f. full - california state board of pharmacy5 10 15 20 25 1 2 3 4 6 7 11 12 13 14 16 17 18 19 21 22...
TRANSCRIPT
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Petition to Revoke Probation Against
ANNE V TADIN1 3560 Las Flores Canyon Malibu CA 90265
Original Phannacist License No RPH 18843
Respondent
Case No 2641
DEFAULT DECISION AND ORDER
[Gov Code sect11520J
FINDINGS OF FACT
1 On or about August 5 2003 COlnplainant Patricia F Ranis in her official
capacity as the Executive Officer of the Board ofPhannacy Depatinlent ofConsulner Affairs
filed Petition to Revoke Probation No 2641 against Atme V Tadini (Respondent) before the
Board ofPhanl1acy
2 On or about Aplil25 1953 the Board ofPhannacy (Board) issued
Original Phanl1acist License No RPH 18843 to Respondent The Original Phannacist License
was in full force and effect at all titnes relevant to the charges brought herein and will expire on
August 31 2004 unless renewed
3 On or about Septelnber 5 2003 Janice Williatns an enlployee of the
Departlnent of Justice served by Certified and First Class Mail a copy of the Petition to Revoke
Probation No 2641 Statement to Respondent Notice of Defense Request for Discovery and
Government Code sections 115075 115076 and 115077 to Respondents address of record
with the Board which was and is 3560 Las Flores Canyon Malibu CA 90265 A copy of the
1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Petition to Revoke Probation is attached as exhihit A and is incorporated herein by reference
4 Service of the Petition to Revoke Probation was effective as a matter of
law under the provisions of Govel1llnent Code section 11505 subdivision (c)
5 Govermnent Code section 11506 states in pertinent pati
( c) The respondent shall be entitled to a hearing on the Inerits if the respondent
files a notice of defense and the notice shall be deelned a specific denial of all parts of the
accusation not expressly admitted Failure to file a notice of defense shall constitute a waiver of
respondents light to a hearing but the agency in its discretion lnay nevertheless grant a hearinRmiddot
6 Respondent failed to file a Notice of Defense within 15 days after service
upon her of the Petition to Revoke Probation and therefore waived her right to a heating on the
lnerits of Petition to Revoke Probation No 2641
7 California Govermnent Code section 11520 states in pertinent part
(a) If the respondent either fails to file a notice of defense or to appear at the
hearing the agency n1ay take action based upon the respondents express adlnissions or
upon other evidence and affidavits Inay be used as evidence without any notice to
respondent
8 Pursuant to its autholity under Govenunent Code section 11520 the Board
finds Respondent is in default The Board will take action without fUliher hearing and based on
Respondents express adlnissions by way of default and the evidence before it contained in
exhibits A finds that the allegations in Petition to Revoke Probation No 2641 are hue
9 The total costs for investigation and enforce111ent are $185625 as of
October 31 2003
DETERMINATION OF ISSUES
1 Based on the foregoing findings of fact Respondent Am1e V Tadini has
subjected her Oliginal Phatmacist License No RPH 18843 to discipline
2 A copy of the Petition to Revoke Probation is attached
3 The agency has jurisdiction to adjudicate this case by default
4 The Board of Ph ann acy is authorized to revoke Respondents Original
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Phannacist License based upon the following violations alleged in the Petition to Revoke
Probation
a Respondent failed to cOlnply with certain tenns and conditions of
probation
ORDER
IT IS SO ORDERED that Original Pharmacist License No RPH 18843
heretofore issued to Respondent Anne V Tadini is revoked
Pursuant to Govenunent Code section 11520 subdivision (c) Respondent Inay
serve a written ITIotion requesting that the Decision be vacated and stating the grounds relied on
within seven (7) days after service of the Decision on Respondent The agency in its discretion
n1ay vacate the Decision and grant a hearing on a showing of good cause as defined in the
statute
This Decision shall beCOlne effective on Februa ry 6 I 2004
It is so ORDERED _-J-oadujDIJ11aurJY-I---L7+f--pound2uOwOt4t--_
BOARD OF PHARMACY DEPARTMENT OF CONSUMERAFFAlRS STATE OF CALlFORNIA
By
Attachment
Exhibit A Petition to Revoke Probation No2641
DOJ docket number0358311 O-LA2003500311
GBGCDKeyg
3
5
10
15
20
25
1
2
3
4
6
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
8 9
I
W
~
BILL LOCKYER Attorney General of the State of California
GLYNDA B GOMEZ State Bar No 143448 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2542 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRSSTATE OF CALIFORNIA
In the Matter of the Petition to Revoke ProbatiQn Against
ANNE V TADINI 3560 Las Flores Canyon Malibu CA 90265
Original Pharmacist License No RPH 18843
Respondent
Case No 2641
PETITION TO REVOKE PROBATION
Complainant alleges
PARTIES
1 Patricia F Harris (Complainant) brings this Petition to Revoke Probation
solely in her official capacity as the Executive Officer of the Board of Pharmacy Department of
Consumer Affairs
2 On or about April 25 1953 the Board ofPharmacy issued Original
Pharmacist License No RPH 18843 to Anne V Tadini (Respondent) The license will expire on
August 31 2004 unless renewed
3 In a disciplinary action entitled In the Matter ofAccusation Against Anne
V Tadini Case No 2098 the Board ofPharmacy issued a decision effective September 21
2000 in which Respondents Original Pharmacist License was revoked However the revocation
was stayed and Respondents license was placed on probation for a period of three (3) years with
1
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22middot
23
24
26
27
28
certain terms and conditions A copy of that decision is attached as Exhibit A and is incorporated
by reference
JURISDICTION
4 This Petition to Revoke Probation is brought before the Board of
Phannacy (Board) Department of Consumer Affairs under the authority of the following laws
All section references are to the Business and Professions Code unless otherwise indicated
5 Section 4300 states in pertinent part
( a) Every license issued may be suspended or revoked
(d) The board may initiate disciplinary proceedings to revoke or suspend any
probationary certificate of licensure for any violation of the terms and conditions of probation
Upon satisfactory completion ofprobation the board shall convert the probationary certificate to
a regular certificate free of conditions
CAUSE TO REVOKE PROBATION
6 The probation ofRespondent Anne Tadini is subject to revocation in that
Respondent failed to comply with conditions 1 3 7 8 and 9 of probation in the following
respects
ACTUAL SUSPENSION
A Probation Condition 1 states
As part of suspension Respondent is suspended from the practice ofpharmacy
for twenty (20) days beginning the effective date of this decision
During suspension Respondent shall not enter any pharmacy area or any portion
of the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect of the practice ofphannacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent was suspended from the practice ofpharmacy for twenty (20) days
from September 212000 to October 112000 inclusive From on or about September 19 2000
to on or about March 20 2001 three times a week Respondent practiced as a pharmacist for
Royal Care Pharmacy
REPORTING TO THE BOARD
B Probation Condition 3 states
Respondent shall report to theBoard or its designee quarterly The report shall
be made either in person or in writing as directed If the final probation report is not made as
directed probation shall be extended automatically until such time as the final report is made
Respondent failed to report to the Board either in person or in wri~ing as
directed Respondent submitted only three quarterly reports which covered the period from
September 20 2000 through June 2001
CONTINUING EDUCATION
C Probation Condition 7 states
Respondent shall provide evidence of efforts to maintain skill and knowledge as
a pharmacist as directed by the Board
Respondent has failed to submit any evidence of continuing education
EXAMINATION
D Probation Condition 8 states
Respondent shall take and pass the law sections( s) of the phannacist licensure
examination as scheduled by the Board within six (6) months effective date of this decision If
respondent fails the examination or fails to take the examination respondent shall be suspended
upon written notice Respondent shall not resume the practice ofpharmacy until she takes and
3
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
28
4
passes the same section( s) at a subsequent examination and is notified in writing she has passed
the examination
During suspension respondent shall not enter any pharmacy area or any portion of
the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect ofth~ practice ofpharmacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent failed to apply to take the law section of the pharmacist licensure
exam within the first six months ofprobation as required
NOTICE TO EMPLOYERS
E Probation Condition 9 states
