Sep 23 2008 12:07 ¢ SEP-23-2888 12:43 AHCA STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2006-07994 RICKY E. RICHARDSON, RESPONDENT. Se ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through Its undersigned counsel, and files this Administrative Complaint before the Board of Hearing Aid Specialists against Respondent, Ricky E. Richardson, and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of hearing aid specialists Pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 484, Florida Statutes, 2. At all times material to this Complaint, Respondent was a licensed Hearing Aid Specialist within the state of Florida, having been issued license number 2786, 3. Respondent's address of record is P.O, Box 513, Wildwood, Florida 34785, 4, On or about January 20, 2006, the Respondent allowed an unlicensed individual to perform the functions of a hearing aid specialist. 5. Section 484.056(1)(a), Florida Statutes, Provides, among other things, that a violation of any provision of Section 456.072(1), Florida Statutes, constitutes grounds for disciplinary action by the Board of Hearing Aid Specialists, Sep 23 2008 12:08 a 6. Section 456.072(1)(j), Florida Statutes, provides that aiding, assisting, SEP-23-2088 12:43 AHCA procuring, employing, or advising any unlicensed’ person or entity to Practice a Profession contrary to this chapter, the chapter regulating the profession, or the rules of the department or the board, constitutes grounds for disciplinary action by the Board of Hearing Ald Specialists, 7. Respondent allowed an unlicensed individual to perform the functions ofa ' hearing aid specialist on or about January 20, 2006. . 8 Based on the foregoing, Respondent has violated Section 484.056(1)(a), Florida Statutes, by violating 456.072(1)(j), Florida Statutes. WHEREFORE, the Petitioner respectfully requests that the Board of Hearing Aid Specialists enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's license, restriction of Practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate, DOH y. Ricky E. Richardsan DOH Cese Number 2006-07094 2\PSU\Medical\William Mitler\Board of Hearing Aid Speclalists\Richardson 2006-07994 \Richardson.Administrative Complaint.doc Page 2 Sep 23 2008 12:08 P.@5 SEP-23-2088 12:43 AHCA a =e Oe, ne DEPAR vA Na TMENT OF HEALTH EPUTY CLERK CLERK; DATE___\)- 28 ‘OU PCP: \\\\uclOLe PCP Members: Uae ole DOH v, Ricky E. Richardson DOH Case Number 2006-07994 J:\PSU\Medical Complaint.doc M. Rony Francois, M.D., M.S.P.H., Ph.D. Secretary, Department of Health (Gon. William F. Miller Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bln C-65 _~, Tallahassee, FL 32399-3265 - Florida Bar # 0421080 (850) 245-4640 Ext, 8203 (850) 245-4683 FAX Page 3 \Williarn Miller\Board of Hearing Ald Specialists\Richardsar 2006-07994 \Richardson Administrative Sep 23 2008 12:08 ra SEP-23-2088 12:43 AHCA DOH v. Ricky E. Richardson DOH Case Number 2006-07994 NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call. and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing is requested. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and Prosecution of this matter. Pursuant to Section 456,072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition to any other discipline imposed. DOH v. Ricky E. Richardson DOH Case Number 2006-07994 J:\PSU\Medical\William Milter\Board of Hearing Aid Specialists\Richardson 2006-07994 \Richardson Administrative Complalnt.doc Page 4

Docket for Case No: 08-004758PL