Sep 23 2008 12:08 SEP-23-2008 12:44 w th? = P.Be STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2006-18404 RICKY E. RICHARDSON, RESPONDENT. ey | INI TIV| P IT 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, At all times material to this Complaint, the Respondent allowed an unlicensed individual, J.D,C., to perform the functions of a hearing aid specialist at Miracle Ear located in Sears at 1801 NW Highway 19, Crystal River, Florida 34428, man ne Sep 23 2008 12:08 SEP-23-2088 12tde4 _ AHCA w 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 Ald Specialists. 6. Section 456.072(1)(j), Florida Statutes, provides that aiding, assisting, 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 Aid Specialists. 7. Respondent allowed an unlicensed individual, J.D.C.,, to perform the functions of a hearing aid specialist at Miracle Ear located in Sears at 1801 NW Highway 19, Crystal River, Florida 34428. 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 v. Ricky E. Richardson Page 2 DOH Case Number 2006-18404 J:\PSU\Medical\William Miller\Hoard of Heating Ald Specialists\Richardson 2006-18404\Richardson. Administrative Complainti,doc Sep 23 2008 12:09 SEP-23-2088 12:44 _— AACA w P.@9 SIGNED this_<0 _dayof Vovemian = 2006. M. Rony Francois, M.D., M.S.P.H., Ph.D, Secretary, Department of Health Willlam F. Miller Assistant General Counsel FILED DEPARTMENT GIEHEALTH DOH Prosecution Services Unit CLERK: Ag) _. 4052 Bald Cypress Way, Bin C-65 DATE / Tallahassee, FL 32399-3265 Florida Bar # 0421080 (850) 245-4640 Ext, 8203 pcp: WW\iwlole (850) 245-4683 FAX PCP Members: Bolamoo DOH v. Ricky E. Richardson DOH Case Number 2006-18904 J:\PSU\Medical\William Miller\Board of Hearing Aid Speciallsts\Richardson 2006-18404\Richardson, Administrative Complainti.doc Page 3 Sep 23 2008 12:09 SEP-23-2088 12:44 AHCA _ DOH v. Ricky E. Richardson DOH Case Number 2006-18404 NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted [n 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 £. Richardson Page 4 DOH Case Number 2006-18404 JAPSU\Medical\William Miller\Board of Hearing Ald Specialists\Richardson 2006-18404\Richardson.Administrative Complalnt2 doc

Docket for Case No: 08-004759PL