Respondent shall notify all present and prospective employers of the decision in
case number 2098 and the terms conditions and restrictions imposed on respondent by the
decision Within thirty (30) days of the effective date of this decision and within fifteen (15)
days of respondent undertaking new employment respondent shall cause her employer to report
to the Board in writing acknowledging the employer has read the decision in case number 2098
If respondent works for or is employed by or through a pharmacy employment service
Respondent must notify the pharmacist-in-charge andor owner at every pharmacy at which she is
to employed or used of the fact and terms of the decision in case number 2098 in advance of the
respondent commencing work at the pharmacy Employment within the meaning of this
provision shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an employee or
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
independent contractor
Respondent was required to notify all present and prospective employers
of the terms and conditions ofprobation Respondent failed to notify her employer Royal Care
Phannacy or owner of the pharmacy that she was on probation
PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board ofPharmacy issue a decision
1 Revoking the probation that was granted by the Board of Pharmacy in
Case No 2098 and imposing the disciplinary order that was stayed thereby revoking Original
Phannacist License No RPH 18843 issued to Anne V Tadini
2 Revoking or suspending Original Pharmacist License No RPH 18843
issued to Anne V Tadini
3 Taking such other and further action as deemed necessary and proper
DATED
fJ~
03583110-LA2003500311
TadiniA_Pet2Revkwpd
CML (071102003)
PATRICIA F HARRIS Executive Officer Board ofPharmacy Department of Consumer Affairs State ofCalifornia Complainant
5
-
Exhibit A
Decision and Order
Board of Pharmacy Case No 2641
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
) )
-bullbull-=----shy
BILL LOCKYER Attorney General of the State of California
ZAVEN V SINANIAN Deputy Attorney General State Bar No 140076
Department of Justice 300 South Spring Street Los Angeles California 90013 Telephone (213) 897-6015
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 39799 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42084 HUSSEIN A DARWISH Owner Pharmacy Technician Registration
No TCH 24271 ~ )
)
)
~
~
and
LA BOTICA PHARMACY 2622 Clarendon Avenue Huntington Park CA 90255 Pharmacy Permit No PHY 40905 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
1 Exhibit 2-L of I~ Pages
No2098 OAH No L-1999030089
STIPULATION IN SETTLEMENT DECISION AND ORDER AS TO RESPONDENT ANNE V TADINI PHARMACIST LICENSE NO RPH 18843
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Petition to Revoke Probation is attached as exhihit A and is incorporated herein by reference
4 Service of the Petition to Revoke Probation was effective as a matter of
law under the provisions of Govel1llnent Code section 11505 subdivision (c)
5 Govermnent Code section 11506 states in pertinent pati
( c) The respondent shall be entitled to a hearing on the Inerits if the respondent
files a notice of defense and the notice shall be deelned a specific denial of all parts of the
accusation not expressly admitted Failure to file a notice of defense shall constitute a waiver of
respondents light to a hearing but the agency in its discretion lnay nevertheless grant a hearinRmiddot
6 Respondent failed to file a Notice of Defense within 15 days after service
upon her of the Petition to Revoke Probation and therefore waived her right to a heating on the
lnerits of Petition to Revoke Probation No 2641
7 California Govermnent Code section 11520 states in pertinent part
(a) If the respondent either fails to file a notice of defense or to appear at the
hearing the agency n1ay take action based upon the respondents express adlnissions or
upon other evidence and affidavits Inay be used as evidence without any notice to
respondent
8 Pursuant to its autholity under Govenunent Code section 11520 the Board
finds Respondent is in default The Board will take action without fUliher hearing and based on
Respondents express adlnissions by way of default and the evidence before it contained in
exhibits A finds that the allegations in Petition to Revoke Probation No 2641 are hue
9 The total costs for investigation and enforce111ent are $185625 as of
October 31 2003
DETERMINATION OF ISSUES
1 Based on the foregoing findings of fact Respondent Am1e V Tadini has
subjected her Oliginal Phatmacist License No RPH 18843 to discipline
2 A copy of the Petition to Revoke Probation is attached
3 The agency has jurisdiction to adjudicate this case by default
4 The Board of Ph ann acy is authorized to revoke Respondents Original
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Phannacist License based upon the following violations alleged in the Petition to Revoke
Probation
a Respondent failed to cOlnply with certain tenns and conditions of
probation
ORDER
IT IS SO ORDERED that Original Pharmacist License No RPH 18843
heretofore issued to Respondent Anne V Tadini is revoked
Pursuant to Govenunent Code section 11520 subdivision (c) Respondent Inay
serve a written ITIotion requesting that the Decision be vacated and stating the grounds relied on
within seven (7) days after service of the Decision on Respondent The agency in its discretion
n1ay vacate the Decision and grant a hearing on a showing of good cause as defined in the
statute
This Decision shall beCOlne effective on Februa ry 6 I 2004
It is so ORDERED _-J-oadujDIJ11aurJY-I---L7+f--pound2uOwOt4t--_
BOARD OF PHARMACY DEPARTMENT OF CONSUMERAFFAlRS STATE OF CALlFORNIA
By
Attachment
Exhibit A Petition to Revoke Probation No2641
DOJ docket number0358311 O-LA2003500311
GBGCDKeyg
3
5
10
15
20
25
1
2
3
4
6
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
8 9
I
W
~
BILL LOCKYER Attorney General of the State of California
GLYNDA B GOMEZ State Bar No 143448 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2542 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRSSTATE OF CALIFORNIA
In the Matter of the Petition to Revoke ProbatiQn Against
ANNE V TADINI 3560 Las Flores Canyon Malibu CA 90265
Original Pharmacist License No RPH 18843
Respondent
Case No 2641
PETITION TO REVOKE PROBATION
Complainant alleges
PARTIES
1 Patricia F Harris (Complainant) brings this Petition to Revoke Probation
solely in her official capacity as the Executive Officer of the Board of Pharmacy Department of
Consumer Affairs
2 On or about April 25 1953 the Board ofPharmacy issued Original
Pharmacist License No RPH 18843 to Anne V Tadini (Respondent) The license will expire on
August 31 2004 unless renewed
3 In a disciplinary action entitled In the Matter ofAccusation Against Anne
V Tadini Case No 2098 the Board ofPharmacy issued a decision effective September 21
2000 in which Respondents Original Pharmacist License was revoked However the revocation
was stayed and Respondents license was placed on probation for a period of three (3) years with
1
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22middot
23
24
26
27
28
certain terms and conditions A copy of that decision is attached as Exhibit A and is incorporated
by reference
JURISDICTION
4 This Petition to Revoke Probation is brought before the Board of
Phannacy (Board) Department of Consumer Affairs under the authority of the following laws
All section references are to the Business and Professions Code unless otherwise indicated
5 Section 4300 states in pertinent part
( a) Every license issued may be suspended or revoked
(d) The board may initiate disciplinary proceedings to revoke or suspend any
probationary certificate of licensure for any violation of the terms and conditions of probation
Upon satisfactory completion ofprobation the board shall convert the probationary certificate to
a regular certificate free of conditions
CAUSE TO REVOKE PROBATION
6 The probation ofRespondent Anne Tadini is subject to revocation in that
Respondent failed to comply with conditions 1 3 7 8 and 9 of probation in the following
respects
ACTUAL SUSPENSION
A Probation Condition 1 states
As part of suspension Respondent is suspended from the practice ofpharmacy
for twenty (20) days beginning the effective date of this decision
During suspension Respondent shall not enter any pharmacy area or any portion
of the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect of the practice ofphannacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent was suspended from the practice ofpharmacy for twenty (20) days
from September 212000 to October 112000 inclusive From on or about September 19 2000
to on or about March 20 2001 three times a week Respondent practiced as a pharmacist for
Royal Care Pharmacy
REPORTING TO THE BOARD
B Probation Condition 3 states
Respondent shall report to theBoard or its designee quarterly The report shall
be made either in person or in writing as directed If the final probation report is not made as
directed probation shall be extended automatically until such time as the final report is made
Respondent failed to report to the Board either in person or in wri~ing as
directed Respondent submitted only three quarterly reports which covered the period from
