs from assorted locations where she had been assigned to work as a floating pharmacist. 9. The Respondent indicated that this activity had taken place at various times over the past year, and consisted a variety of drugs including both controlled and non-controlled substances. The Respondent admitted to taking the following from the co inventory at the Walgreen’s Store: a. . Provigil — 12 dosages b. Diadrex — 12 dosages c, Augmentin 500 mg ~ 5 dosages d. Entex LA — 6 dosages €. Ativan 2 mg. — 6 dosages f. “Hydrocodone — 12 dosages 10. In addition to the foregoing, the Respondent admitted to being responsible for taking twenty eight (28) Dexedrine Spansule 5 mg. capsules from store number 4033 in Venice, Florida. 11. Furthermore, the Respondent admitted that on July 26, 1999 she had taken both Vicoprofen and Provigil tablets, 12> The conduct of the Respondent as aforesaid is contrary to the provisions contained in Section 465.015(2)(c), Florida Statutes, for dispensing drugs without first being furnished with a prescription; Section 465.016(1Xi), Florida Statutes, for distributing a legend drug, including a controlled substance other than in the course of the professional of pharmacy; Section 465.016(1)(m), Florida Statutes, for being unable to practice pharmacy with reasonable skill and safety by reason of use of drugs, narcotics, or chemicals; and Section 465 .016(1}(d)2, Florida Statutes, for being unfit or incompetent to practice pharmacy by reason of the misuse or abuse of any medicinal drug appearing in any schedule set forth in Chapter 893, Florida Statutes. 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. SOS: teeter saree 1: EDtmEN atm iset AE MiSRRO Ec ~_ oN SIGNED thigythay of _{ ha ew 2000. Robert G. Brooks, M.D. ~. Secretary, Department of Health By: Nancy M. Snurko , Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR AGENCY: Lawrence F. Kranert, Jr. ( Senior Attorney Florida Bar No. 0171063 DEPAR Agency for Health Care Administration De MENT OF H General-Counsel's Office - MQA pry CLERK Allied Health CLERK MebiR, Kens n P.O. Box t4229 D. + 35- Tallahassee, Florida 32317-4229 ATE__{(-.30-25e5 (850)487-2225 07/13/00_ 1 PCP: XN es DATE: Mist gg

Docket for Case No: 03-002705PL