September 20 2000 through June 2001
CONTINUING EDUCATION
C Probation Condition 7 states
Respondent shall provide evidence of efforts to maintain skill and knowledge as
a pharmacist as directed by the Board
Respondent has failed to submit any evidence of continuing education
EXAMINATION
D Probation Condition 8 states
Respondent shall take and pass the law sections( s) of the phannacist licensure
examination as scheduled by the Board within six (6) months effective date of this decision If
respondent fails the examination or fails to take the examination respondent shall be suspended
upon written notice Respondent shall not resume the practice ofpharmacy until she takes and
3
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
28
4
passes the same section( s) at a subsequent examination and is notified in writing she has passed
the examination
During suspension respondent shall not enter any pharmacy area or any portion of
the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect ofth~ practice ofpharmacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent failed to apply to take the law section of the pharmacist licensure
exam within the first six months ofprobation as required
NOTICE TO EMPLOYERS
E Probation Condition 9 states
Respondent shall notify all present and prospective employers of the decision in
case number 2098 and the terms conditions and restrictions imposed on respondent by the
decision Within thirty (30) days of the effective date of this decision and within fifteen (15)
days of respondent undertaking new employment respondent shall cause her employer to report
to the Board in writing acknowledging the employer has read the decision in case number 2098
If respondent works for or is employed by or through a pharmacy employment service
Respondent must notify the pharmacist-in-charge andor owner at every pharmacy at which she is
to employed or used of the fact and terms of the decision in case number 2098 in advance of the
respondent commencing work at the pharmacy Employment within the meaning of this
provision shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an employee or
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
independent contractor
Respondent was required to notify all present and prospective employers
of the terms and conditions ofprobation Respondent failed to notify her employer Royal Care
Phannacy or owner of the pharmacy that she was on probation
PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board ofPharmacy issue a decision
1 Revoking the probation that was granted by the Board of Pharmacy in
Case No 2098 and imposing the disciplinary order that was stayed thereby revoking Original
Phannacist License No RPH 18843 issued to Anne V Tadini
2 Revoking or suspending Original Pharmacist License No RPH 18843
issued to Anne V Tadini
3 Taking such other and further action as deemed necessary and proper
DATED
fJ~
03583110-LA2003500311
TadiniA_Pet2Revkwpd
CML (071102003)
PATRICIA F HARRIS Executive Officer Board ofPharmacy Department of Consumer Affairs State ofCalifornia Complainant
5
-
Exhibit A
Decision and Order
Board of Pharmacy Case No 2641
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
) )
-bullbull-=----shy
BILL LOCKYER Attorney General of the State of California
ZAVEN V SINANIAN Deputy Attorney General State Bar No 140076
Department of Justice 300 South Spring Street Los Angeles California 90013 Telephone (213) 897-6015
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 39799 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42084 HUSSEIN A DARWISH Owner Pharmacy Technician Registration
No TCH 24271 ~ )
)
)
~
~
and
LA BOTICA PHARMACY 2622 Clarendon Avenue Huntington Park CA 90255 Pharmacy Permit No PHY 40905 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
1 Exhibit 2-L of I~ Pages
No2098 OAH No L-1999030089
STIPULATION IN SETTLEMENT DECISION AND ORDER AS TO RESPONDENT ANNE V TADINI PHARMACIST LICENSE NO RPH 18843
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Phannacist License based upon the following violations alleged in the Petition to Revoke
Probation
a Respondent failed to cOlnply with certain tenns and conditions of
probation
ORDER
IT IS SO ORDERED that Original Pharmacist License No RPH 18843
heretofore issued to Respondent Anne V Tadini is revoked
Pursuant to Govenunent Code section 11520 subdivision (c) Respondent Inay
serve a written ITIotion requesting that the Decision be vacated and stating the grounds relied on
within seven (7) days after service of the Decision on Respondent The agency in its discretion
n1ay vacate the Decision and grant a hearing on a showing of good cause as defined in the
statute
This Decision shall beCOlne effective on Februa ry 6 I 2004
It is so ORDERED _-J-oadujDIJ11aurJY-I---L7+f--pound2uOwOt4t--_
BOARD OF PHARMACY DEPARTMENT OF CONSUMERAFFAlRS STATE OF CALlFORNIA
By
Attachment
Exhibit A Petition to Revoke Probation No2641
DOJ docket number0358311 O-LA2003500311
GBGCDKeyg
3
5
10
15
20
25
1
2
3
4
6
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
8 9
I
W
~
BILL LOCKYER Attorney General of the State of California
GLYNDA B GOMEZ State Bar No 143448 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2542 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRSSTATE OF CALIFORNIA
In the Matter of the Petition to Revoke ProbatiQn Against
ANNE V TADINI 3560 Las Flores Canyon Malibu CA 90265
Original Pharmacist License No RPH 18843
Respondent
Case No 2641
PETITION TO REVOKE PROBATION
Complainant alleges
PARTIES
1 Patricia F Harris (Complainant) brings this Petition to Revoke Probation
solely in her official capacity as the Executive Officer of the Board of Pharmacy Department of
Consumer Affairs
2 On or about April 25 1953 the Board ofPharmacy issued Original
Pharmacist License No RPH 18843 to Anne V Tadini (Respondent) The license will expire on
August 31 2004 unless renewed
3 In a disciplinary action entitled In the Matter ofAccusation Against Anne
V Tadini Case No 2098 the Board ofPharmacy issued a decision effective September 21
2000 in which Respondents Original Pharmacist License was revoked However the revocation
was stayed and Respondents license was placed on probation for a period of three (3) years with
1
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22middot
23
24
26
27
28
certain terms and conditions A copy of that decision is attached as Exhibit A and is incorporated
by reference
JURISDICTION
4 This Petition to Revoke Probation is brought before the Board of
Phannacy (Board) Department of Consumer Affairs under the authority of the following laws
All section references are to the Business and Professions Code unless otherwise indicated
5 Section 4300 states in pertinent part
( a) Every license issued may be suspended or revoked
(d) The board may initiate disciplinary proceedings to revoke or suspend any
probationary certificate of licensure for any violation of the terms and conditions of probation
Upon satisfactory completion ofprobation the board shall convert the probationary certificate to
a regular certificate free of conditions
CAUSE TO REVOKE PROBATION
6 The probation ofRespondent Anne Tadini is subject to revocation in that
Respondent failed to comply with conditions 1 3 7 8 and 9 of probation in the following
respects
ACTUAL SUSPENSION
A Probation Condition 1 states
As part of suspension Respondent is suspended from the practice ofpharmacy
for twenty (20) days beginning the effective date of this decision
During suspension Respondent shall not enter any pharmacy area or any portion
of the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect of the practice ofphannacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent was suspended from the practice ofpharmacy for twenty (20) days
from September 212000 to October 112000 inclusive From on or about September 19 2000
to on or about March 20 2001 three times a week Respondent practiced as a pharmacist for
Royal Care Pharmacy
REPORTING TO THE BOARD
B Probation Condition 3 states
Respondent shall report to theBoard or its designee quarterly The report shall
be made either in person or in writing as directed If the final probation report is not made as
directed probation shall be extended automatically until such time as the final report is made
Respondent failed to report to the Board either in person or in wri~ing as
directed Respondent submitted only three quarterly reports which covered the period from
September 20 2000 through June 2001
CONTINUING EDUCATION
C Probation Condition 7 states
Respondent shall provide evidence of efforts to maintain skill and knowledge as
a pharmacist as directed by the Board
Respondent has failed to submit any evidence of continuing education
EXAMINATION
D Probation Condition 8 states
Respondent shall take and pass the law sections( s) of the phannacist licensure
examination as scheduled by the Board within six (6) months effective date of this decision If
respondent fails the examination or fails to take the examination respondent shall be suspended
upon written notice Respondent shall not resume the practice ofpharmacy until she takes and
3
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
28
4
passes the same section( s) at a subsequent examination and is notified in writing she has passed
the examination
During suspension respondent shall not enter any pharmacy area or any portion of
the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect ofth~ practice ofpharmacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent failed to apply to take the law section of the pharmacist licensure
exam within the first six months ofprobation as required
NOTICE TO EMPLOYERS
E Probation Condition 9 states
Respondent shall notify all present and prospective employers of the decision in
case number 2098 and the terms conditions and restrictions imposed on respondent by the
decision Within thirty (30) days of the effective date of this decision and within fifteen (15)
days of respondent undertaking new employment respondent shall cause her employer to report
to the Board in writing acknowledging the employer has read the decision in case number 2098
If respondent works for or is employed by or through a pharmacy employment service
Respondent must notify the pharmacist-in-charge andor owner at every pharmacy at which she is
to employed or used of the fact and terms of the decision in case number 2098 in advance of the
respondent commencing work at the pharmacy Employment within the meaning of this
provision shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an employee or
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
independent contractor
Respondent was required to notify all present and prospective employers
of the terms and conditions ofprobation Respondent failed to notify her employer Royal Care
Phannacy or owner of the pharmacy that she was on probation
PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board ofPharmacy issue a decision
1 Revoking the probation that was granted by the Board of Pharmacy in
Case No 2098 and imposing the disciplinary order that was stayed thereby revoking Original
Phannacist License No RPH 18843 issued to Anne V Tadini
2 Revoking or suspending Original Pharmacist License No RPH 18843
issued to Anne V Tadini
3 Taking such other and further action as deemed necessary and proper
DATED
fJ~
03583110-LA2003500311
TadiniA_Pet2Revkwpd
CML (071102003)
PATRICIA F HARRIS Executive Officer Board ofPharmacy Department of Consumer Affairs State ofCalifornia Complainant
5
-
Exhibit A
Decision and Order
Board of Pharmacy Case No 2641
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
) )
-bullbull-=----shy
BILL LOCKYER Attorney General of the State of California
ZAVEN V SINANIAN Deputy Attorney General State Bar No 140076
Department of Justice 300 South Spring Street Los Angeles California 90013 Telephone (213) 897-6015
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 39799 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42084 HUSSEIN A DARWISH Owner Pharmacy Technician Registration
No TCH 24271 ~ )
)
)
~
~
and
LA BOTICA PHARMACY 2622 Clarendon Avenue Huntington Park CA 90255 Pharmacy Permit No PHY 40905 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
1 Exhibit 2-L of I~ Pages
No2098 OAH No L-1999030089
STIPULATION IN SETTLEMENT DECISION AND ORDER AS TO RESPONDENT ANNE V TADINI PHARMACIST LICENSE NO RPH 18843
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
5
10
15
20
25
1
2
3
4
6
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
8 9
I
W
~
BILL LOCKYER Attorney General of the State of California
GLYNDA B GOMEZ State Bar No 143448 Deputy Attorney General
California Department of Justice 300 So Spring Street Suite 1702 Los Angeles CA 90013 Telephone (213) 897-2542 Facsimile (213) 897-2804
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRSSTATE OF CALIFORNIA
In the Matter of the Petition to Revoke ProbatiQn Against
ANNE V TADINI 3560 Las Flores Canyon Malibu CA 90265
Original Pharmacist License No RPH 18843
Respondent
Case No 2641
PETITION TO REVOKE PROBATION
Complainant alleges
PARTIES
1 Patricia F Harris (Complainant) brings this Petition to Revoke Probation
solely in her official capacity as the Executive Officer of the Board of Pharmacy Department of
Consumer Affairs
2 On or about April 25 1953 the Board ofPharmacy issued Original
Pharmacist License No RPH 18843 to Anne V Tadini (Respondent) The license will expire on
August 31 2004 unless renewed
3 In a disciplinary action entitled In the Matter ofAccusation Against Anne
V Tadini Case No 2098 the Board ofPharmacy issued a decision effective September 21
2000 in which Respondents Original Pharmacist License was revoked However the revocation
was stayed and Respondents license was placed on probation for a period of three (3) years with
1
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22middot
23
24
26
27
28
certain terms and conditions A copy of that decision is attached as Exhibit A and is incorporated
by reference
JURISDICTION
4 This Petition to Revoke Probation is brought before the Board of
Phannacy (Board) Department of Consumer Affairs under the authority of the following laws
All section references are to the Business and Professions Code unless otherwise indicated
5 Section 4300 states in pertinent part
( a) Every license issued may be suspended or revoked
(d) The board may initiate disciplinary proceedings to revoke or suspend any
probationary certificate of licensure for any violation of the terms and conditions of probation
Upon satisfactory completion ofprobation the board shall convert the probationary certificate to
a regular certificate free of conditions
CAUSE TO REVOKE PROBATION
6 The probation ofRespondent Anne Tadini is subject to revocation in that
Respondent failed to comply with conditions 1 3 7 8 and 9 of probation in the following
respects
ACTUAL SUSPENSION
A Probation Condition 1 states
As part of suspension Respondent is suspended from the practice ofpharmacy
for twenty (20) days beginning the effective date of this decision
During suspension Respondent shall not enter any pharmacy area or any portion
of the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect of the practice ofphannacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent was suspended from the practice ofpharmacy for twenty (20) days
from September 212000 to October 112000 inclusive From on or about September 19 2000
to on or about March 20 2001 three times a week Respondent practiced as a pharmacist for
Royal Care Pharmacy
REPORTING TO THE BOARD
B Probation Condition 3 states
Respondent shall report to theBoard or its designee quarterly The report shall
be made either in person or in writing as directed If the final probation report is not made as
directed probation shall be extended automatically until such time as the final report is made
Respondent failed to report to the Board either in person or in wri~ing as
directed Respondent submitted only three quarterly reports which covered the period from
September 20 2000 through June 2001
CONTINUING EDUCATION
C Probation Condition 7 states
Respondent shall provide evidence of efforts to maintain skill and knowledge as
a pharmacist as directed by the Board
Respondent has failed to submit any evidence of continuing education
EXAMINATION
D Probation Condition 8 states
Respondent shall take and pass the law sections( s) of the phannacist licensure
examination as scheduled by the Board within six (6) months effective date of this decision If
respondent fails the examination or fails to take the examination respondent shall be suspended
upon written notice Respondent shall not resume the practice ofpharmacy until she takes and
3
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
28
4
passes the same section( s) at a subsequent examination and is notified in writing she has passed
the examination
During suspension respondent shall not enter any pharmacy area or any portion of
the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect ofth~ practice ofpharmacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent failed to apply to take the law section of the pharmacist licensure
exam within the first six months ofprobation as required
NOTICE TO EMPLOYERS
E Probation Condition 9 states
Respondent shall notify all present and prospective employers of the decision in
case number 2098 and the terms conditions and restrictions imposed on respondent by the
decision Within thirty (30) days of the effective date of this decision and within fifteen (15)
days of respondent undertaking new employment respondent shall cause her employer to report
to the Board in writing acknowledging the employer has read the decision in case number 2098
If respondent works for or is employed by or through a pharmacy employment service
Respondent must notify the pharmacist-in-charge andor owner at every pharmacy at which she is
to employed or used of the fact and terms of the decision in case number 2098 in advance of the
respondent commencing work at the pharmacy Employment within the meaning of this
provision shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an employee or
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
independent contractor
Respondent was required to notify all present and prospective employers
of the terms and conditions ofprobation Respondent failed to notify her employer Royal Care
Phannacy or owner of the pharmacy that she was on probation
PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board ofPharmacy issue a decision
1 Revoking the probation that was granted by the Board of Pharmacy in
Case No 2098 and imposing the disciplinary order that was stayed thereby revoking Original
Phannacist License No RPH 18843 issued to Anne V Tadini
2 Revoking or suspending Original Pharmacist License No RPH 18843
issued to Anne V Tadini
3 Taking such other and further action as deemed necessary and proper
DATED
fJ~
03583110-LA2003500311
TadiniA_Pet2Revkwpd
CML (071102003)
PATRICIA F HARRIS Executive Officer Board ofPharmacy Department of Consumer Affairs State ofCalifornia Complainant
5
-
Exhibit A
Decision and Order
Board of Pharmacy Case No 2641
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
) )
-bullbull-=----shy
BILL LOCKYER Attorney General of the State of California
ZAVEN V SINANIAN Deputy Attorney General State Bar No 140076
Department of Justice 300 South Spring Street Los Angeles California 90013 Telephone (213) 897-6015
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 39799 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42084 HUSSEIN A DARWISH Owner Pharmacy Technician Registration
No TCH 24271 ~ )
)
)
~
~
and
LA BOTICA PHARMACY 2622 Clarendon Avenue Huntington Park CA 90255 Pharmacy Permit No PHY 40905 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
1 Exhibit 2-L of I~ Pages
No2098 OAH No L-1999030089
STIPULATION IN SETTLEMENT DECISION AND ORDER AS TO RESPONDENT ANNE V TADINI PHARMACIST LICENSE NO RPH 18843
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22middot
23
24
26
27
28
certain terms and conditions A copy of that decision is attached as Exhibit A and is incorporated
by reference
JURISDICTION
4 This Petition to Revoke Probation is brought before the Board of
Phannacy (Board) Department of Consumer Affairs under the authority of the following laws
All section references are to the Business and Professions Code unless otherwise indicated
5 Section 4300 states in pertinent part
( a) Every license issued may be suspended or revoked
(d) The board may initiate disciplinary proceedings to revoke or suspend any
probationary certificate of licensure for any violation of the terms and conditions of probation
Upon satisfactory completion ofprobation the board shall convert the probationary certificate to
a regular certificate free of conditions
CAUSE TO REVOKE PROBATION
6 The probation ofRespondent Anne Tadini is subject to revocation in that
Respondent failed to comply with conditions 1 3 7 8 and 9 of probation in the following
respects
ACTUAL SUSPENSION
A Probation Condition 1 states
As part of suspension Respondent is suspended from the practice ofpharmacy
for twenty (20) days beginning the effective date of this decision
During suspension Respondent shall not enter any pharmacy area or any portion
of the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect of the practice ofphannacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent was suspended from the practice ofpharmacy for twenty (20) days
from September 212000 to October 112000 inclusive From on or about September 19 2000
to on or about March 20 2001 three times a week Respondent practiced as a pharmacist for
Royal Care Pharmacy
REPORTING TO THE BOARD
B Probation Condition 3 states
Respondent shall report to theBoard or its designee quarterly The report shall
be made either in person or in writing as directed If the final probation report is not made as
directed probation shall be extended automatically until such time as the final report is made
Respondent failed to report to the Board either in person or in wri~ing as
directed Respondent submitted only three quarterly reports which covered the period from
September 20 2000 through June 2001
CONTINUING EDUCATION
C Probation Condition 7 states
Respondent shall provide evidence of efforts to maintain skill and knowledge as
a pharmacist as directed by the Board
Respondent has failed to submit any evidence of continuing education
EXAMINATION
D Probation Condition 8 states
Respondent shall take and pass the law sections( s) of the phannacist licensure
examination as scheduled by the Board within six (6) months effective date of this decision If
respondent fails the examination or fails to take the examination respondent shall be suspended
upon written notice Respondent shall not resume the practice ofpharmacy until she takes and
3
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
28
4
passes the same section( s) at a subsequent examination and is notified in writing she has passed
the examination
During suspension respondent shall not enter any pharmacy area or any portion of
the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect ofth~ practice ofpharmacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent failed to apply to take the law section of the pharmacist licensure
exam within the first six months ofprobation as required
NOTICE TO EMPLOYERS
E Probation Condition 9 states
Respondent shall notify all present and prospective employers of the decision in
case number 2098 and the terms conditions and restrictions imposed on respondent by the
decision Within thirty (30) days of the effective date of this decision and within fifteen (15)
days of respondent undertaking new employment respondent shall cause her employer to report
to the Board in writing acknowledging the employer has read the decision in case number 2098
If respondent works for or is employed by or through a pharmacy employment service
Respondent must notify the pharmacist-in-charge andor owner at every pharmacy at which she is
to employed or used of the fact and terms of the decision in case number 2098 in advance of the
respondent commencing work at the pharmacy Employment within the meaning of this
provision shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an employee or
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
independent contractor
Respondent was required to notify all present and prospective employers
of the terms and conditions ofprobation Respondent failed to notify her employer Royal Care
Phannacy or owner of the pharmacy that she was on probation
PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board ofPharmacy issue a decision
1 Revoking the probation that was granted by the Board of Pharmacy in
Case No 2098 and imposing the disciplinary order that was stayed thereby revoking Original
Phannacist License No RPH 18843 issued to Anne V Tadini
2 Revoking or suspending Original Pharmacist License No RPH 18843
issued to Anne V Tadini
3 Taking such other and further action as deemed necessary and proper
DATED
fJ~
03583110-LA2003500311
TadiniA_Pet2Revkwpd
CML (071102003)
PATRICIA F HARRIS Executive Officer Board ofPharmacy Department of Consumer Affairs State ofCalifornia Complainant
5
-
Exhibit A
Decision and Order
Board of Pharmacy Case No 2641
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
) )
-bullbull-=----shy
BILL LOCKYER Attorney General of the State of California
ZAVEN V SINANIAN Deputy Attorney General State Bar No 140076
Department of Justice 300 South Spring Street Los Angeles California 90013 Telephone (213) 897-6015
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 39799 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42084 HUSSEIN A DARWISH Owner Pharmacy Technician Registration
No TCH 24271 ~ )
)
)
~
~
and
LA BOTICA PHARMACY 2622 Clarendon Avenue Huntington Park CA 90255 Pharmacy Permit No PHY 40905 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
1 Exhibit 2-L of I~ Pages
No2098 OAH No L-1999030089
STIPULATION IN SETTLEMENT DECISION AND ORDER AS TO RESPONDENT ANNE V TADINI PHARMACIST LICENSE NO RPH 18843
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect of the practice ofphannacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent was suspended from the practice ofpharmacy for twenty (20) days
from September 212000 to October 112000 inclusive From on or about September 19 2000
to on or about March 20 2001 three times a week Respondent practiced as a pharmacist for
Royal Care Pharmacy
REPORTING TO THE BOARD
B Probation Condition 3 states
Respondent shall report to theBoard or its designee quarterly The report shall
be made either in person or in writing as directed If the final probation report is not made as
directed probation shall be extended automatically until such time as the final report is made
Respondent failed to report to the Board either in person or in wri~ing as
directed Respondent submitted only three quarterly reports which covered the period from
September 20 2000 through June 2001
CONTINUING EDUCATION
C Probation Condition 7 states
Respondent shall provide evidence of efforts to maintain skill and knowledge as
a pharmacist as directed by the Board
Respondent has failed to submit any evidence of continuing education
EXAMINATION
D Probation Condition 8 states
Respondent shall take and pass the law sections( s) of the phannacist licensure
examination as scheduled by the Board within six (6) months effective date of this decision If
respondent fails the examination or fails to take the examination respondent shall be suspended
upon written notice Respondent shall not resume the practice ofpharmacy until she takes and
3
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
28
4
passes the same section( s) at a subsequent examination and is notified in writing she has passed
the examination
During suspension respondent shall not enter any pharmacy area or any portion of
the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect ofth~ practice ofpharmacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent failed to apply to take the law section of the pharmacist licensure
exam within the first six months ofprobation as required
NOTICE TO EMPLOYERS
E Probation Condition 9 states
Respondent shall notify all present and prospective employers of the decision in
case number 2098 and the terms conditions and restrictions imposed on respondent by the
decision Within thirty (30) days of the effective date of this decision and within fifteen (15)
days of respondent undertaking new employment respondent shall cause her employer to report
to the Board in writing acknowledging the employer has read the decision in case number 2098
If respondent works for or is employed by or through a pharmacy employment service
Respondent must notify the pharmacist-in-charge andor owner at every pharmacy at which she is
to employed or used of the fact and terms of the decision in case number 2098 in advance of the
respondent commencing work at the pharmacy Employment within the meaning of this
provision shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an employee or
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
independent contractor
Respondent was required to notify all present and prospective employers
of the terms and conditions ofprobation Respondent failed to notify her employer Royal Care
Phannacy or owner of the pharmacy that she was on probation
PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board ofPharmacy issue a decision
1 Revoking the probation that was granted by the Board of Pharmacy in
Case No 2098 and imposing the disciplinary order that was stayed thereby revoking Original
Phannacist License No RPH 18843 issued to Anne V Tadini
2 Revoking or suspending Original Pharmacist License No RPH 18843
issued to Anne V Tadini
3 Taking such other and further action as deemed necessary and proper
DATED
fJ~
03583110-LA2003500311
TadiniA_Pet2Revkwpd
CML (071102003)
PATRICIA F HARRIS Executive Officer Board ofPharmacy Department of Consumer Affairs State ofCalifornia Complainant
5
-
Exhibit A
Decision and Order
Board of Pharmacy Case No 2641
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
) )
-bullbull-=----shy
BILL LOCKYER Attorney General of the State of California
ZAVEN V SINANIAN Deputy Attorney General State Bar No 140076
Department of Justice 300 South Spring Street Los Angeles California 90013 Telephone (213) 897-6015
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 39799 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42084 HUSSEIN A DARWISH Owner Pharmacy Technician Registration
No TCH 24271 ~ )
)
)
~
~
and
LA BOTICA PHARMACY 2622 Clarendon Avenue Huntington Park CA 90255 Pharmacy Permit No PHY 40905 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
1 Exhibit 2-L of I~ Pages
No2098 OAH No L-1999030089
STIPULATION IN SETTLEMENT DECISION AND ORDER AS TO RESPONDENT ANNE V TADINI PHARMACIST LICENSE NO RPH 18843
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
28
4
passes the same section( s) at a subsequent examination and is notified in writing she has passed
the examination
During suspension respondent shall not enter any pharmacy area or any portion of
the licensed premises of a wholesaler medical device retailer or any other distributor of drugs
which is licensed by the Board or any manufacturer or where dangerous drugs controlled
substances or legend drugs are maintained Respondent shall not practice pharmacy nor do any
act involving drug selection selection of stock manufacturing compounding dispensing or
patient consultation nor shall respondent manage administer or be a consultant to any licensee
of the Board or have access to or control the ordering manufacturing or dispensing of dangerous
drugs or controlled substances of dangerous drugs or controlled substances Respondent shall
not direct or control any aspect ofth~ practice ofpharmacy Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or she holds an
interest at the time this decision becomes effective
Respondent failed to apply to take the law section of the pharmacist licensure
exam within the first six months ofprobation as required
NOTICE TO EMPLOYERS
E Probation Condition 9 states
Respondent shall notify all present and prospective employers of the decision in
case number 2098 and the terms conditions and restrictions imposed on respondent by the
decision Within thirty (30) days of the effective date of this decision and within fifteen (15)
days of respondent undertaking new employment respondent shall cause her employer to report
to the Board in writing acknowledging the employer has read the decision in case number 2098
If respondent works for or is employed by or through a pharmacy employment service
Respondent must notify the pharmacist-in-charge andor owner at every pharmacy at which she is
to employed or used of the fact and terms of the decision in case number 2098 in advance of the
respondent commencing work at the pharmacy Employment within the meaning of this
provision shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an employee or
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
independent contractor
Respondent was required to notify all present and prospective employers
of the terms and conditions ofprobation Respondent failed to notify her employer Royal Care
Phannacy or owner of the pharmacy that she was on probation
PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board ofPharmacy issue a decision
1 Revoking the probation that was granted by the Board of Pharmacy in
Case No 2098 and imposing the disciplinary order that was stayed thereby revoking Original
Phannacist License No RPH 18843 issued to Anne V Tadini
2 Revoking or suspending Original Pharmacist License No RPH 18843
issued to Anne V Tadini
3 Taking such other and further action as deemed necessary and proper
DATED
fJ~
03583110-LA2003500311
TadiniA_Pet2Revkwpd
CML (071102003)
PATRICIA F HARRIS Executive Officer Board ofPharmacy Department of Consumer Affairs State ofCalifornia Complainant
5
-
Exhibit A
Decision and Order
Board of Pharmacy Case No 2641
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
) )
-bullbull-=----shy
BILL LOCKYER Attorney General of the State of California
ZAVEN V SINANIAN Deputy Attorney General State Bar No 140076
Department of Justice 300 South Spring Street Los Angeles California 90013 Telephone (213) 897-6015
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 39799 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42084 HUSSEIN A DARWISH Owner Pharmacy Technician Registration
No TCH 24271 ~ )
)
)
~
~
and
LA BOTICA PHARMACY 2622 Clarendon Avenue Huntington Park CA 90255 Pharmacy Permit No PHY 40905 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
1 Exhibit 2-L of I~ Pages
No2098 OAH No L-1999030089
STIPULATION IN SETTLEMENT DECISION AND ORDER AS TO RESPONDENT ANNE V TADINI PHARMACIST LICENSE NO RPH 18843
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
independent contractor
Respondent was required to notify all present and prospective employers
of the terms and conditions ofprobation Respondent failed to notify her employer Royal Care
Phannacy or owner of the pharmacy that she was on probation
PRAYER
WHEREFORE Complainant requests that a hearing be held on the matters herein
alleged and that following the hearing the Board ofPharmacy issue a decision
1 Revoking the probation that was granted by the Board of Pharmacy in
Case No 2098 and imposing the disciplinary order that was stayed thereby revoking Original
Phannacist License No RPH 18843 issued to Anne V Tadini
2 Revoking or suspending Original Pharmacist License No RPH 18843
issued to Anne V Tadini
3 Taking such other and further action as deemed necessary and proper
DATED
fJ~
03583110-LA2003500311
TadiniA_Pet2Revkwpd
CML (071102003)
PATRICIA F HARRIS Executive Officer Board ofPharmacy Department of Consumer Affairs State ofCalifornia Complainant
5
-
Exhibit A
Decision and Order
Board of Pharmacy Case No 2641
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
) )
-bullbull-=----shy
BILL LOCKYER Attorney General of the State of California
ZAVEN V SINANIAN Deputy Attorney General State Bar No 140076
Department of Justice 300 South Spring Street Los Angeles California 90013 Telephone (213) 897-6015
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 39799 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42084 HUSSEIN A DARWISH Owner Pharmacy Technician Registration
No TCH 24271 ~ )
)
)
~
~
and
LA BOTICA PHARMACY 2622 Clarendon Avenue Huntington Park CA 90255 Pharmacy Permit No PHY 40905 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
1 Exhibit 2-L of I~ Pages
No2098 OAH No L-1999030089
STIPULATION IN SETTLEMENT DECISION AND ORDER AS TO RESPONDENT ANNE V TADINI PHARMACIST LICENSE NO RPH 18843
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
-
Exhibit A
Decision and Order
Board of Pharmacy Case No 2641
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
) )
-bullbull-=----shy
BILL LOCKYER Attorney General of the State of California
ZAVEN V SINANIAN Deputy Attorney General State Bar No 140076
Department of Justice 300 South Spring Street Los Angeles California 90013 Telephone (213) 897-6015
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 39799 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42084 HUSSEIN A DARWISH Owner Pharmacy Technician Registration
No TCH 24271 ~ )
)
)
~
~
and
LA BOTICA PHARMACY 2622 Clarendon Avenue Huntington Park CA 90255 Pharmacy Permit No PHY 40905 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
1 Exhibit 2-L of I~ Pages
No2098 OAH No L-1999030089
STIPULATION IN SETTLEMENT DECISION AND ORDER AS TO RESPONDENT ANNE V TADINI PHARMACIST LICENSE NO RPH 18843
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
) )
-bullbull-=----shy
BILL LOCKYER Attorney General of the State of California
ZAVEN V SINANIAN Deputy Attorney General State Bar No 140076
Department of Justice 300 South Spring Street Los Angeles California 90013 Telephone (213) 897-6015
Attorneys for Complainant
BEFORE THE BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA
In the Matter of the Accusation Against
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 39799 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LA BOTICA PHARMACY 6304 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42084 HUSSEIN A DARWISH Owner Pharmacy Technician Registration
No TCH 24271 ~ )
)
)
~
~
and
LA BOTICA PHARMACY 2622 Clarendon Avenue Huntington Park CA 90255 Pharmacy Permit No PHY 40905 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
1 Exhibit 2-L of I~ Pages
No2098 OAH No L-1999030089
STIPULATION IN SETTLEMENT DECISION AND ORDER AS TO RESPONDENT ANNE V TADINI PHARMACIST LICENSE NO RPH 18843
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
II
III
II
2 bull
~
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
) ) -=-----shy
) )
~ ) )
~ ~ )
~ ~ l )
)
~ ) )
~
~ )
Exhibit dshydof I~ Pages
1
2 LA BOTICA PHARMACY 6408 Pacific Boulevard Huntington Park CA 90255 Pharmacy Permit No PHY 42017 KHALED HUSSEIN-AHMED Owner Pharmacist License No RPH 45552
and
LYNWOOD PHARMACY 3598 East Imperial Hwy Lynwood CA 90262 Pharmacy Permit No PHY 44002 DICK S LIEM Owner Pharmacist License No RPH 41484
and
KHALED HUSSEIN-AHMED Owner 7137 Stewart Gray Road Downey CA 90240 Pharmacist License No RPH 45552
and
ANNE TADINI 3560 Las Flores Canyon Malibu CA 90265 Pharmacist License No RPH 18843
and
FRANK A LEVANT 11670 Sunset Blvd 209 Los Angeles CA 90049 Pharmacist License No RPH 15637
and
DICK S LIEM Owner 2650 Wheaton Place Fullerton CA 92633 Pharmacist License No RPH 41484
and
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
1
2
3
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
2 3
24
2 5
26
27
~
l l l
3 Exhibit d--shy~of~Pages
__42_7_1________4
5
______N_O_T_C_H_2
_
HUSSEIN A DARWISH Owner 7600 W Manchester Avenue 344 Playa Del Rey CA 90293 Pharmacy Technician Registration
Respondents
In the interest of a prompt and speedy settlernent of this matter consistent with
the public interest and the responsibility of the Board of Pharmacy (hereinafter the
Board) Department of Consumer Affairs State of California the parties submit this
Stipulation and Decision to the Board for its approval and adoption as the final
disposition of the Accusation in this matter
The parties stipulate the following is true
1 An Second Amended and First Supplemental Accusation (hereinafter
Accusation) case number 2098 is currently pending before the Board against Anne
V Tadini Pharmacist License No RPH 18843 (hereinafter Respondent) The
Accusation together with all other statutorily required documents were duly served on
Respondent on or about October 28 1999 by regular mail and certified mail
addressed to Anne Tadini 3560 Las Flores Cny Malibu California 90265 (article
number Z 038 375 039) A true and correct copy of the Accusation No 2098 is
attached as Exhibit A and incorporated by reference
2 Respondent is represented by Ronald S Marks 6320 Canoga Avenue
Woodland Hills California 91367 (818) 347-8112 in this matter Respondent has fully
and completely discussed with counsel the effects of this stipulation
3 ~spondent understands the nature of the charges alleged in the
Accusation Respondent is fully aware of the right to a hearing on the charges and
allegations contained in said Accusation right to reconsideration appeal and all other
rights accorded pursuant to the California Business and Professions Code and
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
) ----
4 Exhibit L L of L Pages
Government Code and freely and voluntarily waive such rights
4 Respondent freely and voluntarily waives each and ev~ry one of the rights
set forth in paragraph 3
5 Respondent Tadini understands that in signing this stipulation rather than
contesting the accusation they are enabling the Board of Pharmacy of the State of
California to issue its order imposing discipline upon her license
6 For purposes of settlement only Respondent admits all of the facts
alleged in paragraphs 22 24 and 30 of the A~cusation accordingly cause for
discipline exists against her pharmacist license number RPH 18843 as is set forth in
the Accusation All other allegations are expressly denied
7 Admissions made by Respondent herein are for purposes of this
proceeding for any other disciplinary proceedings by the Board and for any petition for
reinstatement reduction of penalty or application for relicensure and shall have no
force or effect in any other case or proceeding except as between the parties hereto
8 This stipulation is subject to the approval of the Board It is understood by
Respondentthat in deciding whether to adopt this stipulation the Board may receive
oral and written communications from its staff and the Attorney Generals office
Communications pursuant to this paragraph shall not disqualify the Board or other
persons from future participation in this or any other matter affecting Respondent In
the event this settlement is not adopted by the Board the stipulation will not become
effective and may not be used for any purpose except for this paragraph which shall
remain in effect
9 The parties agree that facsimile copies of this Stipulation including
facsimife signaTures of the parties may be used in lieu of original documents and
signatures The facsimile copies will have the same force and effect as originals
10 Pursuant to the foregoing it is further stipulated and agreed that the
Board may without further notice or formal proceeding issue and enter an Order as its
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
)
-=-----shy
5 Exhibit d-S- of 1)- Pages
decision in case number 2098 as follows
ORDER
A Pharmacist License number RPH 18843 issued to Respondent Anne V
Tadini is hereby revoked However said revocation is stayed and Respondent is
placed on probation for three (3) years on the following terms and conditions
1 ACTUAL SUSPENSION
As part of suspension Respondent is suspended from the practice of
pharmacy for twenty (20) days beginning the effective date of this decision
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
distributor of drugs which is licensed by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or controlled substances Respondent shall not direct
or control any aspect of the practice of pharmacy Subject to the above restrictions
respondent may continu~ to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
2 OBEY ALL LAWS
Respondent shall obey all federal and state laws and regulations
substantially related or governing the practice of pharmacy
3 REPORTING TO THE BOARD
Respondent shall report to the Board or its designee quarterly_ The report
shall be made either in person or in writing as directed If the final probation report is
not made as directed probation shall be extended automatically until such time as the
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
--=-----
2
23
24
26
27
6 bull Exhibit ~ -k of J- Pages
2t
final report is made
4 INTERVIEW WITH THE BOARD
Upon receipt of reasonable notice respondent shall appear in person for
interviews with the Board or its designee upon request at various intervals at a location
to be determined by the Board or its designee Failure to appear for a scheduled
interview without prior notification to Board staff shall be considered a violation of
probation
5 COOPERATION WITH BOARD STAFF
Respondent shall cooperate with the Boards inspectional program and in
the Boards monitoring and investigation of the respondents compliance with the terms
and conditions of hisher probation Failure to cooperate shall be considered a
violation of probation
6 PEER REVIEW
Respondent shall submit to peer review as deemed necessary by the
Board
7 CONTINUING EDUCATION
Respondent shall provide evidence of efforts to maintain skill and
knowledge a~ a pharmacist as directed by the Board
8 EXAMINATION
Respondent shall take and pass the law section(s) of the pharmacist
licensure examination as scheduled by the Board within six (6) months effective date of
his decision If respondent f~ils the examination or fails to take the examination
respondent shall be suspended upon written notice Respondent shall not resume the
practice of pharmacy until she takes and passes the same sections(s) at a subsequent
examination and is notified in writing she has passed the examination
During suspension respondent shall not enter any pharmacy area or any
portion of the licensed premises of a wholesaler medical device retailer or any other
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
t 6
1 7
18
19
21
22
23
24
26
27
I ) )
-=---shy
11
III
11
7
Exhibit dshy7 of 1)- PlnA~
distributor of drugs which is licensee by the Board or any manufacturer or where
dangerous drugs controlled substances or legend drugs are maintained Respondent
shall not practice pharmacy nor do any act involving drug selection selection of stock
manufacturing compounding dispensing or patient consultation nor shall respondent
manage administer or be a consultant to any licensee of the Board or have access to
or control the ordering manufacturing or dispensing of dangerous drugs or controlled
substances of dangerous drugs or contr~lIed substances Respondent shall not direct
or control any aspect of the practice of pharmacy_ Subject to the above restrictions
respondent may continue to own or hold an interest in any pharmacy in which he or
she holds an interest at the time this decision becomes effective
9 NOTICE TO EMPLOYERS
Respondent shall notify all present and prospective employers of the
decision in case number 2098 and the terms conditions and restrictions imposed on
respondent by the decision Within thirty (30) days of the effective date of this decision
and within fifteen (15) days of respondent undertaking new employment respondent
shall cause her employer to report to the Board in writing acknowledging the employer
has read the decision in case number 2098 If respondent works for or is employed by
or through a pharmacy employment service respondent must notify the pharmacist-inshy
charge andlor owner at every pharmacy at which she is to employed or used of the fact
and terms of the decision in case number 2098 in advance of the respondent
commencing work at the pharmacy Employment within the meaning of this provision
shall include any full-time part-time temporary or relief service or pharmacy
management service as a pharmacist whether the respondent is considered an
employee or Independent contractor
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
1 7
18
19
20
21
22
23
24
25
26
27
) ) )
~
10 NO PRECEPTORSHIPS SUPERVISION OF INTERNS BEING
PHARMACIST-IN-CHARGE
Respondent shall not supervise any intern pharmacist or perform any of
the duties of a preceptor nor shall respondent be the pharmacist-in-charge of any
pharmacy licensed by the Board
11 TOLLING OF SUSPENSION
If respondent leaves California to reLSide or practice outside this state or
for any period exceeding ten (10) days (including v~cation) respondent must notify the
Board in writing of the dates ofdeparture and return Periods of residency or practice
outside the state or any absence exceeding a period of ten (10) days shall not apply to
the reduction of the suspension period Respondent shall not practice pharmacy upon
returning to this state until notification by the Board that the period of sus pension has
been completed
12 NO OWNERSHIP OF LICENSED PREMrSES
Respondent shall not own have any legal or beneficial interest inor serve
as a manager administrator member officer director associate or partner of any
business firm partnership or corporation currently or hereinafter licensed by the
Board Respondent shall sell or transfer any legal or beneficial interest in any entity
licensed by the Board within 90 days following the effective date of this decision and
shall immediately thereafter provide written proof thereof to the Board
13 PROBATION MONITORING COSTS
Respondent shall pay the reasonable costs associated with probation
monitoring as determined by the Board each and every year of probation Such costs
shall be payabm to the Board at the end of each year of probation Failure to pay such
costs shall be considered a violation of probation
14 STATUS OF LICENSE
Respondent shall~ at all times while on probation maintain an active
8 ExhibitL Lof P Pages
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
5
10
15
20
25
1
2
3
4
6
7
8
9
11
12
13
14
16
1 7
18
19
21
22
23
24
26
27
I
) --=----shy
III
9 Exhibit shy~of d- Pages
current license with the Board including any period during which suspension or
probation is tolled If respondents license expires by operation of law or otherwise
upon renewal or reapplication respondents license shall be subject to all terms of this
probation not previously satisfied
15 NOTIFICATION OF EMPLOYMENTMAILING ADDRESS CHANGE
Within ten (10) days of a change in employment - either leaving or
commencing employment -- respondent shall so notify the Board in writing including
the address of the new employer within ten (10) days of a change of mailing address
respondent shall notify the Board in writing If respondent works for or is employed
through a pharmacy employment service respondent shall as requested provide to
the Board or its designee with a work schedule indic~ting dates and location of
employment
16 TOLLING OF PROBATION
If respondent leaves California to reside or practice outside this state
respondent must notify the Board in writing of the dates of departure and return within
ten (10) days of departure or return Periods of residency except such periods where
the respondent is actively practicing pharmacy within California or practice outside
California shall not apply to reduction of the probationary period Should respondent
regardless of residency for any reason cease practicing pharm~cy in California
respondent must notify the Board in writing within ten (10) days of cessation of the
practice of pharmacy or resuming the practice of pharmacy Cessation of practice
means any period of time exceeding thirty (30) days in which respondent is not
engaged in the practice of pharmacy as defined in section 4052 of the Business and
Professions Code It is a violation of probation for respondents probation to remain
tolled pursuant-to the provisions of this condition for a period exceeding a consecutive
period of three (3 )years
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
) ) )
bull-=---shy
III
III
10 Exhibit d Dof d-- Pages
1 17 VIOLATION OF PROBATION
If respondent violates probation in any respect the Board after giving
respondent notice and an opportunity to be heard may revoke probation and carry out
the disciplinary order which was stayed If a petition to revoke probation or an
accusation is filed against respondent during probation the Board shall have
contin~ing jurisdiction and the period of probation shall be extended until the petition
to revoke probation is heard and decided If a respondent has not complied with any
term or condition of probation the Board shall have continuing jurisdiction over
respondent and probation shall automatically be extended until all terms and
conditions have been met or the Board has taken other action as deemed appropriate
to treat the failure to comply as a violation of probation to terminate probation and to
impose the penalty which was stayed
18 COMPLETION OF PROBATION
Upon successful completion of probation the respondents license will be
fully restored~
I concur in the stipulation and order
---F-------DATED - 2000
BILL LOCKYER Attorney General of the State of California
bull~ ~S VENVSlN)(NIAN
Deputy Attorney General Attorneys for Complainant
DATED ~ 2000
RortaidSWMarks Esq Attorney for Respondents
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
1
2
3
4
5
6
7
8
9
10
11
12
13
14
lS
16
17
18
19
20
21
22
23
24
25
26
27
-~
kk5a 1-00
III
III
I I I
Exhibit ~ 11 LL of 1)- Pages
I have carefully read and fully understand the stipulation and order set forth
above I understand that in signing this stipulation I am waiving my right to a hearing
on the charges set forth in the Accusation on file in this matter I have discussed the
terms and conditions set forth in the Stipulation and Order with my attorney Ronald S
Marks Esq I further understand that in signing thi~ stipulation the Board may enter
the foregoing order placing certain requirements restrictions and limitations on my right
to practice as a Pharmacist in the State of California
DATED IJ- 2 - 2000 II
~ ~A--N--N~E~V~~TA~D~IN~I~----~~
Pharmacist License No RPH 1884 ~
Respondent
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President
5
10
15
20
25
30
)
1
2
3
4
6
8
9
7
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
29
31
Exhibit ~ rd of )- Pages
DECISION AND ORDER
OF THE BOARD OF PHARMACY
The foregoing Stipulation and Order in the Matter of the Accusation
Against Anne Tadini Case No 2098 is hereby adopted as the Order of the
California Board of Pharmacy Department of Consumer Affairs An effective
date of September 21 2000 has been assigned to this Decision and
Order
Made this 2200 day of_A_ugu-s_t___bull 2000
BOARD OF PHARMACY
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
BY~ 6f I
~B~RT H ELSNER
Board President